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Draft Salden Chase Masterplan and Delivery SPD, January 2010Response from Milton Keynes Council

SALDEN CHASE MASTERPLAN & DELIVERY SPDCONSULTATION DRAFT, JANUARY 2010

COMMENTS FROM MILTON KEYNES COUNCIL

1. Background/ general comments

1.1 Milton Keynes Council’s Cabinet on 16th February 2010 agreed a report setting out the broad issues that a subsequent detailed response would address.

1.2 The SPD represents an opportunity to set out an ambitious strategy to guide the development of this important site especially given its role as an extension to a forward thinking city like Milton Keynes. An overall criticism of the document is that it is not sufficiently challenging; many of the statements and principles within it are generic and not place specific. Whilst the opportunity to comment on the SPD is welcomed, it would have been preferable to have produced a jointly prepared SPD, endorsed by both authorities.

1.3 The SPD would benefit from more illustrative material to demonstrate more clearly what is being proposed. Plans that show the location of the site in relation to the wider Milton Keynes area, together with links to public transport routes would help to establish its context. Equally, cross sections and illustrative drawings of key locations within the SDA, such as the local centres and the main distributor roads would help to show how the development might look.

1.4 Additionally, the SPD defers decisions on some key aspects of the development to further studies, for example the Transport Assessment. To improve clarity at this stage in the process, the SPD should be more prescriptive as to the key principles, including, for example the extension of the grid road network into the site and the treatment of Whaddon Road.

1.5 MKC’s response includes detailed comments on each section of the draft SPD, but we would like to flag up the following general issues:

(a) Emphasis within the SPD, the role of the SDA as a sustainable urban extension to Milton Keynes

(i) The relationship of this site to the urban area of Milton Keynes and Bletchley continues to be underplayed. Fundamentally, if there was no Milton Keynes there would be no SDA. SEP Policy MKAV2 is quite clear that the SDA is a new sustainable urban extension to Milton Keynes.

(ii) Establishing the role and function of the site is key to establishing its character and the standards to be applied to the development.

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(b) Place shaping – what sort of place is to be created, what will it look like and what will it be like to live in?

(i) Vision needs more clarity as to character of the SDA

(ii) Needs to reflect MK as an ambitious, forward thinking city

(iii) SPD needs to address the site’s location at a key gateway to MK

(c) Travel and transport

(i) Reducing the need to travel should be integral to the key development principles

(ii) The Transport Assessment must look at and deal with existing issues and sustainable travel as well as addressing the potential impact of the new development.

(iii) Key Development Principle SC15 in the SPD sets out a number of requirements to be addressed in the Transport Assessment. The inclusion of requirements for a reserve within the site for a route for a link road between the A421 and the A4146 is welcomed. Scenarios of the Milton Keynes transport model that include the provision of this link road have been run by the developer as part of the work on their Transport Assessment. The outcome of this work is not yet known.

(iv) In terms of connections with the surrounding area, the SPD needs to address north-south links to Snelshall and Tattenhoe Park and more clarity is required for the links to Far Bletchley and beyond.

(d) Sustainable construction and renewable energy

(i) Standards in the SPD should be higher to reflect those applied in Milton Keynes and include a local carbon offset mechanism.

(ii) Land use budget and infrastructure schedule need to make allowance for energy centres and/ or combined heat and power provision

(e) Community support and development

(i) Omission of reference to community support for the new residents in the SPD. Community support and arrivals work in the expansion areas is delivered by the MK Council for Voluntary Organisations and is

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supported through the Tariff. This approach should be rolled out into the SDA.

(ii) Lessons learned from previous development in Milton Keynes could usefully inform the SPD

(f) Infrastructure requirements, costs and delivery

(i) Standards used to assess the amount of on-site infrastructure need to reflect those applied by MKC as well as by AVDC. For example, reserve sites are used in Milton Keynes, but not in Aylesbury Vale.

(ii) Where there is a difference in the levels of provision required by each authority, this should be flagged up and discussed

(iii) Phasing of delivery of key infrastructure items e.g. schools requires careful cross-boundary liaison

(g) SPD preparation process and engagement

(i) Need for ongoing engagement through the formation of a stakeholder group

1.6 These broad points are picked up in detail in the following table which comments on the SPD chapter by chapter.

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Detailed comments

Para / section MKC comments PURPOSE OF DOCUMENT

A 2.1 &Para 1.3.1

Who produced this document and Joint working between authorities: Early drafts of the SPD were prepared with input from officers from AVDC, Bucks CC and MKC. There were discussions around the production of a jointly prepared and jointly agreed SPD. MKC favoured a draft that included scenarios or posed questions to seek views where the MKC standards and approach differs from that common to AVDC and Bucks. The potential extension of the grid road network into the site is one such example.

The version of the SPD considered by AVDC’s Environmental Scrutiny Committee on 10 November had, however been amended to reflect the AVDC ‘house’ style of SPD, and moved away from a jointly produced document. MKC held a workshop for local councils, Members and residents’ associations on 16th November 2009 where the Working Draft SPD was considered. Parish councils and Members within Buckinghamshire were involved to attend the workshop but all declined, so those attending were drawn solely from the Milton Keynes area. Detailed comments made at that workshop were sent to AVDC on 18 November and we are grateful for the opportunity to comment. The layout of the final draft SPD has been further amended, with some sections removed (notably the opportunities and constraints section (see our comments on Page 17 below) and others relocated.

