Central Milton Keynes Development Framework Supplementary Planning Document, January 2013

Consultation Statement This consultation statement sets out the consultation undertaken in the preparation of the Central Milton Keynes Development Framework Supplementary Planning Document (‘the SPD’)and the subsequent process to adopt the final version of the SPD. It sets out how the Council has complied with the requirements of Regulations 11 and 12 of the Town and Country Planning (Local Development) (England) Regulations 2012.

There has been an ongoing process of engagement with the businesses, land owning interests and local community interests in Central Milton Keynes in the preparation of the SPD. Preparation of the Draft Supplementary Planning Document During preparation of the draft Central Milton Keynes Development Framework SPD, the Urban Design team and the Development Plans team undertook consultation with other stakeholders and the main landowner interests in Central Milton Keynes together with key Council departments, especially Highways and Development Management. These consultees have provided technical and supporting information to provide the basis for the Development Framework.

As this is very much a review of the existing CMK Development Framework (2002), an important part of the preparation process has been a review of the lessons that have been learned over the intervening years since that original Development Framework was adopted. During 2011 interviews were carried out with members of the development industry active in CMK and representatives of the business community. Discussions followed with elected members and key stakeholders around the quality and impact of completed developments, the implementation of key policy/principles, changing policy, governance arrangements as well as the changing economic outlook. (Lessons Learnt note attached at Appendix 1).

In order to understand the future residential requirements for CMK and what sort of homes should be built in the future the council undertook a survey of CMK residents in September-October 2011. The survey asked for their views and experiences of living in CMK and whether the housing meets all of their needs (survey results at Appendix 2) . This issue was developed further in a meeting with developers and key stakeholders to discuss the future of the residential market in CMK, which was held in January 2012 (notes from the meeting at Appendix 3)

A Stakeholder Workshop was then held in March 2012 with representatives of Council departments, developers, the Town Council and other interested parties to discuss the issues and options arising from the preliminary work on the Development Framework Review (notes of workshop attached as Appendix 4).

Informal Consultation

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During March through May 2012, the Council undertook Informal Consultation on the emerging issues and options for the CMK Development Framework review as part of the online ‘wiki’ consultation on the emerging CMK business neighbourhood development plan process.

The Informal Consultation was an opportunity for local residents, local Ward Councillors, local Parish/Town Councils, service providers and other interested stakeholders to find out about the direction of travel of the review and to add their own comments to the document. The comments made are reflected in the draft SPD.

Strategic Environmental Assessment An SEA Screening Report was produced to assess the requirement for a Strategic Environmental Assessment of the draft SPD. This was sent to the statutory bodies. One response was received, from the Environment Agency, which confirmed the council’s opinion that an SEA is not required.

Regulation 12 Consultation on the Draft SPD The draft SPD was subject to the following consultation arrangements:

a) The Draft SPD and supporting documents (SEA Screening Statement, Consultation Statement) were made available for inspection:

at Civic Offices, 1 Saxon Gate East, Central Milton Keynes, MK9 3EJ at all of the borough libraries. Library locations and opening hours are

available from: http://www.milton-keynes.gov.uk/library_services/displayarticle.asp?ID=67529

on the council’s website: www.milton-keynes.gov.uk/udla

b) A press release was issued to the local newspapers with information about where a copy of the documents could be obtained and when and where the documents could be inspected.

c) A covering letter or e mail was sent to consultees on the Council’s Objective ‐consultation database, notifying them of the publication of the draft SPD. Consultees included:

all specific consultation bodies those General consultation bodies with an interest in the draft SPD planning agents, developers and landowners with an interest in Central

Milton Keynes d) To ensure all stakeholders had an opportunity to comment, and taking account of the earlier informal consultation period, a period of 8 weeks consultation was allowed for the draft SPD. The consultation ran from Monday 17 September to Monday 12 November 2012.

Consideration of representations received during the consultation period

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Following consultation, all comments were reported to the Council for consideration and the SPD was amended where necessary prior to adoption. Representations on the SPD and a council response to them are set out in Appendix 5.

Members Workshop, 29 November 2012On the 29 November 2012 the consultation responses were considered at a workshop held with elected members. The workshop focussed on the responses received and looked in detail at the key issues including the level of protection to be given to the public realm in CMK; the protection given to the connectivity of the grid; changes to building lines; the need for character areas and the role and status of the SPD. A summary of the issues discussed is set below.

Issue raised in consultation Workshop view

The DF is not visionary enough, no wow factor!! Adhering to the Block Structure should not discount innovation. Network Rail is an example. Amend the DF to state this otherwise members happy that it is visionary enough

Boundaries of the study area Members agreed with the existing redline boundary that includes both sides of the greenframe

Does the DF sufficiently protect the public realm infrastructure?

Members agreed that the proposed wording saying “that changes to the infrastructure will only be considered and permitted if significant public benefits result” would on the one hand offer enough protection of the public realm and give a clear message that the presumption is to protect it but on the other hand would also allow flexibility for alterations to occur.

Does the DF sufficiently protect the connectivity of the CMK grid?

Members agreed that the existing wording in the draft DF does offer the appropriate level of protection to the connectivity of the CMK grid. It provides protection of the CMK grid as well as a degree of flexibility that would not put potential investors from coming to talk to the council about their potential project

How much importance / certainty should be attached to the Bus Hopper Service?

It was agreed that it should be more of an aspiration than be shown in such detail in the Framework. There was a wider issue of wayfinding to direct visitors arriving at the central rail station to the many buses (some 42 per hour) that connect Station Square to the city centre.

Should the Midsummer Place PT / pedestrian link be protected?

Agreed that the DF would highlight the link as a factual representation of the existing walkway agreement. This has nothing to do with it as a

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future PT link. NB: for consistency the other walkway agreements across CMK should also be shown on a plan.

Should Witan and Secklow Gate be seen as District Distributors like Grafton, Saxon and Marlborough Gates?

Discussion around the status of Witan and Secklow Gates. The opinion of Transport officers is that the gates correspond to district distributors (MKLP para 7.28) but that this does not include Witan and Secklow Gates, as these are not shown on Plan T1 in the local plan. The other gates (Grafton, Saxon and Marlborough) have a greater level of connectivity with the wider grid than do Witan and Secklow.

The DF allows building lines to come forward within B4 and Campbell Park in line with existing outline planning consents. Should this be allowed?

Members disagreed with this. Wording should be added to the DF to state that the same principles will apply for B4 and Campbell Park as for the rest of CMK.

Is a new civic square needed for CMK? It was agreed that the site for a new civic square should go on the temporary surface level car park next to the Point. It was also agreed that the Plan should include an asterisk/star on the car park to site to highlight the location.

Are character areas needed? Members agreed that the character areas identified are important to retain. It was agreed to highlight Block F1 for educational or major investor use

Should mixed use development be encouraged for every new development?

Members disagreed that mixed use developments should be encouraged for all new development in CMK – leave the current approach in the CMK DF Review as it is.

Should buildings of architectural heritage be included? The alternative maybe to require a local list to be compiled

Members agreed that other than the listed centre:mk no other buildings should be highlighted. The DF should rather point to the forthcoming production of a local list comprising buildings of heritage.

Should the DF require car parking demand to be ‘managed‘ (through eg increased car parking charges) as a way of improving public transport usage.

Members disagreed with this wording. It was agreed to include the wording included in footnote 79 to Core Strategy Policy CS11

Should the SPD say what the financial contribution should be if a developer does not meet the parking standard provision?

The SPD should state the required financial contribution for unprovided but required parking spaces should be increased but an actual amount should not be included

Should the SPD say Campbell Park is predominantly for residential use – one

Members agreed that Campbell Park should predominantly be residential

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representation said it should be kept for a substantial amount of employment use

Should the DF be saying that Campbell Park is more suitable for family housing – will this create opportunities for HIMOs to flourish?

Members disagreed with this and stated clearly that family housing should not be included in either Campbell Park or CMK. The DF could say that Blocks A,B,C,D and E are more for young professionals and Campbell Park for empty nesters and people downsizing

AdoptionOn 30 January 2013, Cabinet considered the consultation responses to the draft SPD and the proposed changes to the document arising from the responses and as informed by the Member workshop. A number of minor updates and addenda to the revised CMK Development Framework needed to correct drafting errors were also considered and accepted by Cabinet. The Cabinet report is available from: www.cmis.milton-keynes.gov.uk/CmisWebPublic/Meeting.aspx?meetingID=9987

In line with the recommendations in the Cabinet report, the Central Milton Keynes Development Framework SPD was formally adopted on the 30 January 2013.

Further information is available from: www.milton-keynes.gov.uk/planning-policy

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APPENDIX 1

CMK Development Framework ReviewLessons Learnt Since Development Framework was adopted in 2002

EXECUTIVE SUMMARY

This Report has been prepared to understand the Lessons Learnt since the CMK Development Framework (DF) was adopted in 2002 and will be used to inform and underpin new policy for CMK as part of the reviewed DF.

National and Local Context

1. The national context in terms of government policy on the development of cities, EP/HCA’s remit nationally and locally as well as the national economy, were together very different in 2001 than today

Process

2. The DF identified itself a strategic and visionary document, not a delivery or implementation plan, yet despite it recognising and identifying the need for further studies and briefs to assist with implementation, it was seen in 2002 as ready to deliver development. In some areas it clearly wasn’t ready to deliver development and it is worth considering whether clearer policy or the completion of the additional studies and briefs identified would provide greater clarity and certainty to developers and increase investor confidence.

