MILTON KEYNES COUNCIL
CORE STRATEGY Development Plan Document
PRE-SUBMISSION PUBLICATION STAGE
Wednesday 17th February – Wednesday 31st March 2010
REPRESENTATION FORM
Please read the ‘Guidance Note for Respondents’ (at the end of this form) before completing this form.
Please return to Milton Keynes Council by 5pm on Wednesday 31st March 2010. This form can be completed online using our ‘Limehouse’ consultation system at http://miltonkeynes-consult.limehouse.co.uk, where you can also print or save a copy for your own records.
Alternatively, you can send completed forms to us:
- By email, to
- By fax, to 01908 252330
- By post using our freepost address, to Development Plans Team, Milton Keynes Council, FREEPOST NATE 294, Spatial Planning, Civic Offices, 1 Saxon Gate East, Central Milton Keynes, MK9 3BR
Please do not send duplicates. Note that all comments will be made available for the public to read and therefore cannot be treated as confidential. Type or print clearly in black or blue ink. Use a separate form for each representation. If you use additional sheets, please mark them clearly with your name or organisation.
Personal Details / Agent Details (if applicable)Title / Ms
First Name / F M
Last Name / Fry
Job Title
(where relevant) / Vice Chair
Organisation (where relevant) / Woburn Sands and District Society
Address
Post Code
Telephone Number
Email Address
- 5 -
Name or Organisation: Woburn Sands and District Society
Representation Details
Q1. To which part of the Core Strategy does this representation relate? Please use a separate form for each section you wish to comment on
Policy Number / CS5 Point 6CS11 bullet point 7 / Paragraph Number / Spatial Vision Milton Keynes in 2006 No 11
Para 6.7
Para 11.13
NB We have not completed an additional form for each of the above as the arguments on legality and soundness are the same for each of these.
Q2. Do you consider the Core Strategy is…? Please mark one answer for each question
Yes / No(a) Legally compliant / No
(b) Sound / No
If you answered ‘No’ to Q2(b), please complete Q3. In all other circumstances, please go straight to Q4.
Q3. Do you consider the Core Strategy is unsound because it is not… (please mark all you think apply)
(a) Justified / No / (b) Effective / (c) Consistent with national policy / NoQ4. Please give details of why you consider the Core Strategy is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance of the Core Strategy, please also use this box to set out your comments.
We consider that the Policies Numbered and Paragraphs Numbered above are not legally compliant as there has been no consultation/ community involvement in respect of· future bridges over and/or a new Junction 13a at the strategic reserve area north of A421 and east of Fen Farm, identified in the Local Plan proposals map as SR1, and Policy EA4 in the local plan. This would by its position cross into Central Bedfordshire, as the MK Boundary with Central Bedfordshire is along the M1 for the full extent and more of the strategic reserve area SR1. Any Junction 13a or bridge over, would be straight into Central Bedfordshire.
This proposal was not part of the consulted and agreed Local Plan, nor was it part of the consultation on the Preferred Options for the Core Strategy.
There has been no consultation or community involvement with Central Bedfordshire Council, Central Bedfordshire settlements in the area, or indeed the East of England Regional Assembly, as Central Bedfordshire falls within the East of England Plan Region, not the South East England Plan Region.
Additionally we consider that the Policies Numbered and Paragraphs Numbered above are not legally compliant they do not conform generally to the published SE Regional Spatial Strategy which requires Milton Keynes to test further long term expansions east of the M1 within its own not insubstantial rural area; nor do they conform generally to the published EE Regional Spatial Strategy which gives no reference to expansion of Milton Keynes into Central Bedfordshire. This last RSS is currently subject to review, which will not be finalised until towards the end of 2011, and will test the S of States view that 5,600 dwellings can be accommodated in Aspley Guise as part of a SE extension of Milton Keynes, west of the M1. The East of England Review will not be considering any other extension of Milton Keynes into its Central Bedfordshire Region. The SE Joint Regional Strategy review is currently commencing, and of course can not consider development into another region, as was clearly recognised by the S of State, in her changes to the draft SE Plan before it was published.
We consider that the Policies Numbered and Paragraphs Numbered above are also unsound in respect of :
· future bridges over and/or a new Junction 13a at the strategic reserve area north of A421 and east of Fen Farm identified in the Local Plan proposals map as SR1, and Policy EA4 in the local plan; which would by its position cross into Central Bedfordshire, since the MK boundary with Central Bedfordshire is along the M1 for the full extent and more of the strategic reserve area SR1. Any Junction 13a or bridge over, would be straight into Central Bedfordshire.
in that they are neither justified nor consistent with national policy.
There is no robust or credible evidence base for such a proposal, there has been no local community or other stakeholders participation in such a proposal, there has been no sustainability assessment in respect of such a proposal, nor is it consistent with national policy in that it is at odds with published regional spatial strategies.
To put our views in context:
1. The SE Plan panel examination and report concluded that 5,600 dwellings as part of a 10,400 SE urban extension of Milton Keynes could be accommodated in the Aspley Guise Triangle.
2. The Secretary of State in her proposed changes, finally recognised that it was not legal for one regional plan to plan development in another regional plans area and initially proposed that the 5,600 dwellings should be accommodated within the MK unitary authority area in its not insubstantial rural area east of the M1. This caused an outcry from MK Council and MK Partnership.