The consultation draft is therefore considerably different to the initial version into which MKC had an input. It would be more accurate to state in para A 2.1 that “This document has been produced by Aylesbury Vale District Council, Buckinghamshire County Council and Aylesbury Vale Advantage. Milton Keynes Council contributed to early drafts of the SPD. “

Para 1.4.3 Prior to the submission of reserved matters, a Design Code/s should be produced (a single design code for 5400 homes is probably too much – rather a design code per phase (approx 1000 homes) should be done. The reserved matters will therefore be based on the Design Code

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The final paragraph refers to public and stakeholder involvement. This would be a good place to refer to the establishment of a cross-boundary stakeholder group for Salden Chase, incorporating local councillors, parishes and residents’ groups/ local stakeholders from both sides of the administrative boundary. A statement to confirm the role of such a group should also be added to the SPD – ie initial role could be information sharing and awareness-raising with the group’s role evolving to include comments on design codes / planning applications over time.

Diagram 2, p7 In line with the above comment Diagram 2 should include a box for design codes. The stakeholder group could be added to the table to show how it fits with the process.

VISION

Vision overall The overall feeling is that much of the vision and principles could be applicable to any greenfield development anywhere – they need to be more specific to the site.

While it is acknowledged that this is a strategic document, with much detail to follow, it is a key policy document and some elements of the development will be controversial. A decision should therefore be taken at this level, for example, on whether grid roads would be included (and if not the nature of the loop distributor road), the role the site plays as a gateway into MK, what a distinctive development means.

MK is a modern city that is unique, ambitious and forward looking– this is not acknowledged nor reflected in any of the principles (especially as it is an urban extension). We appreciate that whilst we should not be seeking to ‘roll out the carpet’ there is a missed opportunity to identify the best features of the original city and consider how these can best be incorporated into the design of this site.

Aspirations for sustainability and construction quality of the development at Salden Chase should include innovation in, for example, the application of low carbon technology and should

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reflect MKC’s aspirations as expressed in the Pre-submission Core Strategy (see Strategic Objective 10: “To mitigate the Borough’s impact on climate change and reduce CO2 emissions through:

Implementing higher than national requirements for sustainable homes and buildings Locating development away from areas of flood risk Promoting community energy networks and strategic renewable energy developments Reducing waste generation and increasing the amount of recycling Sustainable transport initiatives” )

The SPD is not a masterplan in the urban design sense of the word and should not be referred to as such. It is more a Development Framework.

The document is not sufficiently challenging or ambitious. It sets out standard practice and in some cases it does not even go that far. In terms of transport we have an opportunity to create something very much more geared towards both the reduction of travel and more sustainable travel. Reducing the need to travel should be given much more prominence as this is much more sustainable than travelling even by non-car modes.

The MK context is also ignored in the sense that Bottledump and Tattenhoe Roundabouts represent key gateways into MK, yet the SPD does not mention them as key gateways nor does it provide guidance on how this role should be addressed. Again this might be controversial but the SPD should offer some guidance as to what is required.

Another general point is the view that this is an extension to MK. Whilst it is currently geographically in Aylesbury Vale, its identity and form must reflect MK. This is also relevant to the planning of infrastructure and the key transport links. Access to the site and the major internal links should be designed to standards that reflect the requirements of MKC. This point is relevant to the provision of on-site and off-site redways and leisure routes also.

The document makes several references to a “Transport Impact Assessment” – a small point, but the

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correct terminology is ‘Transport Assessment’ (TA). The assessment should look at and deal with existing issues and sustainable travel etc. as well as looking at potential impacts.

2.1.1 Vision statement in bold: The first sentence in the box must say, “To create an exemplar sustainable urban extension to Milton Keynes, of regional significance….” As our point above, the site is located at a key gateway into Milton Keynes on the A421. There should be some acknowledgement of this and consideration as to whether or how this gateway function should be addressed in the design of the site.

2.1.1Vision outcomes: (b)

Vision outcome, b) should include reducing the need to travel. Homeworking, high quality in-home IT connections and provision of local internet access and business starter units all reduce travel needs. Retail collection and delivery boxes also avoid the need to travel longer distances.

Also, what is going to be considered to be “the earliest appropriate opportunity”? 50, 100, 250 homes etc

c) Are the public transport contributions going to be divided between bus and E-W rail, or is the rail contribution going to be assessed separately (ie is the bus contribution going to be ring fenced)?

(d) The vision should say that the movement network is to be structured around providing shortest most direct possible routes to local centres, facilities and services

(g) Vision outcome g) and SC2 vii are contradictory in that on the one hand the identity of Newton Longville is to be protected yet on the other hand the development must respect the best characteristics of nearby villages

Site context

General Although the allocation of a travellers’ site at the Bottledump roundabout is referred to in para 1.2.8 there should be further mention of this in the Site Context section and in the Key Development Principles section

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as it is a constraint which needs to be recognised and planned for in the development of the site.