Policy that has underpinned development and associated infrastructure in CMK and impacted on Viability

3. There have been a significant amount of new high density apartments built in CMK with outline approval for many more. The critical question now is, “What is the residential market for CMK and what sort of residential mix would be most appropriate and deliverable for CMK over the next 20 years?”

4. Linked to the above is the current policy requirement for a minimum of 100du/ha. Does this act as a constraint in terms of the types of housing that might be desirable in the future in CMK

5. The revised affordable housing mix with 25% social rent has been shown to affect the viability of schemes

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6. Evidence suggests it is not practical to ‘pepperpot’ affordable flatted housing with market housing within the same floor. It needs to be done per floor/core or per block.

7. Mixed Use Development. Horizontal mixed use development (residential above offices) is not supported or feasible. Care also needs to be taken to not vertically mix office and residential uses in very close proximity.

8. The identified quarters are perhaps over-complicated and don’t make commercial sense. They probably encouraged too much dispersal of mixed use development and offices in particular which has the effect of reducing land values.

9. The parking aspects of the CMK Planning Obligations SPG need revisiting, in particular the fact that 70% of development provision goes off site as public parking yet no financial contribution is required

10. The amount the council receive for a displaced parking space is approximately only 1/6th the value of a new parking space in a MSCP

11. Multi-storey car parks have not been delivered for a variety of reasons no least because of the current payment received for displaced surface level parking

12. Overall quantum of surface level parking should not be reduced until such time as a credible parking strategy for getting people into CMK is found

13. While evidence suggests very few businesses have left CMK because of parking, some new businesses have not come into CMK because of the parking regime.

14. Businesses have indicated that they would be more content with the current parking regime if the longer term vision for parking and public transport was made clearer

15. Bringing building lines forward to boulevards and gates has been difficult and / or impractical to achieve for a variety of reasons

16. The principle of bringing building lines forward in existing areas of development is believed to have had an impact on confidence of existing investors and potential new investors

17. If building lines are too come forward, new footpath widths need to be increased from what was envisaged

18. If a fine grained CMK is desirable (as per the DF) with numerous pedestrian routes, it needs to be questioned currently whether routes should go around blocks or through blocks (or a combination of both as currently occurs).

Developments Completed in last 10 years

19. The Hub: While a mixed use development was achieved, the layout did not accord with the DF as the development did not follow the perimeter block concept with active frontages facing outward onto the public realm and a defined private interior.

20. C4.1 (Sainsbury’s / Vizion): This development demonstrated more closely than the Hub what can result from adhering to the perimeter block layout with a clear public and private interface and active frontages to

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most areas of public realm. An internal pedestrian route does however to an extent undermine this and is one slightly less successful feature of the scheme

21. There is divided opinion as to the quality of environment and benefits that have been delivered by closing in of the Witan / Avebury underpass and bringing forward of building lines between the Hub and Vizion.

22. Block E3 (Theatre District Phase 2) and the Pinnacle both demonstrated the benefits of adhering to the DF principles of perimeter block development with a clear public side and private back.

23. Network National Rail Centre: this development demonstrated firstly the flexibility in the DF and secondly, the reluctance to bring building lines forward

Proposals

24. the centre:mk: this demonstrated that firstly the project was perhaps too ambitious and secondly that the viability was an issue because of the extensive modifications and improvements that were required to public infrastructure but which were an inherent part of the planning application to adhere the urban design objectives for CMK

25. Xscape: the current proposal, as with the Hub, demonstrates the difficulty of having linear blocks with dual fronted buildings that have high quality public realm on both sides of the block

26. Lloyds Court: consultation on a brief for this site has indicated the lack of support for firstly potentially bringing building lines forward at all, and secondly for potentially building in the ‘greenframe’.

27. The Lloyds Court Brief has also highlighted that the original layout of highway infrastructure was designed to allow heavy duty vehicles to move around development blocks and if building lines are brought forward and / or development is included within the outer row of North or South Row, this would require modifications to existing infrastructure to enable these movements to still easily occur

28. Campbell Park Canal Side Development: The isolated position of this site, together with the downturn in the market and the significant infrastructure requirements needed as part of the development all led to the returned tenders been deemed unacceptable to proceed.

Delivery and Governance

29. Lack of clarity – while the CMK Team had a defined co-ordination role, various other agencies including the council still had responsibility for delivery of certain aspects of the DF and these were not always consistent with the DF.

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30. No single point of contact – the CMK Team could not play this role, many programmes and strategies which related to or impacted on the DF were the responsibilities of other organisations

31. Mixed Messages – the above 2 points led to mixed messages being delivered investors/developers which led to delays and hence incurring of extra costs

32. Lack of a champion for CMK33. Changing governance arrangements with the establishment of

MKP/MKPC which added further confusion and bureaucracy34. The impact of undelivered developments meant non-delivery of the

‘softer’ outputs of non-development projects identified in the DF(from eg s106 funding)

35. Projects were too complex and over-ambitious particularly because of the modifications to public realm infrastructure that was intrinsically linked to the development. If developments got abandoned infrastructure changes would also fall away. Consideration needs to be given to decouple public realm proposals and infrastructure changes that are doubtful from development opportunities

36. The economic climate was very strong in 2000 and development values were good which together with EP’s remit to support growth and their landholdings in CMK led to very ambitious proposals. The economic climate is now different and the HCA resources are very different. Less ambitious and more ‘focussed’ proposals and policy should therefore be considered.

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1. Introduction

1.1 Purpose and Aims of Report

1.1.1 The purpose of this report is to highlight and understand the lessons learnt since the DF was adopted in 2002 and how this impacted on and influenced the delivery of development in terms of :

Context – national and local Process Policy that has underpinned development and associated infrastructure in

CMK and impacted on Viability Developments completed in last 10 years Proposals Governance and Delivery

1.1.2 This will consequently guide and inform the preparation of the new policy as well as issues around governance and delivery to be prepared as part of the drafting of the Reviewed CMK DF.

1.1.3 The aim of the report is to present Lessons Learnt that are as factual as possible rather than on subjective views and anecdotal evidence.

1.1.4 Numerous comments were made about CMK in general. While these may have a bearing on the creation of new policy and principles for CMK, where they are not directly attributable to the DF (and hence lessons learnt from it), they have been omitted.

1.1.5 As part of the consultation on Lessons Learnt, there were numerous comments made about business growth. While these comments are not directly attributable to the DF, they are felt as useful in the context of understanding future business growth in CMK and have therefore been included as Appendix A. The Council’s Environmental Health Team also made comments on the Lessons Learnt report regarding issues of noise and taxis concerning licencing and mixed use developments. These again are not directly attributable to the DF but have been included for interest as Appendix C

1.1.6 It is important to note that the role of this document is not to identify solutions, these will emerge as part of subsequent stages of the review of the CMK Development Framework.

1.1.7. It is recognised that these Lessons Learnt don’t necessarily represent an exhaustive list – additional Lessons Learnt may emerge as the review of CMK Development Framework progresses.

1.2 Context

National

1.2.1 The Central Milton Keynes Development Framework was commissioned in Autumn 2000 at a time when the recently completed government commissioned Richard Rogers Urban Task Force : Towards an Urban

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Renaissance (1999) was promoting more compact and walkable cities. The Governments Sustainable Communities Plan (2003) was also being prepared which reinforced much of what the Task Force Report was recommending.

1.2.2 Milton Keynes was identified in the Sustainable Communities Plan as one of the Growth Areas. As part of this English Partnerships (EP) were given a new role to support development and regeneration across the growth areas, reflecting the priority that the Government attached to accelerating their development.

1.2.3 In 2000, the national economy was also very strong. This together with the Government drive for sustainable growth allowed the Development Framework to be very ambitious in its proposals

Local

1.2.4 The Development Framework (DF) was commissioned in Autumn 2000 to shape the growth of CMK to rise to the challenge of growth and further development as the original 1970s masterplan of Milton Keynes Development Corporation (MKDC) was nearing its completion. Only one city block (B4) and much of Campbell Park, plus a range of smaller infill sites, remained untouched. Forecasts were that that these sites would be developed out by 2006 if the MKDC plan was completed – giving rise to a need for a new framework for future growth and delivery in the city centre.

1.2.5 The DF established a revised urban form but also responded to the economic, cultural and community needs facing the new city of almost 250,000 citizens, planned to grow further in the coming 30 years with up to 70,000 additional homes. To prepare for this second generation of development, the Framework sought to optimise the potential of the land and development assets in a maturing city centre but also sought to respond to the changing needs of the increasingly diverse population and to strengthen and grow the economy. It is focussed on the needs of existing residents and employers, but also on future inward investors, new residents attracted to Milton Keynes and to visitors.

1.2.6 The proposed masterplan would also alter the established ways of managing and delivering projects.

1.2.7 EP also had considerable land assets in CMK, which together with its remit of supporting growth and development was seen as a key vehicle for helping deliver a more walkable, compact CMK through the changing of its structure. This again allowed Development Framework to be very ambitious in its proposals.

1.2.8 It is worth noting that the CMK DF did not occur in a policy vacuum and was informed by various pieces of work prior to its commencement. A timeline of other projects that led to the preparation of the DF is included as an Appendix B.

