Site Allocations Plan Statement of Consultation...ProposedSubmission Autumn2016 tbc...

Site Allocations Plan Statement of Consultation

3Introduction1

4Background2

5Preparation Timetable3

6Overview of key stages of consultation4

8Compliance with Statement of Community Involvement5

11Regulation 22(c) Requirements6

Appendices

13Site Allocations ProformaA

20ConsulteesB

21Summary of issues raised on Issues & OptionsC

41Summary of Issues raised on Preferred OptionsD

Contents

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1 Introduction

1.1 This statement sets out how Milton Keynes Council has involved stakeholders andthe community in the preparation of its Site Allocations Plan and summarises the resultsof the public consultation. This statement shows how the consultation undertaken hassatisfied the requirements of the Council’s Statement of Community Involvement, adoptedMarch 2014(1).

1.2 This document has been produced to demonstrate compliance with Regulation 22cof the Town and Country Planning (Local Planning) (England) Regulations 2012(2) whichrequires a statement setting out the following:

Which bodies and persons the local planning authority invited to make representationsunder regulation 18;How those bodies and persons were invited to make representations under regulation18;A summary of the main issues raised by the representations made pursuant toregulation 18;How any representations made pursuant to regulation 18 have been taken into account;If representations were made pursuant to regulation 20, the number of representationsmade and a summary of the main issues raised in those representations.

1.3 This statement will be updated following the publicity period on the ProposedSubmission Draft Site Allocations Plan in order to provide a summary of any representationsthat might be received pursuant to regulation 20.

1 http://www.milton-keynes.gov.uk/planning-and-building/planning-policy/statement-of-community-involvement-sci2 http://www.legislation.gov.uk/uksi/2012/767/made

1 . Introduction

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2 Background

2.1 The Site Allocations Plan will allocate additional residential development sites toensure that the Council can demonstrate a deliverable five-year housing land supply positionto support the Core Strategy.

2.2 A new Local Plan is also being prepared, referred to as Plan:MK. Plan:MK will reviewand replace the remaining policies in the Milton Keynes Local Plan (2005) and replace thecurrent Core Strategy, by developing a new strategy to guide the future development andgrowth of the Borough up to 2036.

2.3 The Site Allocations Plan has been under preparation since 2014. There have beentwo rounds of consultation under regulation 18 of the Town and Country Planning (LocalPlanning) (England) Regulations, 2012. These are the Issues and Options and the emergingPreferred Options.

2.4 The Council consulted on the initial Issues and Options document from September2014 to November 2014. During the Issues & Options consultation the Council receiveddetails of over 100 ‘new’ potential sites, including Council owned sites. Once sites thatdid not follow the settlement hierarchy were discounted (3) these additional sites werereduced to 69, with 55 of these being within the urban area.

2.5 In order to gather high-level feedback about these additional sites it was consideredthat they should be subject to the same public exposure as the original 50 sites. An‘additional sites’ consultation was therefore programmed for February 2015.

2.6 Subsequently, after public representations and consideration by the Council, certaincouncil-owned sites were withdrawn from the Site Allocations Plan and it was agreed bya cross-party Cabinet Advisory Group that the Site Allocations Plan should instead proceeddirectly to a Preferred Options consultation which allowed opportunity for comments tobe made on the additional sites that had not received formal publicity to date.

2.7 Following the Issues & Options consultation in 2014 the Council assessed 61 sites inthe urban area and identified its emerging preferred options. The Emerging PreferredOptions consultation, which took place from October 2015 to February 2016, invitedfeedback on the preferred site allocations, the site assessment process as well as coveringmore general aspects of the plan such as the overall level of development.

2.8 This Consultation Statement will be updated further following the publicity on theproposed submission draft Site Allocations Plan, which is scheduled to take place fromlate October until late December 2016.

3 Some sites were not located within or adjoining the urban area or the rural settlements ofNewport Pagnell, Olney, Woburn Sands or Sherington. These sites are not applicable as theSite Allocations Plan will follow the settlement hierarchy established in the Core Strategy.They will, however, be carried forward to the next iteration of the SHLAA and Plan:MK.

2 . Background

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3 Preparation Timetable

3.1 The Site Allocations Plan has been in development since 2014, and has been subjectto extensive consultation as shown in the table below:

Table 3.1

Approx. Number ofrepresentations

TimescaleStage

N/aSeptember 2013 - November2014

Initial ‘call for sites’and evidence

Gathering

768September 2014 - November2014

Site Allocations Plan:Issues and Options,Consultation(regulation 18)

580October 2015 - February 2016Site Allocations Plan:Emerging PreferredOptions Consultation(regulation 18)

tbcAutumn 2016Proposed SubmissionDraft Plan publicity(regulation 19)

3 . Preparation Timetable

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4 Overview of key stages of consultation

4.1 The first stage in the development of the Site Allocations plan was the evidencegathering stage which includes the ‘Call for Sites’ (September to November 2014):developers, agents, community groups and the public were invited to submit sites thatthey felt would be suitable for housing.

4.2 The Issues and Options stage was the first statutory phase in the preparation of theSite Allocations Plan, under regulation 18 in the Town and Country Planning (Local Planning)(England) Regulations, 2012. Consultation on the Site Allocations Plan: Issues and Optionsran from September 2014 - November 2014.

4.3 The Site Allocations Plan: Issues and Options document covered various aspects, themain issues it focused on were;

The amount of land that should be allocated

The split of development across the rural area

The proposed method for the assessment of sites

The suitability of certain small-medium sized sites that have already been put forwardfor consideration; and

Whether there are any alternative small-medium sized sites that should be considered

4.4 The results of this consultation informed the Emerging Preferred Options Consultation.

4.5 Following the consultation on the Issues and Options, the Council assessed all theoptions available and sought feedback on the assessment methodology and outcome, whilstconsidering what this might mean for the final plan. In total, 62 sites in the urban areawere put through a 3 stage assessment covering 37 criteria in order to ensure that themost sustainable options were selected.

4.6 The Emerging Preferred Options document asked for comments on the followingmatters:

The amount of land to be allocated resulting from the council updating the way itcalculates its land supply

Factors affecting land supply

Assumptions made in the plan about site capacity and densities

Rural sites and Neighbourhood Plans

The site assessment process, including the method by which the findings of theEmployment Land Study have been applied.

Policy requirements to be included in the site allocation policies.

4 . Overview of key stages of consultation

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4.7 In view of the amount of information provided, the consultation on the EmergingPreferred Options Site Allocations Plan was for 12 weeks rather than the usual 8 beginningthe 28th October 2015. The deadline was subsequently extended and finally closed on the10th February 2016.