The Site Context section would benefit from the inclusion of site photos

Within the Site Context a plan is needed to show the wider context ie connections to Central Milton Keynes and the key, cross-city public transport routes as well as more detail of the transport links – ie to Tattenhoe Park and into Far Bletchley. The plan should show local and strategic links including links to redways; the site’s relationship to the rest of MK and the grid road network; public transport routes etc

Figure 3.2 Fig 3.2 is an important plan as it represents the Site Analysis (in part) but it is too crude and unclear

Page 17 At the end of the Vision and Site Context sections (pg 17) there should be an ‘Opportunities and Constraints’ Plan produced (which is informed by the Vision and Site Context)

Constraints should include, amongst others: The oil and gas pipelines crossing the site Noise implications of a reopened East-West rail link Existing developments and allocations eg the travellers’ site at the Bottledump roundabout.

Development Principles

Omission Addressing environmental impacts: Noise - the SPD doesn't seem to mention noise impacts of the development (particularly the construction phase) on MK residents, nor the potential impact of traffic and industrial noise from within MK (eg from existing industry at Snelshall) on residents of the new development. Air Quality: The draft SPD does not mention any requirement to assess the impact of the development on air quality. SC15 discusses the need for a Transport Assessment because of the increase in traffic on

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roads within Milton Keynes and Aylesbury Vale.

Consequently, for a development of this size an Air Quality Assessment should also support the planning application.

SC1 SC1 and SC2 both emphasise the need for a development with its own unique identity. This is an important statement but needs to be elaborated on. This identity can be achieved through the nature of green infrastructure, layout of streets and blocks as well as the detailed design appearance of buildings. While this is only an SPD and more detailed documents will elaborate on this statement, some key points should be made such as: Are grid roads to be included and importantly is more contemporary architecture encouraged? The latter can be a controversial point and therefore something should be said in the SPD on it. Since this is a greenfield site contemporary architecture should be sought particularly along prominent frontages, while more traditional forms can occur on the southern rural edges.

SC2 Reducing the need to travel should be a key part of SC2.

In the opening paragraph specific mention of the need to consider the setting of the Newton Longville conservation area is a little out of balance, given that there is no similar mention of the need to consider the impact on the amenity of the established residential area of Far Bletchley.

Point vii: it is unclear why the palette of materials should reflect the best characteristics of Buckingham. It would be more relevant for this development to reflect the best of contemporary development within Milton Keynes and to gradually soften this towards the western and southern edges of the site by blending with a palette more characteristic of the surrounding rural villages.

SC3 Some flexibility needs to be worked into the layout of the site, especially in relation to the local centres, should the railway station associated with East-West Rail not be delivered for any reason.

This and other risks to delivery should be addressed in a Risk Management section in the Delivery and

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Implementation chapter.

SC5 SC5 should include local internet access, business starter units, delivery/collection points, an IT hub

SC6 This principle states that all development in the SDA should help to support and enhance the overall viability of Aylesbury Vale. We consider that this is unbalanced as it fails to recognise the relevance of the SDA to supporting employment provision within Milton Keynes. SEP Policy MKAV2 is quite clear that the SDA is a new sustainable urban extension to Milton Keynes. The SDAs are also intended to be locations where some new employment provision for Milton Keynes should be provided. SEP para 23.13 states that in order to accommodate the additional jobs it is assumed that additional employment land will need to be provided as part of the sustainable urban extensions.

SC7 & SC42 This principle requires a minimum of 7ha of employment land to be provided on-site. This figure is less than half that originally considered necessary for the SDA by GVA Grimley (15ha net) and there is no explanation as to how this figure has been derived. The figure produced by GVA Grimley is based on a target ratio of 1:1 new jobs to homes, as per the SEP (para 23.7) which would result in a requirement of 5,390 new jobs. We acknowledge that this is a Borough wide target and not all those jobs will be provided within the SDA, however, the provision of only 7ha falls well below what should be provided. The shortfall is even more marked when considered against the jobs: homes ratio in Milton Keynes which is 1.5:1.

A recent planning application for a B2 use in Milton Keynes1 has highlighted that although the city has a good stock of employment land, there appears to be a lack of affordable, large-scale employment sites (4-5ha). The limited amount of employment land proposed for the SDA would not help to address this deficit.

Although the employment budget is expressed as a minimum, we have concerns that the capacity of the site is limited (see our statement for the AVDC Core Strategy Examination) and this would allow little room

1 See Development Control Committee report, 18 February 2010: http://cmis.milton-keynes.gov.uk/CmisWebPublic/Binary.ashx?Document=29363

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http://cmis.milton-keynes.gov.uk/CmisWebPublic/Binary.ashx?Document=29363


for manoeuvre to increase the amount of employment floorspace on-site. Our representations on the AVDC Core Strategy have suggested that additional land could be identified to the north of the A421.

SC9 More needs to be said on density. Whilst point iii is welcomed, it is unclear as to what is meant by “Densities should be mixed between……”. This is an important point as today far too much housing is built at the narrow range of approximately 30-40du/ha whereas the ranges proposed in this SPD are much broader which is positive. The problem however is the word ‘mixed’. This is too vague as it might mean that 90% is in the medium range. The wording should say an equal split in terms of the 3 ranges is required.

SC11 & 12 Should reflect MKC standards that justify a 20% renewables target, and require all buildings to be zero carbon i.e. Code level 6 or equivalent, including those before 2016.

Section 4.4 Links to the rest of MK: The north-south provision (or lack of it) is a serious omission; links to Snelshall and Tattenhoe Park need to be made and shown on plans. It may be that new underpasses are required and that new redways or leisure routes are required beyond the site; this should be reflected in the SPD and in the infrastructure schedule. Similarly the link to Far Bletchley needs more clarity and the routes within Far Bletchley need auditing and improving where required.