2. Lessons : ‘Process’

2.1 Conflict between Vision identified in DF and Perception

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2.1.1 On one hand the DF identified itself as a visionary and flexible strategy, not an implementation / delivery plan. Furthermore because the preparation of the DF took several years and coincided with the preparation of the Local Plan, it created a policy vacuum leading to a hiatus in development. In recognition of this and because of the pressure to get on with projects in CMK, the DF was not as detailed as initially intended. This in part led to the DF identifying various further stages of work that were needed. These included:

Development Briefs for individual sites and quarters. This was seen as important because the DF established strategic principles and objectives for the whole of CMK which it said would need to be interpreted within the opportunities and constraints of specific sites/quarters.

To inform the preparation of the Briefs, a number of studies were required:

The impact of changing building lines on the boulevards Maintenance and management of existing and future public realm Financing of Public Realm Density and scale study to set parameters Wider transport study of MK A landscape strategy

2.1.2 On the other hand, and despite these above further studies identified as needed, the perception in 2002 was that the Development Framework was ready to deliver development, yet no work had occurred on how it is to be delivered (for example the 3 dimensional aspects pertaining to level changes, the impact on existing utilities, or the issue of bringing building lines forward in places of existing development).

2.1.3 Much of what is identified in 2.1.1 above has not been prepared. In recognition of the above, in 2008, the CMK ‘Guidance for Delivery project was set up by the CMK Team (on behalf of the joint arrangement between MKC and EP) with workstreams covering Block Parameter Plans, Tall Buildings Strategy, Greenframe Strategy, car parking etc. At the time the Guidance project was getting underway, the changes to the CMK governance were taking shape which led to the shift in responsibility from the CMK Team to an MKC lead. While the Tall Buildings Strategy SPD was taken to the stage of formal consultation, no further work on these workstreams has occurred.

2.1.4 The Council have however recently started preparing development briefs for sites where a developer interest has been shown with the intended benefit of providing more certainty to a developer about the principles applicable for that specific site.

2.1.5 Based on the above it needs to be questioned whether around certain issues (such as building lines, car parking, greenframe) there needs to be clearer policy or acknowledgement that further studies are needed and agreement that they are undertaken. This would have the benefit of providing greater clarity and certainty to developers and increase investor confidence.

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3. Lessons : Policy that has Underpinned Development and Associated Infrastructure in CMK and impacted on Viability

3.1 Residential Mix

3.1.1 One of the most important steps forward in CMK as identified in the Development Framework (DF) has been the introduction of significant elements of urban residential living in CMK. This has created a new market, moving on from the generally lower-grade and low density residential to be found in CMK. This has balanced sale with key worker and affordable housing; buy-to-let and corporate-lets; first time homes with luxury apartments. Each of these markets was ill catered for in CMK prior to the Development Framework.

3.1.2 CBX3 Phase 1 and C4.1 have delivered over 920 residential units. The developer dictated the mix particularly in the Hub where at the time Buy-to-Let was very popular and 1 and 2 bed apartments were the dwelling type that buy-to-let investors knew would sell. In C4.1 for example, ‘blocks’ are being run as serviced apartments

3.1.3 While there has been considerable growth in MK over the past 20 years and the fact that almost anything built can be sold and occupied,(developers will build what the market can sell) doesn't however prove there was specifically a greater demand for small apartments than for many other kinds of dwelling that could have been built in CMK (or MK).

3.1.4 The critical question now is, “What is the residential market for CMK and what sort of residential mix would be most appropriate and deliverable for CMK over the next 20 years?”

3.1.5 Too many small apartments attract the ‘buy to let’ market but do not create settled communities

3.1.6 The introduction of a greater proportion and range of family accommodation could positively contribute to neighbourhood development but does the additional cost of delivering larger units in an urban setting mean that they are not necessarily good value for money when compared to ‘suburban’ Milton Keynes where there are abundant opportunities for family housing in a perhaps more appropriate suburban setting? There is for example a considerable amount of (albeit lower cost) family housing within the estates immediately around CMK.

3.1.7 The current plans in terms of the 2 key sites in CMK for residential development (ie West End and Campbell Park) are similar in terms of residential density and mix which doesn’t acknowledge that there is potentially two very different markets. It is suggested that further investigation / discussions is needed to decide what is desirable and required regarding residential uses for these 2 key sites. It might be that a different ‘USP’ is created for each of these areas would broaden the market appeal.

3.1.8 Understanding what is appropriate and deliverable in CMK regarding residential mix is also important in terms of potential pupil yields and school planning.

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3.1.9 It is important to understand who homes are being built for in CMK. Evidence from the Centre for Cities indicates that at the higher end of the labour market, advanced producer services, such as accountancy, advertising, finance and law are increasingly concentrating in high cost city centre locations. This is even more the case for CMK where there is an increasing focus on the growth of knowledge based jobs/industries (1 of the 6 priorities of the MKC Economic Development Strategy). At the same time lower skilled jobs have been slowly dispersing out of city centres. Does this help in establishing a certain market in terms of future housing in CMK?

3.1.10 As a separate but related issue, the Centre for Cities report say that in cities, worklessness, is often concentrated in inner city locations partly driven by the housing offer – leading to a spatial mismatch between where workless city residents live and where the lower skilled, entry level jobs are located.

3.2 Residential Densities

3.2.1 The DF and Local Plan require a minimum of 100du/ha for residential development in CMK and Campbell Park. While there is not a clear direct relationship between density and urban form, this minimum density does require a higher degree of apartments.

3.2.2 Developers struggled with sales and viability on Campbell Park Phase 1 which is why the site has stalled pending redesign of the remaining section, which is for more townhouses and fewer apartments to reduce the amount of basement parking and reduce construction costs. This demonstrated that a mix of just 23% townhouses and 77% flats (1,2&3 bed) only just manages to meet the minimum local plan density requirement (100du/ha) by achieving a density of 106 du/ha. There is no evidence to suggest that the replan is driven by an increased demand for family housing rather than a fall in demand for flats and very expensive construction methods.

3.2.3 If there is therefore an increased demand for family type accommodation this will reduce the density such that it will be difficult to comply with the above mentioned policy on density requirements. This therefore may require a relaxation of local plan policy.

3.3 Affordable Housing

3.3.1 The Affordable Housing requirements under the Outline permissions for both the SRQ and Campbell Park are under the Affordable Housing SPG – 25% Intermediate and 5% Social Rent – so the Social Rented housing does not have much impact on the overall housing. Council housing records show that there are approx 45-50 Social Rent units in C4.1 & CBX3 and none in Campbell Park. B4.4 (West End) site has been tendered in accordance with the current planning approval and s106 agreement including a 25% Intermediate/5% Social Rent affordable housing mix, however developers are required to submit an alternative bid based on the revised affordable housing mix which will show any impact on scheme viability.

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3.3.2 The argument against changing the Affordable Housing mix in remaining phases of these 2 key sites to address current Affordable policy and need, has been that it adversely affects viability.

3.3.3 The Government and the HCA expects Affordable Rent (where the tenant is charged up to 80% of Market Rent) to replace Social Rent on new developments – Affordable Rent is expected to house the same client group as Social Rent, but it doesn’t.

3.3.4 Evidence from the Vizion has shown that it is not practical to ‘pepperpot’ affordable flatted housing with market housing within the same floor. It has been stated that it need to be done per floor/core or per block.

3.4 Mixed Use Development (office/residential and retail/evening economy and residential)

3.4.1 The reluctance of institutional investors to ‘buy into’ horizontal mixed use (residential/office) development has reduced the attractiveness of commercial sites and could have a negative impact on the aspiration to improve the office market offer

3.4.2 The implementation of new office developments has been constrained by the proximity of the sites to new/proposed residential development. Elsewhere in CMK mixed use office/residential development sites have not proved attractive to the market, and investors have expressed concerns through IMK that anything more that discreet amounts of residential development in a primarily business environment (ie the Central Business District) can seriously deter occupiers from the area. This has been confirmed by DTZ Consulting who has previously advised that horizontal mixed use office/residential development is unattractive to institutional investors.

3.4.3 While vertical mixed use development (eg residential adjacent to offices) does contribute to the vitality of a city centre, it needs to be carefully considered (especially where extensive glazing and / or balconies are incorporated) when in close proximity to office accommodation. Businesses within Metropolitan House at the Hub have for example, expressed concerns about the close proximity to the residential units within Staten House, where there is only a very narrow gap between the 2 buildings. While not necessarily a lesson for the DF, Appendix C highlights some comments from the Council’s Environmental Health Team regarding evening economy mixed use development.

3.5 Quarters

3.5.1 The DF identified an extensive series city centre quarters as well as quarters within quarters. The description of each quarter was not intended to be land-use zoning exercise but rather provide a an outline of the nature, location and aspirations and principles of development that will give each part of CMK a distinct character and Key Projects that will define the character of different parts of CMK.

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3.5.2 This delineation of Quarters is not unusual – the 1992 Planning Manual did something similar with a Principal Zones for Central Milton Keynes Plan which outlined some quarters of similar character to that identified in the DF.

3.5.3 It could however be argued that these quarters need to be revisited for the following reasons:

3.5.4 The quarters plan is too complicated with too many quarters outlined that don’t appear to have a clear rationale and hence don’t help clarify and assist in investment decisions.

3.5.5 It is not clear in practice, or in any operation of the local commercial market, that there is any relevance to the identified quarters. There appears to be no sense that the City Spine, City Core, Business Hub, Central Business District and Enterprise and Knowledge Quarter can be distinguished.