4 . Overview of key stages of consultation

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5 Compliance with Statement of Community Involvement

5.1 The Council's Statement of Community Involvement, March 2014(4) (SCI) sets outhow Milton Keynes Council will engage with local communities and stakeholders in thedevelopment of planning policy documents and in the determination of planning applicationswithin the Borough. Section 2 of the SCI sets out the consultation and engagement methodswhich the Council will use, where appropriate. In addition to meeting the standardrequirements the Council will, where appropriate, undertake additional consultation andengagement at various stages of the document preparation process. The table below setsout these methods and highlights those that have been used in the preparation of the SiteAllocations Plan.

Table 5.1

Methods undertaken for the SiteAllocations Plan

Statement of CommunityInvolvement additionalconsultation andengagement methods

Stages

Newspaper articles advertising theconsultation were picked upindependently by outlets givenexisting interest in the process.

Local MediaIssues and Options

Emerging PreferredOptions

Press releases tocirculate to the localnewspapers and radiostations

Proposed SubmissionDraft publicity Newspaper articles or

advertisements toprovide detail and raiseawareness and interest

Bulletin and weekly news used.Planning staff all advertised theconsultations using emailsignatures.

Internal departments – shareinformation across theCouncil, via weekly bulletinand Members’ Weekly News

Issues and Options


Proposed SubmissionDraft publicity

No longer in circulationLiveMK newslettern/a

Both consultations advertised onCouncil twitter feed.

Social networking (forexample Facebook or Twitter)

Issues and Options



4 http://www.milton-keynes.gov.uk/planning-and-building/planning-policy/statement-of-community-involvement-sci

5 . Compliance with Statement of Community Involvement

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Methods undertaken for the SiteAllocations Plan

Statement of CommunityInvolvement additionalconsultation andengagement methods

Stages

Site notices displayed for all sitesin Issues & Options stage, only‘likely’ or ‘possible’ preferred

Display site noticesIssues and Options

Emerging PreferredOptions options were advertised using this

method in the second EmergingPreferred Options regulation 18consultation.


Presentations held concurrentlywith Plan:MK events for Issues &Options consultation. For

Deliver presentations or holdQ&A sessions

Issues and Options

Emerging PreferredOptions Emerging Preferred Options

consultation, meetings offered toall parish councils.

Leaflet made available duringissues and options consultationalthough not for site-specificemerging preferred options.

Prepare and make availableleaflets

Issues and Options

Presentations held concurrentlywith Plan:MK events for Issues &Options consultation. For

Advertising consultationevents or meetings,

or providing information onissues through posters andflyers

Issues and Options

Emerging PreferredOptions Emerging Preferred Options

consultation, meetings offered toall parish councils.

Exhibitions and roadshows held inconjunction with Plan:MK eventsfor issues and optionsconsultation.

Hold exhibitions or roadshowsIssues and Options

Engage with groups that maybe harder to reach forexample Youth Cabinet andfaith

communities

Door-to-door leaflet drops

Hold interactive workshopsor discussion groups with keystakeholders


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5.2 In order to satisfy the requirements of Regulation 18 (‘preparation of a local plan’)of the Town and Country Planning (Local Planning) (England) Regulations 2012, a list ofthe bodies and individuals that were invited to make representations at both the Issuesand Options and emerging Preferred Options stages is included at Appendix 2.

5.3 The consultation responses received as a result of these consultation methods wereadded to the Council's Consultation Portal (Objective). This system also allowed consulteesto make their representations online, by inputting their responses directly into theweb-based system.


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6 Regulation 22(c) Requirements

6.1 As outlined above, regulation 22(c) of the Town and Country Planning (Local Planning)(England) Regulations 2012 requires a consultation statement to provide certain informationin respect of the consultative process that has informed plan preparation.

6.2 The specific points referred to in regulation 22(c) are addressed below:

6.3 Which bodies and persons the local planning authority invited to makerepresentations under regulation 18:

Regulation 18 was discharged with the consultations undertaken on the Issues andOptions and the Emerging Preferred Options versions of the Site Allocations Planstarting in September 2014 and October 2015 respectively. In each instance, thebodies and persons invited to make representations consisted of all parish councilsand ward councillors within the Borough, adjoining authorities, landowners of potentialsites, statutory consultees (Natural England, Historic England, the Environment Agency,Highways England) and over 5,500 other groups and individuals who have previouslymade representations to planning policy in Milton Keynes, or have opted in to receiveupdates regarding this. The list of bodies and individuals invited to makerepresentations at this stage is provided in Appendix B.

6.4 How those bodies and persons were invited to make representations underregulation 18:

Organisations and individuals were invited to make representations by email or byletter where an email address was not available. Representations were accepted viaemail, letter, or via the ‘Objective’ consultation portal website.

6.5 A summary of the main issues raised by the representations made pursuant toregulation 18:

A summary of the main issues raised at the Issues and Options and the PreferredOptions stages of the plan is included in Appendix C

6.6 How any representations made pursuant to regulation 18 have been taken intoaccount:

The principle way that the representations on the first regulation 18 consultation forthe Issues & Options were used was to identify additional sites to assess as potentialoptions. The additional sites were assessed alongside previously identified options.

Other comments relating to the urban and rural areas were taken into account byfocussing the Emerging Preferred Options and draft plan on the urban area only, toreflect the development of neighbourhood plans in the rural area.

6 . Regulation 22(c) Requirements

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Representations relating to land supply methodology were considered but largelysuperceded by certain appeal decisions that provided a more definitive perspectiveon how the Council should calculate land supply and subsequently make additionalallowance in the Site Allocations Plan.

Representations made during the Emerging Preferred Options consultation haveprincipally informed how site assessments have been amended and also the keyprinciples or prescribed particulars that have been drafted to guide delivery.

6.7 If representations were made pursuant to regulation 20, the number ofrepresentations made and a summary of the main issues raised in those representations.

6.8 To follow following completion of Regulation 19 consultation.

6 . Regulation 22(c) Requirements

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Appendix A Site Allocations Proforma

Appendix A . Site Allocations Proforma

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Appendix B Consultees

As per the council's Statement of community Involvement, the following bodies andindividuals were consulted on the Site Allocations Plan:

Specific Consultation Bodies

Town and Parish Councils within MKTown and Parish Councils adjacent to MKAdjacent Local Planning Authorities, and other LPAs within the South East MidlandsLocal Enterprise PartnershipHomes and Communities AgencyNatural EnglandEnvironment AgencyEnglish HeritageNetwork Rail Infrastructure LimitedHighways AgencyElectronic Communications providersUtility providersPrimary Care Trust/National Health Service

General Consultation Bodies

Voluntary bodies whose activities benefit the areaBodies representing interests of different racial, ethnic or national groups in the areaBodies representing the interests of different religious groups in the areaBodies representing the interests of disabled persons in the areaBodies representing the interests of businesses in the area

Other Consultees

Developers, housebuilders and their agentsOther organisations or individuals who are on our consultation database

Appendix B . Consultees

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Appendix C Summary of issues raised on Issues & Options

Site Allocations Plan – summary of comments made on the Issues & Optionsconsultation

1) Introduction

This report summarises the response to the Site Allocations Plan Issues & Optionsconsultation, which ran from 10th September to 5th November 2014. In total there were754 comments received from 516 individuals. The response to the main questions in theSite Allocations Plan are summarised in section 2, section 3 provides an overview of thenext steps, section 4 is a sample proforma whilst section 5 contains maps showing newsites submitted during the ‘call for sites’ process, which ran concurrently with theconsultation.