This section should refer to the Bletchley transport study which MKC is about to commence. In response to local concerns of traffic issues in the Bletchley area, MKC Cabinet in November 2009 requested officers to develop a study brief to assess a longer term transportation strategy for Bletchley recognising the inherent pressures from major developments to the South and South West of the town. The Study will provide a transport strategy which will consider issues including the Southern Bletchley Bypass/distributor route; the creation of more car parking areas; Traffic congestion issues: Public Transport improvements including provision of new bus station in Bletchley; links to East West Rail (Bletchley Station)

The study is to be completed by July/August 2010 and will be reported to Cabinet in September 2010 and

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will link to ongoing work on the Transport Assessment for the SDA

Para 4.4.2 This mentions the need to consider extension of routes such as grid roads, redways etc, but no decision is taken. It is unclear as to how this will be progressed.

SC15 SC15 also needs to mention reducing the need to travel

SC15 (x) and SC21 - these seem to perpetuate the idea that the bus services from the development will link onto the end of East-West bus, something that has been thought to be undesirable because a route via Westcroft and Shenley Wood will give an extended and unattractive journey time to CMK compared to the route shown in the developers TA.

SC17 & 19 Pedestrian and cycle routes should wherever possible be part of the street network rather than segregated from other routes, to ensure safety and convenience.

SC18 SC18 should start with reducing the need to travel before going on to modal shift. There is no mention of car free proposals, car share clubs, car pooling. On-site provision should be made for a ‘travel shop’ that provides an information point for travel info and has a car pool, cycle pool and other facilities within it. These requirements should also find their way into the infrastructure schedule at the back.

SC20 Public Transport is not dealt with in nearly enough detail. Bus routes within the site and routes to/from other major nodes should be shown in the SPD, siting of stops at schools and local facilities within the site should be clarified. Rail provision does not feature in the infrastructure schedule and there is no clarity or certainty around the provision of a station. This would be very influential on the layout of the site and must be clarified before masterplanning takes place. It needs to be established whether the layout can achieve the aim of 400m distance from bus routes.

The reference to Park and Ride should cross refer to the frequency of service and requirement for contributions as set out on p46 in the Infrastructure schedule

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SC20 attempts to be prescriptive but in doing so is not prescriptive enough: 1. points (i) and (ii) - what about buses on Sundays? 2. point (iii) - what are the key destinations within AV and MK? 2.1.1 (b) (page 8) includes Newton

Longville and (iii) includes Westcroft. The developers TA work does not mention anything other than services to Bletchley and CMK (ie no bus service to Westcroft and no direct links to other places such as Buckingham).

3. point (i) - is this level of frequency meant to apply to all routes from the site from day one or will it be phased?

4. SC20 makes no reference to standard of vehicle other than “disabled access” which is more or less standard now anyway.

5. SC20 makes no reference to level of frequency for the Park & Ride bus service.

SC21 The location of the Park & Ride site has not yet been fully tested and therefore it is unclear if the proposed site is viable. Furthermore, it is not proven that a 2ha allocation is sufficient for the level of parking, landscaping and facilities that would be provided. On site facilities are not mentioned in the SPD and it is important that a high quality waiting and information point is provided, also incorporating security, toilets etc.

Whaddon Road: MKC experience of other similar situations (Walton Road, Wavendon; Whaddon Road, Kingsmead) is that making such routes more tortuous and sending them through housing developments may have some impact on traffic volumes, but has a very negative impact on the dwellings along the route. We see no reason why Whaddon Road should not stay open on its current alignment but with traffic calming features and other ‘events’ (such as the creation of the local centre) to discourage high volumes (and speeds) of through traffic.

SC22 SC22 - point (iii) traffic calming on bus routes should be avoided and roads used by buses should be designed for full size buses (2.55m wide x 12.5m long) as a minimum.

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Section 4.5 Community

This section and the associated key development principles (SC23 – SC 27 incl) deal primarily with the provision of community facilities and the built form.

SC24 refers to maximising opportunities for community cohesion and while this is welcome, it is to be achieved again through the built form. There is therefore a lack of reference to community development and support for new residents along the lines of the model used in Milton Keynes. Community support and arrivals work in the existing Milton Keynes expansion areas is delivered by the MK Council for Voluntary Organisations and is supported by the Tariff. One area of work is the establishment of an arrivals programme for the expansion areas to provide links and support to new residents. Given the cross-boundary nature of this site arrivals work is likely to be all the more important to ensure that new residents are aware of who to contact for services and are able to access them easily.

Reserve sites: In order to provide for community needs that cannot be foreseen at the outset of the planning process, Milton Keynes has historically required reserve sites as part of major developments. These are small sites in residential areas that are left undeveloped for a number of years and can be used to accommodate uses such as sheltered housing, meeting places, health centres, places of worship etc. Policy C9 in the Adopted MK Local Plan requires provision of reserve sites to a standard of 0.75 ha per 1000 population. The reserve sites can be transferred back to the developer if they are not required after a set period of time eg the MK Tariff includes a release date for reserve sites of 10 years from implementation of the planning permission.

SC26 Salden Chase directly adjoins Milton Keynes. It is close to the Western Expansion Area which will see 5,232 dwellings being built with 5 new schools planned. (4 primaries and 1 secondary). To the south east of Salden Chase, there is a development of 1650 houses at Newton Leys, Milton Keynes. This development will also include a primary school.

