Sustainability Appraisal (SA) of Plan:MK

SA Report Addendum

October 2018

SA of Plan MK

REVISION SCHEDULE

Rev Date Details Prepared by Reviewed by Approved by

1 Oct SA Report Addendum published Mark Fessey Steven Smith Steven Smith 2018 alongside proposed modifications to Associate Technical Technical Plan:MK as previously submitted Director Director

Limitations

This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) in accordance with its contract with Milton Keynes Council (“the Client”) and in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. AECOM shall have no liability to any third party that makes use of or relies upon this document.

AECOM Infrastructure & Environment UK Limited 2 Leman Street, London E1 8FA Telephone: 020 7061 7000

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TABLE OF CONTENTS

1 INTRODUCTION ...... 1

PART 1: WHAT HAS PLAN-MAKING / SA INVOLVED UP TO THIS POINT? ...... 3

2 INTRODUCTION (TO PART 1) ...... 4 3 ESTABLISHING THE REASONABLE ALTERNATIVES ...... 6 4 APPRAISING REASONABLE ALTERNATIVES ...... 20 5 DEVELOPING THE PREFERRED APPROACH ...... 28

PART 2: WHAT ARE SA FINDINGS AT THIS CURRENT STAGE?...... 29

6 INTRODUCTION (TO PART 2) ...... 30 7 APPRAISAL OF PROPOSED MAIN MODIFICATIONS ...... 31

PART 3: WHAT HAPPENS NEXT? ...... 44

8 INTRODUCTION (TO PART 3) ...... 45 9 PLAN FINALISATION ...... 45 10 MONITORING ...... 45

APPENDIX I – SITE OPTIONS ...... 46 APPENDIX II – REASONABLE SPATIAL STRATEGY ALTERNATIVES ...... 67

SA REPORT ADDENDUM II

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1 INTRODUCTION

1.1 Background

1.1.1 The aim of Plan:MK is to allocate land for development, present policies to guide future planning applications and ultimately provide a planning framework for the district up to 2031. There are a range of defined plan objectives, which can be seen in Section 2 of the plan document (MK/SUB/001).1

1.1.2 Plan:MK was submitted to the Secretary of State for Housing, Communities and Local Government, for examination by an appointed Planning Inspector in early 2018. Examination hearings sessions were held in July and August 2018.

1.1.3 A key outcome of hearing sessions was an understanding that there is a need for a series of modifications,2 in order for the plan to be found ‘sound’ by the Planning Inspector. The scope of modifications was broadly agreed during hearing sessions, and set out in a log of ‘action points’, with further guidance from the Inspector presented within a series of notes.3

1.1.4 A key matter for the examination is the spatial strategy - i.e. the approach to allocating land for development - and it is this matter that was the focus of the Inspector’s final note of August 31st (INS6). The note, when read alongside the action points, serves to clarify that the Inspector is broadly satisfied with the submission spatial strategy, but that modifications are necessary to adjust detailed aspects in relation to the two strategic urban extensions that are central to the submission plan, namely ‘South East MK’ and ‘East of MK’.

1.1.5 INS6 concluded with the following statement from the Inspector: “It is for the Council to action and progress the proposed main modifications and if required I am happy to provide further clarification to the Council.” Work to develop proposed modifications has now been completed, and proposed modifications are published for consultation at the current time.

1.2 This SA Report Addendum

1.2.1 The Local Plan is being developed alongside a process of Sustainability Appraisal (SA), a legally required process that aims to ensure that the significant effects of an emerging draft plan (and alternatives) are systematically considered and communicated. It is a requirement that SA is undertaken in-line with the procedures prescribed by the Environmental Assessment of Plans and Programmes Regulations (the ‘SEA Regulations’) 2004.

1.2.2 The aim of this SA Report Addendum is essentially to present information on the proposed modifications, and alternatives, with a view to informing consultation and plan finalisation.

Structure of this report

1.2.3 In order to achieve this aim, this SA Report Addendum sets out to answer three questions -

1. What has plan-making / SA involved up to this point? – particularly consideration given to reasonable alternatives.

1. What are the SA findings at this stage? – i.e. in relation to proposed modifications.

2. What happens next?

1 See https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/plan-mk-evidence-base 2 There is a need to prepare both ‘main’ and ‘additional’ modifications; however, proposed additional modifications need not be a focus of SA, as by their very nature they are minor edits without substantive implications. 3 See www.milton-keynes.gov.uk/planning-and-building/planning-policy/plan-mk-examination

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N.B. This report is known as an SA Report ‘Addendum’ on the basis that it is an Addendum to the SA Report submitted in early 2018. The focus of this report is proposed modifications, as opposed to the plan as a whole (the remit of the SA Report).4

1.3 What is the scope of the SA?

1.3.1 In short, the scope of SA work at the current time is A) particular elements of Plan:MK that remain open for discussion, following the examination hearing sessions, and the notes received from the Inspector; and B) a defined list of issues and objectives (‘the SA framework’) defined through past scoping work - see Table 1.1.5

Table 1.1: The SA framework Sustainability objective Communities

1. Reduce levels of crime and create vibrant communities. 2. Reduce the gap between the most deprived areas of Milton Keynes and the average. 3. Improve education attainment and qualification levels so that everyone can find and stay in work. 4. Protect and improve residents’ health and reduce health inequalities. 5 Ensure that everyone has the opportunity to live in an affordable, sustainably constructed home. 6. Ensure all section of the community have good access to services and facilities. Environment 7. Maintain and improve the air quality in the borough. 8. Conserve and enhance the borough’s biodiversity. 9. Combat climate change by reducing levels of carbon dioxide. 10. Conserve and enhance the borough’s heritage and cultural assets. 11. Conserve and enhance the borough’s landscapes. 12. Encourage efficient use of natural resources (inc. land/soils). 13. Limit noise pollution. 14. Limit and reduce road congestion and encourage sustainable transportation. 15. Maintain and improve water quality and minimise the risk of flooding. 16. Reduce waste generation and encourage sustainable waste management. Economy

17. Encourage the creation of new businesses. 18. Sustain economic growth and enhance competiveness. 19. Ensure high and stable levels of employment.

4 Whilst the focus of this report is on proposed modifications (and alternatives), there is a need to bear in mind that the proposed modifications will (if taken forward) be implemented alongside, and impact ‘cumulatively’, with the rest of the Local Plan. 5 This SA framework was established following consultation on a Scoping Report in 2014.

SA REPORT ADDENDUM 2 INTRODUCTION

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PART 1: WHAT HAS PLAN-MAKING / SA INVOLVED UP TO THIS POINT?

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2 INTRODUCTION (TO PART 1)

2.1.1 The Local Plan-making / SA process has been ongoing for a number of years, as explained within Part 1 of the SA Report, and as summarised by Figure 2.1.

2.1.2 At the current time, rather than recap the whole story, there is a need to explain the work undertaken in September 2018, subsequent to examination hearings and receipt of the Inspector’s note INS6, which led to the development of proposed modifications.

2.1.3 Specifically, in-line with regulatory requirements, there is a need to explain how work was undertaken to develop and then appraise reasonable alternatives, and how the Council then took into account alternatives appraisal findings when determining a preferred approach.6

Figure 2.1: Key steps in the plan-making / SA process

2.1.4 More specifically still, this part of the report presents information regarding the consideration of reasonable alternative approaches to housing growth, or ‘spatial strategy alternatives’. It is clear that allocating land for housing is central to the achievement of plan objectives.7

2.1.5 Spatial strategy alternatives were the focus of the Part 1 of the SA Report, and the Inspector specifically requested that spatial strategy alternatives be revisited ahead of preparing proposed modifications, with findings presented in this report.8

What about other plan issues?

2.1.6 The scope of proposed modifications covers a range of thematic policy issues/objectives, both borough-wide and site-specific; however, it is reasonable for preferred policy approaches to emerge without formal consideration having been given to reasonable alternatives. Such issues/objectives are not of the same magnitude of strategic importance as the ‘spatial strategy’, and (it follows that) there is less potential to meaningfully discuss, and differentiate alternatives in terms, of significant effects. Informal discussion of alternatives is presented in Chapter 6, to frame the appraisal of proposed modifications.

6 There is a requirement for the SA Report to present an appraisal of ‘reasonable alternatives’ and ‘an outline of the reasons for selecting the alternatives dealt with’. The aim is to inform the consultation, and subsequent plan finalisation. It follows that it is appropriate for this SA Report Addendum to present equivalent (and up-to-date) information on reasonable alternatives. 7 Regulation 12(2) requires that, when determining what should be a focus of alternatives appraisal, account is taken of “the objectives and geographical scope of the plan”. 8 Discussions during the Examination Hearings led to a conclusion that there would be a need to revisit the appraisal of individual site options ahead of preparing proposed modifications, and that it would naturally be the case that this updated appraisal of site options would, in turn, lead to a need to re-consider the matter of reasonable spatial strategy alternatives (i.e. alternative combinations of site options). The Inspector’s Note of 31st August then confirmed matters, stating: “In short, the approach verbally outlined by… AECOM in response to the note of 14 August 2018 sounds like a constructive and objective way forward and I will look at the SA addendum prior to consultation on proposed main modifications.”

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What about site options?

2.1.7 Site options are not ‘reasonable alternatives’ where there is no mutually exclusive choice to be made between them;9 however, it is naturally the case that there is a need to consider site options as part of the process of arriving at reasonable spatial strategy alternatives. As such, site options are discussed in Chapter 3 (“Selecting the reasonable alternatives”). The aim is not to formally ‘appraise’ site options, but rather to subject site options to a proportionate examination, suited to the task of informing the selection of reasonable alternatives.

What about SA work from past stages?

2.1.8 Appraisal findings from past stages (see Figure 2.1) are not repeated here, but rather are discussed, as necessary, as an input to the establishment of reasonable spatial strategy alternatives, i.e. as part of the discussion of “outline reasons for selecting the alternatives dealt with”. Previous reports have been superseded, but remain on the Council’s website.

Structure of this part of the report

2.1.9 This part of the report is structured as follows -

Chapter 3 - explains the reasons for selecting the alternatives dealt with Chapter 4 - presents an appraisal of the reasonable alternatives Chapter 5 - explains reasons for selecting the preferred option

Who’s responsibility?

2.1.10 It is important to be clear that: selecting reasonable alternatives - is the responsibility of the plan-maker (MKC), with AECOM acting in an advisory capacity; appraising the reasonable alternatives - is the responsibility of AECOM; and selecting the preferred option - is the responsibility of the plan-maker (MKC).

9 A site option is not a ‘reasonable alternative’, in the context of a Local Plan, where there is no understanding of how the site option in question would be delivered in combination with other sites, and noting that it is the central objective of all Local Plans to deliver a package of sites in combination. If a site option is presented without an explanation of how it would be delivered in combination with other sites (e.g. “in addition to sites X, Y and Z”; or “in place of site X”) then the choice remains essentially undefined. The SEA Directive and Regulations aim to ensure that plan-makers and stakeholders are presented with a clear, mutually exclusive choice.

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3 ESTABLISHING THE REASONABLE ALTERNATIVES

3.1 Introduction

3.1.1 The aim here is to discuss the key steps taken in September 2018 that led to the development of reasonable spatial strategy alternatives for appraisal and consultation.

3.1.2 Ultimately, the aim of this chapter is to present ‘an outline of the reasons for selecting the alternatives dealt with’, in accordance with the Regulations.10

3.1.3 Specifically, this chapter explains how reasonable alternatives were established subsequent to certain initial steps - see Figure 3.1.

Figure 3.1: Establishing reasonable spatial strategy alternatives(2018)

Structure of this chapter

3.2 - Discusses strategic options/parameters

3.3 - Discusses site options

3.4 - Explains how understanding was drawn upon to establish the reasonable alternatives

10 Schedule II of the Environmental Assessment of Plans and Programmes (‘SEA’) Regulations 2004

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3.2 Strategic options/parameters

Introduction

3.2.1 The aim here is to update the discussion presented within Section 6.2 of the SA Report, in light of latest understanding established through: Regulation 19 representations; examination hearing statements; discussions during the examination hearing sessions; the agreed action points published subsequent to the hearings; and the written guidance provided by the Inspector’s two recent notes (INS4 and INS6).

N.B. discussion is presented mindful that the examination is ongoing, with the Inspector yet to reach final conclusions on any aspect of the submission plan or underpinning evidence.

3.2.2 This section discusses strategic options/parameters under the following headings -  Housing quanta  Broad housing distribution  Employment land

Housing quanta

3.2.3 Matter 4 for the examination hearing sessions dealt with “the overall need and requirement for housing”, with discussions focusing broadly on three matters: 1) the plan period; 2) the objectively assessed housing need (OAHN); and the housing target/requirement.

3.2.4 With regards to the plan period, arguments were made that Plan:MK should cover a longer period of time, and, in turn, provide for the additional housing and employment needs arising. It was also suggested that there is a reasonable need to examine alternative plan periods through the SA process. The specific suggestion was that there is a need for a longer plan period in order to respond to the ambitious long-term growth aspirations expressed though the MK Futures 2050 Commission Report (2016; see a summary at paras 6.2.8 to 6.2.10 of the SA Report) and wider Government growth aspirations for the Oxford to Cambridge corridor.

3.2.5 However, the Inspector subsequently provided the following guidance within INS4 -

“To justify the Plan period to 2031 there would be a need to commit to a review within a defined timescale. I am persuaded there are particular circumstances relating to the need for coordinated strategic growth in Milton Keynes that would justify this approach. As discussed at the hearings, the Council’s commitment to a review of Plan:MK should be formalised in a policy of the Plan as a main modification. The policy should set out the factors that will guide the timing of the review but in any event should commit to submitting a plan document containing strategic policies no later than 2022. Additional supporting text to the policy should contextualise the particular circumstances for the timing of the plan review, including the current plan period to 2031 as well as the developing background for very substantial, aspirational growth along the Cambridge-Oxford Arc.”

3.2.6 In light of this guidance, and the fact that the Council has now taken the necessary step of developing a proposed modification relating to plan review, there was determined to be no reasonable need to explore further the matter of the plan period through appraisal of / consultation on reasonable spatial strategy alternatives (and, in any case, it would be a challenge to meaningfully appraise alternative plan periods, as shorter plan period scenarios would need to be defined with assumptions made regarding housing beyond the plan period). In other words, it was determined that the plan period should be a constant across the reasonable spatial strategy alternatives (henceforth ‘RAs’).

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3.2.7 In relation to OAHN, various detailed arguments were made during examination hearings, which led to the Inspector subsequently providing the following guidance within INS6 -

“I have reflected on the written evidence, the discussion at the hearings and the Council’s subsequent clarification on the application of the East of England Forecasting Model (EEFM). Based on what is before me, I see no need at this stage to recommend any adjustments to the submitted OAN of 1,766 dwellings per annum for plan soundness. The Council’s clarification on the EEFM should accompany the main modifications consultation and I will consider any related submissions before preparing my report.”

3.2.8 The Council subsequently sought and received clarification on the application of the EEFM, and, in turn, was able to confirm continued support for the submission OAHN. As such, there was determined to be no reasonable need to explore further the matter of OAHN, through appraisal of / consultation on RAs (and, in any case, OAHN is by definition an objective matter as opposed to a policy matter to be explored through SA). In other words, it was determined that OAHN should be a constant across the RAs.

3.2.9 In relation to the housing target, this was a matter that was the focus of SA work prior to finalisation of Plan:MK for submission, with the 2017 RAs varying in respect of total housing quantum (leaving aside the matter of needing to provide for additional homes as a contingency for non-delivery) from ‘OAHN plus 4%’ to ‘OAHN plus 15%’.11 However, there was limited discussions on the subject during the hearing sessions, with the general consensus seemingly that it is appropriate for Plan:MK to provide for OAHN within the plan period (which, in practice, means allocating sites with capacity sufficient to provide for OAHN plus a suitable contingency for non-delivery), as opposed to providing for above or below OAHN.

3.2.10 It also seemingly somewhat goes without saying that there is a need to provide for the housing target on a smooth trajectory, i.e. Plan:MK should be monitored against an annual delivery target of 26,500 (i.e. OAHN for the plan period) / 15 (i.e. the plan period) = 1,766 dpa.

3.2.11 These conclusions are corroborated by the following statement made by the Inspector in INS4 (as the first sentence under the heading of ‘Housing land supply’): “I am satisfied that the Council’s trajectory for delivery is broadly justified.”

3.2.12 As such, there was determined to be limited - but not necessarily nil - strategic argument for exploring further the matter of the housing target through appraisal of / consultation on RAs. This matter is returned to below, within Section 3.5.

Broad housing distribution

3.2.13 Matter 2 for the examination hearings was ‘Spatial strategy’, with discussions focusing broadly on three matters: 1) the decision to focus allocations on the MK urban area only; 2) the selection of urban sites; and 3) the selection of urban extension sites.

3.2.14 In relation to the matter of focusing allocations on the MK urban area only, there were certain arguments made by promoters of omission sites at villages, in particular on deliverability grounds, i.e. it can be argued that diversifying the land supply, to include greater supply from smaller sites in the rural area (which will tend to be associated with low delivery risk) would add robustness to the housing delivery trajectory. However, there are counter arguments, namely strong arguments to suggest that the supply trajectory is suitably robust, such that there is high confidence in the ability to deliver OAHN over the plan period on a smooth- enough trajectory. There were also certain arguments made on sustainability grounds, e.g. it can be argued that villages need growth in order to maintain local services and facilities; however, these arguments are generally not persuasive in the Plan:MK context, given the number of completions and commitments in place at villages.

11 The 2017 reasonable spatial strategy alternatives (RAs) were presented in Table 6.6 of the SA Report, and were also subsequently re-presented - in an improved form - within the SA ‘note’ of June 2018 (MK/SUB/005a).

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3.2.15 This matter was not explicitly addressed in either INS4, INS5 or INS6 (or the list of agreed action points), whilst the Inspector has made a clear statement regarding his satisfaction with housing delivery trajectory (see para 3.2.11 above).

3.2.16 As such, there was determined to be no reasonable need to explore further the decision to focus allocations on the MK urban area only through appraisal of / consultation on RAs, i.e. it was determined that this factor should be held constant across the RAs.

3.2.17 In relation to urban sites, this was a matter that was the focus of SA work prior to finalisation of Plan:MK for submission, with the 2017 RAs varying in respect of the number of homes at allocated sites in the urban area.11 Specifically, five of the RAs involved allocations for 2,900 homes, with the other three involving allocations for 3,500 homes. However, there was relatively limited discussion of this matter during the examination hearings, and it is not something that was explicitly addressed within either INS4, INS5 or INS6 (or the list of agreed action points, although one agreed action is of note, namely that which reflects the Inspector’s request that urban allocations be shown more prominently in the plan, i.e. not in an appendix).

3.2.18 As such, there was determined to be no reasonable need to explore further the matter of urban site selection through appraisal of / consultation on RAs, i.e. it was determined that this factor should be held constant across the RAs.

3.2.19 In relation to urban extension sites, this was a matter that was the focus of SA work prior to finalisation of Plan:MK for submission, with 2017 RAs varying in respect of the number of homes to be delivered at South East MK (1,500 or 3,000) and East of MK (nil, 1,500 or 3,000). This was also a matter that was a focus of discussion during examination hearings, with concerns raised regarding the suitability of the two submission urban extension sites and (perhaps more so) the delivery risks associated with both sites. In particular, the suggestion was that delivery risks dictate that a conservative approach should be taken when assigning housing delivery from these sites within the housing trajectory.

3.2.20 However, the Inspector subsequently gave clear guidance that both sites are suitable, and also guidance regarding the housing delivery trajectory that should be assumed. Specifically -  Within INS4 the Inspector states that: “I am satisfied that the Council’s trajectory for delivery is broadly justified. The only exception is South East Milton Keynes where, notwithstanding the Council’s positive approach to delivery, the timetable needs to be put back by one year so that initial completions would be in 2023/24. It would be a matter for the Council to consider the re-profiling of delivery at this strategic site over the plan period, including the 450 units projected to be delivered in the year 2030/31. Nonetheless, some 50 units should not be counted in the year 2022/23 for the purposes of deliverable supply.”  Within INS6 the Inspector states that: “My advice to the Council is that having clarified the site is allocated in Plan:MK, a judgement needs to be applied as to whether it can reasonably deliver a scale of development in the plan period. In my view there is evidence that would justify some positive allowance at MKE (recognising the extent of the plan period), particularly for housing development. From the evidence presented, I would suggest that a case could be made for the alternative trajectory of at least 1,475 dwellings from 2026/27 onwards as being justified, effective and positively prepared having regard to the following factors…”

3.2.21 In light of this guidance, there was determined to be no reasonable need to explore further the matter of allocating / assigning a delivery trajectory to either South East MK or East of MK through appraisal of / consultation on RAs. This left the question of whether there is a reasonable need to explore further spatial strategy options involving allocation of one or more urban extension omission sites. This matter is returned to below, within Section 3.5.