2) Summary of responses

Question 1

• Do you have any views on the scope or content of the Vision and/or Objectives?

There were 37 responses to this question. In general the vision and objectives of the planwere well-received, with an understanding that the plan’s preparation is a requirementof the Core Strategy. Several respondents suggested we need to expressly focus on certainthings in the plan’s vision/objectives, such as regeneration, self-build homes, protectinghistorical/environmental assets, securing infrastructure, or the concept of an InternationalSporting City. Several respondents from the development industry suggested the CoreStrategy housing targets were already out of date and that the SAP would not fulfil itsobjective of boosting housing land supply in the short term.

Question 2

• Do you have any comments on the Council's conclusions regarding the availability ofexisting housing commitments or the approach to incorporating windfall development?

• Do you have any comments on the approach to incorporating past shortfalls and theNPPF buffer in the requirements (i.e. the use of the Liverpool methodology vs theSedgefield methodology)?

• How many homes do you think we should be planning for in the urban area? Do you thinkthe Council should avoid any risk and plan for the level of housing suggested by theSedgefield approach (500-600 homes)?

• Do you agree that land for a minimum of 622 new homes should be identified in therural area, specifically including deliverable sites for 300-350 homes?

• Should an additional allowance for delay in Plan:MK or any other reason be added tothese totals? If so, why is this and what level of provision do you believe should be made?

There were 43 responses to this question, predominantly from the development industrywho advocated the use of the Sedgefield methodology and the incorporation of significantbuffers and allowances to guard against delay or unforeseen shortfalls. There were alsoseveral respondents who argued against any disaggregation of housing targets between

Appendix C . Summary of issues raised on Issues & Options

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the rural and urban areas, who suggested we should treat the Borough as a holistic marketarea. In general, members of the public that responded to this question (and question 7)misinterpreted the concept of a rolling 5-year land supply and erroneously calculated thatthe Council has a supply of housing land of between 10 and 18 years (due to the allocationof the various expansion areas). Other points included the need to review settlementboundaries to justify an allowance for windfall and the need to consider overlappingHousing Market Areas through the Duty to Cooperate.

Question 3

• Do you know of any other sites which don’t already appear in Annex F 'Profiles ofpotential Site Allocations' that we should be considering for allocation through the SiteAllocations process? If so, please provide details and a location plan on the form providedin Annex C 'Proforma for submitting new sites for consideration'.

Sites promoted during the consultation exercise are shown on maps at the end of thisreport. Exactly 100 sites were submitted in total. 68 of these meet the basic criteria ofthe Site Allocations Plan and will be assessed at the next stage while 32 others are notapplicable by virtue of being too small, too large, and/or not adjoining key settlements.These sites will be retained in our records and used to update the next Strategic HousingLand Availability Assessment and in the preparation of Plan:MK.

Question 4

• Do you have any comments to make on the Site Assessment Framework set out in AnnexD 'Draft Site Assessment Framework'?

• Are there are any other factors the Council needs to consider, or any that are notrelevant to assessing site suitability?

• Do you agree with the weighting criteria included in Stage 3 of the Framework?

• Do you agree with the list of sites ruled out after Stage 1 of the assessment in AnnexE 'List of sites ruled out after the Stage 1 assessment'? If, not tell us why sites should beconsidered further.

There were 34 responses to this question. In general there was support for the principleof the Site Assessment Framework although there were suggestions about how to improveits effectiveness. These included a closer assessment of adjacent uses; impact on theStrategic Road Network; impact on landscape outside of MK Borough; a more explicitsummary of planning history; a closer focus on deliverability (e.g. if/how the site has beenmarketed); closer assessment of local healthcare capacity; removal of favourable weightingbased on relationship with existing settlement (as this doesn’t necessarily indicate goodconnectivity); removal of favourable weighting based on brownfield status (as this quiteoften impairs deliverability due to remediation work required etc.); greater specificityover what ‘quality’ of facility the site is close to (e.g. supermarket versus cornerstore);greater weight for agricultural land quality; proximity to primary schools to have narrowerscoring threshold than secondary schools.

Question 5

• Do you have any general comments to make about any of the potential sites identifiedin the Potential Sites document?


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Table C.1 below summarises the site-specific comments made during the consultation. Itdoes not constitute the views of officers or the findings of any technical evidence;comments may therefore be inaccurate, contradictory or irrelevant. Only commentsgenuinely related to planning are summarised, comments relating to the general principalof growth or other non-material factors (e.g. the motives of the landowner) are countedbut not summarised. This is particularly applicable to sites in the Wavendon/Woburn Sandsarea, where many comments were received citing the relevant site references yet as thefeedback was more about the principal of growth in the rural area, these comments werelogged under Question 7 instead. Where site-specific comments were made about thesesites, these are counted and summarised below.

The majority of feedback on sites was ‘negative’ with the exception of landowners anddevelopers who naturally supported the allocation of their interests and in some casessubmitted detailed proposals and technical evidence. Other sites generated a more polarisedopinion, most notably in Sherington.

Question 6

• Do you have any comments to make of the relationship between Neighbourhood Plansand the Site Allocations Plan process?

There were 12 responses to this question. Effectively all respondents advocated the primacyof Neighbourhood Plans in guiding local development decisions. However most alsoconfirmed that the Site Allocations Plan should not deviate from its timetable or scopebecause of emerging Neighbourhood Plans – there was widespread support for ensuringthe two processes ‘dovetailed’.

Question 7

• Do you agree that the focus of new allocations should mainly be on Newport Pagnell,Olney, and to a lesser extent Sherington, given the level of recent development, andongoing development, in Woburn Sands?

• Alternatively, should further growth be considered in Woburn Sands? If so, what is thejustification for this?

• Do you have any general views on the split of development across the rural settlements,particularly the potential approach of planning for 225-250 homes in Olney and 425-450homes in Newport Pagnell?