Therefore within a small geographical area, both Buckinghamshire County Council and Milton Keynes

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Council will each see around 6 new schools over the next 15 years. There must be a co-ordinated approach between Children’s and Young People’s Services at MKC and Buckinghamshire County Council to manage this increase in provision in order to ensure that local communities’ needs are met without provoking undue pupil mobility within existing schools.

SC26/SC27/ SC42 & Infrastructure Schedule

The SPD does not indicate how pupil yield from the new housing will be calculated. This is critical to securing agreement with any developer regarding the number of places that will be required to serve the development. BCC consulted last year on how it calculated pupil yield in terms of developer contributions, so it may be appropriate to mention that policy specifically.

However the infrastructure table 5.1 indicates that there will be 5 primary schools offering a total of 1890 pupil places or 9 Forms of Entry, assuming class sizes of 30 (Note that SC26 and SC42 refer to 4 primary schools) . When planning school places in Milton Keynes an average pupil yield of 5% is used, ie that for every 100 houses built there will 5 pupils per school year group. Based on 5390 dwellings this will produce 270 pupils per cohort, which equates to 9 forms of entry. It is assumed that this number of new places means that there is no appropriate spare capacity to access in other BCC schools.

In terms of secondary provision, BCC has a selective system and Table 5.1 indicates that there will be 630 grammar school places. It is not stated if this will mean adding capacity to existing provision. If it does then Milton Keynes Council will be able to comment further if and when statutory notices are published for the expansion. As Milton Keynes does not operate a selective system, it is difficult to comment on whether this provision will be sufficient. Table 5.1 also shows a new secondary school being provided with 1,260 places. With the stated 6th Form size of 210 places this will mean 7 forms of entry, assuming a class size of 30. 630 Grammar places would appear to accommodate the further 2 forms of entry required to match primary provision.

It should be stressed that the 5% yield is an average figure for Milton Keynes and research on the eastern flank of the city has shown that some new estates are experiencing higher yields for prolonged periods of time. Tenure type also has an impact on this yield. It would be advisable in our experience to plan contingencies at this early stage in case a higher yield occurs. For example securing a reserve site, or

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securing sites that are capable of supporting the future expansion of the new schools if required.

Para 4.6 Drainage, Water & Flooding

A strategic flood risk assessment should be prepared, in order to properly assess and plan for strategic water management requirements rather than taking a piecemeal approach to this. There are concerns that the development should not worsen incidences of flooding further downstream on the Water Eaton Brook in Bletchley.

Para 4.7.6 4.7.6 Seeks to reduce the visual impact on Newton Longville. It is unclear as to whether AVDC are intending to use the 500metres [and more] of farmland between the nearest part of the site and Newton Longville to achieve visual mitigation. Clearly, this intention would involve off-site landscape works within the intervening land. Without use of the intervening land scope for visual mitigation from NL is limited.

Para 4.7.7 4.7.7 Discusses the relationship with The Racecourses estate and whether the there should be an open space buffer between the existing and the new development. Residents of the Racecourses have not been given similar opportunities to those in Newton Longville to consider the interface between the existing and new development. The expectation however should be that the interface with existing and new settlement should be handled with great sensitivity in order to minimise anxiety of residents and optimise the links and inter-active opportunities for both.

Management of Green InfrastructureWhilst this is a consultation draft, little consideration has been given to the long term management of GI, the resources required and organisations for delivering the service. This issue should be considered prior to adoption of the LDS since it represents a significant cost to the project as a whole which should be quantified to enable viable, coordinated delivery and maintenance. There is a variety of agencies which could be considered for managing the GI depending on the objectives of AVDC, the developers and community for example, AVDC’s own landscape team; a Community Trust; The Milton Keynes Parks Trust, a Private Management Organisation or a Parish Council.

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Within Milton Keynes, the Parks Trust is nominated by Milton Keynes Council and Milton Keynes Partnership as the adopting body for areas of landscape and open space. As it is intended to extend the Milton Keynes linear parks system into Salden Chase, the management GI in the SDA by the Parks Trust would ensure continuity of standards and the linkage of the SDA into the multifunctional GI system from which Milton Keynes already benefits. The Trust is an independent, charitable organisation whose sole purpose is the maintenance of green space for public benefit. It is self financed with a long term financial strategy ensuring that there is no cost to public sector finances. It is also understood that The Parks Trust already manages a small area within Aylesbury Vale.”

SC31- 36 Renewable energyIn support of the AVDC aspiration for a zero carbon development, the GI could be examined for its capacity to support renewable energy at a scale which is compatible with an urban open space environment. Consideration be given to areas of short rotation willow coppice, waste wood use, small/medium scale wind energy and [on public buildings] - photo-voltaic solar energy.

SC31 The purpose of SUDS is to minimise downstream flooding impacts of the development. Surface water is proposed to be directed into Loughton Brook or Water Eaton Brook and MK is downstream in each case. The proposal intends to use GI as the means of flood mitigation and this must be handled with appropriate sensitivity to be beneficial in both amenity and ecological terms. The EEA [Brooklands] example in MK is however a reminder that flood water amelioration requires substantial ground engineering and associated structures which have a significant influence on the design and use of the green space in which they are located. It is very important to design SUDS into the open space rather than have to fit open space around the demands of SUDS. Open Space can satisfactorily fulfil a multi-use role but only through careful and considered design, integration of uses and appropriately resourced management.

