LDF AG MEETING: 9 SEPT 2010 SUMMARY OF THIRD PARTY REPRESENTATIONS (As at 4.00pm, 8.9.10)

Date of Name Organisation Request to Written Subject of comments Ref email speak? comments submitted?

1.9.10 James Farmer X 9 Bow Brickhill Consortium land (south of B-B railway) and EWR 1

1.9.10 Clive Faine Abbeygate 9 X Economic development, CMK review -

3.9.10 Stuart Turner ? 9 Level of growth; retain the SE SDA 2

3.9.10 Alan Francis 9 Promised -

4.9.10 Alice Cramplin CPRE (Beds Branch) X 9 Support deletion of SE SDA; need to review assumptions about 3 development in neighbouring areas

4.9.10 Fran Fry & X 9 SE SDA changes (support and outstanding concerns) 4 District Society

6.9.10 Katherine Else RPS Group (for Old X 9 Tickford Fields Farm 5 Road Securities)

6.9.10 Jennifer Lampert J Lampert Associates X 9 Derivation of housing targets; deletion of SE SDA (clients’ land 6 holdings affected)

6.9.10 Julia Upton MK Community ? X Expressed an interest in attending LDF AG meeting - Foundation

7.9.10 Kevin Coleman JB Planning Associates 9 9 Derivation of housing targets; revised boundary for SE SDA 7

7.9.10 Mick Moutrie 9 9 Economic prosperity / 2 speed city 8

7.9.10 David Jackson Savills (for SE MK 9 9 5 August LDF AG papers; housing requirements; site capacity; 9 Consortium) employment land requirement; infrastructure delivery plan; Core Strategy end date. NB Comments drafted prior to papers for 9 Sept LDF AG being available

(1) IH / 8.9.10 Date of Name Organisation Request to Written Subject of comments Ref email speak? comments submitted?

Further reps received after 7.9.10

8.9.10 P Mavrogordato X 9 Church Farm SRA; land at Lodge. Need to continue 10 to plan for next 20 years nor just for the short term Letter, not email

8.9.10 Andrew Thomas MK Forum X 9 Process of amending the CS; interim position; commitment to 11 review

8.9.10 Tom Whild Terence O’Rourke (for ? 9 The letter previously sent to the Chief Executive following the 12 various landowners in LDF AG meeting on 5 August the SE SDA)

8.9.10 Roger Turnbull Apt Planning (for X 9 Supports higher target of 2,000 homes per year 13 Realmoak and Corran Wakefield)

(2) IH / 8.9.10

49 Vandyke Close Woburn Sands MK17 8UU

31ST August 2010

Ref: Milton Keynes Core Strategy

Please could you consider the following points whilst reviewing the core strategy?

Milton Keynes growth should encourage a modal shift from the car, and towards the use of the soon to be upgraded East West Rail link. Therefore development should be fundamentally based on capturing the economic benefits associated with linking Milton Keynes to the knowledge based hubs of Oxford & Cambridge. I would categorically oppose any growth west of the M1, this would in no way support the regionally important East West Rail, and additionally the huge costs involved with crossing the motorway would be prohibitive.

Milton Keynes South East SDA could be based on 10,400 dwellings to accommodate the expected population growth in the South East, and to provide a fair chance for future generations to get on the property ladder. To cut growth targets would force up the cost of homes locally by restricting supply, and social housing would become a scarce commodity, previous generations have been provided a plentiful supply of homes, but now it seems the people who benefitted from previous growth feel that younger people cannot be given the same right to a roof over their heads.

The spatial strategy should be changed to include development land south of the Bedford - railway (the Bow Brickhill Development Consortium site) this is the most supportive site associated with EWR

I have recently consulted with a senior planner at the Government of the South East who has confirmed the implementation of the East West Rail will only be possible if planning permission is granted for sufficient homes along the rail link. Therefore I would urge Milton Keynes Council to retain the South East SDA, and seek to retain the existing housing targets.

Yours Faithfully

Mr J Farmer

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Local Development Framework Advisory Group. Proposed Changes to the Core Strategy.

Introduction The revocation of regional spatial strategies by the Secretary of State has prompted a review of the Core Strategy. However there is cross party agreement that the published Core Strategy remains unchanged, subject only to the local perspective following, primarily, the revocation of regional spatial strategies (RSS), and that MK will remain a prime growth area.

Proposed changes Councillor Galloway as chair, and Councillors Hopkins and White of the Local Development Framework Advisory Group (LDFAG) have prepared a draft paper that contains a list of the detailed changes under consideration. These details are contained within the ‘Supplementary paper: What next for the Core Strategy?’ This information was tabled as supplementary Item 5 at the 26th August 2010 LDFAG meeting.

Extent & scope of policy change The introductory note to supplementary Item 5 talks about policy directions and item 3.2 refers to a motion already agreed by the LDFAG on the 5th August which points to a revised policy direction for the Core Strategy which seems to go beyond the intent as indicated by the cross party group above.

A more detailed explanation of the policy direction is required with a much clearer explanation of what represents a proposal. A number of the noted items in the motion agreed at the 5th August meeting of the LDFAG now appear to have become proposals and detailed as proposed changes in supplementary Item 5. Some items appear to contradict each other.

For example the bringing forward and reliance on of the strategic reserve sites (SRS) for housing has become a proposal, despite the possibility of this meaning a possible deficit in housing land supply over a 15-year period. This reliance would also limit the planning capability to devise a sustainable development framework and the development of a zero carbon city.

Development context As a practitioner I am interested in the success of Milton Keynes, the development of a sustainable community, and the creation of a built environment to support the Core Strategy vision as explained in Section 4 of the Core Strategy ‘ A Vision for the Place’.

Impact of changes on vision There is concern that proposed changes go beyond a focus that is limited to the revocation of regional spatial strategies. While this may be unintentional the proposed changes start to impact on the heart of the vision for the Core Strategy and ultimately our ability to deliver a sustainable built environment. Without further consideration of the changes we could be creating a situation

(4) that leads to a comprehensive review of the Core Strategy and a further period of uncertainty and limited progress that could extent beyond a point when we could be emerging from the current downturn.

These and the following arguments are based on the premise that growth is a necessary part of the economic strength of MK and is essential to our success and ability to deliver what we want for MK.

Housing targets & delivery rates Item 3. 2 of the introductory note to supplementary Item 5 includes a number of statements that when taken together draw the conclusion that all the Strategic Development Areas (SDA) are no longer required. This conclusion is based on an assumption about a revised housing target that is not yet agreed, and on a belief that we need only rely on existing land supply commitments and possible some or all of the current Strategic Reserve Sites. This approach is questioned.

There appears to be a presumption made that growth and housing numbers for the next 15 years can be based on a completion rate of no greater than 1,500 – 2000 homes per year, that the projected housing figure can be built around this, and that, as a consequence the current land supply will be sufficient. These rates if projected would add up to something in the order of 22,500 to 30,000 homes over a 15-year period.

As things stand there is a land supply in place for approximately 20,000 dwellings that could last 10 years.

At a delivery rate of 1,500 homes per year the land supply could be used up within 13.3 years and a rate of 2000 homes per year within 10 years. Well before the end of the plan period of 2026. To put this in perspective an upper figure of 2000 homes per year is ambitious. For example the average yearly figure over a period from 1991 to 2009 was 1,600 dwelling completions. However the anticipated low number of houses to be delivered over the next couple of years should not be used as a reason for running down a land bank.

Under the governments policy in PPS3 the local authority is required to show that they have a 15-year supply of housing land, which if the MKC is committed to a sustainable growth programme this supply should relate to a properly planned development framework.

There is a concern that by adopting the proposed approach that the strategic position and an ability to plan for long term growth is being compromised.