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Employment land

3.2.22 Matter 4 for the examination hearings was ‘Meeting employment needs’, with the Council generally seeking to re-state the strategy outlined within the Employment Land Topic Paper, which is one whereby -  demand will be more than met by the existing employment land supply for all employment land types other than ‘B8’, i.e. warehousing and distribution;  for B8 there is a forecast demand for 104 ha and an existing supply of 56.5 ha, leaving a shortfall of 47.5 ha to be provided for through Plan:MK; and  the proposed approach is to allocate one strategic employment site - South Caldecotte - which at 57 ha is more than sufficient to meet the identified needs (on the assumption that at least 80% of the site is suited to B8).

3.2.23 The demand and existing supply figures were discussed during examination hearings, with several reasons given for suggesting that the B8 shortfall is greater than or less than 47.5 ha (also see discussion at para 4.7 of the Employment Land Topic Paper).

3.2.24 However, the Inspector subsequently gave no reason within INS4, INS5 or INS6 to suggest that there are any significant concerns with the submission strategy. The only relevant statement was within INS6, where the Inspector stated: “The SA outlines that were MKE to deliver homes within the Plan period it would deliver employment and thus negate the need for the proposed employment site at South Caldecotte. I am not persuaded based on the evidence before me that would be a reasonable scenario.” This statement serves to indicate that the Inspector is satisfied that South Caldecotte is a suitable and necessary employment allocation, and that an assumption regarding a degree of employment land delivery at East of MK could potentially be called for. It does not serve to indicate, however, that the Inspector believes there to be a need to consider additional supply from any other site.

3.2.25 As such, there was determined to be limited - but not necessarily nil - strategic argument for exploring further the matter of employment land through appraisal of / consultation on RAs. This matter is returned to below, within Section 3.5.

3.3 Site options

Introduction

3.3.1 Having discussed the strategic options/parameters understood to have bearing on the establishment of reasonable spatial strategy alternatives in September 2018, there is a need to discuss the site options in contention for allocation. Site options can be thought of as the ‘building blocks’ for establishing reasonable spatial strategy alternatives.

3.3.2 Two sets of site options are the focus of discussion here -

1) Housing / mixed use site options 2) Employment site options

Housing / mixed use site options

3.3.3 Housing / mixed use site options were considered as part of the process of arriving at reasonable spatial strategy alternatives in 2017, with findings reported in Sections 6.3 (Site options) and 6.4 (Refined site options) of the SA Report.

3.3.4 Section 6.3 of the SA Report sought to introduce the available site options and then subject them to ‘screening’, in order to arrive at a shortlist for detailed consideration. Table 3.1 summarises the screening outcomes.

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Table 3.1: Screening site options

Category Progress to ‘detailed consideration’?

Urban No

Rural No

Urban edge Yes, but only a shortlist

3.3.5 The Inspector subsequently agreed this screening conclusion, namely that only a shortlist of MK urban edge site options need be the focus of detailed consideration. There was little or no suggestion during examination hearings that urban or rural site options warranted detailed consideration through SA, and this was not a matter covered within INS4, INS5 or INS6. Furthermore, on a strategic level (see Section 3.2, above) there is a strong indication that the Inspector is broadly satisfied with the justification for the submission strategy in respect of urban and rural site allocations (or the lack of allocations, in the case of the rural area).

3.3.6 The shortlist of (‘screened-in’) MK urban edge site options reported within Section 6.3 of the SA Report comprised eight sites. The Inspector agreed this shortlist verbally during the final hearing session on 30th August.

3.3.7 However, on reflection it was determined reasonable to add one additional site to the shortlist, namely Levante Gate. This site was screened-out in 2017;12 however, a planning application was subsequently submitted for a 500 home scheme, which was recommended for approval by Officers before being refused by the Development Control Committee on 6th September.13

3.3.8 Section 6.4 of the SA Report presented summary conclusions on the shortlisted site options, with more detailed findings presented in Appendix III. Updated summary conclusions are presented in Table 3.2, below, with updated detailed findings presented in Appendix I. The location of the shortlisted site options can be seen in Figure 3.2.

12 Levante Gate was screened-out in 2017 as “sequentially less preferable than the other medium scale site options discussed below, as it would only link to the urban area upon completion of the permitted Eaton Leys site, and even at that point would not relate well.” 13 Application 17/03233/OUT see http://milton-keynes.cmis.uk.com/milton- keynes/Calendar/tabid/70/ctl/ViewMeetingPublic/mid/397/Meeting/6048/Committee/1212/SelectedTab/Documents/Default.aspx

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Table 3.2: Conclusions on shortlisted MK edge site options (September 2018) in size order

Name Commentary

The site is distant (7km+) from CMK, in only moderate proximity to a train station (c.1.5 to 2km) and there would be relatively limited potential to walk/cycle to key destinations (although a recent planning application included delivery of a 1fe primary school and a local centre; the adjacent 600 home Eaton Leys scheme includes a local centre with a health centre and primary school; and the proposed Caldecotte South strategic employment site would be adjacent). The site is also subject to notable environmental constraints in respect of ‘landscape’ and ‘agricultural land’. In respect of the former, the Council’s Landscape Officer objected to a recent planning application, including on the grounds that development would set a precedent for other development proposals which cumulatively would have an adverse effect on the landscape character and the wider environment; however, the Officers Report relating to the planning application concludes “the Levante Gate relative quality of the landscape that the application site sits in is not high”. In respect [500 homes] of the latter, the site has been surveyed in detail and found to comprise 52% Grade 2 (i.e. second highest quality nationally) land, and 26% grade 3a (i.e. also ‘best and most versatile’). Whilst it is not possible to be certain, in the absence of consistent data, it would appear likely that this is the most constrained of the site options in respect of agricultural land. There are also delivery risks, as development might need to follow completion - or at least substantial progress - on the adjacent Eaton Leys site, plus the site falls within the preferred Oxford to Cambridge Expressway route corridor. However, the site benefits from relating very well to the strategic road network (A4146 and A5), along which run higher frequency bus services; and the site also benefits from its proximity to the A4146/A5 roundabout, which is programmed to receive a major upgrade. Further expansion to the east, within the area of land bounded by the M1, A421 and the railway line, extending into Central Beds, makes strategic sense in certain (socio- economic) respects, recognising the need to focus growth in proximity to EWR stations (Woburn Sands station is within walking distance) and the Oxford to Cambridge Expressway, which will pass through Junction 13 of the M1. However, the site is subject to a relatively high degree of constraint, with ‘medium’ Wavendon Golf landscape sensitivity (including due to evidence of former parkland) and three Course clusters of listed buildings (ten in total) adjoining the site. Also, the site will only relate [700 homes] well to the MK urban edge following completion of the SLA.14 The site should logically be reconsidered in the future, once the SLA is completed or close to completion, and once South East MK (a sequentially preferable site) is at least underway. In the interim period site promoters might investigate the potential for a more strategic-scale scheme taking in additional land to the east, including the land discussed below as the “Wavendon / Woburn Sands (‘Eastern’) Broad Area”.

14 The Strategic Land Allocation was the main allocation made through the Core Strategy (2013).

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Name Commentary

Development would benefit from good links to the WEA, and in turn good links to other key destinations including CMK; however, development would be distant from the EWR / Expressway corridor. The site could deliver strategic green infrastructure benefits (also sports and recreation provision), potentially delivering the first phase of a wider ‘Calverton Valley Park’ - an extension to the Ouse Valley strategic green infrastructure corridor, extending between Calverton and Whaddon. Also, the site potentially performs relatively well in respect of agricultural land quality, on the basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b WEA Expansion quality land, i.e. land that is not ‘best and most versatile’. [1,000 homes] However, development would extend the WEA beyond the extent deemed to be suitable in 2005, at the time of allocation. The Calverton Road would form a new boundary; however, along this road is the string of three ‘Weald Villages’, including one designated conservation area. Site promoters suggest that coalescence can be avoided (at least in respect of Upper Weald and Middle Weald) through greenspace buffers; however, significant concerns remain. Finally, there are delivery concerns on the basis that: A) the site is in two parts, with intervening land outside the control of the developer; and B) the site has not been actively promoted during the Plan:MK examination.

Unlike the sites discussed above, this site would adjoin the existing urban edge, and indeed could link directly to an existing grid road. Also of note is the larger nature of this scheme, which leads to confidence in respect of community infrastructure delivery (although, having said this, an alternative smaller scheme has recently been promote to the Council, which does not include a school or any local centre). It is also noted that there is a good range of existing local facilities within walking/cycling distance, and CMK is relatively close. Also, the site potentially performs well in respect of agricultural land quality, on the basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’. Shenley Dens Farm However, a scheme of this scale would lead to significant impacts to a landscape [1,500 homes] defined as having ‘high’ sensitivity. Landscape sensitivity has long been a concern in this area, with the 2005 the Local Plan Inspector concluding that a virtually identical site: “… would be visible from large parts of the Whaddon Valley. The Shenley Ridge is a significant feature in the landscape and I agree with the Llewelyn-Davies assessment that it is a feature that would form a logical and obvious boundary to development… I do not see the logic of regarding the Whaddon Valley as a possible long-term development area. To do so disregards the qualities of the valley landscape and the merits of the Shenley Ridge as a logical and clear long-term boundary.” The site also contains a listed farmhouse at its centre, and partially wraps around Oakhill Wood, a large ancient woodland (mostly replanted) that falls within the Whaddon Chase BOA.15

15 BOAs are extensive areas that include a concentration of important habitat, and within which there will likely be a good degree of ecological connectivity over a relatively large scale. There is a need to maintain and increase ecological connectivity within BOAs, which can potentially be achieved through development, where this leads to targeted habitat creation, restoration or enhancement.

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Name Commentary

As discussed above, further expansion to the east, within the area of land bounded by the M1, A421 and the railway line, extending into Central Bedfordshire District, makes strategic sense in certain (socio-economic) respects, recognising the need to focus growth in proximity to East West Rail stations (Woburn Sands and Apsley Guise stations are in proximity) and the Oxford to Cambridge Expressway. However, this site is currently a considerable distance from the urban edge, and would only adjoin the urban edge were Wavendon Golf Course (and arguable South East MK) to be allocated and delivered first. There is no potential for all three sites to Wavendon/Woburn be allocated through Plan:MK, given the Plan:MK plan period and the quantum of (‘eastern’) broad area homes required in that plan period. The site should logically be reconsidered in the [1,500+ homes] future, ideally in combination with adjacent Wavendon Golf Club. Any future planning of MK expansion into this area would also need to take careful consideration of growth aspirations, and constraints, in neighbouring Central Bedfordshire District. The Draft Central Bedfordshire Local Plan proposed a series of ‘linked villages’ in the ‘Apsley Guise Triangle’; however, this proposal was removed from the subsequent ‘pre-submission’ version of the plan, with the Council stating: “We believe these locations do have potential for growth but… they are dependent on critical infrastructure (e.g. East West Rail) to support them.”16

The site benefits from linking well to the existing urban edge, and new communities would have good access to two train stations on East West Rail and nearby strategic employment sites. Also, the scale of the site leads to the opportunity to deliver new strategic community infrastructure, to include a secondary school, potentially to the benefit of existing as well as new residents (e.g. perhaps residents of any new villages that might be developed to the east in the Apsley Guise Triangle). However, much of the site would not link directly to the grid road or redways network, and the site extends across the railway line, which will result in the need for one or more new bridges. Also, the site falls within the preferred Oxford to Cambridge South East MK Expressway route corridor, which leads to a degree of delivery risk, and also [3,000 homes] potentially some concerns in respect of impacts on the new community (e.g. pollution, severance). There are limited environmental constraints, with a key consideration being the gap to Woburn Sands and Bow Brickhill, and also agricultural land quality. In respect of the former, the gap would decrease significantly; however, the landscape has ‘low’ sensitivity (albeit landscape assessment work suggests the need for ‘small scale development). In respect of the latter, the site has been surveyed in detail and found to comprise a mix of grades 2, 3a and 3b quality agricultural land, with grade 2 land (i.e. land of second highest quality nationally) found at the Bow Brickhill end of the site.

16 See http://www.centralbedfordshire.gov.uk/planning/policy/local-plan/pre-submission.aspx. N.B. latest understanding is that Phase 2 of East West Rail will open in 2023, at which point Apsley Guise station will have a service to Bicester and Oxford (also Aylesbury by 2024) and an improvement on the current service to Milton Keynes and Bedford.

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SA of Plan MK

Name Commentary

There is the potential to deliver a new community with a good degree of self- containment, but also functioning as an urban extension to MK (also relating fairly well to Newport Pagnell). In addition to a secondary school, the intention is that the scheme would involve an extensive employment area at M1 J14, and a second strategic employment area within the triangle of land at the site’s northwestern extent. Also, there is the potential to deliver environmental net gains and ‘ecosystem service’ benefits through enhancements along, and increased accessed to, the River Ouzel. However, there are also potential draw-backs to this scheme from a communities perspective, recognising that the new community would be relatively poorly linked to CMK, with the M1 acting as a barrier. The site is also significantly constrained by East of MK (north) flood risk associated with the river Ouzel, and the impact on Olney of increased traffic [3,000 homes+] is a concern, particularly given the designated AQMA. In other respects the site is quite unconstrained in environmental terms, although there is a strong likelihood that the site contains extensive areas of best and most versatile agricultural land. Proximity to the village of Moulsoe (where there is a grade 1 listed church) is a consideration; however, it is anticipated that a substantial landscape buffer can be retained. The site benefits from being well located to a motorway junction, with two existing road bridges and a footbridge (plus the A422 bridge at the site’s northern edge); however, there would nonetheless be a need for extensive and costly infrastructure upgrades, which leads to delivery risks.

This site is also of a scale sufficient to deliver strategic community infrastructure, e.g. a secondary school. However, the M1 constitutes a major barrier between the site and the existing MK urban area; and the site would link to CMK via the EEA (and potentially also the SLA), which could create challenges. There is also a degree of flood risk on site, and there is a likelihood of extensive BMV agricultural land. East of MK (south) [3,000 homes+] There is no potential to allocate both East of M1 sites, and so the southern site should be reconsidered in the future, as a potential extension option to the northern site, should the northern site be allocated and begin to build-out. There would be a need to liaise closely with Central Bedfordshire District, taking careful account of aspirations for Cranfield University, Cranfield village and the Marston Moretaine area, which is proposed as a focus of growth by the emerging Central Bedfordshire Plan.

Sequentially less preferable the East of M1 (north) site discussed above, for a number of reasons. Notably, there would be a need to bridge the extensive flood plain of the River Great Ouse / Linford Lakes; and growth to the north of MK would not relate well to the existing transport network (there is no M1 junction in the vicinity) or the Expressway / EWR corridor. There is also a greater degree of onsite North of MK landscape, heritage and biodiversity constraint. [3,000 homes+] Once again, this site might be considered again in the future, given the potential to deliver a large scale scheme that delivers new and upgraded infrastructure upgrades, and given the likelihood that many of the constraints that exist can be successfully overcome or sufficiently mitigated; however, at the current time there are sequentially preferable sites, and there is only a need to find sites for a limited number of new homes, which in turn means this site can be ruled-out of contention.

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SA of Plan MK

Employment site options

3.3.9 Three employment site options were introduced within Sections 6.3 (Site options) of the SA Report, and two alternative approaches to employment land provision were reflected within the reasonable spatial strategy alternatives (Table 6.6 of the SA Report); however, the SA Report did not subject the three competing site options to detailed consideration in isolation.

3.3.10 Criticisms were received on this point through representations, and then the Council sought to respond by presenting a detailed consideration of the competing site options within the Employment Land Topic Paper prepared for submission (March 2018). Nonetheless, concerns were raised during the examination hearings.

3.3.11 As such, the aim here is to present a more full and detailed consideration of the competing site options. As per the discussion of housing/mixed use site options above, the aim is to inform a decision as to which site options should be taken forward for formal appraisal, as an element of the refined reasonable spatial strategy alternatives.

3.3.12 Detailed consideration of the employment site options is presented within Appendix I, with summary conclusions presented in Table 3.3, below. The location of the employment site options can be seen in Figure 3.2.

Table 3.3: Conclusions on employment site options (September 2018) in size order

Name Commentary

The site is suitable for employment development in certain respects, including on the basis that it is quite well linked to the M1 (c.4km at its closest point, and c.7km when measured from the Chicheley Hill roundabout). However: the developable area is North East of only 25 ha, which falls well short of the identified target figure to be met by Plan:MK. Newport Pagnell Also, the site does not relate well to Newport Pagnell in built form terms, even once [25 ha of B8] account is taken of the committed strategic eastwards expansion of the town, and there is landscape constraint (albeit the developable area figure assigned does reflect this constraint). Also, the site is likely to include a significant element of best and most versatile agricultural land.

Whilst some distance from the M1, the site is located on the A5 - a main strategic route that is now linked to the M1 c.18.5km to the south (J11a), via the new A5/M1 link road (journey time 15 minutes). The site is also linked to M1 junctions 13 and 14 to the north via duel carriageway roads (shorter distance, but a need to pass through roundabouts with a risk of traffic). Caldecotte South Furthermore, the site is very well linked to Bow Brickhill train station and close to [57 ha site able to existing employment areas. Also, the site has been surveyed and found to comprise deliver at least 47.5 mostly grade 3b agricultural land, with only perhaps the western 20% of the site ha of B8] comprising grade 3a land, i.e. land that is ‘best and most versatile’. However, proximity to Bow Brickhill also raises some concerns in respect of traffic. Also, the site is subject to a significant landscape constraint in that views over MK from the Greensand Ridge will be impacted. Another issue relates to the presence of a patch of Biodiversity Action Plan (BAP) grassland habitat.

East of MK See discussion of the mixed use site in Table 3.2.

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SA of Plan MK

3.4 The reasonable alternatives

Introduction

3.4.1 The aim of this section is to draw upon the ‘top down’ understanding of strategic options/parameters explained within Section 3.2, and the ‘bottom-up’ understanding of site options explained within Section 3.3 in order to arrive at a set of refined reasonable spatial strategy alternatives. Essentially, the task is to update the reasonable spatial strategy alternatives presented/appraised within the SA Report, in light of latest evidence.

Summary of top-down understanding

3.4.2 On the basis of the discussion presented in Section 3.2 it is apparent that there is very limited room for manoeuvre at the current time. The Inspector has indicated that he is broadly satisfied with the submission spatial strategy, and it would seem that the ‘door is left open’ only for alternatives that would involve a fairly modest departure. Specifically -  Housing - Plan period and OAHN can now be considered fixed, providing for below OAHN can be ruled-out as unreasonable, and there has been little or no indication that the housing target should be anything other than OAHN. The Inspector has also stated clear support for the ‘trajectory for delivery’, which in practice equates to support for the sites selected.  Employment - the Inspector has indicated that he is satisfied with the South Caldecotte strategic allocation, and comfortable with the likelihood of additional supply at the East of MK strategic mixed use allocation.

Summary of bottom-up understanding (housing)

3.4.3 The first point to make is that the analysis presented in Table 3.2 serves to corroborate the ‘top down’ understanding discussed above in relation to South East MK and East of MK, namely understanding that both submission allocations are strongly justified, and hence need not be examined further as a variable across the reasonable spatial strategy alternatives. Both sites perform well when viewed in isolation (i.e. without assumptions made regarding delivery in combination with other allocations), both in an absolute sense and when viewed relative to other competing sites.

3.4.4 The second conclusion to draw from Table 3.2 is that the two very large (3,000+ homes) housing / mixed use omission sites can be ruled-out on the basis of being too large. Either site might be revisited in the future, but allocation through Plan:MK - in addition to the submission allocations at South East MK and East of MK - would equate to over-allocation.