There are however limits to multi-use open space when uses become “competitive” and conflicts may arise. We would therefore recommend a compatibility analysis be used to help determine uses and locations as uses emerge within the GI, particularly SUDS.

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SC33 SC33 Outlines many of the expected issues and states the need for a Landscape Strategy. A Landscape Strategy is standard for large developments and this should include a comprehensive survey of all landscape features/assets as a key informant to further site planning. This is particularly important in order to create enhanced opportunities and green corridors within and through the site. The MK example has been to retain and utilise existing landscape features [woods, trees, water courses, ponds, hedgerows, etc within public open space and this should be the basis of the model for Salden Chase and the EIA. The Concept Plan [figure 4.1] does not appear to have fully picked up this approach. The landscape strategy should include maximising urban food growing and plants that produce edible fruits, nuts etc.

SC41/ SC42 Further design guidance / principles are required on the nature of the loop distributor road (bus route), the ‘Link Road’ and Whaddon Road

Further guidance should also be said on the nature of the A421 frontage

SC42 & Table 5.1 Infrastructure Schedule

Civic Amenity Site: There is no provision for a civic amenity site in this area. MKC is very concerned that a development of this size will put a considerable strain on the MK Bleak Hall site, which is currently too small for the population which it services. We estimate that Bleak Hall is the nearest CA site for around 40% of the existing MK population. Despite recent improvements to this site, it continues to operate at capacity and we are not able to offer all the services which we offer at our other 2 existing CA sites, and will offer at a 4th planned for the Eastern Area expansion.

Residents of Salden Chase are likely to use Bleak Hall or other MK CA sites since they are closer than sites in Bucks (the nearest is Buckingham) and have relatively fewer restrictions. No other CA sites are planned on the western side of MK, though we continue to seek for a suitable site.

We would suggest that a CA site is made available in Salden Chase for residents to deposit bulky and

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garden wastes, and furthermore would like to suggest that a suitable area for this is to co-locate it next to an existing long-term paper recycling business (Pearce Recycling) which is located just on the AVDC side of Bottledump Roundabout. We do not know whether this business is likely to remain at this location, but, even if it does not, this would remain a good location.

If no CA site provision is made then MKC may need to consider restricting usage of its CA sites to MKC residents only. Buckinghamshire CC’s website indicates that they are shortly to introduce automatic number plate recognition at their sites and MKC may need to consider similar technology. It is likely that any CA site in this vicinity would be used by both MKC and Bucks CC residents and that arrangements should be made between the two local authorities regarding apportionment of CA site management costs (preferably the CA site should be supplied and constructed or provision made for its construction by the developer) and waste transport and disposal costs, dependent upon usage of the site by residents from each area. Alternately, Bucks CC could make a contribution towards the management and disposal costs of a 5th CA site within the MKC area, and a site for this needs to be available.

SC42 & Table 5.1 Infrastructure Schedule

Table 5.1 specifies the sizes of new schools to be provided in terms of the number of places to be offered. However the size of each site is not stipulated, only given as a global total in SC 42 paragraph iii, which includes infrastructure other than education. Figure 4.1 shows the secondary site. Various policies refer to the location of primary schools and collocation of services and infrastructure. In our experience, a 420 place primary will require a site of 2.1 hectares and a 1260 place secondary will require a site of in the region of 10 hectares. Again, experience in MK is that the site provided for a school needs to be useable in its entirety – ie a level site, not constrained such as by the presence of oil or gas pipelines, which would present difficulties for laying out of playing fields.

Also depending on AVDC’s requirements regarding drop off zones, larger sites may be required. There would be greater clarity if site size and the relevant DCSF specification is given.

SC43 & Table 5.1

The SPD gives no detail on how the opening of new schools will be phased. This may well be dealt with in the context of a s106 agreement involving BCC. Table 5.1 shows new secondary provision not being

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Infrastructure Schedule

available until 2021(when at least 2001 houses will be built) and primary provision being provided in each of the 3 phases. Experience in Milton Keynes suggests the following questions are pertinent for developments of this type:-

1. what are the interim arrangements for pupils moving into the area before new places are provided?2. at what stage of the development will schools be opened? (Table 5.1 gives a broad indication of

this only)3. What are the lead-in times for school build projects bearing in mind the competition requirements in

the Education and Inspections Act 2006?4. Will schools open with all year groups immediately or will schools open with limited year groups and

then build upwards?

The opening of schools will need to be managed carefully to ensure that needs of the new community are met and that existing schools in the area are not destabilised as the availability of places in new schools tends to attract new pupils and can therefore raise pupil mobility rates.

Figure 4.1 Concept Plan

Concept Plan – the background photo is very unclear. It should also highlight key existing roads such as the A421. The plan should reflect SC17 and show primary streets etc rather than “distributor roads”.

The Concept Plan sets out a number of broad corridors centred on the site perimeters, Weasel Lane and proposed distributor roads but does not obviously relate to other features such as hedgerows, trees, ponds, etc. It would be expected that existing features were fully recorded prior to determining GI type and coverage.

Delivery & Implementation

Delivery Section – general

The Joint Delivery Teams that operate within Milton Keynes should be referred to as their remit could be extended to assist delivery within the SDA. The Joint Delivery Teams cover Community Infrastructure, Environment, Utilities, Emergency Services, Transport, housing and inward investment.