As a consequences growth will be dependent on the development of a number of smaller and fragmented development areas and that because of their location, shape and size this will means that the ability to plan and coordinate development in a coherent way will be lost.

(5) If anything a strategic land supply for growth should extent beyond a 15-year period, there is a risk with the approach being adopted that land supply could fall well short of this 15-year period.

Location of strategic reserve sites/areas There is a concern that the strategic reserve sites will be developed in isolation and not properly integrated with the rest of the city, and without the ability to provide a comprehensive public transport system to support the communities within these areas. If access is poor there is a real risk of creating further deprived areas. Some of these problems have been associated with the expansion areas where development is located on the periphery of the city. Newton Leys is another example of an isolated development area.

There are five strategic reserves identified in MK Local Plan 2001 – 2011 Adopted 2005. These are:-

1. Land north of the A421 and east of Fen Farm is identified as a strategic reserve area (Ref. policy SR1)

Four further locations were identified as strategic reserve areas on the Proposals Map. These are:-

1. Glebe Farm, south of A421, Wavendon (SR2) 2. Eagle Farm, south of A421, Wavendon (SR3) 3. Church Farm, east of Wavendon Gate and Old Farm Park, Wavendon (SR4) 4. Tickford Fields Farm and land adjoining, North Crawley Road, (SR5)

These locations have been carried over. The policy states that these areas are considered to have potential for development after 2011, but will only be considered for additional housing, employment or other development in a review of or alteration to this Plan.

All these including Tickford Fields, Newport Pagnell, which is regarded as rural settlement are to be replaced, carried over and included in the Site Allocation DPD as Strategic Reserve Areas (SRAs). (Ref. Core Strategy. Appendix C and policy ref. EA4A)

Planned development & area options. The principle of development to the SE as a Strategic Development Area has been established through a process of comparing growth options and public consultation. The principle of development to the SE should be retained in the Core Strategy at this time.

The omission of the SE Strategic Development Area will undermine the

(6) possibility of a planned approach and the creation of sustainable development framework for this area that could sensibly contribute to the development of a zero carbon city. This does not prevent the 4 strategic reserve sites located in the SE from being integrated into a comprehensively planned development framework for the area.

This raises a question over the extent and status of the SE Strategic Development Area. The approach does not negate a review of the SE Strategic area. However an omission at this time from the Core Strategy is considered premature until consideration has been given to a number of scenarios that incorporates revisions to growth once figures are known, and where a revised and reduced growth should be. For example part of this area could emerge in a revised SDA, or consolidated in part as an action area plan within the SE SDA or as a new Strategic Reserve Area.

My focus is on the area of land to the SE that falls within the MKC administrative area. The proposed changes as they stand will negate any opportunity to address the proper master planning of this area, and time to consider the best way to ‘close off’ the bottom end of the Eastern Expansion area and at the same time to maximise the potential of development related to a new city portal at Junction 13a.

Criteria of assessment At this time no updated assessment has been made of the land supply required, and particularly for housing where the criteria for quantifying the land take has changed. There are many aspects to this to be considered for example; -

- Revised densities and a presumption for lower housing densities where these can still be argued on a sustainable basis - New patterns of development that best support public transport. - Need for land for employment uses and extended areas of open space where a greater role for productive landscapes should be anticipated. - Review of open space provision.

Without allowing the opportunity for this piece of work prior to omitting the SE development area we run the risk of the whole process being unravelled, with the question of development to the east of the motorway being reintroduced even though this has been examined and dismissed. This could result in another 10-year period of inertia with another lengthy and disruptive public consultation process.

Soundness & evidence base. A sound Core Strategy is required. Any changes to the Council’s Core Strategy must be scrutinised before a revised document is submitted to the Secretary of State for Examination in Public. Matching local need, and housing requirements to serviceable land is a critical part of an evidence base.

(7) Since the RSS housing targets can no longer be relied on an alternative evidence base to support the level of growth is required. The most likely is the Strategic Housing Land Availability Assessment (SHLAA) that was commissioned by MKC in 2008.

The report was updated in October 2009 and states that :- ‘The estimates from the 2009 housing requirements assessment shows that there is a net requirement for 16,832 extra dwellings in Milton Keynes over the next five years’.

This equates to a requirement of 3,366 homes per year and if we are relying solely on the existing strategic reserve sites there is the potential of the land supply being used up in under 6 years. Cleary, this rate of delivery is not likely in the current economic downturn, but the scenario does highlight the issue of local need and demand on land supply and being prepared for an upturn with accelerated delivery rates.

Supplementary Item 5 suggests that assessments of Interim targets will be based on this document and work carried out as part of the annual review of the Strategic Housing land Availability Assessment (SHLAA) and the annual forecasts of housing completions by the Joint Housing Delivery Team (officers from the Council, MK Partnership and other key stakeholders).

Relying on the strategic reserve sites for the land supply or even waiting to a future review of the Core Strategy to review this position puts MKC in a weak position and open to challenges by developers.

A position that retains the possibility of development to the SE in principle for the immediate future until revised development plans have been considered puts the council in a stronger position even if the status is changed from a Strategic Development Area (SDA) to a Strategic Reserve Area (SRA).

Summary I would ask you to considered these points and for a position that calls for

‘The principle of development to the SE as a strategic development area within the MKC administrative area be retained at this time to allow time for the development policy to be reviewed and the relative merits of the 4 strategic reserve areas within the SE to be considered as part of this review, and where local plan policies EA4 and EA4a are retained as currently presented in the Core Strategy under Appendix C’.

Or at least some suitable wording that could be incorporated into the text of the changes to ensure that the potential of a development area to the northern end of the SESDA is not negated in its entirety, albeit subject to review.

Stuart Turner – Architecture &Urban Design.. st to ih– 03.09.10 rev. -.

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FW: Milton Keynes Core Strategy Page 1 of 2

Lane, Gavin

From: M & AF Crampin [[email protected]] Sent: 04 September 2010 21:05 To: Haynes, Ian Subject: FW: Milton Keynes Core Strategy

65 Mount Pleasant , Beds MK17 8JX

Dear Mr Haynes

I am receipt of Mr Nick Fenwick’s letter of 31 August 2010 addressed to all key stakeholders in the Milton Keynes Core Strategy.

I write on behalf of the Campaign to Protect Rural England, Branch. Our branch, being Bedfordshire based, is principally concerned with the previously proposed extension of the SE Strategic Development Area into rural parishes in Bedfordshire. However, we have followed carefully developments relating to the whole designated area, since, of course, they have a bearing on the outcome as far as Bedfordshire is concerned. You will be aware that we have always deplored the proposals to extend Milton Keynes into Bedfordshire, and, also, the process, involving the SE Region of which we were not part, through which the proposals have been progressed.

I have looked at the Supplementary and Discussion Papers: “What next for the Core Strategy” and the other papers prepared for the Local Development Framework Advisory Group’s meeting on 26 August, including the Proposed Changes to the Core Strategy to take account of the revocation of Regional Spatial Strategies.