3.4.5 The third conclusion is that proposals for the’ Wavendon/Woburn (Eastern) Broad Area’ are not sufficiently advanced to enable allocation through Plan:MK; and, furthermore, a scheme would need to be delivered subsequent to development at Wavendon Golf Club, leading to over-allocation and/or a risk of development only commencing beyond the plan period.

3.4.6 The fourth conclusion is that ‘WEA Expansion’ is the sequentially least preferable of the four remaining housing / mixed-use sites in contention. It is also the case that it is being less actively promoted than the other sites, leading to concerns in respect of deliverability.

3.4.7 This leaves three housing / mixed use omission sites that might feasibly be allocated in order to deliver additional growth (housing only) -  Levante Gate (500 homes)  Wavendon Golf Club (700 homes)  Shenley Dens (1,500 homes)

3.4.8 These housing / mixed use sites are considered further below.

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SA of Plan MK

Summary of bottom-up understanding (employment)

3.4.9 North East of Newport Pagnell is potentially suitable when viewed in isolation, i.e. blind to demand and other strategic considerations. However, allocation of this site is not needed. Demand for B8 employment land will be more than met by delivery at the South Caldecotte allocation, and the strong likelihood of significant additional delivery within the East of MK strategic mixed-use site.

The reasonable alternatives

3.4.10 One argument is to suggest that there is only one reasonable spatial strategy option at the current time, namely the submission allocations (as modified),17 about which no major concerns have been raised by the Inspector.

3.4.11 However, on balance it is considered reasonable to consider the following five alternatives (also shown graphically across a series of maps, below) -

1) Submission allocations

2) Submission allocations plus 500 homes at Levante Gate

3) Submission allocations plus 700 homes at Wavendon Golf Club

4) Submission allocations plus 1,200 homes at Levante Gate and Wavendon Golf Club

5) Submission allocations plus 1,500 homes at Shenley Dens

3.4.12 There are other site combinations that could deliver higher growth still; however, these options are ruled-out as unreasonable on the basis that they would involve over-allocation. The submission allocations involve land sufficient to deliver OAHN plus a ‘buffer’ of 16.7% (before account is taken of the need to apply a contingency for unanticipated non-delivery), whilst Option 5 would involve a 22% buffer.

17 Some minor changes to the submission allocations have been agreed already through the allocation. Most notably, the extent of the South East MK allocation has been extended with the addition of a field to the east.

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Contains Ordnance Survey Data © Crown Copyright and database right 2018. Development Sites have been provided by Milton Keynes Council. L O E P G C E M H M T E m o o i i I x l N m u t O p e o s l D m d n o i N n

y i U k g t m

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3 4 ± 5 k m Contains Ordnance Survey Data © Crown Copyright and database right 2018. Development Sites have been provided by Milton Keynes Council. L O E P G C E M H M T E m o o i i I x l N m u t O p e o s l D m d n o i N n

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3 4 ± 5 k m Contains Ordnance Survey Data © Crown Copyright and database right 2018. Development Sites have been provided by Milton Keynes Council. L O E P G C E M H M T E m o o i i I x l N m u t O p e o s l D m d n o i N n

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3 4 ± 5 k m Contains Ordnance Survey Data © Crown Copyright and database right 2018. Development Sites have been provided by Milton Keynes Council. L O E P G C E M H M T E m o o i i I x l N m u t O p e o s l D m d n o i N n

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3 4 ± 5 k m Contains Ordnance Survey Data © Crown Copyright and database right 2018. Development Sites have been provided by Milton Keynes Council. L O E P G C E M H M T E m o o i i I x l N m u t O p e o s l D m d n o i N n

y i U k g t m

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3 4 ± 5 k m SA of Plan MK

4 APPRAISING REASONABLE ALTERNATIVES

4.1 Introduction

4.1.1 The aim of this chapter is to present summary appraisal findings in relation to the reasonable alternatives introduced above. Detailed appraisal findings are presented in Appendix II.

4.2 Summary alternatives appraisal findings

4.2.1 Table 4.1 presents summary appraisal findings in relation to the nine alternatives introduced above. Detailed appraisal methodology is explained in Appendix IV, but in summary:

Within each row (i.e. for each of the topics that comprise the SA framework) the columns to the right hand side seek to both categorise the performance of each option in terms of ‘significant effects’ (using red / amber / green) and also rank the alternatives in order of performance. Also, ‘ = ’ is used to denote instances where the alternatives perform on a par (i.e. it not possible to differentiate between them).

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Table 4.1: Summary appraisal of the refined reasonable spatial strategy alternatives (Sept 2018) Rank of performance / categorisation of effects

Option 1 Option 2 Option 3 Option 4 Option5 Topic Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Levante Gate Wavendon GC Levante Gate Shenley Dens Wavendon GC

Communities 2 2 3

Deprivation = = = = =

Education 2 2 3

Health 2 2 3

Homes 5 4 3 2

Services 2 2 3

Air quality = = = = =

Biodiversity 2

Climate = = = = = change

Heritage 2 2 2

Landscapes 3 2 4 5

Nat resources 3 2 4 2

Noise 2 2

Transport 3 2

Water = = = = =

Business/ Economy/ = = = = = Employment

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SA of Plan MK

Option 1 Option 2 Option 3 Option 4 Option5 Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Levante Gate Wavendon GC Levante Gate Shenley Dens Wavendon GC

Conclusion A headline conclusion is that Option 1 (submission allocations) performs best, or equal best, in terms of all objectives other than ‘Housing’. The housing land supply under Option 1 (the lowest growth option) has been determined to be suitably robust by the Plan:MK Planning Inspector (see paras. 3.2.10 and 3.2.11, above) in that it will deliver the established OAHN / housing target (26,500 homes) over the course of the plan period, and on a suitably smooth trajectory (i.e. in the region of 1,766 dpa). However, additional supply (i.e. Options 2 to 5) would further reduce the risk of falling below the committed/required housing trajectory due to unforeseen delays to delivery at one or more sites (and thereby further increase confidence in respect of the Council’s ability to demonstrate a rolling five year housing land supply, and meet the Housing Delivery Test, across the plan period). The second point to note is that Option 5 performs relatively well in relation to a number of objectives, but notably poorly in terms of ‘Landscape’, as the additional allocation in question - Shenley Dens - is constrained by its location on the Shenley Ridge. An alternative Shenley Dens scheme, using only the eastern-most c.1/3 of the site (namely that which relates best to the existing urban edge) has recently been promoted to the Council; however, landscape concerns would remain. The northern edge would abut the open space planned as the southwestern buffer of the WEA, responding to the Shenley Ridge. A third point to note is the identical conclusion reached within the ‘Communities’, ‘Education’, ‘Health’ and ‘Services’ rows of the appraisal table. Option 4 performs poorly as it runs contrary to the broad policy of supporting housing delivery at strategic scale sites that are well suited to delivering significant new and upgraded infrastructure. Focusing on the question of Option 2 versus Option 3, the appraisal finds Option 3 to perform better in landscape, noise and transport terms; however, these conclusions are all somewhat marginal, and it does not automatically follow that Option 3 is the better option overall (e.g. noting that Option 2 performs better in ‘Heritage’ terms).

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5 DEVELOPING THE PREFERRED APPROACH

5.1 Introduction

5.1.1 The aim of this Chapter is to present the Council’s response to the alternatives appraisal / the Council’s reasons for developing the preferred approach in-light of alternatives appraisal.

5.2 The Council’s outline reasons

5.2.1 The Council’s preferred approach is Option 1, i.e. the Council’s view is that further modifications to the submission spatial strategy are not warranted.

5.2.2 The following text, which is provided by the Council, explains the justification for supporting Option 1 -

“The alternatives appraisal lends clear justification for Option 1. The housing supply trajectory, under Option 1, is considered suitably robust, and whilst arguments for providing for an increased rate of housing delivery are emerging - given Government’s commitment to delivering 1 million new homes in the Oxford to Cambridge Arc by 2050 - it will be for the review of Plan:MK to respond.

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SA of Plan MK

PART 2: WHAT ARE SA FINDINGS AT THIS CURRENT STAGE?

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SA of Plan MK

6 INTRODUCTION (TO PART 2)

6.1.1 The aim of this part of the report is to present appraisal findings in relation to the proposed modifications (to Plan:MK as submitted) that are currently published for consultation.

6.1.2 Before presenting the appraisal, there is firstly a need to discuss methodology and also list proposed modifications that can be ‘screened-out’ from detailed appraisal.

6.2 Methodology

6.2.1 The appraisal identifies and evaluates ‘likely significant effects’ of proposed modifications on the baseline, drawing on the sustainability topics / objectives identified through scoping (see Table 3.1) as a methodological framework.

6.2.2 The focus of the appraisal is on the proposed modifications (given that it is the proposed modifications that are currently the focus of consultation); however, explicit consideration is also given to the effects of Plan:MK as modified (i.e. the cumulative effects of the proposed modifications and the rest of Plan:MK as submitted).

6.2.3 Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration, and understanding of the baseline. Given uncertainties there is inevitably a need to make assumptions, e.g. in relation to plan implementation and which/how aspects of the baseline would be impacted.

6.2.4 Assumptions are made cautiously, and explained within the text. The aim is to strike a balance between comprehensiveness and conciseness/accessibility to the non-specialist. In many instances, given reasonable assumptions, it is not possible to predict significant effects, but it is possible to comment on effects in more general terms.

6.2.5 It is important to note that effects are predicted taking account of the criteria presented within Schedule 1 of the SEA Regulations.18 So, for example, account is taken of the probability, duration, frequency and reversibility of effects as appropriate. Cumulative effects are also considered, i.e. effects that become apparent once the effects of the proposed modifications / the submission plan plus modifications are considered in a wider context.

6.3 Screening the proposed modifications19

6.3.1 Of the 45 proposed modifications, the following can be screened-out, on the basis that they have limited substantive implications (i.e. are not likely to result in significant effects) -  MM1 - deletion of Policy MK1, which essentially repeats NPPF, para 14.  MM2 - supporting text relating to the review of Plan:MK.  MM7 - explains the anticipated trajectory of housing delivery over the plan period.  MM19 - requires a comprehensive development framework for East of MK.  MM27 - deals with Policy HN11 (Hot Food Takeaways), clarifying that the 400m zone will be assessed on the most logical walking distance from the main school entrance.  MM20 - deletes supporting text, with the text moved to Policy SD3.  MM40 - corrects a drafting error relating to developer contributions for public art.  MM42 - adds one site allocation (60 dwellings), which forms part of the previous outline application for residential development across Campbell Park.  MM43 to 45 - deal with new and adjusted appendices to the plan.

6.3.2 The remaining proposed modifications (‘MMs’) are discussed within the appraisal below.

18 Environmental Assessment of Plans and Programmes Regulations 2004 19 To reiterate, the focus is on ‘main’ modifications only.

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7 APPRAISAL OF PROPOSED MAIN MODIFICATIONS

7.1 Introduction

7.1.1 This section presents an appraisal of the ‘screened-in’ proposed modifications. Also, consideration is given to the effects of ‘the submitted plans plus proposed modifications’.

7.1.2 The appraisal is presented below under 17 topic headings (‘the SA framework’), with each topic-specific narrative split using two sub-headings.

7.2 Communities

Proposed modifications

7.2.1 MM5 proposes new supporting text, with the aim of making Policy DS1 effective. The text explains that, within the rural area of the Borough, most new development will be concentrated within the key settlements of Newport Pagnell, Olney and Woburn Sands. Elsewhere within the rural area new development will occur within villages and other rural settlements at locations identified in made neighbourhood plans. This provides important clarity for rural communities.

7.2.2 MM12 proposes additional text in support of Policy SD3 (Central Milton Keynes – Growth and Areas of Change), providing detail on the type and mix of uses the Council would consider appropriate as part of a primarily residential–led development scheme at Campbell Park. This guidance should help to ensure the community evolves in a planned fashion.

7.2.3 MM13 deals with Policy SD2 (Central Milton Keynes - Role and Function), proposing a modification to the area comprising the CMK Primary Shopping Area (PSA), bringing the area into line with the adopted Core Strategy, and excluding the area around the Xscape building. The effect should be to ensure effective ‘zoning’ of distinct areas within CMK.

7.2.4 MM15 deals with SD13 (South East Milton Keynes Strategic Urban Extension), establishing a number of site specific requirements. Perhaps most notably, there is a new requirement for -

“schools to accommodate seven forms of entry for secondary education and 6 forms of entry for primary education, as well as necessary nursery and early years provision. Schools should be capable of dual use as community facilities”.

7.2.5 MM16 proposes an eastwards extension to the extent of the South East MK strategic urban extension. The parcel of land might alternatively provide a small green buffer between the site and the existing settlement of Woburn Sands.

7.2.6 MM17 - proposes a modest northern extension to the ‘East of MK’ strategic urban extension site. The additional land is at the further point from CMK, potentially serving to bring into question the ability of new residents to be suitably well linked to CMK.

7.2.7 MM37 deals with Policy L4 (Public Open Space Provision in New Estates) requiring a -

“management and maintenance strategy outlining details of future ownership and the responsible maintenance body (e.g. Parks Trust), and a long term financially sustainable maintenance plan…”

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SA of Plan MK

Submission Plan:MK plus proposed modifications

7.2.8 The SA Report concluded the following in relation to the submission plan -

The proposal is to support two large scale new developments, which should deliver new community facilities; however, delivery at both is somewhat uncertain, and there is a degree of uncertainty regarding the extent/nature of community facilities to be delivered at the South East MK proposed allocation (including in relation to secondary school provision). The proposal to follow a restrained approach to growth within the MK urban area, with a focus of housing growth within CMK and Campbell Park, is broadly supported. The proposed thematic / development management type policies are all strongly supported, including on the basis that they propose building upon the special characteristics of MK communities, as established over the past fifty years. Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects.

7.2.9 The effect of proposed modifications is strongly positive, and in particular the proposal to deliver a new seven form entry secondary school; however, it is still not possible to conclude that the positive effects of Plan:MK will be ‘significant’.

7.3 Deprivation

Proposed modifications

7.3.1 See discussion of adjustments to affordable housing policy below, under ‘Housing’.

Submission Plan:MK plus proposed modifications

7.3.2 The SA Report concluded the following in relation to the submission plan -

The proposed spatial strategy has limited implications for the achievement of ‘deprivation’ related objectives, although the effect may be to deliver ‘above OAHN’, which in turn would involve meeting affordable housing needs more fully, which in turn would have positive implications for ‘deprivation’ objectives. Perhaps the most notable element of the Proposed Submission Plan is the policy support for Central Bletchley Urban Design Framework, with policy criteria proposed that will help to guide future planning decisions. Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects.

7.3.3 This conclusion broadly holds true for the submission plan plus proposed modifications. Adjustments to affordable housing policy are positive, but fairly minor.

7.4 Education

Proposed modifications

7.4.1 See discussion of the new requirement for a secondary above, under ‘Communities’.

Submission Plan:MK plus proposed modifications

7.4.2 The SA Report concluded the following in relation to the submission plan -

The proposal is to support two large scale new developments, which should deliver new community facilities, and there is a specific policy requirement for the East of M1 site to deliver a new secondary school; however, delivery at both is somewhat uncertain. The proposed thematic / development management type policies are all strongly supported, in particular, Policy EH1 (Provision of New Schools – Planning Considerations) and Policy EH2 (Provision of New Schools – Site Size and Location). Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects.

7.4.3 This conclusion broadly holds true for the submission plan plus proposed modifications. See further discussion above, under ‘Communities’.

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7.5 Health

Proposed modifications

7.5.1 MM28 - deals with Policy HN11 (Hot Food Takeaways), clarifying that -

“The Council has produced an indicative map (refer to Appendix J). This confirms the intent of the policy is to manage food options in proximity to schools to address the prevalence of overweight and obesity in children. As such, Policy EH8 would not result in a moratorium on additional Hot Food Takeaway provision in the Borough including locations such as CMK and a number of district/town centres. More detailed analysis of the 400m logical walking distance on a case by case basis may provide some further flexibility.”

Submission Plan:MK plus proposed modifications

7.5.2 The SA Report concluded the following in relation to the submission plan -

Policy SD1 (Place-Making Principles for Development) and other thematic / development management type policies should ensure development of sustainable new communities, with positive implications for health determinants. The proposal to follow a restrained approach to growth in the urban area, with limited development of existing urban open spaces, is also supported. Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects, recognising the wide-ranging nature of health determinants.

7.5.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.6 Homes

Proposed modifications

7.6.1 MM3 proposes new policy DS0 (Review of Plan:MK), which commits the Council to undertaking an early review of Plan:MK, with the submission of a draft plan for examination, containing strategic policies for the long-term growth of Milton Keynes, no later than December 2022. Following the completion of the joint Strategic Growth Study and adoption of the Council’s Strategy for 2050, the review of Plan:MK will bring the delivery of the long-term aspirations for transformational growth into a statutory planning policy document. The parameters and format of the review will also reflect Milton Keynes’ growth proposals within the context of progress on the delivery of the Government’s wider Cambridge – Milton Keynes – Oxford Corridor growth agenda, including associated national infrastructure projects. This proposed approach is a positive step, from a ‘Housing’ perspective.

7.6.2 MM4, MM6 and MM8 deal with Policy DS2 (Housing strategy), explaining that East of MK is now a formal allocation. A suitably proactive approach is taken to supporting housing delivery, as follows -

“If the necessary infrastructure can be funded and delivered prior to 2031, then the development will be allowed to proceed within the plan period. In that circumstance, the number of dwellings that the site can contribute towards the housing supply of Plan:MK will be dependent upon when development commences. For the purposes of Plan:MK’s housing supply a conservative total of 1,475 dwellings of the potential 3,000 is assumed to be deliverable within the plan period.”

7.6.3 MM14 is also notable for the number of homes allocated at Campbell Park having increased significantly. This is because Campbell Park Northside has changed from being a commitment to an allocation.

7.6.4 MM24 deals with Policy HN2 (Affordable Housing). Most notably, the modifications seek to ensure that the proportion of affordable housing that is available for rent (25%) are available for a rent that is no more than Local Housing Allowance rates.

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7.6.5 MM25 deals with Policy HN5 (Self-Build and Custom Housebuilding), clarifying that -

“To further support prospective custom builders, the strategic growth areas allocated within Plan:MK, and any proposals for further strategic residential development, will be required to provide 1 hectare of the site for serviced dwelling plots for sale to custom builders to contribute towards meeting the evidenced demand for self-build and custom housebuilding...”

7.6.6 MM26 deals with Policy HN11 (Gypsies and Travellers), deleting a criterion that sought to restrict sites coming forward at locations “prominent from public vantage points”.

7.6.7 MM38 proposes new Policy D4, which aims to encourage and support innovation in the design and construction of new homes consistent with MKC’s emerging Strategy for 2050. The requirement is that -

“Proposals for 50 or more dwellings will be required to provide 10% of new dwellings that incorporate innovative design features and modern methods of construction, such as modular / off site construction techniques.”

7.6.8 MM39 proposes new supporting text relating to innovative approaches to housing delivery, for example stating -

7.6.9 “Off-site and modular construction as examples of innovative construction techniques can also help speed up housing delivery through a quicker build programme as well as provide an additional outlet or means of supply of new housing while raising the profile/reputation of Milton Keynes as a “city of design”

Submission Plan:MK plus proposed modifications

7.6.10 The SA Report concluded the following in relation to the submission plan -

The effect of the plan should be to provide for OAHN, and it may be that the effect is to provide for ‘above OAHN’ and thereby more fully provide for the affordable housing needs that exist. Furthermore, the plan provides for the accommodation needs of Gypsies and Travellers, and thematic policies / development management type policies are proposed to ensure a good housing mix, and ensure that specialist accommodation needs are provided for. On this basis, the plan is predicted to result in significant positive effects.

7.6.11 This conclusion broadly holds true for the submission plan plus proposed modifications, and indeed the effect of proposed modifications is to re-inforce this conclusion. The effect of the new commitment to an early review, in particular, is strongly positive. Adjustments to policies HN2 (Affordable Housing) and Policy HN11 (Gypsies and Travellers) are also strongly supported.

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7.7 Services

Proposed modifications

7.7.1 The proposed modifications have limited implications, although see discussion above under ‘Communities’, and also discussion of shopping frontages under ‘Economy’, below.