For example: the Joint Utilities Strategic Delivery Group (JUSDG) is part of a working arrangement

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between Milton Keynes Council (MKC) and Milton Keynes Partnership (MKP) to deliver the Growth Programme as identified in the Local Investment Plan2 (LIP). JUSDG, along with other Joint Delivery Teams, report progress to the Programme Management Board (PMB).

JUSDG would have a joint working arrangement between utility providers, namely, water, electricity, gas and telecoms, developers and other partners, along with MKC and MKP. It contributes to the management of the overall growth programme by coordinating the delivery of utilities to projects and highlighting issues and risks for mitigation.

The Members of the JUSDG will include the following companies / organisations: o Milton Keynes Council (Growth Delivery and Co-ordination; Development Plans; Highway

Maintenance; Transport)o Milton Keynes Partnership (Tariff Team; Projects; Development Control)o Utility Providers (Anglian Water; Independent Water Networks Ltd; Central Networks; Southern Gas

Networks; Openreach)o Developers (Gallaghers; Places for People)

Some of the projects that the Group co-ordinates, but not limited to:o Utility network (connections; upgrades; and, maintenance and asset replacement)o Transport projects (utility diversions)o Digital infrastructureo Smart Grid

Para 5.1.3 There is a clear expectation that the developer will provide or contribute significantly to all the infrastructure required. However there is little mention of the viability of the development once that contribution has been made.

2 http://www.miltonkeynespartnership.info/DocLibrary/MeetingAgendas/MKPC020609AI12.pdf

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http://www.miltonkeynespartnership.info/DocLibrary/MeetingAgendas/MKPC020609AI12.pdf


Infrastructure schedule

The schedule should identify which infrastructure could be delivered by MKC e.g. sports-centre, swimming pools, culture and heritage, waste collection in order to flag up potential economies of scale or joint/shared delivery arrangements. S106 contributions will have to be apportioned accordingly. See our comments below on Annex B – Draft Heads of Terms

The requirements within the Infrastructure Schedule are incomplete: no reference is made to reserve sites (see below), indoor sports facilities or local sports pavilions and changing facilities which we would require alongside the playing pitches.

In terms of indoor sports facilities, the new development would put pressure on the newly redeveloped Bletchley Leisure Centre including the swimming pool. This could require increased staffing, and will push users/groups etc to surrounding facilities such as Medbourne and Tattenhoe Pavilion. A detailed breakdown of MKC’s requirements for sports and leisure facilities is included in the Leisure Services response to the Infrastructure questionnaires in December 2008 and November 2009.

With regard to the infrastructure schedule and the phasing etc the housing completions in the table on p42 does not correspond to the column headings on p43 onwards. The table on p42 gives cumulative totals of 1,050 by 2016, 3,550 by 2021 and 5,390 by 2026 (although the totals given in the table aren’t actually cumulative) yet p43 gives 500, 2000 and 3400 respectively.

Concern about the lack of linkage between housing completions and the delivery of employment and other non-residential uses. Whilst we cannot require businesses to move in to premises, there should be a link between housing completions and the delivery of serviced sites ready for occupation. Similarly, the provision of sites and buildings for local retail and community opportunities should be required at appropriate points. The schedule does touch on community facilities, but is not specific enough and does not clearly state exactly what is required and by when.

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A related issue is the provision of reserve sites, which we have a history of in MK. The retention of opportunities in selected locations for small development proposals that specifically meet local needs dates back to the development corporation days and has often been a successful part of community provision. Reserve sites are being provided in the WEA and EEA and should be provided here.

The infrastructure schedule is still too brief in terms of off-site transport improvements and although much of this is yet to be resolved headings should be included in the list. Junction improvements will be required in MK, the improvements will need to be managed and implemented by or on behalf of MKC. None of this is adequately recognised. It must be accepted that funding will come to MKC from the s.106 and that no works associated with the development can happen without the agreement of MKC as highway authority. MKC would expect to be a party to all legal agreements.

5.2.1 5.2.1 (page 41) - a 13 year build period is anticipated but the delivery table on page 46 refers to bus service support for 5 years. It is unlikely that bus services on the scale proposed will be viable within five years of starting work on the site. Whilst it is acknowledged that contributions may be spent beyond the first five years, it is unlikely that the developer will want to hand over the whole sum required in the first 5 years so there needs to be a recognition that a phased approach will be required to the receipt of these contributions, with the need for some funding during the whole build period.

Infrastructure schedulePage 44-45

Strategic Green Infrastructure / Major open space – contributions to off – site schemes. This appears to recognise the need to create publicly accessible GI outside the red line of the development.

This is commendable and accords with both MKGIP and BGIS and recommended in MKSM. It represents a clear benefit and advance on the MK growth example under which off-site GI is not

supported. The off-site GI principle is sound but as a “new venture” will require substantiation and financial

support against a background of competing interests. The funding methodology for all open space provision, sustainable maintenance and organisation[s]

for service delivery should be agreed as a matter of priority.

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Improved access to SGI – as above, commendable but will need an agreed and sustainable funding policy.

Access and Rights of Way Contributions to upgrades and improvements off-site is commendable. Provision of on site routes should be to augment existing RoW – not to replace them. Existing RoW should be retained and improved. Need to ensure links with existing network in MK and AV.