I am unable to attend the meeting on September 9, but, on behalf of our organisation, I should like to make the following comments.

z We welcome the indication of emerging policy 3.2 c) in the Supplementary Paper, where it is stated that owing to a downwards revision of housing targets to a “realistic” level, the SE SDA is not needed and therefore the land in question should retain the designation of open countryside that it had in the 2005 Plan. We would urge the Council to confirm this sensible and long overdue revision, now made possible by changed government policy and the removal of top down, inappropriate targets. z We urge the Council to abandon the SE SDA whatever level of reworking to the Core Strategy it decides upon. z Your Council’s letter draws our attention to your being “Open for Business”. We would say that only now are you genuinely so, since before now your actions were being

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08/09/2010 FW: Milton Keynes Core Strategy Page 2 of 2

dictated from above and there was no level playing field for democratic interaction with local communities. z We note that the proposed changes to the Core Strategy have deleted all references to the regional plans and to the SDAs. However, Foreword ii seems to assume that growth into other local authority areas will take place. The assumption pervades the document, being picked up, for instance, at Table 4.1‐ point 2 , 5.1. Section 6, despite the deletions, seems to look ahead to some unspecified development, since plans for the transport infrastucture that was to accompany the SE SDA are left in. This future growth should not be assumed. The premises come from the discarded RSS and MKSM and must be revisited in the light of very changed circumstances. A core strategy needs to be explicit and clear. Paragraph 6.12 with its “may at some point” should be omitted. In this context, we note 3c of 5b(ii) in the Council decisions of June 8, where a commitment to oppose expansion by stealth is given. z A fundamental reassessment of Milton Keynes’ policy of growth should now be undertaken. A sustainable city could be one that achieved a steady state. z The Strategy should not seek to promote road developments across other people’s areas, at a time when the need to promote sustainable modes of travel becomes ever more urgent.

Yours sincerely

Alice Crampin

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08/09/2010 WS Woburn Sands and District Society DS

Ian Haynes Chief Spatial Planner Milton Keynes Council

04 September 2010

Dear Mr Haynes

Re: Changes to the Draft Core Strategy.

We have considered the changes the motion agreed at the Local Development Framework Advisory Group (LDFAG) on the 5th August, following the full council motion of the 8th June. We have considered the changes to the draft Core Strategy considered at the LDFAG on the 26th August, which removed references to both regional and sub regional strategies (now abolished).

We will keep our comments short and to the point.

As we understand the changes, following the abolition of the RSS’s (Regional and Sub Regional) it is intended to remove, references to the RSSs and the SEDA and SWDA from revised Core Strategy. MK has sufficient permissions full and outline, and land in the form of the SRAs to the South East and North to meet expansion requirements for at least the next 15 years based on the abolished SE plan annual targets – which of course are unlikely to be achieved. We note the Core Strategy and indeed the housing trajectory will be reviewed annually.

We support this view and we support the removal of references to the RSSs and SEDA and SWDA as set out in the changes put forward to the meeting of the 26th of August. However we consider that the changes as set out will be found unsound at examination, under PPS12 (2008), which has yet to be revised following the abolition of the RSSs.

We are of the view that removing the specific references to the SWDA and SEDA, but leaving in the specific framework, obscurely masked, as further and future development within MK boundaries is unsound and indeed could be misleading to stakeholders. .

PPS12 is quite clear at 4.5 "It is essential that the cores strategy makes clear spatial choices about where developments should go in broad terms. This strong direction will mean that the work involved in the preparation of any subsequent DPDs is reduced. It also means that decision on planning application can be given a clear steer immediately"

(11) A Core Strategy should provide a robust planning framework for the next 15 years for developers, planners, residents and business and that has been resolved, is to be the existing Local Plan Area, and the SRAs identified in the fully consulted Local Plan. Indeed this is the most realistic scenario for Milton Keynes if the Core Strategy is to have any relevance. Further expansion beyond this should follow due process at a later review of the Core Strategy if required, it should not be promulgated in vague references in what is a core planning document..

We are further of the view that the changes retaining a specific framework in respect of developments close to the MK boundary in neighbouring authorities is also unsound, both from the same PPS12 4.5, but additionally DCLG guidance is quite clear following the abolition of the RSSs, that whilst joint working on cross boundary issues is required as indeed in the past, it is not for one LPA to plan for another LPA.

Additionally we note that there is still contained within the document the intention to reserve the SRA north of the A421, East of Fenn Farm for the proposed MK – Bedford waterway, which we support, but additionally for future M1 crossings. As the M1 at this point forms the boundary between MK and CBC, we would oppose this latter, indeed would question whether its inclusion is in violation of the full Council motion of the 8th June “giving a commitment to oppose expansion by stealth of Milton Keynes beyond its existing boundary……………………”

We are supportive of the sustainable expansion of Milton Keynes into an iconic, vibrant regional centre that meets the requirements of both residents and business, however we regret some of what has been done to Milton Keynes in the last few years of Government dictated housing targets – the social and environmental legacy of which will be a drain on Milton Keynes Council resources in years to come.

We hope that you find our comments useful.

Yours sincerely

Fran Fry Vice Chair Woburn Sands and District Society. [email protected]

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To: Milton Keynes Council Local Development Framework Advisory Group September 9th 2010

Comments to be forwarded to the Ian Haynes, Chief Spatial Planner and to Members of the Local Development Framework Advisory Group

From Jennifer Lampert, Director of Jennifer Lampert Associates Ltd: Town Planning Consultants.

I act on behalf of clients with land holdings which will be affected be the current interim Core Strategy Proposals and in the longer term review of this important document. I have been instructed to make representations on behalf of my clients, please find these below.

1. Objection is made to the proposal to only set a housing target that is based on an estimate of the number of houses predicted to be built. This is not a sound approach to growth and does not involve a proper assessment of the amount of housing growth that is required to maintain and support Milton Keynes as a New City of Regional significance and this could have a significant impact on future investment.

Milton Keynes Council, in my view and for sound planning reasons, should continue to support the status of the New City as a being of regional significance, even if Regional Planning has been scrapped by the present Government. The Core Strategy ought to strongly acknowledge the continued capacity of Milton Keynes to play a role a regional level. The importance of the role Milton Keynes can play is supported by the currently proposed Local Economic Partnership arrangements.

There has been much investment over the past 40 years and this has brought the New City economic and social success. This success should not be allowed to decline. The City is a growth point and its future growth must be managed so that the existing citizens and newcomers can continue to enjoy the benefits of living and working in the successful environment and so that the delivery of that environment can successfully continue.

The main report now recommends the adoption of a housing target of 28,000 new homes to be adopted in the Core Strategy for the period 2010 to 2026. This is based on an annual average completion rate of 1,750 homes per year.

The report assesses low, medium and high estimates of completions likely and chooses the mid range i.e. the rate of 1,750 houses per year. See Appendix 1, Housing Target Options and Land Supply. The bulk of these housing numbers are provided by the existing urban permissions and allocated sites.

There appears however to be no proper consideration within the report of exactly what type of growth is proposed for Milton Keynes to 2026, now that the Council are abandoning the previous approach to the Core Strategy in the light of the ‘scrapped’ Regional Housing figures.

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If the Core Strategy is to be revised, how it is revised must be based on sound logic and proven growth figures that are taken from sources such as the population census, the figures supplied by the Strategic Housing Market Assessment (SHMA) also remain relevant, as does evidence provided to the Strategic Housing Land Availability Assessment (SHLAA). There are clearly a range of sources.

Such a review must also, most importantly, be based on the aspirations of the Council for the continued importance of Milton Keynes as a major centre within this region.

To seek to argue that the option for housing growth is purely based on an estimate of what might be built at the current scale of delivery is to deny the whole purpose of a Core Strategy, the purpose of which should be to plan for a successful future.

The figures for housing targets must be derived from the amount of growth that the Council wishes for the area and it must be clearly demonstrated that the scale of growth has been fully considered and tested. There is no evidence in the report that this has yet been done.

Using the currently proposed figures will change the status of the New City from one of regional importance for growth band investment. It would severely limit growth and therefore the ability to attract investment for employment, infrastructure and services.

2. Objection is raised to the way the housing figures are arrived at. (Notwithstanding the objection made in 1 above).

If a revised approach is taken to available housing land, it must start with the proposals in the Adopted Local Plan and it is fair and reasonable to consider the sites that were proposed and allocated as being Strategic Reserve Sites, including Tickford Fields, Newport Pagnell.

However before these sites can be formally introduced and allocated via the revised Core Strategy they MUST be reassessed to address whether they remain the best and most sustainable choices and are deliverable in the light of the abandonment of the previous strategy.