• Do you think that splitting the rural housing requirement equally across the three KeySettlements, and the other approaches set out in paragraph 8.17 are would be reasonableapproaches to take?

• Are there any pressures on services in the rural settlements that you feel should betaken into account in making new allocations? If so, what are these?

• Are there any opportunities for new development to support the continued viability oflocal services that you would like to be taken into account?


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There were 189 responses to this question. The vast majority of these (~80%) were fromresidents in the Woburn Sands area who agreed that the focus on rural allocations shouldnot be in their area (although most did not recognise that this was the proposal in theIssues & Options document so their responses were phrased as objections rather thansupport).

The bulk of the remaining responses came from residents in Sherington who questionedthe existing Core Strategy allocation of 20-40 houses there. This range came underconsiderable scrutiny during the consultation with many stressing that the Parish Councilhad originally only specified 25 dwellings whilst others claiming that Sherington shouldnot be subject to any growth, irrespective of the adopted Core Strategy.

There was limited objection to growth in Newport Pagnell and Olney. Several respondentsspecified Newport Pagnell as particularly suitable to accommodate growth. The roadnetwork and healthcare capacity were the two main pressures in rural areas cited as abarrier to growth in the rural areas.

There was a limited response from the development industry to this question. Somesuggested the concept of ‘fair share’ had no basis in planning policy and others suggestedfigures for Newport and Olney were arbitrary. Others suggested rural growth should beaccommodated in other villages (despite the consultation specifically discounting anyalteration to the Core Strategy settlement hierarchy).

Question 8

• Do you agree that increased weight in the Site Assessment Framework should be givento: a. Brownfield sites over greenfield sites; and b. Sites inside the designated area ratherthan sites outside the designated area in the open countryside?

• Do you support the principle of altering the designation of some employment sites inthe city, which have remained undeveloped since the designation of the city and whicharen’t seen as deliverable employment sites? Aside from those sites listed in the PotentialSites document, are there any other areas we should be considering?

• Do you think it would be appropriate to consider re-designating some areas classed asopen space for development, if this meant limiting the need for greenfield expansion onthe edge of the city?

• If so, under what circumstances would the release of open space for development beacceptable and do you know of any areas that may benefit from redevelopment?

• Do you know of any pieces of amenity open space that could be suitable for development?

• If the higher housing requirement is followed, do you think the focus should be onselecting one or two larger sites (c.500-600 homes) for allocation or should the Councilfocus on identifying a greater range of smaller sites?

There were 27 responses to this question. Most supported increased weighting for brownfieldsites and sites inside the designated area. However, there was little consensus on anyother aspects of the question; some advocated the redesignation of employment andgreen-space where underused, others considered both to be too valuable, either now orin the future. Similarly the support for small sites over large sites (and vice versa) wassplit although most recognised the benefits of each approach.


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Question 9

• Should the Council consider allocating additional land to provide further flexibility tothe land supply position? (this would be over and above the 20% buffer already requiredby the NPPF).

• If so, what additional allowance do you think it would be prudent to consider?

There were 20 responses to this question, which generally mirrored the response to question2. The development industry advocated buffers of up to an additional 20%. These responseswere largely made in the context of Core Strategy housing targets being a minimum andover-delivery not being an inherent issue or risk like under-delivery.


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TableC.1Site

Specific

Commen

ts

Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

Urban

Sites

Parish

Coun

cil

supp

ort

Floo

ding

3Bletch

ley/Fe

nny

Belved

ere

Farm

U1

Parish

Coun

cil

supp

ort

1Bletch

ley/Fe

nny

Form

erMFI

Unit

U2

One

respon

sesubm

ittedwith

55-signa

ture

Award-winning

arch

itec

tural

prop

osal

was

Opp

ortunity

toim

plem

ent

inno

vative

design

,

Loss

ofgree

nspaceused

for

varietyof

leisureactivities.

3Brad

well

Common

Land

off

Ham

pstead

Gate

U3

petition

objectingto

the

site’sinclusion.

design

edfor

thesite

but

neve

rim

plem

ented.

oppo

rtun

ityfor

well-located

supp

orted-liv

ing

units.

Hyd

rological

impa

ctsan

dwetland

ecolog

ical

corridor.

Parish

coun

cila

ndward

mem

berob

ject,loss

ofprom

inen

tan

dhigh

value

employmen

tallocation

,lack

oflocalinfrastructure

capa

city

4Brou

ghton

Land

atBrou

ghton

Atterbury

U4

Parish

Coun

cil

supp

ortan

dlik

ely

toallocate

in

1Fishermea

dGurna

rds

Aven

ueU5

Neigh

bourho

odPlan

for

starter/elde

rly

acco

mmod

ation.


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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

Onlysite

with

noco

mmen

ts.

0Grang

eFa

rmLa

ndoff

Sing

leton

Drive

U6

Impa

ctson

wild

lifeco

rridor,

litter,pa

rking,

surrou

nded

byem

ploymen

t

3LinfordWoo

dWoo

dlan

dsoff

Brec

klan

d

U7

Loss

ofpo

tentialp

ub-site,

traffic,

wild

life

2Med

bourne

Land

North

ofVe

rnier

Cresce

nt

U8

“Nomajor

conc

erns”from

Parish

Coun

cil

Loss

ofpo

tentialp

ub-site,

wild

lifeco

rridor

shou

ldno

tbe

deve

lope

d.

3Mon

kston

Land

off

Ladb

roke

Grove

U9

provided

consultation

isthorou

gh.

“Nomajor

conc

erns”from

Parish

Coun

cil

Loss

ofgree

nspace,

parking

issues,scho

olplaces,

capa

city

ofdo

ctors,draina

ge

8Mon

kston

Land

off

Lillishall

Aven

ue

U10

provided

consultation

isthorou

gh.

Busine

sses

curren

tlyon

the

site

wou

ldha

veto

relocate,

poor

acce

ss,Pa

rish

Coun

cils

object

7Old

Wolve

rton

Galleon

Wha

rfU11

Biod

iversity

Opp

ortunity

Area

1Shen

leyBroo

kEn

dRe

ssite

62offMan

ifold

Lane

U12


Milton

Keyn

esCo

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Statem

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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

Acce

ss,privacy,

traffic

3Shen

leyCh

urch

End

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pend

ent

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olsite

offD

aube

ney

Gate

U13

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availabilityof

adjace

ntarea

sforlarger

allocation

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pressure

onservices,Town

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cilsup

ports

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ding

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yStratford

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ergas

works

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r(purpo

rted

)ha

sco

nfirmed

itis

notavailablefor

deve

lopm

ent.