Submission Plan:MK plus proposed modifications

7.7.2 The SA Report concluded the following in relation to the submission plan -

The proposal is to support two large scale new developments, which should deliver new community facilities, although there is some uncertainty at this stage, ahead of further work(e.g. to establish requirements) and masterplanning. Policy SD1 (Place-Making Principles for Development) - establishes a range of important principles, and other thematic / development management type policies are also supported, including Policy CC5 (New Community Facilities), Policy CC3 (Protection of Community Facilities) and Policy CC2 (Location of Community Facilities). Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects.

7.7.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.8 Air quality

Proposed modifications

7.8.1 None of the proposed modifications are likely to have implications for air quality.

Submission Plan:MK plus proposed modifications

7.8.2 The SA Report concluded the following in relation to the submission plan -

Whilst air pollution is not a significant issue for the borough as a whole, there is nonetheless a need to minimise the number and distance of trips by non-electric private car, in order to avoid worsened air pollution, and the risk of poor air quality hotspots developing (such that further AQMAs might need to be designated). In this respect, the proposed spatial strategy is broadly supported. As discussed below, under ‘Transportation’, both the SE MK strategic urban extension, and the proposed new strategic employment site at Caldecotte South, are well located in transport terms, given proximity to rail stations on East-West Rail; whilst there should be good potential for the East of MK proposal (delivery of which is uncertain) to achieve a good degree of trip internalisation (i.e. there should be good potential to support trips by walking/cycling, and minimise trips offsite). Overall, whilst there could be some localised worsening of air quality, ‘significant’ negative effects are not predicted.

7.8.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.9 Biodiversity

Proposed modifications

7.9.1 MM15 deals with SD13 (South East Milton Keynes Strategic Urban Extension), establishing a number of site specific requirements. Perhaps most notably, there is a new requirement for development to -

“ensure ecological connectivity, and mitigate any harm caused to the Brickhills area and wider landscape character.”

7.9.2 MM18 deals with SD14 (Milton Keynes East), establishing a number of site specific requirements. Perhaps most notably, the modification clarifies the need for -

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“The creation of a linear park through the site that broadly correlates with the River Ouzel floodplain and existing green infrastructure assets of value within and adjacent to it.”

7.9.3 MM11 adds a number of references to green infrastructure to Policy SD1 (Plan-making Principles for Development), notably: “Existing natural assets including green infrastructure features connections and functions should be identified prior to development; and enhanced, extended, protected and connected appropriately – i.e. designed and planned for - so it provides multiple benefits to the environment and wildlife, also to the health and wellbeing of residents and to supporting the local economy.” There is also the clear statement that -

“Development should result in a net gain in biodiversity through use of strategic, connected green infrastructure, in line with policies NE1-6 and ensure consideration.”

7.9.4 MM32 deals with Policy NE2 (Protected Species and Priority Species and Habitats) arguably decreasing the degree of protection provided to priority species and habitats (but maintaining the protection for statutorily protected species. The aim is to make the policy more effective, and there remains a clear statement that -

“Where the site contains priority species or habitats, development should wherever possible promote their preservation, restoration, expansion and/or re-creation in line with Policy NE3.”

7.9.5 MM33 deals with Policy NE3 (Biodiversity and Geological Enhancement), with the policy strengthened by the requirement that development proposals should -

“wherever possible result in measurable net gain in biodiversity… Development proposals of 5 or more dwellings or non-residential floorspace in excess of 1,000 sq. m will be required to use the Defra metric or locally approved Biodiversity Impact Assessment Metric to demonstrate any loss or gain of biodiversity.”

7.9.6 MM34 deals with Policy NE4 (Green Infrastructure), importantly requiring that GI must be -

“… multi-functional to deliver as many ecosystem services as the site requires, for example flood mitigation, access to nature (wellbeing benefits), plants for pollinators, carbon sequestration, and habitat for wildlife.”

7.9.7 MM31 deals with Policy NE1(Protection of sites), emphasising the importance of following the mitigation hierarchy (i.e. avoid as far as possible, mitigate only where necessary and compensate only as a last resort), and also notably adds a reference to protecting ‘irreplaceable habitats’.

Submission Plan:MK plus proposed modifications

7.9.8 The SA Report concluded the following in relation to the submission plan -

Proposed development sites are relatively unconstrained, and a very robust development management policy framework is proposed, in accordance with existing objectives, e.g. the need to reflect / build upon the linear parks network. Overall, the plan performs well, but it is not possible to conclude ‘significant’ positive effects.

7.9.9 The effect of proposed modifications is mostly positive, in particular the new requirements in respect of ‘net gain’; however, it is still not possible to conclude that the positive effects of Plan:MK will be ‘significant’. Practice in respect of achieving ‘net gain’ is emerging.

7.10 Climate change

Proposed modifications

7.10.1 MM27 proposes new Policy D4, which aims to encourage and support innovation in the design and construction of new homes consistent with MKC’s emerging Strategy for 2050. The requirement is that -

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“Proposals for 50 or more dwellings will be required to provide 10% of new dwellings that incorporate innovative design features and modern methods of construction, such as modular / off site construction techniques.”

7.10.2 Modular housing / offsite construction techniques have the potential to reduce the carbon footprint of new development, although there remains some uncertainty ahead of large-scale roll-out of such methods.

7.10.3 MM15 and MM18 supplement site specific policy for the two main strategic urban extensions - South East MK and East of MK; however, there is no proposal to add requirements in respect of delivery of low carbon infrastructure, e.g. localised heat/power generation and a heating network; this is on the basis that the matter is considered to be sufficiently covered by development management policy applying to all planning applications. There is, however, helpful clarification regarding the scale of employment development that should occur within the East of MK site, which is potentially supportive of delivering a heating network.

7.10.4 With regards to CO2 emissions from transport (as opposed to the built environment), see discussion of support for walking/cycling and public transport below, under ‘Transport’.

Submission Plan:MK plus proposed modifications

7.10.5 The SA Report concluded the following in relation to the submission plan -

There may well be an opportunity to deliver low carbon heat or electricity as part of the East of M1 scheme, recognising its scale; however, no such measures have been proposed to date, plus delivery of the site is uncertain at the current time. The proposed thematic / development management policy framework should help to ensure that opportunities are examined fully, and capitalised upon where possible; however, it is recognised that viability considerations will often be prohibitive in practice. Overall, the plan performs moderately well, with there being the potential for more stringent policy to be established (as is invariably the case). Significant effects are not predicted, recognising that climate change mitigation is a global issue.

7.10.6 This conclusion broadly holds true for the submission plan plus proposed modifications. There is increased certainty regarding delivery of East of M1, but still no firm commitments regarding opportunities for the scheme to minimise per capita CO2 emissions.

7.11 Heritage

Proposed modifications

7.11.1 MM15 deals with SD13 (South East Milton Keynes Strategic Urban Extension), establishing a number of site specific requirements. Perhaps most notably, there is a requirement for development to -

“Be informed by an archaeological field study, including a Geophysical Survey, to identify potential below ground archaeology. Where feasible, the Council will expect below ground archaeology to be kept in situ in preference to its removal.”

Submission Plan:MK plus proposed modifications

7.11.2 The SA Report concluded the following in relation to the submission plan -

In conclusion, the plan performs well, recognising that development is generally directed to areas with limited heritage constraint, and there is support for ‘renaissance’ within CMK; however, significant positive effects are not predicted.

7.11.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

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7.12 Landscapes

Proposed modifications

7.12.1 MM10 proposes addition of a new criterion to Policy DS5 (Open countryside). Specifically, the additional proposal is supportive of a more permissive approach to development whereby -

“New dwellings which are of exceptional quality or innovative in the nature of their design might be accepted where they conform with paragraph 55 of the NPPF.”

7.12.2 MM15 deals with SD13 (South East Milton Keynes Strategic Urban Extension), establishing a number of site specific requirements. Perhaps most notably, there is a requirement for development to -

“ensure ecological connectivity, and mitigate any harm caused to the Brickhills area and wider landscape character.”

7.12.3 MM18 deals with SD14 (Milton Keynes East), establishing a number of site specific requirements. Notably, the modification clarifies that the site should -

“protect the identity and character of nearby settlements.”

7.12.4 Also of note from MM18 is clarification of the need for -

“The creation of a linear park through the site that broadly correlates with the River Ouzel floodplain and existing green infrastructure assets of value within and adjacent to it.”

Submission Plan:MK plus proposed modifications

7.12.5 The SA Report concluded the following in relation to the submission plan -

In conclusion, the plan performs well, recognising that development is generally directed to areas with limited landscape constraint, albeit the South of Caldecotte proposed strategic employment site may be subject to a degree of constraint. Overall, significant effects are not predicted.

7.12.6 This conclusion broadly holds true for the submission plan plus proposed modifications, and indeed the effect of proposed modifications is to re-inforce the conclusion that there will not be significant negative landscape impacts. The requirement to “mitigate any harm caused to the Brickhills area” is strongly positive.

7.13 Natural resources

Proposed modifications

7.13.1 MM36 proposes a ned policy - Policy NE7 (Protection of the Best and Most Versatile Agricultural Land) - with MM35 proposing supporting text. The policy states -

“In assessing proposals for the development of greenfield sites, the Council will take into account the economic and other benefits of the best and most versatile agricultural land. Development involving the loss of agricultural land should seek to use areas of poorer quality land (grades 3b, 4 and 5 of the Agricultural Land Classification) in preference to that of a higher quality unless other sustainability considerations suggest otherwise.”

7.13.2 This is supported; however, it will rarely be the case that land falling within the boundary of proposed development sites will be left in agricultural use.

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Submission Plan:MK plus proposed modifications

7.13.3 The SA Report concluded the following in relation to the submission plan -

Development of the South East MK site will result in the loss of best and most versatile agricultural land, and so there is a need to conclude that the plan will result in significant negative effects.

7.13.4 This conclusion broadly holds true for the submission plan plus proposed modifications. A new policy is proposed relating to protection of best and most versatile agricultural land; however, it is judged likely to lead to only minor benefits. There is, first and foremost, a need to take account of agricultural land quality as part of site selection.

7.14 Noise

Proposed modifications

7.14.1 None of the proposed modifications are likely to have implications for air quality.

Submission Plan:MK plus proposed modifications

7.14.2 The SA Report concluded the following in relation to the submission plan -

The proposal is to locate new homes in proximity to significant sources of noise pollution; however, there will be good potential to avoid/mitigate negative effects, through masterplanning and design measures. As such, significant negative effects are not predicted.

7.14.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.15 Transport

Proposed modifications

7.15.1 MM15 deals with SD13 (South East Milton Keynes Strategic Urban Extension), establishing a number of site specific requirements. Perhaps most notably, there is a requirement for development to -

“[integrate with] adjacent grid squares, public transport services and the strategic and local highway grid network in line with the Council’s Mobility Strategy.” There is also a requirement for: “Provision of grade separated crossings of the railway should be provided or retained as appropriate to ensure connectivity of the southern areas of the site with the remainder of the site and the city to the north in line with policies CT1-CT3 and CT5.”

7.15.2 MM16 proposes an eastwards extension to the extent of the South East MK strategic urban extension. The parcel of land is in very close proximity to Wooburn Sands train station (East West Rail), and furthermore it is likely that availability of this land will be supportive enabling suitable road access to the site.

7.15.3 MM18 deals with SD14 (Milton Keynes East), establishing a number of site specific requirements. Perhaps most notably, the modification clarifies that the site should deliver -  “A corridor of land… for a fast mass-transit system, and associated infrastructure, enabling connectivity to CMK and other key destinations. The width of the corridor should be sufficient to enable a range of possible transit solutions to come forward whilst also ensuring the efficient use of land for achieving the scale of development proposed within this policy.” An effect of the modification is to remove reference to Cranfield, as a location that should be linked to CMK via the new route.”

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 “A network of segregated, and where appropriate grade-separated, new and enhanced footpaths, cycleways and bridleways (including redways) to connect to existing routes beyond the site, including provision of appropriate pedestrian and cyclist crossings of the A422 and suitable safe and attractive crossings of the M1 as appropriate.”

Submission Plan:MK plus proposed modifications

7.15.4 The SA Report concluded the following in relation to the submission plan -

Transport modelling work has completed, with the general conclusion reached that Plan:MK will have limited impact on the baseline, recognising that the baseline situation is one whereby there is a large amount of committed housing and employment growth. The proposed allocations at South East MK and South of Caldecotte are broadly supported, but it is difficult to conclude that the proposed East of M1 site performs well, from a transport perspective (albeit there is the potential to support delivery of a mass transit route between CMK and Cranfield University). A robust policy framework is proposed, which should help to ensure that new schemes are delivered in such a way that per capita distance travelled by private (petrol/diesel) cars is minimised. Overall, the plan has somewhat mixed effects, with there being no basis upon which to conclude ‘significant’ effects, either positive or negative.

7.15.5 The effect of proposed modifications is strongly positive, e.g. the new requirement for walking and cycling routes within Milton Keynes East that are “segregated, and where appropriate grade-separated”. However, it is still not possible to conclude that the positive effects of Plan:MK will be ‘significant’.

7.16 Water

Proposed modifications

7.16.1 MM41 deals with Policy SC1 (Sustainable Construction), clarifying that one of the policy requirements (“Water reuse and recycling and rainwater harvesting should also be incorporated wherever feasible to reduce demand on mains water supply”) is subject to viability.

7.16.2 MM29 deals with Policy FR1 (Managing Flood Risk), stating that -

“All new development must incorporate a surface water drainage system with acceptable flood control and demonstrate that water supply, foul sewerage and sewage treatment capacity is available or can be made available in time to serve the development. Suitable access is safeguarded for the maintenance of water supply and drainage infrastructure.”

7.16.3 MM30 adds additional requirements to Policy FR2 (Sustainable Drainage Systems (SUDS) and Integrated Flood Risk Management, in particular requiring “fluvial flood risk reduction features” and also safeguarding of floodplains and floodplain habitats.

Submission Plan:MK plus proposed modifications

7.16.4 The SA Report concluded the following in relation to the submission plan -

The proposed East of M1 strategic allocation is constrained by flood risk; however, delivery of this site is uncertain, and in any case there will be good potential to avoid/mitigate flood risk through careful masterplanning. Significant negative effects are not predicted.

7.16.5 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.17 Waste

Proposed modifications

7.17.1 None of the proposed modifications are likely to have implications for air quality.

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7.17.2 The SA Report concluded the following in relation to the submission plan -

The plan has very minor implications for waste management objectives.

7.17.3 This conclusion broadly holds true for the submission plan plus proposed modifications.

7.18 Business/ Economy/ Employment

Proposed modifications

7.18.1 MM9 proposes addition of a new criterion to Policy DS3 (Employment development strategy). Specifically, the proposed addition commits the Council to encouraging -

“the growth and expansion of existing employment uses where it does not conflict with other policies in the plan”.

7.18.2 MM18 deals with SD14 (Milton Keynes East), establishing a number of site specific requirements. Perhaps most notably, the modification clarifies that the site should deliver -

“Around 105 hectares of land for a mix of employment uses, complementing the role and function of CMK.”

7.18.3 MM21 deals with Policy ER11 (Assessing Edge of Centre and Out of Centre Proposals), aiming to clarify how the two impact thresholds in the policy will be implemented. An important aim is to support the CMK Primary Shopping Area (PSA), with uses suited to the PSA only being allowed outside the PSA after having taken account of -

“a) The impact of the proposal on existing, committed and planned public and private investment in the PSA, and b) The impact of the proposal on vitality and viability of the PSA, including local consumer choice and trade in the PSA.”

7.18.4 MM22 deals with Policy ER19 (Non-Retail Uses on Ground Floors in Town Centres), deleting the requirement that proposals should not lead to a continuous frontage of 3 or more units in non-retail use within the primary shopping frontage

7.18.5 MM23 deals with the specific primary frontage at Kingston (an area close to the eastern extent of the MK urban area, close to the EEA). The aim is to allow for a greater amount of non-retail uses within Kingston.

Submission Plan:MK plus proposed modifications

7.18.6 The SA Report concluded the following in relation to the submission plan -

In conclusion, the plan performs well, recognising that provision is made for delivery of employment land over-and-above what is required. Significant positive effects are predicted.

7.18.7 This conclusion broadly holds true for the submission plan plus proposed modifications, and indeed the effect of proposed modifications is to re-inforce the conclusion that there will be significant positive effects. A highly ambitious approach to employment land delivery is proposed, which is strongly supportive of ambitions for the Oxford to Cambridge Arc.

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7.19 Overall conclusions

7.19.1 The appraisal finds proposed modifications to have wide-ranging positive implications, notably in respect of-  Communities - the effect of proposed modifications is strongly positive, and in particular the proposal to deliver a new seven form entry secondary school.  Homes - the effect of the new commitment to an early review, in particular, is strongly positive. Adjustments to policies HN2 (Affordable Housing) and Policy HN11 (Gypsies and Travellers) are also strongly supported.  Biodiversity - the effect of proposed modifications is mostly positive, in particular the new requirements in respect of ‘net gain’.  Landscape - the requirement to “mitigate any harm caused to the Brickhills area” is strongly positive.  Climate change mitigations - there is increased certainty regarding delivery of East of M1- a strategic site with clear potential to deliver ambitious low carbon infrastructure - but still no firm commitments regarding opportunities for the scheme to minimise per capita CO2 emissions.  Natural resources - a new policy is proposed relating to protection of best and most versatile agricultural land; however, it is judged likely to lead to only minor benefits. There is, first and foremost, a need to take account of agricultural land quality as part of site selection.  Transport - the effect of proposed modifications is strongly positive, e.g. the new requirement for walking and cycling routes within Milton Keynes East that are “segregated, and where appropriate grade-separated”.  Economy - a highly ambitious approach to employment land delivery is proposed, which is strongly supportive of ambitions for the Oxford to Cambridge Arc.

7.19.2 No major tensions (between proposed modifications and sustainability objectives) are highlighted, although there a number of ways in which modifications could feasibly ‘go further’.

Cumulative effects

7.19.3 The overall conclusion of the “appraisal of the proposed submission plan” presented in Chapter 10 of the SA Report was as follows -

“The appraisal finds the Proposed Submission Plan to perform notably well in respect of ‘Housing’ and ‘Businesses / economy / employment’ objectives, with the conclusion reached that there is the likelihood of ‘significant positive effects’ on the baseline. The appraisal also finds the plan to perform well in terms of several other objectives – notably ‘Transport’ – without going as far as to predict significant positive effects.

Significant negative effects are predicted only in respect of ‘Natural resources’ objectives, for the simple reason that the proposed South East MK urban extension would result in significant loss of ‘best and most versatile’ agricultural land. A range of other specific draw-backs, issues and uncertainties are highlighted, including relating to South East MK (uncertainty regarding strategic community infrastructure, and a concern regarding cumulative impacts of growth here alongside completion of the Eastern Expansion Area and Strategic Land Allocation); and East of MK (distance and separation from CMK).

7.19.4 These conclusions broadly hold true for “the submission plan plus proposed modifications”. East of MK is now a firm allocation, but site specific policy has been considerably supplemented. Site specific policy for South East MK has also been supplemented, e.g. with a firm requirement to deliver a new secondary school.