In addition to the sites that are proposed from the Strategic Reserve sites and Tickford Fields, the Council must also carry out a further assessment of other sites that have been put forward through the representations to the Core Strategy and which have been proposed to them through the SHLAA. Not to do this would result in the Core Strategy being unsound and open to challenge.

The Council must also have regard to the availability and suitability of existing sites that previously were already proposed as part of the SE SDA and which are within the Borough boundary.

The SE SDA and other sites, when subjected to the same thorough appraisal, as the SRA sites could well be found to be as suitable as the SRA sites for development, (or even more suitable) either now or for future growth beyond 2026.

It is noted at the end of the main text in pages 63 to 65 that the officers are suggesting that further sustainability appraisal work should be carried out on the SRA sites and others but they suggest in the final paragraph on page 65 that this should be published alongside the revised Pre- submission Core Strategy.

(18)2 Objection is made to this approach, as how can the Council know what to set down in the revised core strategy if it has not carried out the work of reviewing and assessing the SRA sites and the other sites, including the SE SDA sites, against a set of agreed Sustainability criteria?

Conclusions

Objections are made to the overall approach to the growth strategy for Milton Keynes because no consideration has been given to examine the future role of Milton Keynes. No evidence is provided to show what the predicted growth requirements by both natural increase and/or by chosen expansion to retain and strengthen the city’s role as a regional centre.

To decide the growth figures based on purely an estimate of house building completion rates is not addressing the growth issues at all.

Objections are also raised to the choice of housing sites, without any proper assessment. Whilst the starting point may well be to look at the SRA’s those sites should be assessed against agreed Sustainability objectives and considered against other sites. Deliverability must also be a consideration.

The same criteria must be applied to assessing all sites already suggested as part of the previous core strategy process and forwarded via the SHLAA and particularly to those previously considered acceptable.

Only after this work has been carried out can the Council decide how they ought to amend the Core Strategy.

Jennifer Lampert 6th September 2010

Footnote: Points of comment relating to the revised text of the proposed changes are provided as a separate Annex A.

Contact details for email

Jennifer Lampert Associates Ltd Orchard House The square Paxton Berwick –upon-Tweed TD15 1TE

Tel/fax 01289 386000 Mobile 07802 408 907 Email [email protected]

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Annex A

Page 26th August 2010 draft 9th September draft Comment

5 included “or otherwise” deleted “or otherwise” keep “or otherwise “

10 MK is to continue to grow same text If MK is to continue to grow this text should reflect the growth figures

15 SRA and other new SRA and sites retain “and other new Development areas identified through development areas” The site allocation and do not rely on the DPD site allocations DPD

19 para deleted new para stated this is supported and if above past rates are to be achieved then the rates must be given and not restricted

23 no figures given no figures given to be amended to include Table 4.1 point 1 references to other sites such as SE SDA sites and figures provided.

28 refers to SRAs refers to SRA’s to amend to refer to other sites and to the revised numbers of dwellings that can be provided when assessment is completed.

41 ref SE SDA ref SE SDA include parts of SE SDA Table 5.7 table 5.7 either as new development sites or as future new SRA’s

54 refers to site refers to site delete site allocations DPD Allocations DPD allocations DPD and replace by new sites to be properly assessed. These will be identified within the revised core strategy. Such sites will be the SRA’s and other sites.

54 par 6.1 par 6.1 to be amended in the light of the assessment of alternative sites that would then be included in the core strategy

55-56 ref to “or otherwise” now refers to delete ref to site allocations Site allocation DPD and provide a more DPD detailed description of sites

(20)4 including SRA’s and others 55 pages 25 to 28 pages 25 to 28 These pages to be amended in response to the details to be provided following the assessment of sites that will include the SRA’s and new sites.

58 par 6.12 par 6,12 revise to refer to the inclusion of sites within the Borough of MK that were within a SDA to be considered for growth via the current assessment or a future assessment.

105 table 17.1 table 17.1 to be revised in view of new sites being included as a result of the assessment of SRA’s and other sites currently available.

General note: Substantial revisions will need to be made to the text if the Council agree that the housing growth targets have to be amended and subject to the re-appraisal of the SRA’s and of all of the others sites that have been suggested if they show high scores in the sustainability assessment. This includes existing sites that were originally part of the SDA’s.

Jennifer Lampert 6th September 2010.

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Ref: KC/734/

7 September 2010

Ian Haynes Chief Spatial Planner Milton Keynes Council Civic Offices 1 Saxon Gate East MK9 3EJ

Dear Mr Haynes

Re: Milton Keynes Core Strategy; LDF Advisory Committee 9th September

I refer to the recent invitation to submit comments on potential changes to the Core Strategy prior to the 9th September meeting, and we are pleased to set out our initial observations below.

Summary

In essence, our comments below touch on two main issues:

• Firstly, whilst we appreciate that the Council may well wish to adopt a lower housing provision figure, we are concerned that the methodology set out in the draft Committee Paper for arriving at the 28,000 figure is too limited to withstand scrutiny at Examination.

• Secondly, we identify a number of practical, procedural, and evidential issues surrounding the proposed revisions to the Core Strategy and the manner in which the proposed 28,000 new homes would be delivered. We suggest that a revised approach which would address many of the problems that we identify would be to maintain a South East Strategic Development Area, albeit one that is reduced in size and/or scope to meet the lower housing targets that the Council envisages.

The basis for the revised housing target

We appreciate that as part of revisiting the Core Strategy, the Council wishes to reduce the scale of new housing proposed. The Council is of course aware however that any revised housing target will need to be based upon robust and credible evidence.

The methodology put forward in Agenda Item 5 to support the revised target of 28,000 new homes appears however to have two significant flaws.

Firstly, using housing delivery rates over the past few years represents a very one- dimensional approach to assessing new housing. It may be an accurate reflection of current levels of supply, but without any assessment of potential need (from the SHMA) or balanced consideration against wider social and economic objectives, this is an approach that runs a high risk of being found unsound at Examination.

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Ian Haynes 2 7 September 2010

Secondly, it is far from clear that the evidence presented even within Agenda Item 5 supports the contention that 1750 units is a fair reflection of a realistic annual delivery rate. The appended housing trajectory shows for the period 2012/12 to 2018/19 annual delivery rates well in excess of 1750 per annum, and indeed normally around the 2,200-2,300 mark, even after an ‘optimism bias’ has been used to reduce annual build rates in this earlier part of the Plan period. The reason delivery tails off in the latter years of the Plan period is not because MKC cannot deliver more units, but because the constrained land supply results in lower numbers needing to be built. If the housing trajectory is correct, and the City can, subject to land being available, regularly deliver well in excess of 2,000 units per annum for most of the Plan period, then this flatly contradicts a total housing figure which pre-supposes no more than 1750 per annum on average.

If the Council is to proceed with 1750 per annum, despite a much higher locally arising need, on the basis solely this is the maximum that can realistically be built, it will need much more substantive evidence to justify this than is currently presented.

Practical, Procedural and Evidential Issues arising from the proposed Core Strategy amendments

Notwithstanding our comments above, and assuming 28,000 units is settled upon as the overall housing provision figure, there are a number of issues that arise from the proposed amendments to the Core Strategy set out in Agenda Item 6 (and which are in part explained in Agenda Item 5).

In brief, these are:

• The Plan period is assumed to be to 2026, on the assumption of adoption in 2011. We question whether this is realistic. Given the need for appropriate Pre-Submission consultation, and the timescale needed to collect the evidence to support revisions, it is hard to see an Examination being concluded until the middle of 2011 even assuming no delays, which would make adoption in 2011 marginal. Housing provision figures are normally assessed as of 1st April, so to avoid Adoption slipping in to 2011/12 (making the 15 year plan 2026/27), the Core Strategy would need to be adopted prior to April 2011, which is not feasible.