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ss,traffic,

settingof

York

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se,

floo

ding

,TownCo

uncil

objects

20Ston

yStratford

Land

tothe

rear

ofHayes

U15

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life,

senseof

place,

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ity,

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infrastruc

ture,op

en

51Ston

yStratford

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off

Calverton

Road

U16

coun

tryside,

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ding

,elev

ation,

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ss,Town

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cilo

bjec

ts

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cepressure

onacce

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theSLA

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enco

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all

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spec

ies

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atTowergate

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hotelinLo

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–ne

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2Westcroft

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tothe

rear

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rmarke

t

U18

assess

whe

ther

this


Milton

KeynesCouncil

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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

design

ation

shou

ldbe

retained

.

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ofpo

tentialp

ubsite.

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stof

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llStreet

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nfield

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rton

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ayWorks

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owne

rsare

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rawingthe

site

for

considerationas

reside

ntial.

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sine

sssite

issuccessful

andshou

ldbe

expa

nded

notallocatedfor

housing.

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rton

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rton

Mill

Site

GU21

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expa

nsion

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noise,

acce

ss,

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ding

,land

scap

e,too

large,

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pansion

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ofBrickh

illStreet

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ltural

land

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htpo

llution

,floo

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velopm

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pansion

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atLinford

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s

U24


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Keyn

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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

Risk

ofod

ourfrom

sewage

trea

tmen

t,op

encoun

tryside

encroa

chmen

t

2Ex

pansion

Land

South

ofLo

wer

End

Road

(a)

U25

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nco

untryside

encroa

chmen

t1

Expa

nsion

Land

South

ofLower

end

Road

(b)

U26

Provides

Bow

Brickh

ill’s

contribu

tion

in

Traffic,

noise,

acce

ss,

floo

ding

,land

scap

e,too

large,

localinfrastructure

54Ex

pansion

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Westof

BowBrickh

illU27

light

ofBlindPo

ndFa

rmno

tbe

ing

deliv

ered

.

Opp

ortunity

for

trafficrelie

f,shou

ldno

tbe

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poor

access,v

isua

lintrusion,

seriou

sbiod

iversity

impa

ct

5Ex

pansion

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atLittle

Linford

Lane

U28

considered

gree

nfield,

equivalent

deve

lopm

entthe

othe

rside

ofM1

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tsof

way,wild

life,

visual

intrusion,

poor

relation

ship

toex

isting

settlemen

t

6Ex

pansion

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leyDen

sFa

rmU29

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way

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ceAc

tion

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”

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ildco

rridors

associated

with

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scap

e,relation

ship

with

WEA

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ent,access,

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life,

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draina

ge,loss

ofridg

ean

dfurrow

.

116

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nsion

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off

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eway

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setup

with69

templateletters

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itted.

high

-pressure


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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

gasan

dstrategicoil

pipe

lines.

Land

owne

rclarified

prop

osalswere

forasm

all

quan

tity

ofsustaina

ble

bespok

eho

mes

not15

8as

per

theIssues

&Options

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rclarified

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runfrom

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cil

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ortprovided

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next

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ars.

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uncil

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ort(sub

ject

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provision)

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seR2

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ss,

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objects

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ell

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ontraffic,

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cilsup

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Allocation

sPlan

9New

port

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ell

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R4


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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

Goo

dacce

ss,

provides

improved

gree

nspacean

dsports

facilities.

Isolated

,wild

life,

pylons,

floo

ding

,no

ise,

traffic(inc

.em

erge

ncyserviceroute),

TownCo

uncilo

bjec

ts

11New

port

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ell

Land

off

Marsh

End

Road

R5

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prec

lude

saby

pass,

righ

tsof

way,land

scap

e9

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Olney

aR6

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prec

lude

saby

pass,

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tsof

way,land

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e10

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Olney

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centre,fewest

neighb

ouring

prop

erties

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e8

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logicalrou

nding-off

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intrusion,

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tmen

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north

andSouthof

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ndon

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olex

pansion

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off

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0

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ofod

ourfrom

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t,visual

intrusion,

isolated

5Olney

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off

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ton

Road

R11

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eden

tfor

deve

lopm

ent

nearby

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,wild

lifeco

rridor,

visual

intrusion

6Olney

Land

off

YardleyRo

adR1

2


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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

7template

letters

subm

ittedby

reside

nts.

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rby

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ting

centre

could

beano

ise

constraint.

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nfield,visual

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ent,

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cecommercial

traffican

dno

ise

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ss,toosm

alla

ndfar

away

tosupp

ortvilla

gefacilities,

loss

ofem

ploymen

t

25Sherington

Smiths

Yard

R13

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villa

gece

ntre,logical

location

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life,

righ

tof

way,

land

scap

e,Sche

duled

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tMon

umen

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ss

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atCrofts

End

R14

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ning

application

subm

itted

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dacce

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parking,

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ation

16Sherington

Land

atHigh

Street

R15

during

SAP

consultation

period

.

Parish

Coun

cil

repo

rtow

ners

have

withd

rawn

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ss(particu

larlysafety

inrelation

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olchild

ren)

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rear

ofScho

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neR1

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thesite

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cewithMKC

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ay

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ndEa

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ltural

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urnSand

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ndNorth

ofWob

urn

Sand

s

R18


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Notes

‘New

’issues

raised

byconsultation

Summaryof

positive

feed

back

Summaryof

negative

feed

back

No. of reps

Area

Nam

eRe

f

need

sto

bereflec

tedin

site

layout.

Goo

drelation

toex

isting

settlemen

t,least

impa

cton

leve

lcrossing

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imityto

railw

ay,

agricu

ltural

land

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urnSand

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ndWestof

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port

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station

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dary

Well-located,

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ction

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ploymen

t,traffic

5Wob

urnSand

sWye

vale

Nursery

Site

R20

need

sto

bereflec

tedin

site

layout.


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3.Sample proforma


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4. New sites submitted

The maps overleaf show all sites that were originally considered in the Site AllocationsPlan along with newly promoted sites. The maps are roughly split into the south-east,south-west, north-west and central areas of the city with separate maps at the end forNewport Pagnell/Sherington and Olney. The key is as follows:


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Appendix D Summary of Issues raised on Preferred Options

Site Allocations Plan, emerging Preferred Options Stage – summary ofresponses and next steps

Question 1 – general comments

A range of site-specific issues have been raised, which will feed into the amended siteassessments and development of prescriptive policies on those sites that are proposed asallocations.

Question 2 – land supply methodology (28 responses)

Summary of comments:

Overall it was felt that the Site Allocations Plan should allocate enough land to allow forboth a 10% slippage in forecasts and for a 20% buffer on outstanding shortfall as this takesa robust approach to ensure the future supply of housing land. A Planning Consultanthighlighted that each of these measures are likely to help ensure that there is a constantsupply of deliverable housing land and it was felt that this approach is the most appropriateand consistent with the requirements of paragraph 47 of the NPPF.