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Further notes on effect characteristics

7.19.5 The Inspector has requested that further detail is given regarding the various characteristics of the significant effects that are predicted in relation to the proposed submission plan (now proposed submission plan plus proposed modifications). Schedule 1 of the SEA Regulations lists a number of effect characteristics, each of which is considered in turn below  Probability of effects - the appraisal focuses on effects that are probable, although consideration is also given to ‘unlikely’ effects (e.g. it is ‘unlikely’ that the proposed agricultural land policy will lead to best and most versatile agricultural land being retained).  Duration of effects - the proposed allocations will build-out over an extended period of time, and indeed East of MK will deliver partly beyond the plan period. This gives rise to wide- ranging considerations, e.g. the need to avoid subjecting communities to the negative effects of building works over a long period of time, and also the need for development to be in-line with unknown future issues/priorities, e.g. in relation to the Oxford to Cambridge Arc.  Frequency of effects - many of the effects discussed will be broadly continuous, whilst others will be infrequent, in that they will occur when specific developments come forward.  Reversibility of effects - most of the effects discussed will be irreversible, or at least will not be reversible in the foreseeable future.  Cumulative nature of the effects - there is a stand-alone discussion of cumulative effects above, specifically a discussion of the proposed modifications impacting in combination with the rest of Plan:MK, namely that part which is not the focus of proposed modifications. There is also a stand-alone discussion of cumulative effects in the submission SA Report - see Section 10.19 - where the focus is on the effects of Plan:MK in combination with other adopted and emerging plans, including plans for the Oxford to Cambridge Arc.  Transboundary nature of the effects - the aim of the Regulations is to ensure that explicit consideration is given to international effects. Plan:MK is not likely to result in significant effects internationally; however, plans for the Oxford to Cambridge Arc are potentially of international significance, and it is clear that Milton Keynes is central to emerging plans.  Risks to human health or the environment (for example, due to accidents) - impacts to human health have been a focus of appraisal, as have environmental health considerations, including in relation to noise and air quality. Detailed issues will be considered further at the development management stage.  The magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected) - the appraisal has involved discussion of wide-ranging impact receptors, and there has also been a focus on ‘larger than local’ impacts, e.g. the potential for growth of MK to have implications for the achievement of planning / sustainable development objectives across Central Bedfordshire, and across the Ox-Cam Arc.  The value and vulnerability of the area likely to be affected due to special natural characteristics or cultural heritage - the appraisal has included a focus on valued aspects of the baseline, including areas with special natural characteristics or cultural heritage, for example the Greensand Ridge and associated villages, notably the Brickhills.  The value and vulnerability of the area likely to be affected due to exceeded environmental quality standards or limit values - no aspect of the baseline has been identified whereby there is both A) a breach of environmental quality standards or limit values; and B) the potential for a cause-effect relationship with Plan:MK.  The value and vulnerability of the area likely to be affected due to intensive land-use - as above.  The value and vulnerability of the area likely to be affected due to the effects on areas or landscapes which have a recognised national, Community or international protection status - there are no designated landscapes in the vicinity of MK; however, there are a range of areas and assets protected for other reasons. The appraisal has included a focus on the effects of Plan:MK on such areas and assets, e.g. conservation areas.

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PART 3: WHAT HAPPENS NEXT?

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8 INTRODUCTION (TO PART 3)

8.1.1 The aim of this chapter is to explain next steps in the plan-making / SA process.

9 PLAN FINALISATION

9.1.1 Subsequent to the current modifications consultation the Inspector will consider all representations received, before then considering whether or not there is a need for further examination hearing sessions. In due course, the Inspectors will then prepare a report on the soundness of the Local Plan.

9.1.2 Assuming that the Inspector is able to find the plan ‘sound’, it will then be adopted by the Council. At the time of adoption an ‘SA Statement’ will be published that explains the process of plan-making / SA in full and presents ‘measures decided concerning monitoring’.

10 MONITORING

10.1.1 At the current time, there is a need to present ‘measures envisaged concerning monitoring’.

10.1.2 The SA Report presented a list of the proposed monitoring indicators that were deemed to be of particular importance, in light of the appraisal of the plan presented within that report (see Table 13.1 of the SA Report).

10.1.3 At the current time, the most important consideration is the need to monitor implementation of the supplemented site specific policies for the South East MK and East of MK strategic allocations.

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APPENDIX I – SITE OPTIONS

Introduction As explained within Chapter 3 above, detailed consideration was given to site options as part of the process of arriving at reasonable spatial strategy alternatives. Summary findings are presented in Chapter 3, whilst the aim of this appendix is to present detailed findings.

Methodology The tables below present a detailed consideration of each of the site options in turn. Within each table consideration is given to the site option in question under each of the SA framework headings. N.B. the aim of Table A is not to present a formal ‘appraisal’ of each site option. In accordance with the Regulation 12(1) of the SEA Regulations, this SA Report Addendum presents an ‘appraisal’ in relation to “the plan” (or, more specifically, proposed modifications; see Chapter 7) and “reasonable alternatives” (see Chapter 4) only. The aim of discussing site options is to contribute to discussion of “outline of the reasons for selecting the alternatives dealt with” (Schedule 2(8)) presented in Chapter 3.

Detailed consideration of site options

Topic Levante Gate [500 homes]

As a smaller-scale scheme there are concerns in respect of ‘piecemeal’ housing growth, i.e. housing growth without economies of scale to enable strategic infrastructure upgrades, including community infrastructure. However, it is noted that a recent planning application (17/03233/OUT) included delivery of a 1fe primary school and a local centre. The site would benefit from relating very well to the strategic road network (A4146 and A5), along which run higher frequency bus services. However, the site is distant from CMK Communities (7km+); and in only moderate proximity to a train station (c.1.5km to 2km) and existing secondary school (in Water Eaton, c.2km to the west). The site would link well to the adjacent 600 home Eaton Leys scheme, which includes a local centre with a health centre and primary school, and also the adjacent proposed Caldecotte South strategic employment site; however, the site would link poorly to other key destinations by walking/cycling.

The Index of Multiple Deprivation (2015) dataset shows a band of relatively deprived areas running north-south through the MK urban area, with Bletchley and Wolverton being two established regeneration priority areas at either end of this ‘band’. However, none of the MK edge site options under consideration are in close-enough proximity to an area of relative deprivation to suggest the potential for development to result in regeneration benefits. Deprivation Affordable housing provision is another important consideration, with a bearing on achievement of this objective. All of the sites in question would be expected to deliver a good proportion of affordable housing, in accordance with policy; however, it is noted that the recent planning application for 600 homes at this site included 40% affordable housing, i.e. a figure in excess of the Core Strategy policy requirement of 30%.

The matter of ensuring access to schools is discussed above under ‘Communities’. N.B. Education data is not readily available regarding capacity at existing schools.

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As a relatively small site there would not be an expectation that any new healthcare facility would be delivered; however, the adjacent Eaton Leys scheme will deliver a new surgery. Health Another consideration is access to the countryside. In this respect it is noted that a bridleway passes through the centre of the site that is potentially of some strategic importance, in that it links the Grand Union Canal / River Ouzel Valley to the west with Little Brickhill (and the Greensand Ridge beyond) to the east.

The officers report in relation to the recent planning application anticipated that the site would build out immediately upon the granting of planning permission, noting that the site is in the control of a single house builder (the Guinness Partnership). The very fact that this is a smaller site also implies good potential to deliver early, and relatively low delivery risk. Homes However, there could be an argument for development to follow completion of - or at least substantial progress on - the adjacent Eaton Leys site, and/or the planned upgrades to the Kelly’s Kitchen roundabout (A5/A4146). Also, there is an element of delivery risk as the site falls within the preferred Oxford to Cambridge Expressway route corridor.

The matter of delivering new community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings. See also ‘Transport’, below.

There are no designated Air Quality Management Areas (AQMAs) within the MK urban area; however, there is nonetheless a need to minimise the number and distance of trips by non- electric private car, in order to avoid worsened air pollution, and the risk of poor air quality Air quality hotspots developing (such that an AQMA might need to be designated). See discussion above regarding potential to access key destinations by walking, cycling and public transport. See also ‘Transport’, below.

Available evidence serves to suggest that the site is of relatively low biodiversity sensitivity. As stated within the recent officers report: “The most important features of the site are the boundary hedgerows, most of which will be retained as part of the development.” Biodiversity The site lies at the foot of the Greensand Ridge, which is associated with a high density ancient woodland and other priority habitat; however, it is difficult to envisage that development of the site would lead to impacts, or impinge upon the achievement of nature conservation objectives relating to the Ridge.

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to consider the use of community energy networks in their development.” However, in practice viability considerations can be prohibitive, recognising the need to fund/deliver affordable housing and costly infrastructure (e.g. roads and schools). Neither of Climate the Expansion Areas are delivering an energy network, and whilst Policy CS5 (Strategic change Land Allocation, SLA) of the Core Strategy, which allocated the SLA, established policy - “Consider the use of community energy networks” – in practice the entire site now has outline planning permission, with no energy network(s) having been proposed. Focusing on Levante Gate, as a smaller scheme there would be little or no expectation of low carbon energy infrastructure being delivered (also noting that affordable housing delivery is a stated priority of the Guinness Partnership).

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There are no listed buildings in proximity to the site, although proximity to Little Brickhill Conservation Area is a consideration - see discussion below, under ‘Landscape’. Archaeology is another consideration, with the recent officers report to members stating the following: “Both the Council’s Archaeologist and [Historic] England confirm that the application site has high potential for significant buried archaeological remains, and that an Heritage appropriate field evaluation needs to be carried out prior to commencement. Without the provision of an archaeological field evaluation is not possible to demonstrate the sustainability of the development proposal in relation to heritage assets of archaeological interest (buried archaeological remains).” However, it is not clear that this serves as an argument against allocation, recognising that it would be possible to carry out appropriate field evaluation prior to commencement.

The site comprises rising land at the foot of the Greensand Ridge, with the village of Little Brickhill (with a designated conservation area) lying ‘above’ the site, c.1km to the east. The site relates poorly to the existing edge of Milton Keynes, and will not relate well even once the adjacent Eaton Leys scheme is built-out, on the basis that there would be open countryside to the north. Landscapes The Council’s Landscape Officer objected to the recent planning application, including on the grounds that development would set a precedent for other development proposals which cumulatively would have an adverse effect on the landscape character and the wider environment. However, the recent officers report concludes “the relative quality of the landscape that the application site sits in is not high”.

The site has been surveyed in detail and found to comprise 52% Grade 2 (i.e. second highest quality nationally) land, and 26% grade 3a (i.e. land also classified as ‘best and most Nat resources versatile’). Whilst it is not possible to be certain, in the absence of consistent data, it would appear likely that this is the most constrained of the site options in this respect.

The site lies between two ‘A’ roads, including the A5 main trunk road, and so it is fair to Noise conclude that noise pollution is a concern, albeit there will be good potential to avoid or suitably mitigate effects through masterplanning, landscaping and design measures.

Transport matters have already been discussed above, under a number of headings. In summary, the site does not perform well given its location, and also given the small scale of the development (such that there will be limited self-containment). However, the site relates well to the road network, including on the basis that the main junction (A5/A4146) will have capacity following the programmed upgrade, and in turn has Transport good access to existing high quality bus services. In respect of East West Rail, the nearest station would be c.1.5km to 2km distant, which is in cycling distance for many commuters; however, there is uncertainty regarding the ease of cycling. It appears that neither Watling Street (the route to Fenny Stratford Station) or Brickhill Street (the route to Bow Brickhill Station) has a cycle path.

The site is not subject to fluvial flood risk, and subject to only limited surface water flood risk Water (two areas close to the A4146 are at risk of pooling, but it is assumed that it would be possible to avoid built development in these areas).

The site would not deliver employment land. Business/ Economy/ The site does benefit from proximity to existing and proposed strategic employment areas at Employment the southern edge of MK. The site also benefits from moderately good proximity to EWR, and the Oxford to Cambridge Expressway is likely to pass in close proximity.

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Conclusion The site is distant (7km+) from CMK, in only moderate proximity to a train station (c.1.5 to 2km) and there would be relatively limited potential to walk/cycle to key destinations (although a recent planning application included delivery of a 1fe primary school and a local centre; the adjacent 600 home Eaton Leys scheme includes a local centre with a health centre and primary school; and the proposed Caldecotte South strategic employment site would be adjacent). The site is also subject to notable environmental constraints in respect of ‘landscape’ and ‘agricultural land’. In respect of the former, the Council’s Landscape Officer objected to a recent planning application, including on the grounds that development would set a precedent for other development proposals which cumulatively would have an adverse effect on the landscape character and the wider environment; however, the Officers Report relating to the planning application concludes “the relative quality of the landscape that the application site sits in is not high”. In respect of the latter, the site has been surveyed in detail and found to comprise 52% Grade 2 (i.e. second highest quality nationally) land, and 26% grade 3a (i.e. also ‘best and most versatile’). Whilst it is not possible to be certain, in the absence of consistent data, it would appear likely that this is the most constrained of the site options in respect of agricultural land. There are also delivery risks, as development might need to follow completion - or at least substantial progress - on the adjacent Eaton Leys site, plus the site falls within the preferred Oxford to Cambridge Expressway route corridor. However, the site benefits from relating very well to the strategic road network (A4146 and A5), along which run higher frequency bus services; and the site also benefits from its proximity to the A4146/A5 roundabout, which is programmed to receive a major upgrade.

Topic Wavendon Golf Course [700 homes]

As a smaller-scale scheme there are concerns in respect of ‘piecemeal’ housing growth, i.e. housing growth without economies of scale to enable strategic infrastructure upgrades, including community infrastructure. As per the site discussed above, this site would only link to the existing MK urban edge following completion of other strategic schemes - in this case the committed SLA20 to the north, and proposed South East MK to the west. However, this site is preferable in the sense that that both adjacent strategic schemes will deliver new secondary schools, with the SLA set to deliver a secondary school nearby.21 Communities In terms of proximity to existing services/facilities, the nearest existing secondary school is Walton High c.2km to the west, and there are local facilities at nearby Woburn Sands. Also of note is close proximity to Woburn Sands station (East West Rail) and adjacent Newport Road, which has a cycle path and forms part of the Redway Network. A final consideration relates to impacts to existing residents, e.g. residents of Wavendon and southeast MK, noting that: construction of the EEA22 has been ongoing for several years; construction of the SLA and Eaton Leys will soon commence; and, furthermore, there is the likelihood of South East MK and South Caldecotte (Submission Plan:MK allocations) commencing and building-out through the 2020s.

20 The Strategic Land Allocation was the main allocation made through the Core Strategy (2013). 21 See https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/strategic-land-allocation-development-framework- supplementary-planning-document-spd-adopted-november-2013 22 The Eastern Expansion Area was a strategic allocation made through the 2005 Local Plan.

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See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Deprivation Affordable housing provision is another consideration; however, it is not possible to suggest that this site performs any better or worse than other site options.

The matter of ensuring access to schools is discussed above under ‘Communities’. N.B. Education data is not readily available regarding capacity at existing schools.

As discussed above, under ‘Communities’, as a relatively small site there would not be an expectation that any new healthcare facility would be delivered; however, healthcare Health facilities will be delivered as part of adjacent committed / proposed strategic schemes. Another consideration is access to the countryside. In this respect it is noted that the Milton Keynes Boundary Walk long distance path passes through the site.

The timescale for housing delivery is inherently uncertain, given the need to follow the SLA Homes and South East MK.

The matter of delivering new community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings. See also ‘Transport’, below.

This site does not lead to any particular concerns. See further discussion above, under Air quality ‘Levante Gate’.

As an existing golf course there is mature vegetation on the site; however, there is no Biodiversity evidence to suggest any particular biodiversity value/sensitivity.

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to Climate consider the use of community energy networks in their development.” change However, in practice delivery of low carbon infrastructure is unlikely. See discussion above, under ‘Levante Gate’.

There are three clusters of listed buildings (ten in total) adjoining the site, and the site is Heritage 23 assigned ‘medium’ landscape sensitivity including due to evidence of former parkland.

Landscapes As discussed, the site is subject to ‘medium’ landscape sensitivity.

The site is not currently in agricultural use, but could feasibly be returned to agricultural use in the future. Agricultural land quality on the site has not been surveyed, but adjacent land Nat resources has been found to comprise ‘best and most versatile’ quality land (grade 3a). Hence there is a strong likelihood of the site comprising best and most versatile agricultural land.

Noise Noise pollution is not a concern at this site.

Transport matters have already been discussed above, under a number of headings. In summary, the site performs quite well on the basis of: good proximity to Woburn Sands Transport Station (EWR); good proximity to planned/proposed strategic community infrastructure at adjacent planned/proposed strategic sites; and location on the Redway Network.

Water The site is unconstrained by flood risk.

23 Landscape Sensitivity Study to Residential Development in the Borough of Milton Keynes and Adjoining Areas (Gillespies, 2016)

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The site would not deliver employment land. Business/ Economy/ The site does benefit from proximity to existing strategic employment areas on the eastern Employment edge of MK, and also notably benefits from its location on EWR and in proximity to the Oxford to Cambridge Expressway, which will pass through Junction 13 of the M1.

Conclusion Further expansion to the east, within the area of land bounded by the M1, A421 and the railway line, extending into Central Beds, makes strategic sense in certain (socio-economic) respects, recognising the need to focus growth in proximity to EWR stations (Woburn Sands station is within walking distance) and the Oxford to Cambridge Expressway, which will pass through Junction 13 of the M1. However, the site is subject to a relatively high degree of constraint, with ‘medium’ landscape sensitivity (including due to evidence of former parkland) and three clusters of listed buildings (ten in total) adjoining the site. Also, the site will only relate well to the MK urban edge following completion of the SLA. The site should logically be reconsidered in the future, once the SLA is completed or close to completion, and once South East MK (a sequentially preferable site) is at least underway. In the interim period site promoters might investigate the potential for a more strategic-scale scheme taking in additional land to the east, including the land discussed below as the “Wavendon / Woburn Sands (‘Eastern’) Broad Area”.

Topic WEA Expansion [1,000 homes]

Development would benefit from good links to the WEA,24 and in turn good links to other key destinations including CMK. The WEA is set to deliver a new secondary school.25 Communities Representations submitted in relation to this site have not proposed new strategic community infrastructure, but have proposed notable green infrastructure provision - see discussion below, under ‘Health’.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Deprivation Affordable housing provision is another consideration; however, it is not possible to suggest that this site performs any better or worse than other site options.

The matter of ensuring access to schools is discussed above under ‘Communities’. N.B. Education data is not readily available regarding capacity at existing schools.

As discussed above, under ‘Communities’, proposals received to date have not involved delivery of new strategic community infrastructure. Health However, site promoters have proposed extensive greenspace provision (also sports and recreation provision) as the first phase of a wider ‘Calverton Valley Park’ - an extension to the Ouse Valley strategic green infrastructure corridor, extending between Calverton and Whaddon. There could be notable benefits to green infrastructure and, in turn, health.

There are delivery concerns on the basis that: A) the site is in two parts, with intervening Homes land outside the control of the developer; and B) the site has not been actively promoted during the Plan:MK examination.

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

This site does not lead to any particular concerns. See further discussion above, under Air quality ‘Levante Gate’.

The available evidence does not suggest any particular strategic biodiversity concerns Biodiversity associated with this site, also noting the proposal to deliver strategic green infrastructure.

24 The Western Expansion Area was a strategic allocation made through the 2005 Local Plan. 25 See https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/western-expansion-area-development-framework-spd

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Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to Climate consider the use of community energy networks in their development.” change However, in practice delivery of low carbon infrastructure is unlikely. See discussion above, under ‘Levante Gate’.

The site lies adjacent to the Calverton Conservation Area, and hence can be considered one Heritage of the more constrained site options, in heritage terms.

Development would extend the WEA beyond the extent deemed to be suitable in 2005, at the time of allocation. The Calverton Road would form a new boundary; however, along this road is the string of three ‘Weald Villages’. Site promoters suggest that coalescence can be avoided (at least in respect of Upper Weald and Middle Weald) through greenspace buffers; Landscapes however, significant concerns remain. At the western extent of the WEA the adopted Development Framework SPD proposes a green buffer including “major open space [to create a] buffer between development and Calverton Villages” and a “District Park [to create a] buffer between development and Upper Weald”.

The site potentially performs relatively well in respect of agricultural land quality, on the Nat resources basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’.

Noise Noise pollution is not a concern at this site.

Transport matters have already been discussed above, under a number of headings. In Transport summary, the site performs quite given good links to the WEA and also given that CMK is relatively easily accessible.

A narrow band of surface water flood risk passes through this site, but it should be possible Water to address this through masterplanning and design measures.

Business/ The site would not deliver employment land and is notably distant from EWR and the Economy/ planned route of the Oxford to Cambridge Expressway. Employment

Conclusion Development would benefit from good links to the WEA, and in turn good links to other key destinations including CMK; however, development would be distant from the EWR / Expressway corridor. The site could deliver strategic green infrastructure benefits (also sports and recreation provision), potentially delivering the first phase of a wider ‘Calverton Valley Park’ - an extension to the Ouse Valley strategic green infrastructure corridor, extending between Calverton and Whaddon. Also, the site potentially performs relatively well in respect of agricultural land quality, on the basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’. However, development would extend the WEA beyond the extent deemed to be suitable in 2005, at the time of allocation. The Calverton Road would form a new boundary; however, along this road is the string of three ‘Weald Villages’, including one designated conservation area. Site promoters suggest that coalescence can be avoided (at least in respect of Upper Weald and Middle Weald) through greenspace buffers; however, significant concerns remain. Finally, there are delivery concerns as: A) the site is in two parts, with intervening land outside the control of the developer; and B) the site has not been actively promoted during the Plan:MK examination.