• Split between the City and Rural targets – we understand the logic behind having a separate target for the City and for the rural areas. However, having reduced the overall level of housing for the District as a whole, it is difficult to understand the logic or the evidence base which supports the decision to maintain the same absolute number of new homes in the rural area as previously (para 3.8 of Agenda Item 5). The effect of this if of course to materially increase the number of new homes being built in the rural area at the expense of more sustainable urban locations. What evidence is there to support a revised distribution whereby the rural areas take proportionately more homes?

• Land supply in the Rural areas – the consequence of maintaining the rural target unchanged is that there is still a shortfall of over 1200 units in the rural areas, whilst land supply at the City is just about at parity (Appendix 1). This produces the rather strange position of a Core Strategy that would seek to provide for substantial new housing sites in the rural areas, whilst providing no new housing above existing commitments at the City.

• PPS12 sets a requirement for Core Strategies to be flexible and capable of responding to changing circumstances, and clearly housing land delivery is one variable over which Councils do not have complete control, and for which Core Strategies are expected to provide some contingency. A “surplus” of +11 units out of (23)

Ian Haynes 3 7 September 2010

circa 26,000 homes over 15 years is not a robust land supply position. This problem is apparently recognised in paragraph 3.12 of Agenda Item 5 wherein it is suggested that the Site Allocations DPD could provide an opportunity to consider additional sites or provide some flexibility/contingency in supply if new homes are not delivered as expected from other sites. But that is not the case – the Site Allocations DPD has to be in conformity with the Core Strategy, and if the Core Strategy sets a policy framework that limits development only to the locations shown in Appendix 1 then the Site Allocations DPD would have no such flexibility. The Core Strategy would need to have a policy or otherwise set the locations within which a subsequent Site Allocations DPD could look to find additional land if required.

• The revised Core Strategy text pre-supposes that the strategy for land supply at the City includes the 2,500 units notionally falling within the three Strategic Reserve Areas to the South-East of the City. But as Officers noted in their written response to the last meeting of the Advisory Group, the Strategic Reserve Areas have not been allocated for development in any previous Plan, and therefore either the Core Strategy needs to allocate them (and in which case it will need to go through a process of ensuring that they are indeed the right sites to allocate), or it will need to set a framework that will enable the Site Allocations DPD to allocate them in due course. At the moment, the text of the Core Strategy as proposed is neither one nor the other, and as drafted, is unsound in its reliance on Greenfield sites that have no development status.

• The previous Local Plan Strategic Reserve Areas are in any event essentially the residue of the old Local Plan process. Their origin is not as a result of any strategic exercise undertaken by the Council, but the result of the previous Local Plan Inspector assessing sites that happen to have been put forward by development interests at the time, in the context of an identified shortfall. The Council’s SHLAA has already identified additional land within the vicinity of the old SRAs which is assessed as being equally suitable for development, so to endorse the SRAs without due consideration of their suitability or the reasonable alternatives would compound the problem of lack of due process.

Proposed Amended Approach

We believe that the practical and procedural concerns above could be addressed quite simply be retaining a modified version of the South East Strategic Development Area, which sets a framework by which the old Strategic Reserve Areas or indeed additional/alternative sites can come forward as part of a co-ordinated approach to housing, employment and infrastructure to the South East of the City. To reflect the change in emphasis, it may be appropriate to delete the word ‘Development’ from the title.

Clearly the scale of development in the South East area would be less than previously envisaged, reflecting whatever revised overall housing target is eventually settled on. Importantly, however, the SE SA would provide the vehicle both to allow a proper consideration of the future of the Strategic Reserve Areas, and give the Core Strategy the flexibility it currently lacks to potentially bring additional land forward if required. It might of course be that not all of the former SRA land is required, or that there are alternative areas of land that could be brought forward alongside all or part of the old SRAs.

The boundary of the SE SA could be kept the same as previously – this would provide the greatest flexibility, allow the most comprehensive vision to be pursued for the area, and allow for post-plan requirements to be dealt with as well, without of course committing the Council to delivering any more development than is necessary to meet the revised housing target. Alternatively, a reduced Strategic Area could be identified to more closely reflect the more limited scale of development now envisaged.

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Ian Haynes 4 7 September 2010

The Council may recall that one of the key factors that eventually influenced the location and extent of the SRAs was their position to the north of the “Wavendon Settled Ridge”, a landscape character area with a boundary running roughly east-west along Lower End Road.

The plan below shows a possible smaller area which could form a revised SE SA boundary – even this smaller area contains land identified in the Council’s SHLAA as being suitable for development which is outside of the previous SRAs but which equally lies beyond the “Wavendon Settled Ridge”, thereby providing the opportunity for a flexible land supply.

The previous proposals for the SE SDA assumed the preparation of a separate Masterplan to be adopted as SPD. Assuming a smaller scale of development, there is no reason why the Site Allocations DPD should not address the precise development areas boundaries, provided that the Core Strategy gives the Site Allocations DPD the flexibility to do so via an appropriate strategic policy. Our approach need not therefore be the costly exercise previously envisaged.

In our view, retaining a modified/reduced SE SA has a number of significant benefits, which we would summarise as follows:

• Retaining a commitment to a comprehensive approach within the wider South East Strategic Area is in no way a commitment to the scale of growth envisaged in the current Core Strategy, but the commitment to achieving a long-term, Master-planned solution to development in this area will strengthen the Council’s position in terms of its ability to reject premature applications;

• A comprehensive approach to the future of the South East area is important, if the benefits of development are to be maximised, and if the necessary relationship between new homes, jobs and infrastructure is to be achieved;

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Ian Haynes 5 7 September 2010

• The existing Reserve Areas are an historic legacy of the Local Plan. The identification of these particular sites as development sites was not based upon a wider analysis of the whole area or an overall vision for the future, and background work on the capacity and principles for the SE SDA prepared to support the Core Strategy to date has already indicated that the Reserve Sites are not the only suitable development locations, and indeed may not in their entirety even be the best development locations;

• Development requirements will continue beyond the end date of the current Core Strategy. A comprehensive approach to Master-planning of the South East area can protect the Council’s ability to accommodate additional development in the future, whereas a piecemeal approach based on the existing Reserve Areas only will not;

• Retaining the South East Strategic Area as a broad Core Strategy location minimises the changes required to the existing strategy, and assists in a smooth transition to a revised Core Strategy.

Whatever scale of new homes and jobs is therefore settled upon as part of the wider review of the Core Strategy, we would ask the Council to retain the concept of a comprehensive approach to the South East area, even if the scale of development to be planned, the area covered, or even the terminology of the name of the Strategic Development Area, is refined.

I would be grateful if you could bring the above matters to the attention of the Advisory Committee before the 9th September.

Yours sincerely

Kevin Coleman Associate Director [email protected]

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Economic prosperity or a two speed city? Submission to LDFAG Core Strategy 9 September 2010

Milton Keynes unemployment 2000 to 2010

2,600 jobs would support 1,750 dwellings at 1.5 jobs per household or 40,000 extra jobs over the next 15 years. This is equivalent to an annual growth of 1.8%.

11,600 jobs were lost every year in Milton Keynes between 2003 and 2007 before the crash. Ref 3.1.2 MK Employment Surveys August 06 and July 08. An average 13,500 jobs a year were created. A growth rate of 1.6%.

6,420 Milton Keynes citizens are claiming Job Seekers Allowance or 4.0% of the working age population. This is higher than both the UK rate of 3.6% and the regional rate 2.5%

11,000 Milton Keynes citizens are unemployed according to the latest ILO figures or 8.5% of the working age population, This is higher than the national rate of 7.8%. The ILO definition of unemployment includes all people of working age who are willing and able to work but who are without work.

