LDF AG MEETING: 9 SEPT 2010 SUMMARY of THIRD PARTY REPRESENTATIONS (As at 4.00Pm, 8.9.10)
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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 Woburn Sands & 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 Wavendon 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 Milton Keynes 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 - Bletchley 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 (3) 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.