However it was felt that, in order to combat the possibility of slippage on the large sitesin their first five years, a greater number of allocations as well as housing numbers shouldbe made. If the slippage is not countered by other allocations at a small or medium scalethen the undersupply of housing in the Borough will continue. Another developer commentedthat there should be a more accurate assessment of the land likely to come forward fromthe large strategic sites, within the 5 year land supply period. Any shortfall from thesesites is likely to make a significant difference to the land supply figure. When making theadditional housing allocations, a more dispersed strategy within the rural towns should beundertaken.

Response:

As per the interim Housing Land Availability statement of November 2015, this methodologywill be carried forward to the June 2016 Housing Land Availability statement. The draftsubmission plan will be published shortly after this to ensure consistency with the latestland supply situation. Notably, several possible sites have progressed as applications, soproposed allocations will need to avoid duplicating this process.

The purpose of the Site Allocations Plan was set out in the Core Strategy; to provide a‘boost’ or ‘top up’ in land supply by allocating smaller sites, to complement the largerstrategic expansion areas that do not contribute to land supply in the short term.

The required amount of allocations has varied over time according to land supplycircumstances. Originally, the Core Strategy envisaged approximately 1,000 additionaldwellings being allocated through the Site Allocations Plan. This figure rose in the aftermathof a recent planning appeal after which the Council revised its methodology for calculatingsupply but has fallen in light of a large amount of development being allocated inNeighbourhood Plans particularly in the rural areas.

Appendix D . Summary of Issues raised on Preferred Options

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The latest land supply report (published June 2016) concludes that using the mostup-to-date methodology and the most current circumstances on committed sites, theCouncil can demonstrate a land supply of 4.8 years, or a deficit of 479 dwellings. Thistherefore represents the bare minimum that is considered should be allocated.

It is, however, considered prudent to allocate more development than this for two reasons.Firstly, there are suitable sites available to meet a higher level of development. It wouldtherefore be difficult to justify the omission of suitable sites purely on the basis that theyare not ‘needed’. Secondly, even with an ‘optimism bias’ applied, it is possible that supplyforecasts might slip. Therefore a higher amount of development ought to be allocated tocompensate for this.

Considering both these reasons, and the fact that stated capacities are indicative andshould be considered a maximum, it is recommended that the plan proceed with allocatingland for around 1,000 dwellings as originally intended

Question 3 – other land supply factors (22 responses)


Other factors that should be taken into account when determining the overall level ofdevelopment in the Site Allocations Plan included having a more accurate assessment ofland that is likely to come forward from the large strategic sites and having a more accurateestimation of the land available from each site within the Site Allocations Plan. In relationto sites within Central Milton Keynes, the Site Allocations Plan should take account ofcompeting land pressures as highlighted by other planning policy documents. There alsoneeds to be flexibility in case Neighbourhood Plans do not progress to ensure deliverableland is brought forward across the whole Borough. Housing densities should be reviewedto consider allowing higher densities on accessible, well located sites to help meet thehousing supply. Buckinghamshire County Council commented that consideration should begiven to the cumulative traffic impacts of proposed development especially the impactof proposed expansion on the A421, A418 and A4146. It was felt that the overall figure forthe level of development within the Site Allocations should be increased to account forthe recent demographic projections, potential slow Sustainable Urban Extension deliveryrates, and the dwindling Milton Keynes land supply figure.

Overall it was felt that the Liverpool Method of determining how land supply is calculatedis unsuitable, as this splits the shortfall over the remaining 10 years of the plan period.The justification for this approach is the reliance on large sites with long lead in times. Itwas suggest that this position can no longer be maintained, and that the shortfall shouldbe dealt with at the earliest possible opportunity. Therefore the Sedgefield approachshould be adopted, which will increase the level of land which needs to be allocated inthe Site Allocations Plan.

In relation to Plan:MK it was identified that although the purpose of the SAP is not toprovide land in support of the emerging Plan:MK, it should be seen as an important toolto inform the site identification process for Plan:MK. With this in mind, a thoroughassessment of all submitted sites should be undertaken as part of the SAP process. It wasalso noted that while the Council is only looking to fulfil the short to medium housingsupply requirement of the Core Strategy via the SAP, it must bear in mind that by the timePlan:MK is adopted, the housing supply requirements are likely to have significantlychanged; it is also important to bear in mind that the SAP is far from finalised and is notlikely to be adopted much sooner than Plan:MK.


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Response:

See response to question 2 above.

Additionally, the Council favours the Liverpool method of accommodating shortfall, whichmeans spreading this backlog over the remaining plan period rather than within the next5 years (the Sedgefield method). The specific circumstances of Milton Keynes mean thatmost new housing is delivered in a number of large strategic sites (see Appendix 1), whichtake many years to build-out. This was acknowledged by the Core Strategy inspector inparagraphs 84 to 96 of her report.

Question 4 – capacities (23 responses)


In response to the capacities being either high or lower, it was felt that the approach wasbroadly acceptable but site specific information should be taken into account and thatrather than using an average capacity figures, these should be on a site by site basis asindividual site constraints will make a substantial difference to the capacities that can beachieved. It was also felt that the proposed approach is very prescriptive and fails to takeaccount of site specific characteristics and character opportunities. Matters such as visualimpact, neighbouring densities, relationship to existing settlements, wider landscapeimpacts all play a key role in this matter on a site by site basis, and it was felt that ablanket approach such as this is too simplistic to be effective.

It was identified that a density uplift at new development sites is key in making the mostefficient use of land in Milton Keynes, whilst adding a larger amount of housing to thetotal land supply. Particularly in the urban area of Milton Keynes, where infrastructure isestablished, densities should be raised to support the overall housing need in Milton Keynes.

It was felt that the capacities do not reflect Milton Keynes Council’s identified need for‘Executive Style’ larger homes which are typically built to a lower density. It is consideredan allowance should be made for lower density sites suitable for ‘Executive Style’ homes.This may result in more sites needing to be allocated in order to meet the assessed need.

In relation to rural areas and specific sites, it was felt that rural areas in Zone 4 wouldtraditionally not have housing densities of 30dph. Now that there is no national 30dphminimum housing density requirement, Zone 4 densities do not need to be specified at30dph, but should reflect local densities. It was felt that given the nature and the characterof Olney; a traditional Buckinghamshire market town, and the fact that the settlementconstraints means that the only housing sites are likely to be on the outer edge adjoiningthe countryside, the minimum density should be 30dph. In relation to Wolverton area thedocument notes a density of 40dph, it was accepted that this broadly coincides with theapplication scheme pending at the Railway Works site. It was considered that higherdensities, possibly within a range of densities could be considered appropriate for thisarea.