20,000 Milton Keynes citizens suffer employment deprivation or are “workless” according to the latest Index of Multiple Deprivation or 14.3% of the working age population. This is lower than the national rate of 15.4% but higher than the regional rate of 11.5%. Nine wards have workless rates higher than the national rate including Woughton 30% and Eaton Manor 27%.

21st Century Welfare published by the DWP sets out plans to move people from benefits into work. 11,000, possibly even 20,000, extra new jobs would be needed to achieve this transformation; the equivalent of 700 to 1,300 jobs every year for the next 15 years requiring an annual growth rate of 2.5%.

15,000+ new jobs would be needed every year from inward investment and growth of existing businesses to support 1,750 new houses, compensate for the loss of existing jobs and achieve major welfare reform; hence the priorities should be to develop and to implement a realistic programme for full employment(27) in Milton Keynes.

6 September 2010 L 100903 DJ I Haynes

Mr Ian Haynes Chief Spatial Planner Milton Keynes Council Civic Offices 1 Saxon Gate East David Jackson Milton Keynes E: [email protected] MK9 3HN DL: +44 (0) 1865 269 008 F: +44 (0) 1865 269 001

Wytham Court 11 West Way Oxford OX2 0QL DX 96205 - Oxford West T: +44 (0) 1865 269 000 savills.com

Dear Mr Haynes,

LDF Advisory Group: Submission on behalf of the South East Milton Keynes Consortium

We write on behalf of our client, the South East Milton Keynes Consortium, in relation to the proposed changes to the Core Strategy that were incorporated within the agenda and supplementary papers presented to the LDFAG on 26 August 2010. Before addressing the proposed changes, however, we are seeking a correction to the content of Supplementary Item 5 that also formed part of the papers for the 26 August meeting and this is explained below.

Supplementary Item 5

In Supplementary Paper 5 under the heading Policy Direction, paragraph 3.2 refers to the motion agreed by the LDFAG on 5th August. It states that the motion ‘points to’ a revised policy direction based on 5 items that are listed a)-e) in paragraph 3.2. The author of those 5 items has reworded the content of the motion in such a way that it does not reflect its original content or meaning. Given the Consortium’s interests in the SE Strategic Development Area, we are particularly concerned by item c), which states:

‘This (the lower housing target) means that the SE Strategic Development Area is no longer required as an allocation in the Core Strategy and that this area (other than the allocated Strategic Reserves) will retain the designation of open countryside that it has in the 2005 Local Plan.’

This interpretation cannot be derived from the original motion. The minutes of the 5th August LDFAG meeting contain the wording of the motion and neither in its draft or revised form does it make any reference to the SESDA. The only wording that is in the motion that could underpin item c), and then only the second part of it, is point 4 of the 5th August motion which states:

‘Reaffirms that other sites not contained within the existing Local Plan retain their status as open countryside and thus with a presumption against development.’

This part of the motion is of course a statement of fact in that it confirms the status of land that is outside of any allocation in the 2005 Local Plan. It does not in any way specify what the future status of the land within the SESDA (or any other location) should be in the Core Strategy. Nor could it as this process has yet to be completed and will be determined by a number of factors, including the overall housing requirement.

Item c) of paragraph 3.2 (and other aspects of the ‘revised policy direction for the Core Strategy’ as addressed below) has a direct impact on the Consortium’s interests. We have already expressed our views on the need for openness and transparency in the Core Strategy process. Allied to this must be a level of accuracy that ensures that the Core Strategy is founded on a robust and credible evidence base. We

Offices and associates throughout the Americas, Europe, Asia Pacific, (28)Africa and the Middle East. Savills (L&P) Limited. Chartered Surveyors. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 20 Grosvenor Hill, London W1K 3HQ a therefore request that the inaccurate nature of paragraph 3.2 in Supplementary Paper 5 is remedied as a matter of urgency. Indeed, for reasons set out below, we consider the need for a SESDA remains and its delivery should therefore continue to be safeguarded, including in the framework plans for the SRAs.

Core Strategy Proposed Changes

We have undertaken a detailed reading of the proposed text changes to the Core Strategy. Having read the relevant papers we understand the Council's desire to ensure that the Core Strategy continues to evolve and a planning policy vacuum does not as a result arise. Equally we welcome the message that Milton Keynes is open to business. However, for a number of technical reasons that we detail below we do not consider that the proposed changes will be acceptable to the Planning Inspectorate and as a result the Core Strategy will be found not to be sound. One way for the Consortium to respond to the proposed changes would therefore be to set out detailed amendments to the text that the Consortium consider would be necessary in order for the Core Strategy to be found ‘sound’. However, in its current form the proposed changes omit key elements of information that are fundamental to a sound Core Strategy. Without this basic level of information it is not possible to make a judgement on more detailed aspects of policy wording. In this letter we have therefore concentrated on the fundamental matters that need to be addressed by the Council in the first instance and the Consortium will wish to make more detailed submissions once these matters have been addressed.

Housing Requirement

The Housing Requirement for the Borough is defined in the Pre-Submission Core Strategy (February 2010) at Table 4.1 and states that ‘at least 41,360 new homes’ will be provided within the Borough between 2006 and 2026. Given the revocation of the South East Plan it is right for the Council to want to review this figure and establish from its own work what the correct level of requirement is, consistent with the ‘Localism’ agenda. Unfortunately the wording of the proposed changes does not specify a figure, instead it contains a series of question marks. PPS3: Housing advises at paragraph 3.3 that:

‘In determining the local, sub-regional and regional level of housing provision, Local Planning Authorities and Regional Planning Bodies, working together, should take into account: – Evidence of current and future levels of need and demand for housing and affordability levels based upon: • Local and sub-regional evidence of need and demand, set out in Strategic Housing Market Assessments …’

Reference to regional bodies is no longer relevant with the revocation of the RSS. Instead it now falls to local planning authorities to determine for themselves the level of housing provision for their areas based on the appropriate evidence. We note that although a figure for housing provision is not contained in the Core Strategy, a background paper on this matter has been produced and was tabled at the LDFAG meetings on both the 5 and 26 August. In Annex A five ‘broad options’ were put forward ranging from a minimum of 1250 dwellings p.a. and up to 3370 dwellings p.a. In relation to this Annex, the Consortium considers that both options 3 and 4 are misleading in that they identify only that element of the housing requirement that was planned to be provided within the Milton Keynes authority area and therefore omits that element that was to be accommodated in adjoining authorities. In total the requirement for the Milton Keynes urban area (including that component in adjoining authorities) was 48,850 (2,443 p.a.) in the RSS ‘Option 1’ and 49,950 (2,498 p.a.) in the RSS. It is these higher levels of provision (including that in adjoining authorities) that provide the correct benchmark measure for the assessment of the housing requirement for Milton Keynes.

Notwithstanding the availability of these ‘broad options’, the motion of the 5 August refers to a lower range of housing target being adopted of ‘no fewer than 1500 dwellings and no more than 2000 dwellings’. This position is clearly not derived from any of the broad options presented to the LDFAG and cannot therefore be said to be ‘evidence-based’. Instead it appears to be drawn from a projection that is loosely based on past completion rates (similar to Option 2). Indeed of the ‘broad options’ identified only Option 5 draws on the Strategic Housing Market Assessment (as referred to in PPS3, para 3.3) and this supports provision for new housing at a level of 3370 dwellings p.a. The disparity between the evidence base and the resolution of 5 August is stark. The range of 1500-2000 dwellings p.a. is unacceptably low and should not therefore be included in the Core Strategy. Instead the Council should address this fundamental issue in detail drawing on a reliable evidence base, starting with the SHMA.

