Draft Salden Chase Masterplan and Delivery SPD, January 2010
Response from Milton Keynes Council
SALDEN CHASE MASTERPLAN & DELIVERY SPD
CONSULTATION DRAFT, JANUARY 2010
COMMENTS FROM MILTON KEYNES COUNCIL
1.Background/ general comments
1.1Milton Keynes Council’s Cabinet on 16th February 2010 agreed a report setting out the broad issues that a subsequent detailed response would address.
1.2The 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.
1.3The 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.
1.4Additionally, 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.
1.5MKC’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.
(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 TattenhoePark 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 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
1.6These broad points are picked up in detail in the following table which comments on the SPD chapter by chapter.
1
Draft Salden Chase Masterplan and Delivery SPD, January 2010
Response from Milton Keynes Council
Detailed comments
Para / section / MKC commentsPURPOSE 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, BuckinghamshireCounty Council and Aylesbury Vale Advantage. Milton KeynesCouncil 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
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
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 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 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.
2.1.1
Vision 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 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 TattenhoePark 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 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 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.