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Topic Shenley Dens Farm [1,500 homes]

The larger scale of the proposed scheme leads to confidence in respect of community infrastructure delivery. Also, there is a good range of existing local facilities within walking/cycling distance, including the Hazeley Academy secondary school; and the WEA is set to deliver a new secondary school in relatively close proximity.25 Furthermore, the site Communities could link directly to an existing grid road, and CMK is relatively close. Overall, the site performs relatively well in terms of ‘community’ objectives. N.B. an alternative smaller-scale scheme, using only the eastern-most c.1/3 of the site (namely that which links most closely to the grid road and existing urban edge), has recently been promoted to the Council. The proposal does not include a local centre.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Deprivation Affordable housing provision is another consideration; however, it is not possible to suggest that this site performs any better or worse than other site options.

The matter of ensuring access to schools is discussed above under ‘Communities’. N.B. Education data is not readily available regarding capacity at existing schools.

A 1,500 home scheme might well deliver a new health facility. Health Another consideration is access to the countryside. In this respect it is noted that the Milton Keynes Boundary Walk long distance path passes through the site. N.B. the adjacent woodland is not publicly accessible.

This site performs relatively well. The location of this site adjacent to the existing urban Homes edge, and the fact that it links to the existing grid road network, leads to a degree of confidence regarding potential to deliver early in the plan period.

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

This site does not lead to any particular concerns. See further discussion above, under Air quality ‘Levante Gate’.

The site partially wraps around Oakhill Wood, a large ancient woodland (mostly replanted) Biodiversity that falls within the Whaddon Chase Biodiversity Opportunity Area (BOA).26 As such, the site can be considered relatively constrained in biodiversity terms.

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to Climate consider the use of community energy networks in their development.” change However, in practice delivery of low carbon infrastructure is unlikely. The WEA is not delivering a community heating network.25 See further discussion under ‘Levante Gate’.

The site contains a grade 2 (i.e. lowest grade) listed farmhouse at its centre, which is clearly Heritage associated with a strong agricultural setting. It is also noted that a public footpath runs adjacent to the farmhouse, and is likely to be a popular route.

A scheme of this scale would lead to significant impacts to a landscape defined as having ‘high’ sensitivity.23 Landscape sensitivity has long been a concern in this area, with the 2005 Landscapes the Local Plan Inspector concluding that a virtually identical site - “… would be visible from large parts of the Whaddon Valley. The Shenley Ridge is a significant feature in the landscape and I agree with the Llewelyn-Davies assessment that

26 BOAs are extensive areas that include a concentration of important habitat, and within which there will likely be a good degree of ecological connectivity over a relatively large scale. There is a need to maintain and increase ecological connectivity within BOAs, which can potentially be achieved through development, where this leads to targeted habitat creation, restoration or enhancement.

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it is a feature that would form a logical and obvious boundary to development… I do not see the logic of regarding the Whaddon Valley as a possible long-term development area. To do so disregards the qualities of the valley landscape and the merits of the Shenley Ridge as a logical and clear long-term boundary.” N.B. an alternative Shenley Dens scheme, using only the eastern-most c.1/3 of the site (namely that which relates best to the existing urban edge), has recently been promoted to the Council; however, landscape concerns would remain, with the northern edge still abutting the open space planned as the southwestern buffer of the WEA, responding to the Shenley Ridge.

The site potentially performs relatively well in respect of agricultural land quality - as per the ‘WEA Expansion’ site discussed above, on the basis that adjacent land falling within the Nat resources WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’.

Noise Noise pollution is not a concern at this site.

Transport matters have already been discussed above, under a number of headings. In Transport summary, the site performs well, albeit there is no rail station in proximity.

A narrow band of surface water flood risk passes through this site, but it should be possibile Water to address this through masterplanning and design measures.

Business/ The site would not deliver employment land and is notably distant from EWR and the Economy/ planned route of the Oxford to Cambridge Expressway. Employment

Conclusion Unlike the sites discussed above, this site would adjoin the existing urban edge, and indeed could link directly to an existing grid road. Also of note is the larger nature of this scheme, which leads to confidence in respect of community infrastructure delivery (although, having said this, an alternative smaller scheme has recently been promote to the Council, which does not include a school or any local centre). It is also noted that there is a good range of existing local facilities within walking/cycling distance, and CMK is relatively close. Also, the site potentially performs well in respect of agricultural land quality, on the basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’. However, a scheme of this scale would lead to significant impacts to a landscape defined as having ‘high’ sensitivity. Landscape sensitivity has long been a concern in this area, with the 2005 the Local Plan Inspector concluding that a virtually identical site: “… would be visible from large parts of the Whaddon Valley. The Shenley Ridge is a significant feature in the landscape and I agree with the Llewelyn-Davies assessment that it is a feature that would form a logical and obvious boundary to development… I do not see the logic of regarding the Whaddon Valley as a possible long-term development area. To do so disregards the qualities of the valley landscape and the merits of the Shenley Ridge as a logical and clear long-term boundary.” The site also contains a listed farmhouse at its centre, and partially wraps around Oakhill Wood, a large ancient woodland (mostly replanted) that falls within the Whaddon Chase BOA.

Topic Wavendon/Woburn (‘eastern’) broad area [1,500+ homes]

As discussed above, under ‘Wavendon Golf Course’, further expansion of MK to the east, within the area of land bounded by the M1, A421 and the railway line, extending into Central Bedfordshire District, makes strategic sense in certain (socio-economic) respects, recognising the need to focus growth in proximity to East West Rail stations (Woburn Sands Communities and Apsley Guise stations are in proximity) and the Oxford to Cambridge Expressway. It is also the case that allocation of a strategic site in this area would have the benefit of ending concerns regarding piecemeal growth leading to sub-optimal outcomes, including opportunities missed for strategic infrastructure upgrades. A 200 home scheme is currently the subject of a called-in appeal (16/00672/OUT).

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However, this site is currently a considerable distance from the urban edge, and would only adjoin the urban edge were Wavendon Golf Course (and arguably South East MK) to be allocated and delivered first. There is no potential for all three sites to be allocated through Plan:MK, given the Plan:MK plan period and the quantum of homes required in that plan period (see discussion in Section 3.2). Furthermore, the effect would be to confirm the south-eastern part of MK as an area of strategic housing growth stretching over a period of at least 20 years, with implications for new and existing communities.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Deprivation Affordable housing provision is another consideration; however, it is not possible to suggest that this site performs any better or worse than other site options.

The matter of ensuring access to community infrastructure is discussed above under Education ‘Communities’.

The matter of ensuring access to community infrastructure is discussed above under Health ‘Communities’.

The timescale for housing delivery is inherently uncertain, with there being reasons to Homes suggest that this site could not deliver housing within the plan period.

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

Air quality No particular concerns. See further discussion above, under ‘Levante Gate’.

Biodiversity No particular strategic biodiversity constraints have been identified.

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to Climate consider the use of community energy networks in their development.” change However, in practice delivery of low carbon infrastructure is unlikely. See discussion above, under ‘Levante Gate’.

Heritage No particular strategic heritage constraints have been identified.

Landscapes The site is subject to ‘medium’ landscape sensitivity.23

Agricultural land quality on the site has not been surveyed, but adjacent land has been Nat resources surveyed and been found to comprise ‘best and most versatile’ quality land (grade 3a). Hence the likelihood is that this site comprises best and most versatile agricultural land.

Noise Noise pollution is not a concern at this site, with the M1 being at least 500m to the east.

As discussed above, under ‘Communities’, the site benefits from good proximity to Woburn Transport Sands Station (EWR).

A narrow band of surface water flood risk passes along the southern extent of the site; Water however, it should be possible to address this through masterplanning and design.

Business/ It is not anticipated that the site would deliver employment land, although this is feasibly an Economy/ option that could be explored, given proximity to the Oxford to Cambridge Expressway. Employment

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As discussed above, further expansion to the east, within the area of land bounded by the M1, A421 and the railway line, extending into Central Bedfordshire District, makes strategic sense in certain (socio- economic) respects, recognising the need to focus growth in proximity to East West Rail stations (Woburn Sands and Apsley Guise stations are in proximity) and the Oxford to Cambridge Expressway. However, this site is currently a considerable distance from the urban edge, and would only adjoin the urban edge were Wavendon Golf Course (and arguable South East MK) to be allocated and delivered first. There is no potential for all three sites to be allocated through Plan:MK, given the Plan:MK plan period and the quantum of homes required in that plan period. The site should logically be reconsidered in the future, ideally in combination with adjacent Wavendon Golf Club. Any future planning of MK expansion into this area would also need to take careful consideration of growth aspirations, and constraints, in neighbouring Central Bedfordshire District. The Draft Central Bedfordshire Local Plan proposed a series of ‘linked villages’ in the ‘Apsley Guise Triangle’; however, this proposal was removed from the subsequent ‘pre-submission’ version of the plan, with the Council stating: “We believe these locations do have potential for growth but… they are dependent on critical infrastructure (e.g. East West Rail) to support them.”27

Topic South East MK [3,000 homes]

The site benefits from linking well to the existing urban edge, and new communities would have good access to two train stations on EWR and nearby strategic employment sites. Walton High (secondary school) in Wavendon Gate is within walking distance of the northern part of the site; however, it is anticipated that the site would deliver a new secondary school in order to meet the additional needs arising. That secondary school could be located close to a train station, and hence be accessible to children from relatively far afield, e.g. the Apsley Guise Triangle. Communities However, much of the site would not link directly to the grid road or redways network, and the site runs alongside (and extends across) the railway line. Also, the site falls within the preferred Oxford to Cambridge Expressway route corridor. As such that there are concerns regarding the impact that road and rail infrastructure could have on the new community, in respect of noise and air pollution, and in respect of barriers to movement / connectivity. A final consideration relates to impacts to existing residents, noting that: construction of the Eastern Expansion area has been ongoing for several years; construction of the SLA and Eaton Leys will soon commence; and noting the likelihood of South Caldecotte (Submission Plan:MK employment allocation) commencing in the early part of the plan period.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Affordable housing provision is another consideration; however, it is not possible to suggest Deprivation that this site performs any better or worse than other site options. The site would not deliver early in the plan period, which is less-than-ideal given the extent of affordable housing needs that currently exist; however, there is set to be much housing delivery from other sites early in the plan period (see discussion of the housing trajectory, in Section 3.2).

Education The site would deliver a secondary school.

The site is of sufficient scale to deliver at least one new healthcare facility, and options to deliver a multi-service health/community hub might feasibly be explored with the Clinical Health Commissioning Group (CCG). Residents will also benefit from access to high quality countryside, in the form of the Greensand Ridge, and there should be good potential to deliver green infrastructure.

27 See http://www.centralbedfordshire.gov.uk/planning/policy/local-plan/pre-submission.aspx. N.B. latest understanding is that Phase 2 of East West Rail will open in 2023, at which point Apsley Guise station will have a service to Bicester and Oxford (also Aylesbury by 2024) and an improvement on the current service to Milton Keynes and Bedford.

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The site falls within the preferred Oxford to Cambridge Expressway route corridor, and hence there is inherently an element of uncertainty in respect of delivery timescales; Homes however, the matter has been explored in detail through the Plan:MK Examination, with the Inspector reaching the conclusion that initial completions can be safely anticipated in 2023/24 (see discussion in Section 3.2).

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

There are no designated Air Quality Management Areas (AQMAs) within the MK urban area; however, there is nonetheless a need to minimise the number and distance of trips by non- electric private car, in order to avoid worsened air pollution, and the risk of poor air quality hotspots developing (such that an AQMA might need to be designated). Air quality This site does not lead to any particular concerns, including on the basis of good access to EWR stations, and also given the likelihood of excellent access onto the Oxford to Cambridge Expressway (such that future trip directions might be dispersed, and hence less focused on CMK and other destinations in the MK urban area).

The railway corridor is a locally designated wildlife corridor (although not a Local Wildlife Site), linking to the pond and area of associated habitat at the site’s eastern edge; however, it is anticipated that these assets could be accommodated within green infrastructure. The site is otherwise quite unconstrained. Biodiversity The site lies at the foot of the Greensand Ridge, which is associated with a high density ancient woodland and other priority habitat; however, it is difficult to envisage that development of the site would lead to impacts, or impinge upon the achievement of nature conservation objectives relating to the Ridge.

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to consider the use of community energy networks in their development.” As a large-scale strategic scheme, there could be the potential to deliver a community Climate energy network; however, however, in practice viability considerations can be prohibitive, change recognising the need to fund/deliver affordable housing and a range of other costly infrastructure (e.g. roads and schools). Neither of the Expansion Areas are delivering an energy network, and whilst Policy CS5 (SLA) of the Core Strategy states - “Consider the use of community energy networks” in practice no energy network(s) are planned. Proposals to date have not included a commitment to deliver low carbon infrastructure.

The site is subject to limited constraints, with nearby listed buildings found only within the centres of the nearby villages, namely Bow Brickhill, Wavendon and Woburn Sands. Another consideration is proximity to heritage assets within, and more generally the historic Heritage landscape character associated with, the Greensand Ridge to the south. Danesborough Camp is a Scheduled Monument located c.650m to the south (and c.70m above) the site, and Bow Brickhill Church is a grade 2* listed building located c.700m to the south (and c.80m above) this site. It is not thought likely that there would be impacts to these assets, or more generally the historic landscape character of the Ridge.

Development will impact significantly on the gap to Woburn Sands and Bow Brickhill; however, there would be good potential to ensure robust landscape buffers through delivery of green infrastructure. A related consideration is impacts on views from the Greensand Landscapes Ridge; however, limited sensitive views have been identified to date. The site has been assessed as having ‘low’ sensitivity (albeit landscape assessment work suggests the need for ‘small scale development).23

The site has been surveyed in detail and found to comprise a mix of grades 2, 3a and 3b Nat resources quality agricultural land, with grade 2 land (i.e. land of second highest quality nationally) found at the Bow Brickhill end of the site.

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Noise pollution is a concern, given the adjacent railway line and the potential for the Noise Expressway to pass through or nearby to the site. However, there will be good potential to avoid / mitigate effects through masterplanning, landscaping and design measures.

As discussed above, under ‘Communities’, the site benefits from good proximity to EWR, and some key destinations - including a secondary school and strategic employment sites - Transport will be within walking/cycling distance. However, the site does not link as well to the grid- road network, or the redways network, as might ideally be the case.

The site is not subject to fluvial flood risk, and subject to only limited surface water flood risk (there is one narrow band of surface water flood risk, and three areas alongside the railway Water line are at risk of pooling, but it is assumed that it would be possible to avoid built development in these areas).

Business/ The site would not deliver employment land; however, housing delivery in this area accords Economy/ with the achievement of economic objectives, given excellent access to EWR and the Employment Oxford to Cambridge Expressway preferred route corridor.

Conclusion The site benefits from linking well to the existing urban edge, and new communities would have good access to two train stations on East West Rail and nearby strategic employment sites. Also, the scale of the site leads to the opportunity to deliver new strategic community infrastructure, to include a secondary school, potentially to the benefit of existing as well as new residents (e.g. perhaps residents of any new villages that might be developed to the east in the Apsley Guise Triangle). However, much of the site would not link directly to the grid road or redways network, and the site extends across the railway line, which will result in the need for one or more new bridges. Also, the site falls within the preferred Oxford to Cambridge Expressway route corridor, which leads to a degree of delivery risk, and also potentially some concerns in respect of impacts on the new community (e.g. pollution, severance). There are limited environmental constraints, with a key consideration being the gap to Woburn Sands and Bow Brickhill, and also agricultural land quality. In respect of the former, the gap would decrease significantly; however, the landscape has ‘low’ sensitivity (albeit landscape assessment work suggests the need for ‘small scale development). In respect of the latter, the site has been surveyed in detail and found to comprise a mix of grades 2, 3a and 3b quality agricultural land, with grade 2 land (i.e. land of second highest quality nationally) found at the Bow Brickhill end of the site.

Topic East of MK (north) [3,000 homes+ mixed use]

The capacity of this site is potentially 5,000 homes (c.1,500 within the plan period), plus a strategic employment site, and so it is fair to conclude that there is the opportunity to deliver a comprehensive new community, i.e. one that will benefit from a strong sense of place, and Communities a good degree of self-containment. However, new residents will still ‘look to’ the MK urban area for employment, retail and access to higher order services and facilities, and, in this respect, there are certain concerns regarding the M1 acting as a barrier to connectivity.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Affordable housing provision is another consideration; however, it is not possible to suggest Deprivation that this site performs any better or worse than other site options. The site would not deliver early in the plan period, which is less-than-ideal given the extent of affordable housing needs that currently exist; however, there is set to be much housing delivery from other sites early in the plan period (see discussion of the housing trajectory, in Section 3.2).

Education The site would deliver at least one new secondary school.

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The site is of sufficient scale to deliver at least one new healthcare facility, and options to deliver a multi-service health/community hub might feasibly be explored with the Clinical Commissioning Group (CCG). Health Residents would also benefit from access to high quality countryside, particularly in the form of the River Ouzel floodplain, which it is anticipated can be made accessible. The potential to deliver a country park could be explored.

The site requires significant infrastructure upgrades in advance of housing, most notably at least one new bridge over the M1, and hence there is inherently an element of uncertainty in Homes respect of delivery timescales; however, the matter has been explored in detail through the Plan:MK Examination, with the Inspector reaching the conclusion that c.1,500 homes in the final part of the plan period can be safely anticipated (see discussion in Section 3.2).

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

The site links directly to Olney to the north, where there is a designated air quality management area (AQMA). It is fair to assume that only a small proportion of trips from the Air quality site will pass along the A509 through Olney (noting that the fastest route to Northampton is likely to be via the M1); however, this is a matter worthy of further consideration.

The River Ouzel floodplain (associated with some mature trees and other riparian habitat) passes north/south through the site. It should prove possible to enhance the biodiversity Biodiversity value of floodplain, and enhance access (there is currently no footpath along the river). The site is otherwise unconstrained.

As a large-scale scheme, there is the potential to deliver a community energy network, or Climate other low carbon infrastructure (see discussion above, under South East MK). However, change proposals to date have not included a commitment to deliver low carbon infrastructure.

The site is subject to limited constraints, with the primary concern being the proximity of the site (c.250m, before any account is taken of the potential to deliver a landscape buffer within Heritage the site) to the grade 1 listed church at Moulsoe. The historic core of Newport Pagnell is located at least 1km to the north, beyond more recent development at Tickford End.

A large part of the site - namely that part falling between Willen Road and the A509 - was not covered by the Landscape Sensitivity Study. This is a flat landscape, associated with the floodplain of the River Ouzel. The most sensitive part of the site, from a landscape perspective, is thought to be that associated with the rising land to the east of the A509. This area was examined by the Landscape Sensitivity Study, with the conclusion reached that there is ‘medium’ capacity; however, concerns are reduced by the supplementary conclusion that: “The more open Landscapes landscape on the lower slopes of the Ouzel valley, in proximity to the A509 London Road and the North Crawley Road are less sensitive to residential development.” Finally, there is a need to consider the triangle of land east of the M1 / South of the A422 / west of Willen Road, which would deliver B8 employment land. The site is notably subject to very low landscape constraint, with the Landscape Sensitivity Study (2012) describing “an enclosed landscape with good quality hedges along the road network.” The study also describes the site as brownfield and currently used for gravel extraction.

The great majority of this site has not been surveyed in detail; however, adjacent land has been surveyed and found to comprise best and most versatile agricultural land, and hence there is a strong likelihood of significant ‘BMV’ land within the site. Nat resources The only part of the site that has been surveyed is the triangle of land east of the M1 / South of the A422 / west of Willen Road. The site is also identified (on magic.gov.uk) as comprising grade 2 (i.e. second best quality nationally) agricultural land

Noise pollution is a concern, given the adjacent M1. However, there will be good potential to Noise avoid / mitigate effects through masterplanning, landscaping and design measures.

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The site benefits from being well located to a motorway junction, with two existing road bridges and a footbridge (plus the A422 bridge at the site’s northern edge), and it is anticipated that funding can be made available for at least one new bridge. The potential for a ‘mass transit route’, potentially in the form of a guided busway, linking CMK to Cranfield University has been discussed. The route would naturally pass through Transport the southern part of the site (namely that in proximity to the motorway junction, where significant employment land is proposed in addition to housing) in order to avoid Moulsoe. However, the new community could be relatively poorly linked to CMK. In addition to the M1 potentially acting as a barrier to movement, the likelihood is that a significant proportion of development would be to the east of the floodplain, with residents needing to travel c.1km to reach the M1, before then crossing it to reach the main MK urban area.