Page 2 (29)

a On a related matter, the scale of the housing requirement cannot be fixed to the provision of new jobs in the way sought by the 5 August motion. This matter was addressed during the South East Plan EiP and the Panel concluded that:

‘We agree that to use the ratio (that between jobs and new homes) as a development control tool … would be counter to the intended certainty provided by the new system of housing trajectories, PPS3, para 63, and could provide a disincentive for economic investors.’ (SEP Panel Report, paragraph 23.20).

The Panel’s conclusion remains valid and the Core Strategy should not therefore include any such fixed ratio for development control purposes.

Capacity of Sites

As with the overall housing requirement, there remains considerable uncertainty in the wording of the proposed changes as to what level of housing provision is to be made at particular sites. Referring to Table 4.1, this again contains a series of question marks instead of specifying what the capacity of the Strategic Reserve Sites is. This omission is repeated later in Policy CS5, although we note that paragraph 5.14 retains reference to the capacity of the SRAs being 2,500 dwellings. A similar omission exists in relation to an assessment of the capacity of development on existing Local Plan sites. This was previously assessed at 34,160 dwellings in Table 4.1, but now is deleted in the revised form of that table in the proposed changes.

The failure to identify the capacity of existing allocated sites means that a key element of the spatial strategy for the Borough is flawed. In addition, it is because of the persistent uncertainty over the scale of overall housing requirement for the Borough, coupled with the uncertainty over the capacity of Local Plan sites (including the SRAs) that it is not possible for the Council to state that there is not a need for the SESDA (or indeed other sites). This gives further support to the Consortium’s submission that the text in Supplementary Paper 5 paragraph 3.2 should be deleted, notwithstanding the fact that it does not reflect the wording of the 5 August motion (as referred to earlier). Indeed, it is noted that where Footnote 34 of the Pre-Submission Core Strategy stated ‘total existing developable supply is 34,426, exceeding the SEP minimum requirement’ the proposed changes states only that this text is ‘to be reworded’. This uncertainty, like other matters relating to both housing demand and land supply, need to be resolved if the Core Strategy is to be ‘sound’.

Employment Land Requirement

As with the housing land requirements, the same omissions are made in the proposed changes in relation to employment requirements. Paragraph 5.19 of the Core Strategy as proposed to be changed does not state what the jobs capacity of existing employment land in the Borough is (previously stated to be between 29,000 and 45,000 jobs). Nor does paragraph 5.20 state what number of jobs is required by 2026 (previously stated to be approximately 70,000 jobs). The proposed changes to paragraph 5.20 state that ‘the Core Strategy seeks to continue the current Milton Keynes employment growth rate of 1.5 new jobs per new home’. However, without an explicit statement of how many new homes are to be provided, this ratio of itself does not resolve the uncertainty. Nor is there an evidence base to justify this ratio being maintained – the text merely states that this has been the long term average, which is not in itself a justification for the approach.

Infrastructure Delivery Plan

One effect of maintaining the ratio of creating 1.5 new jobs for every new home would be the continuation of high levels of in-commuting to Milton Keynes. Under the SEP this issue was in part addressed by lowering the level of job growth to an equitable 1 job for every new home built. However, if the ratio in the proposed changes is to be maintained then commuting levels are likely to increase. The Core Strategy will therefore need to demonstrate how that strategy is to be accommodated in terms of the capacity of existing or new transport infrastructure as required by PPS12 paragraph 4.8. PPS12 requires not only that the infrastructure to support the spatial strategy (physical, social and green infrastructure) be identified, but also who will provide the infrastructure and when it will be provided. These matters are not addressed in the proposed changes to the Core Strategy and the document is not therefore sound. An infrastructure delivery plan is therefore required to support the Core Strategy.

Page 3 (30)

a End Date of the Core Strategy

PPS12, paragraph 4.13 states:

‘The time horizon of the core strategy should be at least 15 years from the date of adoption.’

Given the present circumstances there remains considerable uncertainty as to when the Core Strategy might be adopted. The Discussion Paper ‘What next for the Core Strategy?’ (included in the papers for the 26 August LDFAG meeting) at Annex B defines a number of scenarios of how preparation of the Core Strategy may proceed and on what timescale. Only in one scenario – referred to as ‘Refresh’ – could the Core Strategy possibly be ready for submission by the end of 2010. In all other scenarios the Core Strategy is not ready for submission until the end of 2011 at the earliest.

The review of the Core Strategy that is now taking place following revocation of the RS goes beyond what might be considered a ‘refresh’ process. It is clear therefore that submission of the Core Strategy will not be achieved during 2010 and adoption will be well beyond that. In these circumstances the present end date of the Core Strategy at 2026 is inadequate and it should therefore be extended to 2031. You will appreciate this necessary change will have implications for many of the items referred to earlier in this letter.

In light of the above, the Consortium considers that these fundamental issues need to be resolved before a more detailed assessment of the text of the Core Strategy is appropriate. In that context I trust that these comments are useful, but please do contact me if you have any questions. We would be pleased to put these matters directly to the meeting of the LDFAG on 9th September.

Yours sincerely

David Jackson MA MRTPI Director

cc: Consortium Principals

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8 September 2010

Councillor M Galloway Cabinet Portfolio Holder: Environment and Planning Milton Keynes Council

Dear Councillor Galloway

LDF Core Strategy: what next?

Milton Keynes Forum Committee has followed closely the LDFAG’s recent deliberations about the consequences for the Core Strategy of removal of the Regional Spatial Strategy and its housing targets. We understand why Members are considering reductions to housing numbers and possible deletion of some development areas. While we understand the general thrust of what has been proposed, we are concerned that the changes have not been based on a rigorous assessment of evidence that is needed to make these kinds of decision.

We consider that making changes to the proposed provision for housing in the Core Strategy in isolation from a wide range of other issues such as employment, shopping provision, transport and CMK will lead to a flawed Strategy. Changes of this kind need a robust evidence base and we think this is currently lacking.

Having given careful consideration to the LDFAG’s recent deliberations on possible changes to housing targets and development areas in the Core Strategy, we consider that:

1. The vision for the future of MK has yet to be adequately developed. This is needed if we are to be clear what the scale and shape of the city should be. The way forward therefore needs to depend on a proper analysis of what kind and size of city we want to be. 2. A more fundamental review of the development of MK is needed that gets much closer to an understanding of the kind of place MK should aim to become, and which is capable of generating new confidence to investors, entrepreneurs, businesses, organisations, incomers and current residents. The message that

(34) the Council now risks giving, to those interested in MK as a place to develop, is that we have lowered our aspirations. The consequence could lead to a loss of important opportunities for MK people.

However, we recognise the difficulty of the decision for the Council, in not wishing to delay the adoption of the Core Strategy further, in light of the vacuum created by the revocation of regional spatial strategies. There is no ideal way forward, with each of the options available to the Council having drawbacks. We further recognise that it is five years since the process started that has shaped the Core Strategy.

We have therefore concluded that, if the Council decides that the best option is to take forward the current draft of the Core Strategy now being considered at the LDFAG meeting, that this should be regarded as an ‘interim position’. The entire document should then be reshaped in the light of the Council's new power to achieve a new core strategy that truly reflects 'the kind of city we want'. The nature of that rethink will require at least two more years to complete the statutory process. We think that the Council should therefore make an absolute commitment to start the review process now, with the aim of having a final draft of a replacement Core Strategy available by the end of 2012.

We would be pleased to discuss these matters further with you, the LDFAG and the Cabinet.

Yours sincerely

Andrew Thomas Secretary MK Forum

For Milton Keynes Forum Committee

CC Ian Haynes, Chief Spatial Planner Gavin Lane, Senior Committee Manager MK Forum Committee

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David Hill, Chief Executive Milton Keynes Council Civic Offices 1 Saxon Gate East Central Milton Keynes MK9 3EJ

17 August 2010

Reference 100375D

Dear Sir

Milton Keynes Local Development Framework, direction following revocation of the South East Plan.