Response:

No sites are now allocated in the rural areas that are covered by Zone 4, nor for the ruraltowns of Olney, Newport Pagnell or Woburn Sands which fall within Zone 3.


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The residential capacities provided are to be treated as indicative only and therefore thereis flexibility for proposals to come forward at a higher or lower level of development thanthat suggested in the Plan.

Question 5 – Neighbourhood plans (27 responses)


Overall it was agreed that it is appropriate for relevant Neighbourhood Plans to determinerural site allocations. This approach allows for neighbourhood plans to achieve greaterweight and avoid prejudice in light of the adoption of a Local Plan and it was felt thatcommunities are best placed to make decisions on where development should beaccommodated. Rural areas should be seen as a valuable source of sustainable housing.Neighbourhood Plans must ensure there are allocations to meet current and future housingneeds as villages need development to remain sustainable and healthy and need to dotheir part in providing housing.

There were concerns that Neighbourhood Plans will be out of date if based upon the CoreStrategy as opposed to the emerging Plan:MK. In some cases, local residents have suggestedthat they do not want to see further development especially in relation to Wavendon andso relying solely on Neighbourhood Plans for delivery in rural areas may have somelimitations and does not provide suitable flexibility. It was felt that the SAP should includerural sites, as any sites allocated by emerging Neighbourhood Plans will add further tohousing capacity and that given that MK cannot currently meet its 5YHLS requirement thisis particularly pertinent.

Response:

Neighbourhood Plans are progressing as expected, the Newport Pagnell NeighbourhoodPlan has recently been made by Milton Keynes council and allocated land for around 1300new dwellings. The Olney Neighbourhood Plan is progressing well and will include asignificant allocation. Other, smaller villages are also intending to deliver additional housingthrough neighbourhood plans which mean that it remains unnecessary to allocate ruralhousing sites in the Site Allocations Plan.

Question 6 – Site assessments (34 responses)


Overall the responses broadly agreed with the process used for assessing the sites.

However it was felt that a flexible approach should be taken with regards to the assessmentof the potential allocation sites. It was important for the council to consider land ownership,as many of the preferred sites are within the ownership of MKDP which is not a developer.Therefore, deliverability issues are significant and as the development process becomesstretched it is less likely that the development will be delivered in a timescale that willhelp the council to address the current housing shortfall.

There were also concerns regarding the implementation of the assessment process andthe conclusions drawn and in particular the general lack of evidence provided to back upthe conclusions set out in the assessment. It was also felt that a number of judgementshave been made which would normally be supported by technical evidence in order toensure that the conclusions of the Council are robust and defensible.


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Response:

Changes to site assessments will be considered and implemented where appropriate. Afundamental issue raised is the lack of evidence on certain aspects. It is not intended thatevery criteria requires its own suite of evidence base of documents as it is acknowledgedthat a degree of subjectivity in the assessment is unavoidable. The sustainability appraisalwill look cumulatively at the proposed site selections and establish if the plan will haveany fundamental social, environmental or economic impacts. This will, in a sense, cutthrough the detail of the site assessments to confirm whether the allocations proposedrepresent sustainable development.

Question 7 – use of the ELS (11 responses)


Broadly the responses supported the way the findings from the Employment Land Studyhad been applied to the assessment process.

It was agreed that the valued and well used employment land within Milton Keynes shouldnot be allocated for change of use and that land that is not valued at a premium and isunderused should be considered and assessed for other purposes.

There were concerns however, that some of the sites proposed would not constituteappropriate locations for residential development, especially in terms of residential amenityissues. There were also concerns about the over reliance on brownfield land to producehousing units at a quick delivery rate which could be problematic due to issues withremediation and ground works which could make development unviable for developers.

Response:

Support noted. The suitability of a site for residential use is considered as part of theoverall assessment. The identification of a site in the Employment Land Study does notautomatically mean that a residential allocation will follow, if the location or nature ofthe site would make it unsuitable for housing.

Question 8 – Surgery capacity (13 responses)


There was a mixed response on how data on surgery capacity has been applied to theassessment.

There was a consensus that new development can provide funds for new surgeries andthat the impact of a development site can be mitigated on a case by case basis via S106agreements and therefore the current provision of health care facilities should not be aninfluencing factor on allocating sites.

The majority of the responses noted that distance to a surgery is a relevant factor andthat surgery distance should also account for capacity rather than just the nearest surgery.It was also felt that the 1km distance was not a great distance and that all the sites arewithin the urban areas close to public transport links.


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Other concerns were that NHS assessments are often based on an overall picture which isinsufficiently sensitive to local conditions. Surgery capacity based on the available floorspace per patient does not give a full and rounded assessment of capacity, although someresponses did feel this was a useful approach where there was no better indication on howmuch additional patient capacity exists for a particular surgery.

Response:

The distance from a surgery is considered too much of a constraint to compare usefullyacross the range of sites available. This is exacerbated by the fact that only 6 of the 13surgeries ‘green’ rated by the NHS have sites available near them. The distribution ofcapacity therefore means that whilst having close access is desirable, in cumulative termsa negative impact is inevitable if the plan allocates the level of development required.This matter is explored further in the sustainability appraisal whilst dialogue with NHS isongoing to ensure the impacts of proposed allocations can be mitigated to the fullestextent possible.

Throughout the preparation of the plan, the capacity of and proximity to health facilitiesserving potential allocations has been identified as a particularly difficult constraint toovercome. The purpose of the Site Allocations Plan is to maintain a deliverable supply ofland suitable for housing, the availability of which does not necessarily correlate withthose areas of the Borough that enjoy greater capacity of health services. The Council andpromoters of all allocated sites will be expected to maintain a close working relationshipwith NHS England and the Clinical Commissioning Group to plan for new residentialpopulations and identify future opportunities to enhance healthcare provision in bringingforward allocations.

Question 9 – school capacity (8 responses)


There was a mixed response in relation to whether the school capacity had been ratedappropriately.

There were concerns that funding and site constraints may make it difficult to deliver thenew school capacity needed and that the plan should consider the cumulative impact ofnew development particularly in relation to smaller sites, these comments were highlightedby Buckinghamshire County Council.

It was generally felt that shortages in school places would be addressed by developmentcontributions and that it was, therefore, unnecessary to downgrade site ratings on thebasis of a lack of education capacity. It was also felt that, as further technical work isongoing to confirm school capacity and delivery, little weight should be placed on thefindings of the assessment if it is going to be subject to additional evidence/informationgathering.