The site is significantly constrained by the River Ouzel floodplain, which bisects the site; however, work completed to date has shown how a new community could be delivered Water whilst avoiding areas of flood risk. Opportunities for improving flood storage capacity might feasibly be explored, as part of work to ensure the scheme delivers net environmental gains.

At the time of preparing the SA Report the assumption was that there were two alternative approaches that might be taken to the delivery of employment land to the east of the M1, namely: 1) allocation of the triangle of land east of the M1 / South of the A422 / west of Willen Road, which has capacity to deliver up to 19.3 ha of B8; and 2) allocation of the entire East of MK site, with employment at both the ‘triangle’ site and also adjacent to M1 J14. At the current time it is fair to assume that only (2) need be considered further, recognising that the Inspector has indicated that he is satisfied with the justification for allocating East of MK in its entirety. However, taking each of the distinct employment areas in turn -  Triangle of land east of the M1 / South of the A422 / west of Willen Road - the site is quite well linked to the strategic road network. Were the site to come forward in isolation - i.e. rather than as part of a wider ‘East of MK (north)’ strategic mixed use scheme - then Business/ the preferred route to M1 J14 might be via the A422 and A509, which is a 3km journey Economy/ with just roundabout and no concerns regarding traffic passing through residential areas. Employment However, under the scenario whereby employment in this area comes forward as part of the ‘East of MK (north)’ strategic mixed use scheme the site would link to M1 J14 via roads to the west of the M1, as per traffic from the existing Tongwell Industrial Estate. The site is notably subject to very low landscape constraint, and so would seem to be well suited to B8 employment in this respect.  Land in proximity to M1 J14 - this is a highly suitable location for strategic employment growth, given the potential for HGVs and other traffic to immediately join the M1. The area is not subject to any notable strategic constraint that might prevent extensive B8. Finally, there is a need to note that the site does not relate particularly well to the Oxford to Cambridge Expressway corridor preferred route. However, the fact remains that it is suitably close (i.e. one junction distant) and very well related to the M1.

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Conclusion There is the potential to deliver a new community with a good degree of self-containment, but also functioning as an urban extension to MK (also relating fairly well to Newport Pagnell). In addition to a secondary school, the intention is that the scheme would involve an extensive employment area at M1 J14, and a second strategic employment area within the triangle of land at the site’s northwestern extent. Also, there is the potential to deliver environmental net gains and ‘ecosystem service’ benefits through enhancements along, and increased accessed to, the River Ouzel. However, there are also potential draw-backs to this scheme from a communities perspective, recognising that the new community would be relatively poorly linked to CMK, with the M1 acting as a barrier. The site is also significantly constrained by flood risk associated with the river Ouzel, and the impact on Olney of increased traffic is a concern, particularly given the designated AQMA. In other respects the site is quite unconstrained in environmental terms, although there is a strong likelihood that the site contains extensive areas of best and most versatile agricultural land. Proximity to the village of Moulsoe (where there is a grade 1 listed church) is a consideration; however, it is anticipated that a substantial landscape buffer can be retained. The site benefits from being well located to a motorway junction, with two existing road bridges and a footbridge (plus the A422 bridge at the site’s northern edge); however, there would nonetheless be a need for extensive and costly infrastructure upgrades, which leads to delivery risks.

Topic East of MK (south) [3,000 homes+]

This site is also of a scale sufficient to deliver strategic community infrastructure, e.g. a secondary school. However, the M1 constitutes a major barrier between the site and the existing MK urban area. The site would also link to CMK via the EEA (and potentially also Communities the SLA), which could create challenges. Furthermore, the effect would be to confirm the south-eastern part of MK as an area of strategic housing growth stretching over a period of at least 20 years, with implications for new and existing communities.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Affordable housing provision is another consideration; however, it is not possible to suggest Deprivation that this site performs any better or worse than other site options. The site would not deliver early in the plan period, which is less-than-ideal given the extent of affordable housing needs that currently exist; however, there is set to be much housing delivery from other sites early in the plan period (see discussion of the housing trajectory, in Section 3.2).

Education The site would deliver at least one new secondary school.

The site is of sufficient scale to deliver at least one new healthcare facility, and options to Health deliver a multi-service health/community hub might feasibly be explored with the Clinical Commissioning Group (CCG).

The timescale for housing delivery is inherently uncertain, with there being reasons to Homes suggest that this site could not deliver housing within the plan period.

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

Air quality This site does not lead to any particular concerns.

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The site includes two notable woodland patches; however, neither is ancient woodland (and indeed the majority is thought to be recently planted, or recent secondary woodland). There is, however, one very small patch of ancient woodland within the site. Furthermore, there are two notable patches of ‘ancient replanted woodland’ adjacent to the site, and other Biodiversity similar woodland patches in the vicinity, such that overall there is a need to consider the matter of ecological connectivity between woodland patches within this landscape. The site is also notable for including several small streams (three distinct areas of fluvial flood risk), some or all of which might be associated with a degree of biodiversity value.

As a large-scale scheme, there is the potential to deliver a community energy network, or Climate other low carbon infrastructure (see discussion above, under South East MK). However, change proposals to date have not included a commitment to deliver low carbon infrastructure.

The adjacent village of Salford has a notably low density of listed buildings (just four in total), Heritage but notable does contain a grade 1 listed church. The church is at the eastern extent of the village (namely that part furthest from the potential development site).

The majority of this site falls within Landscape Area 6, as examined through the 2012 Landscape Study,23 which is found to have ‘low’ sensitivity. The conclusion reached is that: Landscapes “Residential development could be accommodated without affecting key characteristics and/or values in this landscape. The landscape area adjoins the M1 between junction 13 and 14 and the ongoing development south of the motorway has an urbanising impact on the area. The flat topography and relatively poor landscape structure offer little enclosure...”

Several small patches of land within the site have been surveyed and found to comprise Nat resources BMV agricultural land, although equally some areas have been surveyed and been found to comprise grade 3b land, i.e. non-BMV land.

Noise pollution is a concern, given the adjacent M1. However, there will be good potential to Noise avoid / mitigate effects through masterplanning, landscaping and design measures.

The site is not as well related to an M1 junction as the adjacent ‘north’ site, and the two Transport existing bridges are minor roads. Concerns regarding links to CMK would also apply more generally, as per the discussion presented above, in relation to the ‘north’ site.

There are three notable areas of fluvial flood risk, although it is anticipated that it would be Water possible to avoid built development in these areas.

Business/ The scale of the site would suggest the potential to deliver employment land. The site does Economy/ not benefit from good existing links to the strategic road network; however, M1 J14 is a short Employment distance to the north and M1 J13 (along with the Expressway route) c.2km to the south.

Conclusion This site is also of a scale sufficient to deliver strategic community infrastructure, e.g. a secondary school. However, the M1 constitutes a major barrier between the site and the existing MK urban area; and the site would link to CMK via the EEA (and potentially also the SLA), which could create challenges. There is also a degree of flood risk on site, and there is a likelihood of extensive BMV agricultural land. There is no potential to allocate both East of M1 sites, and so the southern site should be reconsidered in the future, as a potential extension option to the northern site, should the northern site be allocated and begin to build-out. There would be a need to liaise closely with Central Bedfordshire District, taking careful account of aspirations for Cranfield University, Cranfield village and the Marston Moretaine area, which is proposed as a focus of growth by the emerging Central Bedfordshire Plan.

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Topic North of MK [3,000 homes+]

This is the largest of the site options under consideration, although the capacity of the site (having taken account of onsite constraints) has not been established. The site is certainly of a scale sufficient to deliver a mix of uses and strategic community infrastructure, e.g. a secondary school. Communities The site benefits from proximity to Wolverton and Neport Pagnell town centres; and also the Great Ouse Valley, along which is an extensive network of lakes, some which are currently accessible, and others of which might potentially be made accessible. However, the floodplain/lakes complex also acts as a notable barrier to movement, separating the site from the main MK urban area to the south.

See discussion above, under ‘Levante Gate’. In short, development of this scheme is not likely to have notable implications for the achievement of deprivation objectives. Deprivation Affordable housing provision is another consideration; however, it is not possible to suggest that this site performs any better or worse than other site options.

Education The site would deliver at least one new secondary school.

The site is of sufficient scale to deliver at least one new healthcare facility, and options to deliver a multi-service health/community hub might feasibly be explored with the Clinical Health Commissioning Group (CCG). Residents would also benefit from access to high quality countryside, as discussed above, under ‘Communities’.

The site would necessitate major new road infrastructure, noting distance to a motorway Homes junction and potentially the need to bridge the Great Ouse Valley. As such, there is inherent uncertainty regarding delivery timescale.

The matter of access to community infrastructure is discussed above, under the Services ‘Communities’, ‘Education’ and ‘Health’ headings.

Air quality This site does not lead to any particular concerns.

Development would ‘leapfrog’ the Great Ouse Floodplain, which is associated with wide Biodiversity ranging biodiversity sensitivities. Development would also encroach upon, and potentially wrap around, Little Linford Wood (ancient woodland, but not a LWS).

The representation received by the promoters through the Draft Plan MK consultation stated: “The North Milton Keynes development offers potential for strategic renewable Climate energy developments to be delivered as part of the scheme. These would be explored change further by Gallagher Estates in conjunction with MKC should the site be brought forward through Plan:MK.”

Of the three larger site options, it is the North MK site that is the most constrained, with a number of listed buildings at Haversham and Linford (both of which could be subsumed within the scheme). There are also two other isolated listed buildings, and there is a Heritage scheduled monument at Haversham (‘Moated site, fishponds and associated earthworks 150m south-east of Haversham Manor’). The scheme could also encroach upon Castlethorpe, where there is a designated conservation area.

The Landscape Areas 6 and 7, as examined through the 2012 Landscape Study,23 which are both found to have ‘medium’ sensitivity. The study identifies some areas with capacity, Landscapes but notes the sensitivity of higher land to the north, and the importance of maintaining the setting of the historic village of Castlethorpe.

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The site has not been surveyed in detail, nor has nearby land; however, the low resolution Nat resources national dataset shows a band of grade 2 agricultural land in the vicinity of the site. As such, it is fair to conclude the likelihood of significant BMV agricultural land.

Noise Noise pollution is not a concern.

The site is in proximity to Wolverton train station, but is otherwise poorly linked, with no A- Transport road in proximity. There would be a concern regarding traffic along rural roads, and potentially traffic through Castlethorpe and Cosgrove.

Water There is only one narrow band of fluvial flood risk passing through this site.

Business/ The scale of the site would suggest the potential to deliver employment land. However, the Economy/ site relates poorly to the strategic road network. Employment

Conclusion Sequentially less preferable the East of M1 (north) site discussed above, for a number of reasons. Notably, there would be a need to bridge the extensive flood plain of the River Great Ouse / Linford Lakes; and growth to the north of MK would not relate well to the existing transport network (there is no M1 junction in the vicinity) or the Expressway / EWR corridor. There is also a greater degree of onsite landscape, heritage and biodiversity constraint. Once again, this site might be considered again in the future, given the potential to deliver a large scale scheme that delivers new and upgraded infrastructure upgrades, and given the likelihood that many of the constraints that exist can be successfully overcome or sufficiently mitigated; however, at the current time there are sequentially preferable sites, and there is only a need to find sites for a limited number of new homes, which in turn means this site can be ruled-out of contention.

Topic North East of Newport Pagnell [25 ha of B8]

There would be a buffer to Newport Pagnell / Tickford End to the south, and Sherington to Communities the north; however, HGV traffic through Olney would be a concern.

Deprivation

Education

Health This is an employment site option, and so has limited or no implications.

Homes

Services

Air quality HGV traffic through the Olney AQMA would be a significant concern.

Biodiversity No particular strategic biodiversity constraints have been identified.

Climate This is an employment site option, and so has limited or no implications, other than in change respect of transport - see discussion below.

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There are listed buildings a short distance to the west of the site, notably Sherington Bridge (along which passes the Ouse Valley Way), and Sherington to the north has a high density Heritage of listed buildings and a designated conservation area. However, there would be a landscape buffer between the site and these heritage assets.

The site does not relate well to Newport Pagnell in built form terms, even once account is taken of the committed strategic eastwards expansion of the town, and the landform would Landscapes suggest a landscape constraint (albeit the developable area figure assigned does reflect this constraint). The Ouse Valley Way runs along the valley to the west of the site.

Part of the site has been surveyed and found to comprise a mixture of SMV (grades 2 and Nat resources 3a) and non-BMV (grade 3b) agricultural land.

Noise As discussed, HGV traffic through Olney would be a concern.

The site is quite well linked to the M1 (c.4km at its closest point, and c.7km when measured Transport from the Chicheley Hill roundabout).

The site is located on a hill above the River Great Ouse, which serves to highlight the Water importance of managing surface water run-off.

The site is suitable for employment development in certain respects, including on the basis that it is quite well linked to the M1, ad discussed above. Business/ However: the developable area is only 25 ha, which falls well short of the identified target Economy/ figure to be met by Plan:MK. Also, the site does not relate well to Newport Pagnell in built Employment form terms, even once account is taken of the committed strategic eastwards expansion of the town, and there is significant landscape constraint (albeit the developable area figure assigned does reflect this constraint). Also, the site is likely to include an element of best and most versatile agricultural land.

Conclusion The site is suitable for employment development in certain respects, including on the basis that it is quite well linked to the M1 (c.4km at its closest point, and c.7km when measured from the Chicheley Hill roundabout). However: the developable area is only 25 ha, which falls well short of the identified target figure to be met by Plan:MK. Also, the site does not relate well to Newport Pagnell in built form terms, even once account is taken of the committed strategic eastwards expansion of the town, and there is landscape constraint (albeit the developable area figure assigned does reflect this constraint). Also, the site is likely to include a significant element of best and most versatile agricultural land.

Topic Caldecotte South [57 ha site able to deliver at least 47.5 ha of B8]

Proximity to Bow Brickhill raises some concerns in respect of traffic, and in particular there is Communities a concern that the scheme could result in traffic queuing back from the A5/A4146 roundabout as far as the Bow Brickhill level crossing, leading to a safety concern.

Deprivation

Education

Health This is an employment site option, and so has limited or no implications.

Homes

Services

Air quality No particular concerns.

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Biodiversity The site contains a patch of Biodiversity Action Plan (BAP) grassland habitat.

Climate This is an employment site option, and so has limited or no implications, other than in change respect of transport - see discussion below.

There are clusters of listed buildings at Fenny Stratford to the west, and at Bow Brickhill to the east; however, impacts to the setting of most buildings is not thought likely. During the Heritage Plan:MK examination hearings there was discussion of the potential for large warehouse buildings to impact upon views of/across MK from Bow Brickhill Church (grade 2* listed).

The site is subject to a significant landscape constraint in that views over MK from the Landscapes Greensand Ridge will be impacted by the presence of warehouses and other large industrial buildings.

The site has been surveyed and found to comprise mostly grade 3b agricultural land, with Nat resources only perhaps the western 20% of the site comprising grade 3a land, i.e. land that is ‘best and most versatile’.

HGV traffic would pass along duel carriageway roads through the MK urban area, but Noise otherwise limited concerns.

Whilst some distance from the M1, the site is located on the A5 - a main strategic route that is now linked to the M1 c.18.5km to the south (J11a), via the new A5/M1 link road (journey time 15 minutes). The site is also linked to M1 junctions 13 and 14 to the north via duel Transport carriageway roads (shorter distance, but a need to pass through roundabouts with a risk of traffic). Furthermore, the site is very well linked to Bow Brickhill train station and close to existing employment areas.

A significant area at risk of surface water pooling exists at the northwest corner of the site, Water and a narrow band of surface water flood risk passes through the site; however, it is anticipated that issues can be addressed through masterplanning and SuDS measures.

The site is well linked to the strategic road network, albeit relatively distant from the M1. The Business/ Oxford to Cambridge Expressway will, in all likelihood, pass close to the site; however, there Economy/ remains a risk that it could pass through or directly adjacent to the site, with implications for Employment site delivery. The site is large enough to deliver the quantum of B8 required district-wide.

Conclusion Whilst some distance from the M1, the site is located on the A5 - a main strategic route that is now linked to the M1 c.18.5km to the south (J11a), via the new A5/M1 link road (journey time 15 minutes). The site is also linked to M1 junctions 13 and 14 to the north via duel carriageway roads (shorter distance, but a need to pass through roundabouts with a risk of traffic). Furthermore, the site is very well linked to Bow Brickhill train station and close to existing employment areas. Also, the site has been surveyed and found to comprise mostly grade 3b agricultural land, with only perhaps the western 20% of the site comprising grade 3a land, i.e. land that is ‘best and most versatile’. However, proximity to Bow Brickhill also raises some concerns in respect of traffic. Also, the site is subject to a significant landscape constraint in that views over MK from the Greensand Ridge will be impacted. Another issue relates to the presence of a patch of Biodiversity Action Plan (BAP) grassland habitat.

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APPENDIX II – REASONABLE SPATIAL STRATEGY ALTERNATIVES

Introduction As explained within ‘Part 1’ above, a focus of work in September 2018 was on the development and appraisal of refined reasonable spatial strategy alternatives, with a view to informing proposed modifications. The aim of this appendix is to present appraisal findings. The refined reasonable spatial strategy alternatives are as follows -

1) Submission allocations

2) Submission allocations plus 500 homes at Levante Gate

3) Submission allocations plus 700 homes at Wavendon Golf Club

4) Submission allocations plus 1,200 homes at Levante Gate and Wavendon Golf Club

5) Submission allocations plus 1,500 homes at Shenley Dens

Appraisal methodology For each of the options, the assessment examines ‘likely significant effects’ on the baseline, drawing on the sustainability objectives identified through scoping (see Table 1.1) as a methodological framework. Green is used to indicate significant positive effects, whilst red is used to indicate significant negative effects. Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration. The ability to predict effects accurately is also limited by understanding of the baseline (now and in the future under a ‘no plan’ scenario). In light of this, there is a need to make considerable assumptions regarding how scenarios will be implemented ‘on the ground’ and what the effect on particular receptors will be.28 Where there is a need to rely on assumptions in order to reach a conclusion on a ‘significant effect’ this is made explicit in the appraisal text. Where it is not possible to predict likely significant effects on the basis of reasonable assumptions, efforts are made to comment on the relative merits of the alternatives in more general terms and to indicate a rank of preference. This is helpful, as it enables a distinction to be made between the alternatives even where it is not possible to distinguish between them in terms of ‘significant effects’. Finally, it is important to note that effects are predicted taking into account the criteria presented within Regulations.29 So, for example, account is taken of the duration, frequency and reversibility of effects. Cumulative effects are also considered (i.e. where the effects of the plan in combination with the effects of other planned or on-going activity that is outside the control of Plan:MK).

Appraisal findings Appraisal findings are presented below within 17 separate tables (each table dealing with a specific sustainability objective, or combination of objectives) with a final table drawing conclusions. The appraisal methodology is explained above, but to reiterate: For each sustainability topic the performance of each scenario is categorised in terms of ‘significant effects (using red / green) and also ranked in order of preference. Also, ‘ = ’ is used to denote instances of all alternatives performing on a par.

28 Considerable assumptions are made regarding infrastructure delivery, i.e. assumptions are made regarding the infrastructure (of all types) that will come forward in the future alongside (and to some extent funded through) development. 29 Schedule 1 of the Environmental Assessment of Plans and Programmes Regulations 2004.

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Reduce levels of crime and create vibrant communities

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2 3

Significant No effects?