Local Nature Reserves Probably better to work on the principle of creating designated and supported Local Nature

Reserve[s] as a community asset. Adopt an approach to optimise ecological benefits generally throughout GI by appropriate design,

planting and management.

Open Spaces , sets out the rate of provision only – little mention of proposed use and content.

Playing Pitches will need to accord with the MKPP strategy in order to balance demand.

LEAPs and NEAPs Proposes 20 LEAPs and 10 NEAPs

The MKC Local Plan approach is for I NEAP and 2 to 4 LEAPs per grid square. Salden Chase is roughly the equivalent of 3 full sized grid squares so the recommendation would

be for about 10 -12 LEAPs and 3 – 4 NEAPs.

The MKC approach is recommended for the following reasons: Enables both LEAPs and NEAPs to assume the appropriate status and relationship with the

community served.

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Allows variety and identity for each play area. Allows NEAPs to assume the role of destination sites with the full range of play opportunities. Keeps the play areas manageable within reasonable and sustainable resources.

Allotments The proposed standard of provision is well below the MKC Local Plan recommendation [based on national guidance]. The MKC LP standard [.25Ha per 1000 pop] should be regarded as the minimum requirement in view of the following:

Increased popularity and demand for allotments in MK [and nationally] Smaller private gardens typical of new development. Higher density of new development Likelihood of growing demand for allotments. No spare capacity in MK.

Clearly very important to establish sufficient allotments provision at the outset in view of the difficulty to provide retrospectively. The minimum area should be 1.35Ha and in view of the need to locate at not more than 600m from users we would suggest 3 sites each of 0.5Ha for economically viable management. We would further recommend that the GI within Salden Chase allows and encourages flexibility for establishing community orchards, local food growing initiatives and projects.

Much is expected of the GI and while in draft or concept form it remains vulnerable to erosion in favour of other uses.

Page 46: Waste&Annex B – Planning obligation draft

Provision of waste services in the Salden Chase Area.It is unclear whether refuse and recycling, street cleaning and Civic Amenity sites, waste disposal and other waste services are to be provided by AVDC, Bucks CC or MKC. As the MKC boundary currently stands, AVDC would be responsible for waste collection services and Bucks CC for waste disposal services. However, due to the proximity of this development to the urban area of Milton Keynes, it would

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heads of terms probably be more cost-effective for MKC to provide the waste collection service. If AVDC or Bucks CC wishes MKC to undertake these services on their behalf, then S106 money for these services should be passed through to MKC. MKC has provision in several SPD’s already for the necessary infrastructure if this development were to be within Milton Keynes. If these SPD’s are implemented, the waste service should be consulted about the provision of adequate infrastructure.

S106 or other agreements should include:- The provision of receptacles for refuse and recycling collections for all properties. - Adequate provision of sufficient area at each residential and commercial property, or communal

space in the case of flats for the storage of refuse and recyclables as collected by MKC or AVDC, dependent upon the provider. This space should be secure, unobtrusive and easily accessed by both the resident and the collection service.

- Provision of an area for recycling banks at the local retail centre.- Sums for provision of extra vehicles and extra vehicle storage area- A sum for the provision of larger waste treatment facilities to pre-treat residual wastes before landfill

and to manage the handling of collected recyclables/compostables- A home compost bin and a water butt to be placed at all domestic properties which have a garden,

before occupation- A welcome pack for all new properties detailing waste services available to residents.

Annex B The Heads of Terms will need to consider how contributions will be apportioned between infrastructure and services in Aylesbury Vale and infrastructure and services in Milton Keynes.

Draft Heads of Terms : these should be developed to set out the individual items likely to be covered: as per the example below:

1 Education(a) Primary Schools

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(b) Secondary Schools

(c) Early Years Provision

(d) Post-16 Provision in Schools

2 Open Space Sport and Recreation

(a) Playing Fields

(b) Local Play Facilities including LEAPs NEAPs and LAPs

(c) Community Halls and Pavilions

(d) Local and District Parks

(e) Swimming Pool

(f) Sports Halls

(g) Allotments

(h) Provision of Public Open Space

(i) Maintenance of Public Open Space

(j) Adoption and maintenance of balancing and attenuation ponds

3 Social Infrastructure

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(a) Libraries

(b) Museums/Archives

(c) Social/Day Care

(d) Older Persons Housing

(e) Children’s Homes

(f) Community Houses

(g) Crematorium/Burial Grounds

(h) Adult Continuing Education

(i) Public Art

(j) Waste Management

4 Road Schemes 1. To be confirmed2. Junction improvements 3. Off site footpath works4. Offsite cycle way provision

5 Public Transport - to be confirmed eg

(a) Infrastructure to support “diameter” bus routes

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(b) Public Transport Spine

(c) Bus subsidy for new bus services including Real Time Passenger Information

(d) Travel information packs containing information regarding all public transport services servicing related developments

6 Health Facilities

(a) Primary (GP surgeries integrated health centres etc)

(b) Acute Maternity Mental Health

7 Other Strategic items

(a) Higher Education (MK University MK College)

(b) Flooding and drainage

(c) Voluntary Sector contribution

(d) Inward Investment

(e) Carbon offset fund (Policy D4)

(f) Emergency Services

8. Contributions towards the re-opening of the East West Rail link (western section)

9. Land for Reserve Sites for future needs

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10.Waste and recycling strategy

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