In relation to threats or opportunities for education, comments were made on two specificsites (U29 & U11). These related to their providing extra capacity for the area, anotheropportunity that was identified was that extensions of development between Buckinghamand Milton Keynes could create more viable settlements to encourage new infrastructure,additional schools places and access to schools through larger developer contributions.

Response:


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As with access to health facilities, the capacity of schools that would serve new housingallocations has been a key issue throughout the plan preparation process.

The purpose of the Site Allocations Plan is to maintain a deliverable supply of land suitablefor housing, the availability of which does not necessarily correlate with those areas ofthe Borough that enjoy access to schools with capacity. Unlike health provision, the Councilhas more direct control over the planning and delivery of school places but the promotersof all allocated sites will be expected to maintain a close working relationship with thecouncil’s Schools Sufficiency and Access Team in bringing forward allocations.

Question 10 – stage 3 scoring (10 responses)


The majority of responses did not accept that the Stage 3 scores were accurate andconsidered it is necessary that the sites’ viability and constraints are recorded accurately.

It was felt that the relative accessibility of sites should be considered to include proximityto a range of transport modes, instead of using a crude measurements tool that does notapply sensitivities, nor practicalities of travel routes. Alternative routes should beinvestigated to make sure a compressive assessment of the sites has taken place and scoresand measures taken should reflect access points and routes created by developmentproposals and not restricted to existing routes.

Response:

As per question 6, site assessments will be amended accordingly.

Question 11 – sifting (19 responses)


Overall the majority of responses agreed with the principle of sifting sites based on thenumber and severity of red ratings.

It was felt that it is a reasonable way of assessing site constraints providing the siteconstraint has been assessed correctly and that the assessment methodology does notpreclude the assembly of more complex sites. And that due to the fact there is a significantneed for higher housing numbers that it would sensible to broaden the criteria for allocatingsites, these comments were highlighted by an individual and Planning Consultant.

It was agreed that each allocation should be made with a policy which sets out howconstraints should be addressed. Equally that more evidence will be needed before policiescan be prepared which set out constraints to be addressed, these comments werehighlighted by Planning Consultants.

The main concerns were that emphasis should firstly be on the suitability/sustainabilityof the sites, with the RAG ratings acting as a secondary ‘review’ stage, to consider whethersites that appear to be suitable for development are actually capable of delivery. The RAGrating effectively would be used to justify moving sites with a good rating down the listof preferred sites, depending on the severity (or number of) constraints. And that theadded value of the sites, considered at stage 4 of the appraisal process needs to be factoredinto the decision making process, as it is not clear how any added value has been taken


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into account, which is an important omission. And that the document should give moreclarity given as to the sites which will be allocated, these comments were highlighted byPlanning Consultants.

Response:

The sifting process has provided a rough indication of whether sites are suitable forallocation. The Council will refine its site assessments and the application of a finer siftingprocess to determine final proposed allocations.

Question 12 – ranking (13 responses)


The responses supported the principle of a ranking list being used to determine preferredoptions.

It was put forward that a scoring system would mean a more accurate and conclusiveassessment, as it is indicative of how deliverable the sites are given it relates specificallyto constraints to development. And that the use of a traffic code scoring system issubjective and can be seen as not entirely accurate.

There were some concerns that the use of a ranking system may be used as a form ofcategorisation/prioritisation, to assist with the decision-making process, but it should befollowed by site specific policies, which can inform the final decisions, these commentswere highlighted by an individual.

It was also recommended that council could also consider using a Settlement Hierarchyto determine the amount of development which a settlement could sustainablyaccommodate. This could include settlement connectivity, employment opportunities,social infrastructure and services, these comments were highlighted by BuckinghamshireCounty council. It was also suggested that weight should also be given to encouragingvariety, freedom of choice, competition in the housing market, social integration, and theneed for Self-Build, in making the allocations, these comments were highlighted by anindividual.

Response:

The ‘ranking’ of sites will be less significant as the plan is finalised as there will be nopriority order to the allocations made. However the ranking may still be used to draw adistinction between ‘primary’ allocations and ‘secondary’ allocations, based on meetingland supply requirements.

Question 13 – prescriptive policies (16 response)


There was a mixed response of comments in relation to specific sites. Overall it wasidentified that additional policies should avoid being overly prescriptive and should providesufficient flexibility for development to be shaped through the development managementprocess and the doubling up of polices should be avoided; these comments were highlightedby a Developer and Planning Consultant.


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Generally it was identified that any site must be provide a suitable access corridor to theland further out from the centre of Milton Keynes so not to restrict the future expansionand that policy requirements for specific sites should include the delivery of particularfacilities or the upgrade of existing services to serve the existing and new community thesecomments were highlighted by a Planning Consultant. Also that a density minimum shouldbe given to encourage the developer to create a site that makes the most efficient use ofland whilst delivering a variety of homes, these comments were highlighted by an individual.

It was suggested that the plan could maximise opportunities for energy efficiency andrenewable energy generation to existing and new developments and consider the use ofSustainable Urban Drainage Schemes to mitigate flood risk. The plan should consider theuse of developer contributions for critical infrastructure need and commuted sums forrelevant maintenance works. And where policy refers to green space, this should includereference to multifunctional green spaces, ensuring that there is no erosion of green spacewithin areas of intensified growth, to provide a range of social, economic and environmentalwell-being benefits and ensure access to open space within both urban and rural areas,these comments were highlighted by Buckinghamshire County Council.

Lastly, it is important for the site allocations plan to consider the impact of newdevelopment on rural towns and villages. The plan should consider the protection of thespecial setting and rural nature of local towns and villages also a policy on socialinfrastructure would provide opportunities to improve the viability of social care provisionin more rural areas by ensuring that that the vulnerable and others who rely on social careprovision have good access, these comments were highlighted by Buckinghamshire CountyCouncil.

Response:

The Sustainability Appraisal will be used alongside these comments to determine the mosteffective mitigation to make sites sustainable.

Question 14 – additional evidence (34 responses)


In relation if there are any additional site-specific or general evidence that should beprepared if was felt any plan should review the impact on traffic which should includedetailed plans on how such issues as congestion, travel times, health risks, environmentalimpacts from fumes, noise will be dealt with, these comments were highlighted by PerverseBow Brickhill and induvial.

It was felt that evidence should be supplied to justify the discounted housing densities of75% and 50% for large housing sites, these comments were highlighted by an individual.And that it is not entirely clear what level of ecological assessment has so far been carriedout. Prior to adoption of any site a full initial assessment of the ecological value shouldbe undertaken to inform the allocation of the sites in the Local Plan, to determine whetherallocation of the site is appropriate in terms of biodiversity impacts, these comments werehighlighted by Wildlife Trust.


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Site Allocations Plan Statement of Consultation...ProposedSubmission Autumn2016 tbc...

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