3.5.6 The quarters appear to currently allow a liberal spreading of mixed use development throughout CMK, whereas it might be that a more zonal allocation is sought which is thought to better suit commercial realities and the needs of the business community. For example, by being more prescriptive on the predominant location for office uses, this would then restrict the sites available in CMK for offices (ie take capacity out – there are seen to be too may potential office sites currently available which has the effect of bringing land values down and rental values down) and in turn increase land values and rentals

3.5.7 The Sustainable Residential Quarter is in particular, questioned. Further work as part of the CMK Development Framework should identify an appropriate character for it.

3.5.8 The Enterprise and Knowledge Quarter has also not delivered any new development and the following should be questioned:

Sustainability of currently proposed land uses is questioned. Doubts at being able to anchor the Knowledge and Enterprise

Quarter to an educational establishment. No real driver to attract research and knowledge industries to this

quarter. UCMK - requirements and accommodations can be catered for in other

parts of CMK?

3.6 Car Parking

3.6.1 The DF identified the reordering of parking provision and management of parking as central to the release of land to meet urban design, movement and development aspirations.

3.6.2 The principles of parking provision as outlined in the DF were to increase provision in line with new development coming forward (at reduced ratios) and progressively replace surface level parking with decked solutions.

3.6.3 Parking management in CMK through the increase of parking charges was highlighted in the Framework as important to encourage the use of public transport in the city.

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3.6.4 Importantly, the Council does now have a proper assessment of public parking use and availability which can guide future changes and respond to demand as well as when development comes forward and displaces existing provision. This assessment was not available at the time of preparing the Framework and will be an important tool in managing future change.

3.6.5 The Council is also using this data of parking usage to change parking charges in certain areas.

3.6.6 It has shown that since the recession started, the amount of available parking within CMK has in fact increased.

3.6.7 The SPG for Planning Obligations in CMK has had a key impact on the delivery of car parking (for commercial development) in CMK and Campbell Park and this has had a knock on effect for other users of CMK . Under the SPG a maximum of 30% of the permitted car parking can be accommodated on site, the remaining 70% is expected to be provided off site and publicly available, assumed to be in MSCPs. While the rationale for a maximum of 30% made sense from the point of view of preventing developments from being surrounded by huge swathes of surface car parking which could undermine the pedestrian experience among other problems, the SPG does not however require a contribution from developers for the remaining 70% off site parking (however, this was usually captured in the HCA land deal). The level of contribution was initially set at ‘nil’ in the SPG (but with the expectation that the SPG would be updated as investor/developer confidence in the CMK market grew and values increased. To bridge the gap furthermore, EP provided temporary car parks on their land to meet the additional parking requirements, so there hasn’t been a shortfall in parking.

3.6.8 Notwithstanding the above, the implication is that new offices provide insufficient on plot parking with the result in parking overflow, which particularly considering there is no more areas in CMK to build temporary car parks means there is a reduced amount of parking spaces available to CMK's other user groups.

3.6.9 Developers are required to pay £2500 for replacement parking if they can’t reprovide displaced parking on site which is only about 1/6th of the cost of a space in a MSCP. Furthermore if the Council does not reprovide these spaces within a certain time period, then the £2500 per lost parking space has to be repaid to the developer.

3.6.10 With respect to Campbell Park, neither the CMK DF nor Illustrative Framework Plan for Campbell Park acknowledge that, unlike CMK, a large pool of public parking is not available. In consequence, while the SPG like in CMK requires a maximum of 30% parking on plot, the absence of public parking means that the car parking requirements have to be met within each site boundary, which has a significant impact in terms of financial viability and land take. In addition the delivery of 100% parking on plot is contrary to the SPG for planning obligations; MKC have agreed to be flexible on this policy providing 70% of the spaces are publicly available, however, management of the public/private split and potential secure by design issues have not been resolved (see further comment below).

3.6.11 Delivery of the new interceptor peripheral multi-storey car parks has not been possible to date for a number of reasons, but primarily due to:

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o Financial viability; low parking charges v high delivery costs . Currently for a fairly low specification car park operating on 80-90% of capacity between 7am and 6pm), an operative would need to charge 50p/hour to make the MSCP viable to operate. Currently employees in CMK can purchase scratch cards for 15p/hour which is less than a third of what is required to make the MSCP viable. Put differently, if employees are to use MSCPs the latter would need to undercut the current £1.20 per day for parking.

o The Council have slowly been increasing parking charges for surface level car parks (for example very little free parking now exists) but there is still some way to go (as illustrated above) before MSCPs become viable to an operative.

o Location ; there is still significant resistance from the business sector to the principle of parking at arrival point rather than destination.

o The Theatre District Car Park which is considered fairly peripheral (but less so than ones located in the Greenframe) was only 10% occupied (except at Christmas) when charging just 20p/hour

o With the Theatre District Car Park currently being one of the few places to park for free in CMK, it is now full, but clearly this is not viable for the operating of a new peripheral MSCP.

o Political Support ; MSCPs are essentially needed to replace lost parking if building lines come forward and this principle is far from supported by local stakeholders.

o ‘Hearts and Minds’ ; workers and visitors to CMK have got used to parking in very close proximity to the ‘front door’ – the principle of walking from a MSCP is not yet accepted

o Land availability ; the Development Framework sites the MSCP in the Transport Corridor (Green Frame) around CMK. The Green Frame is leased to the Parks Trust who has stated that they will not release land for development on an ad hoc basis and without the benefit of a comprehensive Green Frame Strategy. The Green Frame Strategy has been identified on the LDS to come forward as SPD but is currently awaiting resources and a decision about peripheral MSCPs.

o Integration into the urban fabric ? MSCPs are notoriously difficult to design well

3.6.12 With peripheral MSCPs not coming forward, consideration has been given to increasing the amount of parking provided on site. From an urban design point of view, if this is provided in basement or integrated MSCPs this would not generally detract from a high quality public realm. The Pinnacle for example provides 40% of its parking on site in basement parking. Further consideration perhaps needs to be given to the current parking standards to allow a greater proportion of on plot parking for offices (and their customers) particularly if there is nowhere else to build temporary surface car parks.

3.6.13 The other related issue that hasn’t been resolved is if there is 100% provision on site with 70% publicly accessible then concerns regarding security are raised. It is more difficult to secure a MSCP if it is part private and part

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public. This is the main reason why Network Rail National Centre is providing 2 separate MSCPs (1 public and 1 private).

3.6.14 The basement parking provided at Sainsbury’s in the Vizion is 100% public (3hr free parking) and is well utilized. One problem has however been around the opening times. It was written into the S106 agreement that it be open 24/7, but because of security concerns raised by the Police it now shuts when Sainsbury’s closes at 11pm. This has had a knock on effect for parking at the Hub where customers regularly require parking later than midnight.

3.6.15 The Council did trial a free bus service circulating through CMK from the bus station at Christmas 2010, but it had a very low uptake. It would appear shoppers would prefer to drive around looking and waiting for an available space, although limited marketing also contributed to the low usage.

3.6.16 Similarly, Park and Ride schemes have not proved popular, with shoppers preferring to drive around and waiting for a surface level space to become available. It would appear that until an incentive exists to use the Park and Ride it will not be an attractive option.

3.7 Impact of Parking Regime on Businesses in CMK

3.7.1 Public car parking is principally poor for staff who have to go out and return within the working day – finding parking on return has been said to be difficult

3.7.2 It is suggested that visitors will generally pay up to 3 hours for ‘red’ parking which is acceptable for visitors coming in for a meeting, but there should be the right number of red bays to match this need.

3.7.3 Evidence suggests very few businesses have left CMK because of the increase in parking charges (businesses that leave also leave for other reasons). There are other factors that businesses consider in leaving a city centre location and key ones are about staff retention – many staff like city centre locations because of the amenities on offer in a city centre location.

3.7.4 Evidence does however suggest that the increase in parking charges have put off new businesses coming into CMK. These businesses prefer business parks outside of CMK where there is not just more and cheaper parking but rents are cheaper. There is evidence of recent businesses coming into CMK in CBX because of the benefit of existing parking spaces within the linked MSCP that can be rented.

3.7.5 Research by MKCCM of businesses in CMK has indicated 100% of businesses were satisfied with CMK as a business location. When asked what the worst thing about CMK was in terms of operating a business, 39% said parking availability, cost and charging regime. When asked specific questions on parking the highest percentile of respondents agreed with the ‘quite satisfied’ category.

3.7.6 Businesses have indicated that it is frustrating with the current surface arrangement of surface level parking, to direct clients (when visiting their offices) to available parking. Clients end up driving around looking for parking instead of simply being directed to a specific identifiable MSCP. Wayfinding of available parking is a key concern.

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3.7.7 Businesses have indicated that while the feature of being able to park close to the front door is still an expectation, what has become more important is simply knowing where to park.

3.7.8 One reason why Ashton and Norfolk Houses may be vacant is that there is no allocated parking spaces for tenants.

3.7.9 It would appear that there should be an investigation into the distribution of the types of parking. Businesses in major office buildings have difficulty finding available parking in the middle of the day because there is no short-stay parking for businesses. Premium rate is theoretically short-stay (due to the cost of staying all day) but these are often full for several hours.

3.8 Public Transport and Parking

3.8.1 Businesses have indicated that they would be more content with the current parking regime if the longer term vision for parking and public transport was made clearer. Currently all they see is parking charges going up, with no future alternative offered.