Examination of site options in isolation shows Shenley Dens Farm (Option 5) to be the preferable site amongst those that are a variable across the reasonable alternatives. The larger scale of the proposed scheme leads to confidence in respect of community infrastructure delivery, and there is a good range of existing local facilities within walking/cycling distance. Furthermore, the site could link directly to an existing grid road, and CMK is relatively close.30 The next step is to differentiate Option 2 (Levante Gate) and Option 3 (Wavendon Golf Course). Examination of the two competing site options finds that both are potentially of a scale to deliver (or at least make land available for) a new primary school, but there is little certainty. A recent planning application at Levante Gate did include a 1fe primary school; however, on the other hand, Levante Gate is judged to be relatively poorly linked to existing community infrastructure. On balance, it is not possible to differentiate the two sites, and Discussion therefore the two spatial strategy options, with any confidence. Finally, there is a need to consider whether Option 4 (additional allocation of both Levante Gate and Wavendon Golf Course) is more or less preferable to additional allocation of just one of these sites (Options 2 and 3). In short, it is considered less preferable, on the basis that Option 4 would run contrary to the broad policy of supporting housing delivery at strategic scale sites that are well suited to delivering significant new and upgraded infrastructure. In conclusion, Options 1 and 5 are best performing, but are not predicted to result in significant positive effects, noting the conclusion reached by the Plan:MK Submission SA Report (which essentially presented an appraisal of Option 1). Option 4 is worst performing, but is not predicted to result in significant negative effects; both sites (Levante Gate and Wavendon Golf Club) have a degree of merit, from a communities perspective.

Reduce the gap between the most deprived areas of Milton Keynes and the average.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank = = = = =

Significant No effects?

The Index of Multiple Deprivation (2015) dataset shows a band of relatively deprived areas running north-south through the MK urban area, with Bletchley and Wolverton being two established regeneration priority areas at either end of this ‘band’. However, none of the site Discussion options in question - i.e. those which are a variable across the reasonable alternatives - are in close-enough proximity to an area of relative deprivation to suggest the potential for development to result in regeneration benefits; nor is there the potential to suggest that delivery of more than one of the sites in-combination (i.e. Option 4) would lead to benefits.

30 N.B. an alternative smaller-scale scheme, using only the eastern-most c.1/3 of the site (namely that which links most closely to the grid road and existing urban edge), has recently been promoted to the Council. The proposal does not include a local centre.

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Affordable housing provision is another important consideration, with a bearing on achievement of this objective. All of the sites in question would be expected to deliver a good proportion of affordable housing, in accordance with policy. It is noted that a recent planning application for 600 homes at Levante Gate included 40% affordable housing, i.e. a figure in excess of the Core Strategy policy requirement of 30%; however, there can be no certainty regarding any future planning application. In conclusion, the alternatives perform broadly on a par, and significant positive effects are not predicted (noting the conclusion reached by the Plan:MK Submission SA Report).

Improve education attainment and qualification…so that everyone can find and stay in work

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2 3

Significant No effects?

There is nothing further to add to the discussion presented above, under ‘Communities’. The Discussion conclusions on effect significance are also as per those reached under ‘Communities’ (noting the conclusion reached by the Plan:MK Submission SA Report).

Protect and improve residents’ health and reduce health inequalities

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2 3

Significant No effects?

As per the discussion under ‘Communities’, Shenley Dens is the preferable site, amongst those that are a variable across the alternatives, on the basis that it’s scale leads to confidence in the ability to deliver a local centre, which could well include a GP surgery or medical centre. It is unlikely that any such facility would be delivered at either Levante Gate or Wavendon Golf Course, although both are suitably well linked to existing or forthcoming facilities. Another consideration is access to the countryside. In this respect it is noted that -  Levante Gate (Options 2 and 4) - a bridleway passes through the centre of the site that is potentially of some strategic importance, in that it links the Grand Union Canal / River Ouzel Discussion Valley to the west with Little Brickhill (and the Greensand Ridge beyond) to the east.  Wavendon Golf Course (Options 3 and 4) - the Milton Keynes Boundary Walk long distance path passes through the site.  Shenley Dens (Option 5) - the Milton Keynes Boundary Walk long distance path passes through the site. N.B. the adjacent woodland is not publicly accessible. In conclusion, the overriding consideration is access to medical facilities, and as such the order of preference is as per the ‘Communities’ appraisal, above. The conclusions on effect significance are also as per those reached under ‘Communities’ (noting the conclusion reached by the Plan:MK Submission SA Report).

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Ensure that everyone has the opportunity to live in an affordable, sustainably constructed home

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 5 4 3 2

Significant Yes effects?

The housing land supply under Option 1 (the lowest growth option) has been determined to be suitably robust by the Plan:MK Planning Inspector (see paras. 3.2.10 and 3.2.11, above) in that it will deliver the established OAHN / housing target (26,500 homes) over the course of the plan period, and on a suitably smooth trajectory (i.e. in the region of 1,766 dpa). However, additional supply (i.e. Options 2 to 5) would further reduce the risk of falling below the committed/required housing trajectory due to unforeseen delays to delivery at one or more sites (and thereby further increase confidence in respect of the Council’s ability to demonstrate a rolling five year housing land supply, and meet the Housing Delivery Test, across the plan period). Taking Option 5 as the extreme example, addition of an additional 1,500 homes to the housing land supply would serve to reduce any residual risk that remains associated with the Option 1 trajectory. There would be confidence in the ability to deliver in the region of 1,766 dpa even under a worst-case scenario (from a housing trajectory perspective) whereby the Oxford to Cambridge Expressway must pass through the South East MK strategic site (which is a Discussion constant under all alternatives) leading to delayed delivery and a reduced capacity for housing. In practice, under Option 5, it could transpire that Plan:MK provides for a quantum of homes in the plan period that is significantly in excess of the established OAHN/target figure. This would be the case under a best-case scenario whereby South East MK delivers on the anticipated timescale, and East of MK delivers faster than is currently anticipated (there is the potential for this to happen, depending on whether funding can be secured for new major infrastructure, to include a new bridge over the M1). Under this scenario there would be very positive implications for the achievement of ‘housing’ objectives, particularly in respect of affordable housing delivery.31 The SHMA identifies a need for 8,200 affordable homes, not taking account of any losses from the current stock (such as demolition or clearance, or sales through Right to Buy). This is a challenging target, given viability issues, and in light of past affordable housing delivery rates.32 In conclusion, higher growth options are preferable, but all alternatives would lead to significant positive effects.

31 None of MK’s neighbouring authorities have requested that Plan MK provide for unmet needs (the typical reason for providing for ‘above OAHN’, e.g. this is the reason for the Aylesbury Vale and Central Beds Local Plans proposing to provide for above OAHN). 32 Of the 1,246 completions in the 2016/2017 monitoring year, only 20.1% were affordable, well below the policy requirement.

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Ensure all section of the community have good access to services and facilities

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2 3

Significant No effects?

There is nothing further to add to the discussion presented above, under ‘Communities’. The Discussion conclusions on effect significance are also as per those reached under ‘Communities’ (noting the conclusion reached by the Plan:MK Submission SA Report).

Maintain and improve the air quality in the borough

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank = = = = =

Significant No effects?

There are no designated Air Quality Management Areas (AQMAs) within the MK urban area; however, there is nonetheless a need to minimise the number and distance of trips by non- electric private car, in order to avoid worsened air pollution, and the risk of poor air quality hotspots developing (such that an AQMA might need to be designated). Examination of the individual site options that are a variable across the reasonable alternatives Discussion does not highlight any particular concerns. Neither is it possible to conclude that Option 5 performs worse as a higher growth option (noting that Shenley Dens Farm is well linked to the grid road network, with positive implications for traffic flows and also access to public transport. In conclusion, the alternatives are judged to perform on a par, and significant negative effects are not predicted (noting the conclusion reached by the Plan:MK Submission SA Report).

Conserve and enhance the borough’s biodiversity.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2

Significant No effects?

Examination of site options in isolation shows Shenley Dens Farm (Option 5) to be the most constrained site amongst those that are a variable across the reasonable alternatives. The site Discussion partially wraps around Oakhill Wood, a large ancient woodland (mostly replanted) that falls within the Whaddon Chase Biodiversity Opportunity Area (BOA).33

33 BOAs are extensive areas that include a concentration of important habitat, and within which there will likely be a good degree of ecological connectivity over a relatively large scale. There is a need to maintain and increase ecological connectivity within BOAs, which can potentially be achieved through development, where this leads to targeted habitat creation, restoration or enhancement.

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The next step is to differentiate Option 2 (Levante Gate) and Option 3 (Wavendon Golf Course). There is some reason to suggest that Levante Gate is more constrained; however, this is marginal, and both are associated with limited constraint in absolute terms. As such, Options 2 and 3 are judged to perform broadly on a par. Finally, there is a need to consider whether Option 4 (additional allocation of both Levante Gate and Wavendon Golf Course) is more or less preferable to additional allocation of just one of these sites (Options 2 and 3). It is difficult to make a judgement, noting that allocation of both of these two relatively non-sensitive sites could reduce the pressure on other sites that will be considered through the next Local Plan (Plan:MK is likely to be subject to an immediate review). On balance, Option 4 is judged to perform on a par with Options 2 and 3. Following a similar line of reasoning, it is also not possible to conclude with confidence that Options 2, 3 or 4 are any less preferable to the lowest growth option, namely Option 1. In conclusion, Option 5 performs least well; however, significant negative effects are not predicted, noting that any impacts to the adjacent woodland would be quite indirect (also noting that the wood does not currently have public access). Neither are significant positive effects predicted for the other options. This conclusion is in-line with the conclusion reached by the Plan:MK Submission SA Report (which essentially presented an appraisal of Option 1).

Combat climate change by reducing levels of carbon dioxide.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank = = = = =

Significant No effects?

Policy CS14 (Community Energy Networks and Large Scale Renewable Energy Schemes) of the adopted Core Strategy states: “Proposals for over 100 homes will be encouraged to consider the use of community energy networks in their development.” However, in practice viability considerations can be prohibitive, recognising the need to fund/deliver affordable housing and costly infrastructure (e.g. roads and schools). Neither of the Expansion Areas are delivering an energy network, and whilst Policy CS5 (Strategic Land Allocation, SLA) of the Core Strategy, which allocated the SLA, established policy - “Consider the use of community energy networks” – in practice the entire site now has outline planning permission, with no energy network(s) having been proposed. Discussion Focusing on Levante Gate, even as the largest of the three sites in question - i.e. those that are a variable across the reasonable alternatives - there would be little expectation of low carbon energy infrastructure being delivered, noting the recent planning application, and also noting that affordable housing delivery is a stated priority of the Guinness Partnership. In conclusion, the alternatives are judged to perform on a par. There is an argument to suggest that higher growth options perform poorly as the housing might otherwise be delivered at larger strategic sites through the next Local Plan (Plan:MK is likely to be subject to an immediate review); however, this argument is not persuasive. Significant negative effects are not predicted, noting that climate change is a global issue (such that local actions can have only limited effect).

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Conserve and enhance the borough’s heritage and cultural assets.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2 2

Significant No effects?

Examination of site options in isolation shows Levante Gate (Option 2) to be the preferable site amongst those that are a variable across the reasonable alternatives. There are no listed buildings in proximity to the site (although proximity to Little Brickhill Conservation Area is a consideration - see discussion below, under ‘Landscape’). The next steps is to differentiate Option 3 (Wavendon Golf Course) and Option 5 (Shenley Dens Farm). Both sites are constrained by onsite or nearby listed buildings, and it is difficult to Discussion identify which is more constrained. There is a listed farm building at the centre of Shenley Dens Farm; however, the size of the site should mean that there is good potential to integrate the listed building as part of green infrastructure, or as part of a local centre. In conclusion, Options 3, 4 and 5 would involve allocation of one additional constrained site and so perform worse than Options 1 and 2. Significant negative effects are not predicted, noting the potential for avoidance/mitigation measures and also noting the conclusion reached by the Plan:MK Submission SA Report.

Conserve and enhance the borough’s landscapes.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 3 2 4 5

Significant No Yes effects?

Examination of site options in isolation shows Shenley Dens Farm (Option 5) to be the most constrained site amongst those that are a variable across the reasonable alternatives. A 1,500 home scheme would lead to impacts to a landscape defined as having ‘high’ sensitivity. Landscape sensitivity has long been a concern in this area, with the 2005 the Local Plan Inspector concluding that a virtually identical site - “… would be visible from large parts of the Whaddon Valley. The Shenley Ridge is a significant feature in the landscape and I agree with the Llewelyn-Davies assessment that it is a feature that would form a logical and obvious boundary to development… I do not see the logic of regarding the Whaddon Valley as a possible long-term development area. To do so disregards the qualities of the valley landscape and the merits of the Shenley Ridge as a Discussion logical and clear long-term boundary.” The next step is to differentiate Option 2 (Levante Gate) and Option 3 (Wavendon Golf Course). Both sites are subject to a degree of constraint, but on balance, it is considered appropriate to conclude that Levante Gate is the more constrained site. The site comprises rising land at the foot of the Greensand Ridge, with the village of Little Brickhill (with a designated conservation area) lying ‘above’ the site, c.1km to the east. The Council’s Landscape Officer objected to the recent planning application, including on the grounds that development would set a precedent for other development proposals which cumulatively would have an adverse effect on the landscape character and the wider environment; however, the officers report dealing with the application concluded “the relative quality of the landscape that the application site sits in is not high”.

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In conclusion, Option 5 performs least well, and it is considered appropriate to ‘flag’ the potential for significant negative effects. The landscape is not designated, but is recognised as locally important. N.B. an alternative Shenley Dens scheme, using only the eastern-most c.1/3 of the site (namely that which relates best to the existing urban edge), has recently been promoted to the Council; however, landscape concerns would remain, with the northern edge still abutting the open space planned as the southwestern buffer of the WEA, responding to the Shenley Ridge.

Encourage efficient use of natural resources (inc. land/soils).

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 3 2 4 2

Significant Yes effects?

Work to examine each of the sites (i.e. the sites that are a variable across the alternatives) in turn reaches the following conclusions -  Levante Gate - been surveyed in detail and found to comprise 52% Grade 2 (i.e. second highest quality nationally) land, and 26% grade 3a (i.e. land also classified as ‘best and most versatile’).

 Wavendon Golf Course - the site is not currently in agricultural use, but could feasibly be returned to agricultural use in the future. Agricultural land quality on the site has not been surveyed, but adjacent land has been found to comprise ‘best and most versatile’ quality land (grade 3a). Hence there is a strong likelihood of the site comprising best and most Discussion versatile agricultural land.  Shenley Dens - the site potentially performs relatively well in respect of agricultural land quality - as per the ‘WEA Expansion’ site discussed above, on the basis that adjacent land falling within the WEA has been surveyed and found to mostly comprise grade 3b quality land, i.e. land that is not ‘best and most versatile’. In conclusion, options involving additional allocation of Levante Gate are judged to perform poorly. Options 3 and 5 are judged to perform on a par, recognising that there remains uncertainty as to whether Shenley Dens includes any best and most versatile agricultural land. All alternatives would lead to significant negative effects, in-line with the conclusion reached by the Plan:MK Submission SA Report (which essentially presented an appraisal of Option 1).

Limit noise pollution.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 2 2

Significant No effects?

Noise pollution is a concern at only one of the sites in question (i.e. the sites that are a variable Discussion across the alternatives), namely Levante Gate, which site lies between two ‘A’ roads, including the A5 main trunk road.

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In conclusion, Options 2 and 4, which would involve additional allocation of Levante Gate, perform relatively poorly. Significant negative effects are not predicted, however, noting the

potential for avoidance/mitigation measures and also noting the conclusion reached by the Plan:MK Submission SA Report.

Limit and reduce road congestion and encourage sustainable transportation.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank 3 2

Significant No effects?

Examination of site options in isolation shows Levante Gate (Options 2 and 4) to perform relatively poorly amongst those that are a variable across the reasonable alternatives. Whilst the site is well located on the strategic road network, and in turn has good access to existing high quality bus services, the site is relatively poorly linked by walking/cycling routes. The nearest station would be c.1.5km to 2km distant, which is in cycling distance for many commuters; however, there is uncertainty regarding the ease of cycling. The next steps is to differentiate Option 3 (Wavendon Golf Club) and Option 5 (Shenley Dens). There is some argument to suggest the former is the better linked site, nothing: good proximity to Woburn Sands Station (EWR); good proximity to planned/proposed strategic community Discussion infrastructure; and location on the Redway Network. However, on balance it is not possible to differentiate the sites with confidence. Shenley Dens Farm would link directly to the grid road network, and is within easy walking/cycling distance of a range of services and facilities, with CMK also in relatively close proximity. In conclusion, Wavendon Golf and Shenley Dens are judged to be broadly well located, from a transport perspective, such that Options 3 and 5 perform on a par with Option 1. Levante Gate is less well linked; however, there would nonetheless be the opportunity to support modal shift towards walking/cycling and public transport, hence significant negative effects are not predicted (also noting the conclusion reached by the Plan:MK Submission SA Report).

Maintain and improve water quality and minimise the risk of flooding.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank = = = = =

Significant No effects?

Two of the sites in question (i.e. the sites that are a variable across the alternatives) are subject to a degree of surface water flood risk; however, this is not a major concern, as it should be Discussion possible to address this through masterplanning and design measures. In conclusion, the alternatives perform on a par and significant negative effects are not predicted (noting the conclusion reached by the Plan:MK Submission SA Report).

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Reduce waste generation and encourage sustainable waste management.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank N/a N/a N/a N/a N/a

This objective is not applicable to the current appraisal. It should be possible to manage waste Discussion sustainably under any reasonably foreseeable scenario.

Encourage the creation of new businesses; Sustain economic growth and enhance competiveness; Ensure high and stable levels of employment.

Opt 1 Opt 2 Opt 3 Opt 4 Opt 5

Rank = = = = =

Significant Yes effects?

None of the sites in question would deliver employment land. Another consideration is proximity to existing and proposed strategic employment areas, and also proximity to the EWR / Oxford to Cambridge Expressway corridor; however, it is not Discussion considered appropriate to differentiate the alternatives on this basis. In conclusion, the alternatives perform on a par and significant positive effects are predicted, in line with the conclusion reached by the Plan:MK Submission SA Report.

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Summary appraisal of the refined reasonable spatial strategy alternatives (Sept 2018)

Rank of performance / categorisation of effects

Option 1 Option 2 Option 3 Option 4 Option5 Topic Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Levante Gate Wavendon GC Levante Gate Shenley Dens Wavendon GC

Communities 2 2 3

Deprivation = = = = =

Education 2 2 3

Health 2 2 3

Homes 5 4 3 2

Services 2 2 3

Air quality = = = = =

Biodiversity 2

Climate = = = = = change

Heritage 2 2 2

Landscapes 3 2 4 5

Nat resources 3 2 4 2

Noise 2 2

Transport 3 2

Water = = = = =

Business/ Economy/ = = = = = Employment

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Rank of performance / categorisation of effects

Option 1 Option 2 Option 3 Option 4 Option5 Topic Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Sub’n allocations Levante Gate Wavendon GC Levante Gate Shenley Dens Wavendon GC

Conclusion A headline conclusion is that Option 1 (submission allocations) performs best, or equal best, in terms of all objectives other than ‘Housing’. The housing land supply under Option 1 (the lowest growth option) has been determined to be suitably robust by the Plan:MK Planning Inspector (see paras. 3.2.10 and 3.2.11, above) in that it will deliver the established OAHN / housing target (26,500 homes) over the course of the plan period, and on a suitably smooth trajectory (i.e. in the region of 1,766 dpa). However, additional supply (i.e. Options 2 to 5) would further reduce the risk of falling below the committed/required housing trajectory due to unforeseen delays to delivery at one or more sites (and thereby further increase confidence in respect of the Council’s ability to demonstrate a rolling five year housing land supply, and meet the Housing Delivery Test, across the plan period). The second point to note is that Option 5 performs relatively well in relation to a number of objectives, but notably poorly in terms of ‘Landscape’, as the additional allocation in question - Shenley Dens - is constrained by its location on the Shenley Ridge. An alternative Shenley Dens scheme, using only the eastern-most c.1/3 of the site (namely that which relates best to the existing urban edge) has recently been promoted to the Council; however, landscape concerns would remain. The northern edge would abut the open space planned as the southwestern buffer of the WEA, responding to the Shenley Ridge. A third point to note is the identical conclusion reached within the ‘Communities’, ‘Education’, ‘Health’ and ‘Services’ rows of the appraisal table. Option 4 performs poorly as it runs contrary to the broad policy of supporting housing delivery at strategic scale sites that are well suited to delivering significant new and upgraded infrastructure. Focusing on the question of Option 2 versus Option 3, the appraisal finds Option 3 to perform better in landscape, noise and transport terms; however, these conclusions are all somewhat marginal, and it does not automatically follow that Option 3 is the better option overall (e.g. noting that Option 2 performs better in ‘Heritage’ terms).

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