I write on behalf O&H Properties Ltd, Burford Group, Merton College Oxford and Wavendon Properties Ltd (The Landowners) who own over 210 hectares of land forming part of the emerging South East Milton Keynes Strategic Development Area. The Landowners have been engaged with the planning process for Milton Keynes for a number of years, resulting in the identification of the strategic development area and its continued recognition as a suitable location for the growth of Milton Keynes. This letter relates to the recent meeting of the Council’s Local Development Framework Advisory Committee on 5 August 2010, the results of which have given rise to serious concerns over the decision-making process in relation to the future of the Council’s Local Development Framework (LDF).

The Government is currently introducing changes to the plan-making process which have created some uncertainty over the future of the LDF. As part of the Government’s plans to devolve strategic decision making to the local level, Regional Spatial Strategies (RSS), which formed the strategic tier of planning policy, were revoked on 6 July 2010. Strategic policies relating to the level of growth, including housing numbers, which were once set within the RSS are now the responsibility of the Local Planning Authority.

The Landowners recognise that in light of these changes to the plan-making process the Council may wish to take stock of its position and reassess its priorities in terms of the levels and likely locations of growth and development in and around Milton Keynes. However, if there is to be trust in that process, the decisions made and the policies that arise from it, it is imperative that it is open and transparent, with opportunities for interested parties to be fully involved.

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A meeting of the LDF Advisory Group was held on 5 August 2010. The agenda for that meeting contained item 8, ‘What Next for the Core Strategy?’, which included a report advising on the broad options for the future of the core strategy. The officer’s recommendation to the advisory group was that the group note the report and that a detailed discussion of the available choices would be held at the next meeting of the group, currently scheduled for 26 August.

At the start of the recent meeting a motion was put forward by Cllr Hopkins. The detailed motion, addressing a number of strategic planning matters was not included on the agenda for the meeting and it is apparent that other members did not know about the motion beforehand. The original officer’s report took a measured approach to determining the level of housing growth, highlighting that whatever level of housing growth is decided, it will need to be supported. The motion, while recognising the need for a formal review of housing delivery, goes on to set a range for housing delivery. In particular we refer to the following, from paragraph 10 of the motion:

“…MK commits to a delivery of no fewer than 1500 dwellings and no more than 2000 dwellings from 2014/15 onwards as long as (and only if) a guaranteed 2250 and 3000 new jobs respectively can be assured each year.”

It is understood that the motion was debated at some length and eventually carried, subject to some unspecified ‘small amendments’ and is now informing work at an officer level. Clearly the motion and, in particular the part quoted above, will effectively set the council’s planning policy agenda for the foreseeable future, disregarding the council’s existing evidence base and public consultation carried out to date.

One of the main intended implications of the Government’s revocation of RSSs is to remove centrally imposed housing targets and to allow local areas to determine their own levels of growth. While this is ostensibly the purpose of the motion tabled by Cllr Hopkins, it has been made clear in government guidance, issued at the time that RSSs were revoked, that Local Planning Authorities must still justify housing numbers in planning documents. The guidance highlights the importance that the planning process remains transparent and that the reasoning behind specific decisions can be understood. For all LDF documents it also remains a national requirement that the preparation of LDF documents is supported by a robust evidence base and public consultation.

Given the new emphasis on localism and locally derived targets for housing, it is arguably more important than ever that such decisions are made in an open, transparent and well-reasoned fashion and are supported by a sound evidence base. A failure to adhere to these core principles will erode confidence in the plan and decision making process and create uncertainty for both the public and the business sector at a time when economic growth and investment is under threat.

The Landowners are gravely concerned that with the passing of Cllr Hopkins’ motion on 5 August, he and the members of the LDF Advisory Group have acted in a manner which is inconsistent with national government guidance relating to the production of Local Development Frameworks. Part 10 of the motion effectively sets housing

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figures for Milton Keynes in advance of the systematic review of housing need that is required under standard LDF procedures, recent Government guidance and by part 5 of the motion itself. The content of the motion is, therefore, also likely to prejudice the outcome of any review. We consider that this approach is potentially procedurally flawed, and could leave the Council open to legal challenge.

By agreeing Cllr Hopkins’ motion the LDF Advisory Group has made decisions, which may have major ramifications for the future of the district. This has been done in advance of an appropriate evidence base being available, and without appropriate opportunities for consultation and debate. The decision also disregards the existing evidence base prepared in support of the Core Strategy, which was at a sufficiently advanced stage to be due for submission to the Secretary of State for Communities and Local Government for examination this month. The motion was so fundamentally at odds with the officer’s recommendation of a more measured approach, and on such a major topic that we consider it unreasonable that it can be allowed to influence future policy in this way.

Given the potential long term implications of any change to the LDF we urge the council not to act in haste but to ensure that correct procedure is followed in preparing any update to the LDF, and allow decisions on the future of Milton Keynes to be informed by evidence and made with opportunities for open debate.

Yours sincerely

Ronald Gorman Co-Founder

Cc Nick Fenwick, Assistant Director of Planning Cllr Cec Tallack, Leader of the Council

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SUBMISSION TO MILTON KEYNES LOCAL DEVELOPMENT FRAMEWORK ADVISORY GROUP MEETING on 9th September 2010 By Roger Turnbull Director of Apt Planning Ltd acting for Realmoak Properties Ltd and Corran Wakefield Estates Ltd.

1. The draft Core Strategy circulated with the agenda proposes a revision for page ii that states that the scale of growth planned for Milton Keynes is the highest for any city in the south east outside London, and hence in any new development areas outside the MK Council area, the Council will need to work with its neighbouring authorities to make sure these areas function well as part of the city. 2. The Report’s recommendation of a target of 1,750 homes a year, or 28,000 dwellings 2010-2026, is justified on the basis that there should be no growth of Milton Keynes beyond the urban area and the Local Plan Strategic Reserve Areas. 3. I would support Option 3 for 2,000 dwellings per year, a target of 32,000 dwellings, because the requirement for additional land does not arise until 2021. This should provide sufficient time to “work with our neighbouring authorities to make sure these areas function well as part of the city,” as proposed in the latest revision to page ii of the Core Strategy. 4. Without Option 3, there is no incentive or need for neighbouring authorities to work with Milton Keynes Council over the next 10-15 years, because there would be no development areas outside MK Council area. 5. Without Option 3, any work with neighbouring authorities would be delayed for 10-15 years, which would provide insufficient time to plan for longer term development outside the MK Council area. 6. Option 3 would better recognise that Milton Keynes is one of the most sustainable locations for development in the south east, whose residents have immensely benefitted from the infrastructure and community facilities associated with its Growth Status. A reduced housing target in Option 2 is likely to be reflected in reduced infrastructure and community facilities. 7. Option 3 appears to be achievable because Figures 1 and 2 of the Report forecast 1,976 dwellings per year in the Urban Area alone (9,882 dwellings) in the 5 year period 2011/12 to 2015/16, which with the 110 dwellings per year in the Rest of the Borough, exceeds the Option 3 target of 2,000 dwellings per year by 86 dwellings. Paragraph 6.18 of the Report argues that forecasting in the early part of the trajectory should be more accurate and an optimism bias is not necessary. 8. Conclusions I therefore urge Members to support Option 3 on the grounds that:

(i) It is more likely to encourage neighbouring authorities to start working with Milton Keynes Council on longer term development after 2021 outside the MK Council area. (ii) Better recognises the sustainable location of Milton Keynes, and the benefits to residents in terms of new infrastructure and community facilities. (iii) Appears to be achievable based in the forecasts in Figures 1 and 2 of the Report for the period 2011/12 to 2015/16, which the Report states is likely to be more accurate than later periods.

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