3.8.2 There does not yet appear to be an overall credible public transport strategy for getting the hoped-for numbers of people into CMK - shoppers, shop staff, office staff, leisure visitors, residents, commuters, transport hub users, hotel staff and guests, etc to suggest that the overall quantum of surface level parking can be reduced.

3.8.3 It would appear critical that public transport improves within and into CMK before an argument can be made to reduce surface level car parking.

3.9 Bringing Building Lines Forward

3.9.1 A key principle of the DF was to bring lines forward along Boulevards and Gates, where appropriate, to achieve a more human scaled and pedestrian friendly city centre.

3.9.2 The DF did however acknowledge the difficulty in bringing building lines forward in areas where there is existing development, not only because of potential blight issues, but the ad-hoc bringing forward of building lines would not only be a visual intrusion, but would also break the geometry of the grid and interrupt pedestrian desire lines and legibility.

3.9.3 The principle of bringing building lines forward in areas of existing development did have an impact on existing investor/owner confidence because they were concerned additional development could suddenly be allowed in front of their building which would take their frontage away. This policy also had a negative impact on possible future investors because of the problems perceived if they invested in a single building coming forward from the established building line.

3.9.4 This policy been difficult and / or impractical to achieve for the following reasons:

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It requires the relocation of certain utilities and particularly in the vicinity of junctions : street lighting, telecommunications and traffic signals

Does not allow retention of portes-cochere which are a key element of the public realm, image and infrastructure of CMK

The level changes (sometimes as much 1.5m difference) between the boulevard and gates and surrounding surface level parking would create an awkward relationship between cars (at a raised level) and pedestrians walking along footpaths at a lower level adjacent to the embankments. The DF only really addressed the 2-dimensional aspects and did not for example sufficiently understand the implications of the level change differences across CMK, in particular between the boulevards and gates and surrounding surface level car parking.

A solution to this as has been done for the Hub and Vizion developments is to raise the surface level car parks to be flush with the existing carriageway, but importantly means the existing street trees can’t be retained. Trees can be replaced but there have been strong objections to the removal of existing trees.

The displaced parking has to be reprovided (assumed to be in the peripheral MSCP’s which is not only not currently viable but contentious in its own right).

3.9.5 The above all affects the viability and deliverability of bringing building lines forward.

3.10 Footpath widths (if building lines are brought forward)

3.10.1 In order to accommodate additional utilities and provide sufficient space for trees (root clearance zone and canopy spread) it has been demonstrated that new footpath widths should be increased along boulevards from 8.3m to 9.5m and along Gates from 6.3m to 9.5m

3.10.2 The new footpath width along Witan Gate (adjacent to the Hub and Sainsbury’s) is 6.3m wide; a combination of footpath width and inclusion of service lay-bys has resulted in a non-continuous tree line. Further studies carried out have indicated that at 9.5m wide a new footpath could accommodate a line of trees adjacent to lay-bys together with other street furniture located at a sufficient distance from the building to allow for a substantial tree canopy.

3.11 Parking Bays along Gates and Boulevards (when building lines come forward)

3.11.1 At the Hub along Witan Gate in particular, notwithstanding the fact that on street parking bays have been included, cars have parked on the footpath. This has had the effect of damaging, spoiling and making unsafe the public realm.

3.11.2 Although speculative, this could well be a response to the removal of the supply of existing parking in close proximity to front doors which people have become very accustomed to.

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3.11.3 The other side-effect of losing the parking areas around buildings is that the servicing, which currently takes place from these areas, has been displaced to the Gates and Boulevards

3.12 Wayfinding

3.12.1 This was a subject that did not receive a lot of attention in the DF yet, has through the MKCCM CMK Business Satisfaction Surveys has shown to be a key area, businesses would like to see an improvement in.

3.12.2 On one hand, CMK is very easy to find your way around in because of the strong grid structure, so a car driver driving along the boulevards and gates wayfinding is not particularly problematic (although concerns have been expressed by the centre:mk, Xscape and the Hub about lack of advertising for the shops within these developments).

3.12.3 The issue is more for pedestrians where wayfinding is poor, particularly the first portion of Midsummer Boulevard from Station Square to Grafton Gate and importantly for visitors and business clients when both looking for available parking and then finding their destination from those surface level parking areas.

3.12.3 It is important for the DF Review to address wayfinding or to undertake an additional study to outline a wayfinding strategy. Consideration needs to be given as to whether this should include a study of advertising and sponsorship.

3.13 Fine Grained CMK: Pedestrian Permeability

3.13.1 The existing block structure of CMK has allowed a considerable amount of pedestrian permeability, both along streets and on segregated pedestrian routes through blocks (see para 5.3.3 on Lloyds Court). The latter while often being direct do not always feel safe and clearly public.

3.13.2 In some ways CMK therefore already exhibits considerable pedestrian permeability. A key principle of the DF is to create a perimeter block structure whereby pedestrians walk around along streets that circulate around the ‘outside’ of outward facing development and the block interiors are kept private. This is contrary to much of CMK whereby pedestrians can currently walk through blocks because the principle of perimeter block development with a clear public and private side has not been achieved. New developments such as Theatre District Phase 2, the Pinnacle and to a slightly lesser extent the Vizion have focussed pedestrian movement around the outside of the block, while the Hub has concentrated pedestrian flows through the block.

3.13.3 A key question to ask is whether as both part of new developments and interventions to improve existing pedestrian routes whether the focus should be on pedestrian routes around blocks or through blocks (or combination of both). Clarity is thus required on what a fine grained development means and how it can be delivered.

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4. Lessons : Developments completed in last 10 years

4.1 The Hub

4.1.1 A key principle of the Development Framework was to bring forward schemes which apply strong perimeter block principles – to deliver schemes which have public fronts (front doors and high quality architectural treatments) and more private rears (with servicing, refuse facilities, parking, private amenity space and less expensive materials), creating a strong block structure.

4.1.2 Opting for a development solution of a linear block design with retail uses at ground floor surrounding an enclosed public square, rather than enclosed blocks with a private interior, has created a development where the retail uses have limited ‘dual aspect’ and a successful and a successful public/private condition has not been achieved.

4.1.3 This issue is perhaps a key drawback of the Hub development where the commercially preferred focus of the activity is internalised to the block and not obvious or open to the lengthy Witan Gate frontage. Whilst dual aspect frontages were promised by the developer with activity onto Witan Gate, this has not been delivered and could not be controlled through planning.

4.1.4 The result is that there is very limited activity along Witan Gate, where almost hidden residential front doors are set adjacent to the service entrances of restaurants. In addition, despite a strict estate management regime being a major consideration at the time, a resulting weak estate management has failed to manage tenants use of the refuse and servicing arrangements. This together had a negative impact on the appearance of the Hub.

4.1.5 By locating the public square within the interior of the block, its prominence to passers-by particularly in vehicles is low. While an early concept did include 1 side of the public square opening onto Witan Gate which would have improved visibility, this would not have met good principles of enclosure.

4.1.6 The quality of the residential entrance cores was also subject to a value engineering exercise post planning approval. While the original intention was to highlight the entrances with a full height atrium and clear light filled foyer through the entire depth of the building, these were both omitted when being built and the resulting residential entrances are not obvious and this has detracted for the quality of the end product. These changes were however granted planning approval.

4.1.7 While the Hub is a different residential offer to the Vizion, the lack of a concierge at the Hub has been seen as a downfall (although this has allowed for a reduced service charge which may be beneficial for certain people)

4.2. C4.1 (Sainsbury’s / Vizion) and Development in the Greenframe

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4.2.1 This development followed a competitive tendering process based upon a detailed Design Brief and design standards requirements. The selected developer was required to adhere to the principles of the Brief in the preparation of the planning application.

4.2.2 This scheme has been more successful that the Hub in terms of creating an outward looking development and servicing and parking being located internal to the block.

4.2.3 It still does not however fully comply with the DF principles because an internal public route is still included which does not feel particularly public as it is not overlooked by active frontages and indeed is at times gated off. Active frontages are proposed onto it but when the shops are full it is unclear whether dual aspect frontages will be delivered (as was the problem with the Hub)

4.2.4 The level changes between the boulevard and gates and surrounding surface level parking facilitated the inclusion of basement parking.

4.2.5 Following lessons learnt from implementation of the development at the Hub, a Planning Condition was included restricting the amount of development of non-active frontage permitted on any public elevation.

4.2.6 The scheme has also adhered to the principle of using development to overlook and make feel safer the pedestrian routes into adjacent estates by including residential development within the ‘green frame’ around CMK to overlook the redway underpass into Oldbrook. This has generally been seen as positive, although would be further improved if a similar incursion of development could occur on the Oldbrook side of the H6.

4.2.7 Whilst there’s very limited experience of development in the greenframe, the overall market judgement appears positive. For this particular application there did not seem to be significant regret over the ‘loss’ of landscaping and in the commercial market prospective developers, funders and tenants rather seem to like the idea of CMK being opened up to an arterial road.

4.2.8 It would be worthwhile for policy to identify what factors and / or conditions should be considered in determining where development in the Greenframe (if at all) is acceptable

4.3 Filling in of Avebury Boulevard / Witan Gate Underpass

4.3.1 The relocation of underground services cost circa £700k - £800k.

4.3.2 While not required to close the underpass, a sewer was also relocated. The reason the sewer was diverted was because it ran north to south, straight through the Hub and C4.1. HCA decided to take this on because they wanted a straight run down Witan Gate, not two separate diversions, which would probably have cost more and not been such a good final sewer operation. The cost of moving the sewer (which ended up close to £1.3m) isn’t ‘standard’ as this particular run was part of the strategic ‘trunk’ network and was very deep. In other locations it shouldn’t be so costly to move surface/foul drainage.