3. Therefore the final published SE Plan at Policy MKAV1 and 2 reduced the Total Housing Numbers for MK by 5,600 leaving only 4,800 dwellings to be found in the MK part of the SE urban extension. The East of England Regional Assembly was required to assess 5,600 dwellings to be found in Bedfordshire as part of a 10,400 SE urban extension when they carried out the East of England Review. Para 23.10 of the SE Plan considered that in the longer term that future growth in MK may need to be accommodated east of the M1 motorway “but no allowance is made at this stage in the housing figures for Milton Keynes pending future review of the South East Plan and local development plan”
4. There is no requirement anywhere in the South East Plan, nor could there be, for further expansion of MK into Central Bedfordshire, which of course is part of the EE Regional Spatial Strategy
5. There is no requirement anywhere in the South East Plan, nor could there be, that if the conclusion of the EE Plan review is that a lesser number or no dwellings can be accommodated in the Central Bedfordshire area of the proposed SE Urban Extension of Milton Keynes west of the M1 that Central Bedfordshire should make up the shortfall.
6. There is no requirement anywhere in the South East Plan, that if the conclusion of the EE Plan review is that a lesser number or no dwellings can be accommodated in the Central Bedfordshire area of the proposed SE Urban Extension of Milton Keynes that Milton Keynes should make up the shortfall. The total numbers required of Milton Keynes in respect of the SE Urban Extension west of the M1 is 4,800 dwellings.
7. Since the publication of the SE Plan, the Society has had formal written confirmation, from EERA and the Government Office of the East of England, that should the EE Plan review conclude that there should be a number of dwellings in Central Bedfordshire as part of the SE urban extension west of M1 then the numbers of such expansion will count towards the revised EE Plan totals for housing in Central Bedfordshire, NOT the SE Plan totals for MK.
8. Prior to the examination of the Central Bedfordshire North Core Strategy Milton Keynes Council and Central Bedfordshire agreed in principle a Memorandum of Understanding for 2000 dwellings in Central Bedfordshire, subject to the inclusion of the Central Bedfordshire part of the SESDA in their Core Strategy and the East of England Regional Plan.
9. The inspector ruled that any such extension into Central Bedfordshire, and a proposed extension of the Greenbelt to protect settlements from coalescence was a matter for the EE Plan Review, and thus the adopted Central Bedfordshire North Core Strategy makes clear that “the context and extent of new development and number of homes to be delivered within Central Bedfordshire is to be assessed through a forthcoming review of the East of England Plan”
In summary it is not legally compliant or sound for Milton Keynes Council through its Core Strategy to unilaterally plan for future expansion into both another authority’s area, which is also in another regional spatial strategy area, by proposing:
· future bridges over and/or a new Junction 13a at the strategic reserve area North of A421 and east of Fen Farm identified in the Local Plan proposals map as SR1, and Policy EA4 in the local plan, which would by its position cross into Central Bedfordshire, as the MK Boundary with Central Bedfordshire is along the M1 for the full extent and more of the strategic reserve area SR1. Any Junction 13a or bridge over, would be straight into Central Bedfordshire.
We have become well aware that MK Council’s expressed view is to protect its not insubstantial rural area, and that its wish is to expand South East of the M1, with a view to incorporating Cranfield and other areas into Milton Keynes. However it is neither legally compliant nor sound for them to unilaterally include planning for this aspiration in their submission Core Strategy
Continue on a separate sheet if necessary. Mark any additional pages with your name or organisation
Q5. Please set out what change(s) you consider necessary to make the Core Strategy legally compliant or sound, having regard to the test you have identified in Q3 where your comment relates to soundness. You will need to say why this change will make the Core Strategy legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
Changes that would make the Core Strategy legally compliant would be:1. Amend para 1.8 to read “The Government published the final version of the South East Plan (SEP in May 2009. A proposal for a third SDA east of the M1 was deleted in the SEP. The Core Strategy reflects the final version of the SEP, which means that the possibility of a further SDA east of M1 is deferred for further testing to be undertaken during the plan period of this Core Strategy to inform a future review of the RSS and local development plan.”
2. Amend Spatial Vision Point 11 to read “Transport links to other towns, including Aylesbury, Bedford, Luton and Northampton will have been improved. These include the East-West rail link between Oxford and Cambridge via Milton Keynes, the A421 corridor through the city(linking the A1, M1 and M40, with land safeguarded for future crossings of the motorway north of Junction 14). Promotion of a direct train service from Milton Keynes to the European rail network will be underway”
3. Amend Para 6.7 to read “The Land East of Fen Farm SRA lies to the north of the A421 and includes a transport reservation for the Bedford and Milton Keynes waterway (Local Plan Policy T13)
4. Amend Policy CS5 by removing principle number 6 and renumbering the principles accordingly.
5. Amend Para 11.13 to read “The MKSM Transport Strategy identifies the need for better transport links with nearby towns including Aylesbury, Bedford, Northampton, Luton and, Dunstable to support the local economy, improve access to airports and major hospitals and support the growth in Milton Keynes’ population. In particular, we need to improve east-west transport links, including the A421 and the western section of the East-West rail link to match our north-south connection (West Coast Main Line, M1 and A5). The impact of the new high-speed rail proposal will need to be addressed. Junction improvements have been made at J14 of the M1 and J13 improvements were under construction in 2009-10. Land will need to be safeguarded for future crossings north of Junction 14. Improvements have also been made to junctions on the A5 in MK to mitigate the effect of growth on the highway network.”
6. Amend Policy CS 11 bullet point 7 to read “ Maximising the capacity of the Borough’s highway network through phased improvements in step with housing and employment growth (for example the duelling of the A421 and improvements to key roundabouts on the grid network)”
All and any other references that we may have missed to either a Junction 13a or future M1 crossings in the area of the Strategic Reserve Area North of the A421, and east of Fenn farm to be removed.
Continue on a separate sheet if necessary. Mark any additional pages with your name or organisation
Q6. If your representation is seeking a change, do you consider it necessary to participate at the oral part of the examination?