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4.3.3 Notwithstanding the above costs, the tradeoff needs to understood between the benefits that would be realised by closing the underpass and the issue of undermining of the unique identity of CMK that the closure would bring. Any identified benefits would be better realised by a comprehensive development of all 4 sides of an underpass which is unlikely to come forward.

4.3.4 The extra pedestrian signal has at peak times resulted in some delays for cars but indications are that drivers have got used to this

4.4 The Public Realm Created by Bringing Building Lines Forward Between the Vizion and the Hub along Avebury Boulevard

4.4.1 This controversial proposal has as predicted divided views with some groups saying it is simply replicating other parts of large UK cities, undermining what makes CMK unique and special and creating wind tunnels, while others have supported it citing that it makes CMK feel more like a city centre, enhanced safety and ease of crossing of Avebury Boulevard.

4.4.2 From an urban design perspective it has led to the following:• The contextual relationship between the space and the buildings creates a

safer environment with better natural surveillance of the street from surrounding buildings

• It also creates a more strongly defined junction with buildings reinforcing the edges, providing a sense of scale and aiding city wide legibility. In doing so the junction enables the new form of Avebury Boulevard to be effectively delivered.

• The choice of materials is robust and is largely in keeping with the MK palleteinclusive of black paint finish and stainless steel, and of a simple aesthetic.

4.4.3 It has however meant more mature plane trees have had to be replaced with much younger species along Avebury Boulevard. With respect to Witan Gate, at the time is was seen as an opportunity to introduce a different landscape character (much the same as the Chestnut trees adds distinction to Saxon Gate)

4.5 Block E3 Theatre District Phase 2

4.5.1 Other than the viable delivery of a mixed use development, this development has demonstrated the benefit of adhering to the DF principle of buildings being placed around the outer edge of the development plot forming a continuous public façade with private areas (servicing and parking) enclosed within the block. Two sides of the building at ground floor are clearly public with active ground floor frontages and thus enhanced public realm while the other 2 sides are private.

4.6 The Pinnacle

4.6.1 Unlike many earlier office developments, the Pinnacle development has demonstrated the benefit of adhering to the DF principle of development

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layouts achieving a clear public / private interface. Unlike layouts of many earlier office developments, the development form and configuration clearly defines between public and private space with two interlocking L-shaped buildings defining a private central courtyard. An annex linear block is located to the south which defines what appears to be a semi-private parking area shared between both developments.

4.7 Network Rail National Centre

4.7.1 This development was a complete variation to the sport uses proposed within the Development Framework (and Local Plan). It demonstrated the flexibility of the Development Framework and Local Plan.

4.7.2 Building lines were not brought forward as proposed as a principle in the Development Framework. Despite suggestions to explore this to reduce the severance effect of Grafton Gate, there was no appetite from Network Rail to do so, in part because the site they bought was big enough for their needs, in part because it would have involved another party (the council) and associated stopping up orders of public highway and in part because of the negative reaction associated with recent developments such as the Hub where building lines did come forward.

5. Lessons : Proposals

5.1 the centre:mk

5.1.1 Proposals for ‘thecentre:mk’ were approved for outline planning but not progressed and permission has now lapsed.

5.1.2 The project covered expansion of the existing shopping building out to the boulevard edge of both Midsummer Boulevard and Avebury Boulevard, development of two large multistorey/ decked car parks, residential units as well as a transport interchange. The built elements of the project were accompanied by significant investment in transforming the public realm of Midsummer Boulevard and other areas surrounding the centre. One issue emerging from this was that it was not clear how level changes and associated footpaths and existing street trees would be addressed through the scheme.

5.1.3 As stated above, a significant part of the centre:mk proposals was relating to improved / amended highway infrastructure, public transport and public realm improvements. Any review of the CMK Development Framework needs to take into account and provide a realistic balance between achieving the delivery of development and associated infrastructure and public realm costs.

5.1.4 The DF together with the principles contained in the Central CMK Framework SPD (2006) for Opportunity Areas 3b-c, 4 and 5 envisaged Midsummer Boulevard East to be a ‘high street’ which would help integrate this key part of the City Core creating a pedestrian friendly and scaled public realm in the heart of the city.

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5.1.5 Together the proposals were very ambitious and the lessons may be that more modest and deliverable proposals may achieve many of the outcomes that the grand project sought to deliver.

5.1.6 Agreement on the location and scope/design of a ‘transport interchange’ (if required) in this location along Midsummer Boulevard is essential if a holistic vision for this area is to be achieved. This is beyond the control of an applicant.

5.1.7 Tradeoffs around changes to highway infrastructure need to be understood. The part removal of Secklow Gate was seen as important to eliminate pedestrian severance in the heart of the city centre and to open up full development potential of sites to the south. It is becoming clear that key stakeholders no longer see that the removal of Secklow Gate as a priority for CMK. Before this is abandoned as a project the impact that this grade separated junction has on the quality of environment in the city centre and what is foregone if it is not adapted or removed should be considered

5.2. Xscape Outline Planning Application

5.2.1 This development includes linear blocks within the surface level parking adjacent to Avebury Boulevard. As with Hub, while the intention maybe to have dual front units (facing Avebury Boulevard and the Xscape), the Hub has shown how difficult it is to have active frontages and associated high quality public realm on both sides of a dual front building.

5.3 Lloyds Court

5.3.1 The Council are currently in conjunction with local stakeholders preparing a Development Brief and Parameters Plan for the potential redevelopment of Lloyds Court.

5.3.2 The design principles are suggesting that for 3 reasons it is inappropriate to bring forward building lines toward Silbury Boulevard:

Unless other parts of the established building line along Block D1 were brought forward (which can’t be guaranteed), the bringing forward of the building line in line with the CMK DF would create an uneven building line that would disrupt pedestrian movement, reduce legibility and undermine the unique grid structure of CMK

A portion of the frontage of Lloyds Court sits adjacent to the raised flyover. It would be impractical to therefore bring building lines forward as pedestrians would not in any event be able to cross Silbury Boulevard because of its elevated status

A valuable piece of Public Art sits to the front of Lloyds Court and bringing forward the building line would undermine its setting

5.3.3 There has been a lot of discussion as to whether the existing public route through the building that links the ports-cocheres should be retained whether as part of a refurbishment or a new development. This raises the interesting and important question as to whether pedestrian activity should occur through blocks (like in Lloyds Court) or around blocks following streets.

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5.3.4 Local stakeholders as well as parish councils and members have also expressed a clear desire to firstly, retain any future development within the existing development plot, and secondly, to not allow any development within the ‘greenframe’ around CMK.

5.3.5 The Lloyds Court Brief has also highlighted that the original layout of highway infrastructure was designed to allow heavy duty vehicles to move around development blocks and if building lines are brought forward and / or development is included within the outer row of North or South Row, this would require modifications to existing infrastructure to enable these movements to still easily occur

5.4 Campbell Park Canal Side Development

5.4.1 The DF and Local Plan identified this area as a new destination for leisure and recreation that will mix with homes, offices and live-work space. This principle was incorporated in the outline planning approval and formed the basis of the briefing material.

5.4.2 This site, like all vacant land adjacent to Campbell Park was owned by the HCA and as was common with the developments on EP/HCA and, it went onto the market with a range of Briefing material to including the adopted SPG for Campbell Park, Design Codes as well as a Development and Design Brief, all to help raise design standards.

5.4.3 As part of the development, the successful tender was expected to also provide the following public realm and related infrastructure : A marina accommodating in the region of 100 berths / moorings Accommodation for British Waterways’ new regional headquarters Public realm Provision for a future footbridge across the canal Parking (on site and off site) to meeting a high density of development

(min 100du/ha) An extension to the Park Improvements to Overgate (north of the site)

5.4.4 Following assessment of the tenders, a developer was not selected for this scheme. They were unsuccessful for the following reasons:

5.4.5 This Lessons Learnt paper has already identified the issue that because there is no publicly available parking in Campbell Park (via MSCPs) that all parking needs to be met on site. The density of development requires this to be largely established in basement or MSCPs on site. This together with the above mentioned public realm and associated infrastructure required as part of the development had an impact on the viability of the scheme.

5.4.6 This was not helped by the market starting to change in 2006 which added significance given the long timeframe for implementation

5.4.7 The following were some of the points made as part of the Management Committee Report reporting on the tender results:

The market at the far end of Campbell Park was untested and is making developers risk aware. This was reflected in the disappointing interest from

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developers in this prestigious and unique waterside location at the Stage II of tendering.

There are indications that the size and scale of the marina development is premature in the life of Campbell Park. It is apparent that if this site is re-programmed towards the later stages of the development phases for Campbell Park this site will receive a much more significant level of interest from the Development industry.

5.4.7 The report included the following recommendations:

A comprehensive review of Campbell Park in terms of phasing and utility provision should be undertaken.

Campbell Park is a unique product, the marketing of this needs to be addressed giving it a strong identity through branding and repositioning it’s perception within the market.

A clear release of phases needs to be agreed and possible releases of parcels of land need to be given careful thought and channelled thorough a Campbell Park project team. This will give developers’ the confidence in terms of future vision for this unique destination.

5. Delivery and Governance

5.1 To ensure that the full vision could be realised over a 30 year period, the CMK Development Framework highlighted the need for a strong delivery team, clear decision making and leadership if the implementation of the framework was to be successful.

5.2 The emphasis on co-ordinated delivery was particularly required for two main reasons, outlined below:

5.2.1 Working Toward a Common Agenda

First, the nature of development in CMK would be significantly different to that of the first generation of development up to 2000. This required a very different approach to delivery and engagement.Promotion and Championing CMK: The change in approach to the futuredevelopment of CMK would require promotion and continual reinforcement if the inter-relationships were to work and those investors from outside MK were to be engaged in the new opportunities. Additionally, within the new city it was clear through consultation that CMK was not seen as the ‘heart’ of their city by many residents and some were unaware or excluded from the facilities and services based in the centre. The Championing role was to look both ways: outwardly to attract new investment and growth; and in the city to build civic pride and local identity.Building momentum internally: existing officers responsible for delivery

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(predominantly in MKC and MKP/EP), the public and local interest groups would require careful support and ‘grow capacity’ as the framework was delivered. This would require additional skills and continual effort in managing and leading the process of delivery and ensuring everyone was working to the same Development Framework delivery agenda.Building relationships with delivery partners: different nature and mechanisms of delivery would require a step change in relationships, cross-working and pro-active intervention between the public sector agencies and private sector developers and investors. With CMK identified as the economic heart of MK, these relationships are fundamental to capture energy and investment, provide direction and make decisions.

5.2.2. Delivery of Major, Complex Public Realm, Facilities and Infrastructure Projects

The DF is predicated by delivery of the structuring elements, the ‘softer’ outputs of cultural and community facilities as well as important public realm improvements and transport measures and not simply the building/development projects on defined plots. Previous development in CMK was strictly set within the MKDC masterplan for the city centre and there was a clear distinction between infrastructure (delivered by the public sector) and building projects (delivered by developers or sponsored by the public sector)

Financial modelling required development projects to cross-fund the above infrastructure, service and public realm improvements and for funding to be drawn from a variety of structures and sources. These included contributions from the increase in value of undeveloped land, developer contributions (via s106 and s278 agreements), through the CMK joint venture, funding from MKC and EP/MKP, a business improvement district, car park revenues, SEEDA and the local transport plan.

The Joint Venture would forecast development receipts and then EP would forward fund infrastructure in advance of development value coming into the Joint Venture.

5.3 The Delivery Structure for CMK

5.3.1 In order to help deliver this, this co-ordinated approach to delivery, the following occurred:

5.3.2 In 2003, EP and MKC agreed to co-operate in realising the CMK Development Framework and signed a Joint Agreement to provide an operating framework for the long-term development programme. The agreement established a framework of co-operation between MKC and EP on matters such as individual site development; finance; creation of public space and facilities; land acquisitions; and introduction of public transport and new car parking schemes.

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5.3.3 The CMK Board was established in 2003 comprising MKC, EP/MKP and other stakeholders, fulfilling an ‘agency’ role to ensure that all the components necessary to bring forward the new development plans for the city centre were brought together. These included setting policy and strategies and approving the CMK Business Plan

5.3.4 Within EP/MKP, a multi-discipline CMK Team was established with a role co-ordination and managing individual projects and working in partnership with colleagues from MKC and other agencies. In many ways the team’s role has been to co-ordinate the disparate departments, individuals and agencies; as well as to provide a first point for contact for developers, design teams and objectors.

5.3.5 MKC established a ‘Streetcare’ team to improve maintenance of the public realm and EP/MKP strengthened Invest Milton Keynes. Other service delivery elements were by way of joint committees or working groups (such as social and cultural infrastructure, promotion of animation and transport).

5.3.6 The Champion for CMK was a role identified for the Chair of CMK Board to be appointed by MKC and EP/MKP.

5.4 Lessons learnt from delivery mechanisms

5.4.1 Lack of Clarity and Single Point of Contact

Beyond the CMK team’s co-ordination role, much of the delivery and development of solutions/strategies to deliver the framework goals has not been the responsibility of the CMK Team, but rather of MKC departments and agencies at arm’s length. A number of issues have arisen through this officer team structure:• Although the CMK Team had a defined co-ordination role there was no authority or direct management responsibility placed in the team for the officers from other teams or agencies. MKC officers and those from arms-length agencies were therefore still responsible to their host-organisation for some of whom either delivery of CMK was not a priority or there were policies/agendas in those organisations not wholly compatible with and supportive of the aims and goals of the Development Framework.• It appeared that while decisions were made at Board level, these were not fed back down clearly to council officers responsible for implementation (a case in point was the closing of Witan/Avebury underpass). • The CMK Team could not be the one-stop shop for all aspects of the delivery of the DF. In some cases programmes and strategies which related to or impacted on CMK were developed in MKC and other agencies cutting across the Development Framework objectives or recommendations – for example public transport, management of public realm or street lighting.

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Implementation of the Development Framework adapted to incorporate these initiatives but this slowed implementation and diverted funding.• Developers and potential investors also suffered from the split of responsibilities and approaches. Whilst initial contact would be handled through the CMK Team, there was a lack of clarity as detailed discussion progressed. Different and often conflicting messages from design, planning, transport and between the CMK Team and MKC officers often over-complicated design-development.

Much of the above sits uncomfortably with the fact that it was difficult for the CMK Team to play the role of advocate or Champion as they are nationally-appointed rather than locally-elected and are responsible to a Government agency.

There was thus not a clear single point of contact for investors, developers and their design teams. Mixed messages and delays to decision-making processes adds time and cost to the design process which weakens confidence in the City and its leadership. The public furthermore were not receiving clear and consistent messages about the future of the City Centre.

5.4.2 Lack of a Champion for CMK

While the CMK Board provided an invaluable point where the key stakeholders could debate and decide on development projects or strategy development, it had less autonomy and focus than required to proactively progress the Development Framework. Referral back to MKC and EP for ultimate decisions and funding appeared to slow down implementation.

While the appointed Chair played a central role in bringing and keeping key stakeholders at the table it was not his defined role to be a vocal public advocate or ‘champion’ for CMK or the Development Framework.

5.4.3 Changing Governance Arrangements – further confusion and bureaucracy

The establishment of the Milton Partnership Committee (MKPC) in 2004 led to the role of the Board and Chair of MKPC became confused and decision-making responsibilities overlapped.

Because of the various groups (MKC/MKP/MKPC/CMK Board) with overlapping functions, there was also confusion in delivery as well as external facing to investors and developers. This resulted in October 2007, the CMK Board agreeing to disband itself and fully integrate its workload and working arrangements for CMK with those established by MKPC.

In 2008, EP/MKP furthermore had a changed remit toward growth rather a specific focus on CMK.

5.4.4 Impact of Undelivered Projects on Delivery of non-development projects

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The two notable examples are expansion of the centre:mk and the substantive delivery of the Residential Quarter (Block B4), both of which were in the planning/design process for over five years and were planned to be substantially complete by 2011.

The important lessons with respect to this are:

These major schemes carried many of the ‘softer’ outputs of cultural and community facilities as well as important public realm improvements and transport measures which were to be funded from s106 contributions and land proceeds deriving from development projects . Consequently, the loss is not simply of the development outputs but of the wider ‘softer’ outputs that the Framework sought to deliver. There is clear evidence of this in CMK today

This illustrates the risks of running with large developer-led projects and relying on the project to deliver community and cultural infrastructure – which is still required even if the developer does not progress with the scheme.

With respect to developments such as the centre:mk proposals which required extensive remodelling of major infrastructure a review of the approach to delivery might consider extracting such elements from developer-led projects

There is also a valid challenge that the packaging of the projects was too complex and overly ambitious for the size, skill base and remit of delivery team from MKC and MKP – resulting in compromised delivery in important areas of the city centre. Alternatively, the challenge is that implementing the Framework requires such a change in the underlying structure of CMK that project delivery would always be protracted. The balanced view is probably a mix of both positions.

Each of these points highlights the issues facing future delivery with more limited public sector resources and skills available for delivery in CMK – as to whether the Framework projects can be delivered as currently envisaged.

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APPENDIX A

Vacant floorspace and Refurbishment

The Development Framework did not provide much guidance on the issue of refurbishment of existing office floor space. Yet from the below table there is a significant amount of vacant office floorspace in CMK (as well as outside) much of which is 1st, 2nd and 3rd generation and is of poor quality.

The fact there is a considerable amount of vacant office space outside of CMK that will have cheaper rents and more / cheaper parking means that start up businesses will often seek these locations before CMK.

CMK Vacant Floorspace

Table 7Commercial Stock, Built & Vacant Space, MK & CMK, February 2011

TOTAL OFFICE

SQFTOTAL INDUSTRIAL

SQFCMK OFFICE

SQFOTHER OFFICE

SQFBUILT SPACE 6,584,639 34,230,592 3,599,806 2,984,833

VACANT SPACE 1,230,161 3,542,641 427,971 802,190

% 18.60% 10.30% 11.80% 26.80%Source: MKC/HCA

Over half of all floorspace (3,599,806 sqf) in MK is in CMK, however there is considerable floorspace (2,984,833 sqf) provided outside of CMK. There was more vacant floorspace outside the CMK area than within the CMK area (427,971 sqf compared to 802,190 sqf in February 2011.

The reasons a landlord would refurbish a building are to:

To maintain or improve headline rents

To reduce the time it takes to fill voids and get new tenants in and hence reduce the empty rates liability

The costs of refurbishment are high – often between £40-£75ft/2 and in the current market with depressed levels of rent, the cost of refurbishing the accommodation can quite easily exceed the marginal improvement in rent that would result. If for example you assume a landlord’s refurbishment works have say a 10 year life span the Landlord would require a £3.00 - £4.00 ft/2 per annum return on his investment. These returns are not being seen in today's market. In these cases therefore landlord would get better returns by having cheaper rents if this means not spending anything on refurbishment. Alternatively it would be more viable to redevelop the site than refurbish it.

Landlords face considerable costs with having large parts of their building empty. The landlord will be incurring maintenance costs, will have an empty rates liability

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and there will also be a service charge void which the landlord will have to contribute to.

Market conditions in Milton Keynes have obviously deteriorated over the last 18 months to 2 years in line with the general downturn in economic activity. However due to some large lettings to Countrywide, Network Rail, Job Centre Plus and BSI the take up of office space is being maintained, however effective rental levels not unsurprisingly have fallen away. Due to diminishing demand and increasing stock (particularly relatively poor second hand stock) landlords and tenants of vacant units have become increasingly competitive in their attempt to clear voids and this has already had a noticeable effect of driving down headline rentals and or increasing incentives.

Many of the existing vacant office buildings in CMK have a poor sense of arrival with poor quality reception areas and this undermines their attractiveness to new tenants.

Changes in policy to allow commercial buildings to be converted to residential uses may have an impact on the refurbishment of existing vacant buildings.

‘Fine Grained CMK’ and Growth of Small Businesses

While the DF largely focused on the creation of a fine grain in terms of maximizing pedestrian accessibility and freedom of movement, the inclusion of small businesses facing the boulevards and gates at ground floor would also help to deliver a ‘fine grain’ city centre. The Council’s Economic Development Strategy furthermore has as one its action plans the ensurance of suitable premises for businesses.

The mixed use developments recently built in CMK contain ground floor shell units, often double height, which are simply too large and expensive for a small business, even if a prospective covenant has a profitable track record/covenant.

By its very nature the introduction of new build bespoke small business space as part of a larger new block does not represent a good return on investment. Office buildings are not designed to provide a very high number of small suites suitable for small start-ups. The gross / net loss in floor area as a consequence of corridors , fire requirements, and added service costs ( reception, management costs etc) all impinge on the viability of multi let offices targeting businesses in the 500 - 2,000 sq ft bracket.

Smaller start-ups tend to fit the serviced office providers better albeit total occupation costs for serviced offices can be circa 3 times that of a traditional lease. Benefit to the small start-ups are flexible lease terms, existing telecoms / data coms connections, and central services. It may be useful to check occupancy rates for serviced office providers in CMK?

With the abundant amount of vacant office floor space, it is worth asking why if there are so many small businesses in CMK and the council want to promote the

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growth of small business, why there isn’t a greater take-up of this vacant space. The following reasons can be given:

Rents are often still cheaper outside CMK in one of the business parks – Less available parking than business parks. Some premises eg Norfolk and

Ashton House have no parking Poor quality space – while this is not always the case, the poorer quality

space in CMK tends to be more expensive than the poorer space in out of CMK business parks

Rental areas on offer are often larger than a small business want – This is true of both CMK and out of CMK Business Parks. Many small business work from home or serviced office space ( both in CMK and outside) where the terms of occupation are more flexible.

The above needs to be balanced against the amenities offered by locating in CMK

APPENDIX B

CMK: Timeline

Date City / borough-wide policy

CMK - policy CMK - events

1970 The Plan for Milton Keynes

aka The Master Plan

June 1974 Original 6(1) submission for CMK approved by Secretary of State

1979 Shopping Building opens

Jan 1980 Amended 6(1) submission for CMK approved – deletes proposed section of Avebury Boulevard to allow for a stadium development

1982 MKDC Retail Strategy

1987 Review of MKDC Retail Strategy

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Date City / borough-wide policy

CMK - policy CMK - events

Jan 1989 7(1) submission approved to reinstate missing section of Avebury Boulevard

Sept 1990 Local Plan –1st Draft approved for consultation

Nov 1991 Local Plan – revised Draft published for consultation

Local Plan – revised Draft published for consultation

CMK policies in the Local Plan reflected close working with MKDC on capturing the key design principles for CMK – e.g. covered arcades along buildings with frontages on to Boulevards and Gates

April 1992 MKDC replaced by CNT

Sept – Dec 1992

Local Plan – public inquiry

Sept 1993 Local Plan – Inspector’s Report

Feb 1994 MKBC initiates a review of CMK with BCC and CNT

3 reasons given for a review:

1. CNT about to be wound up and need to review their interests in CMK “to secure by development agreement the completion of the city centre”

2. Still scope to influence the future development of the city centre as there is much land still undeveloped

3. 18 years of experience of development in CMK allows

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Date City / borough-wide policy

CMK - policy CMK - events

informed judgements to be made about the consequences of continuing to develop the city centre as originally planned

As well as MBC, BCC and CNT, the Steering Group included reps from the MK Economic Partnership, MK Forum, MK Parks Trust, MK Community Trust, MK Shopping Centre Association, MK Christian Council and DTZ/Hermes (Shopping Building owners / advisors)

Several consultants were appointed producing reports between Feb 1994 and April 1995 (See list at end of timeline)

1995 Shopping Building extended (new M&S)

Jan 1995 Local Plan – Adopted

Sept 1995 CMK – CMK Review: Report of the Steering Group

Report identifies that

the city centre has been commercially successful

the city centre lacks a ‘heart’ and needs more life and diversity

it requires a new approach to movement into / within the centre to avoid future congestion and to create

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Date City / borough-wide policy

CMK - policy CMK - events

better conditions for pedestrians etc

April 1997 MKC becomes a unitary authority

Takes on powers from BCC including transport, education and social services

March 1998

CNT assets pass to EP

March 1998

Local Plan – Town Centres Issues Paper

Local Plan – Town Centres Issues Paper

Includes summary of key issues identified in the CMK Review

Sept 1998 Milton Keynes City Centre Review: Update

1999 MK Theatre opens

Jan 1999 Local Plan – Directions Paper

2000 Midsummer Place opens

Summer 2000

CMK DF – project team set up, led by EDAW

Sept 2000 Local Plan – 1st Deposit Version

Nov 2000 CMK DF – stakeholder workshops

2001 Xscape opens

April 2001 CMK DF – community planning

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Date City / borough-wide policy

CMK - policy CMK - events

event

Oct 2001 CMK DF – finalised

Jan 2002 CMK DF – adopted as SPD

See list of Technical Appendices to the DF (including a report on consultation) at end of timeline

Oct 2002 Local Plan – 2nd Deposit Version

Local Plan – 2nd Deposit Version published

Incorporates new policies that reflect the CMK DF, including the “Quarters” policies

July 2003 – June 2004

Local Plan – Public Inquiry

Local Plan – Public Inquiry

Objections to CMK policies considered

Sept 2003 CMK – Campbell Park SPD adopted

CMK - Sustainable Residential Quarter SPD adopted

May / Nov 2004

Local Plan – Inspector’s Report

Local Plan – Inspector’s Report

Supports the overall approach to CMK and the new policies (with only minor changes), and the value of the CMK DF in informing these policies

May 2005 Local Plan – Proposed Mods

June 2005 Major extensions approved to Shopping Building

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Date City / borough-wide policy

CMK - policy CMK - events

Dec 2005 Local Plan – Adopted

April 2006 Draft Central CMK SPD consultation

Sept 2006 CMK – Central CMK SPD adopted

CMK – CMK Handbook for the Public Realm adopted (as technical guidance, not SPD)

Dec 2006 Core Strategy – Issues & Options

April 2007 CMK Board releases an Interim Position Statement prior to completion of the Implementation Strategy for the CMK Development Framework on the principles of development promoted by the CMK Development Framework providing clarity regarding principles including Building Lines, Building Heights and Density, Landscape Structure and the CMK Handbook

July 2007 The Hub completed

Sept 2007 Core Strategy – Preferred Options

Core Strategy – Preferred Options

Promotes CMK as main location for office, retail, cultural facilities

Dec 2008 City Core Vision agreed for consultation

2009 Consultation on City Core Vision

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Date City / borough-wide policy

CMK - policy CMK - events

Summer 2009

The Pinnacle completed

Feb 2010 Core Strategy – Pre Submission Version

July 2010 Shopping Building listed

Sept 2010 Core Strategy – revised Pre Submission Version

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CMK Review (1994-1995): Studies and Consultants’ Reports

CNT (in-house) Proposals for D & E BlocksCNT (in-house) Constraints in CMKDTZ Mixed Use Development in CMKMKBC (in-house) CMK Land Use / Density ScenariosStirling Maynard Transport CMK Transportation StudyURBED CMK: Social and Cultural DimensionHartley, Mosscrop & Seed CMK: Urban Design ReviewMKBC CMK: Residents’ StudyAtkins Wootton Jefferies Transport Study – Detailed AssessmentHealey & Baker Commercial Impact Study

CMK Development Framework (2000-2001): Technical Appendices

Mott MacDonald Movement & Transport OptionsShared Intelligence Planning for ProsperityECD Energy & Environmental Energy & Environmental ConsiderationsComedia Planning Today for a Culturally Vibrant Tomorrow Thomas Heatherwick Studio Public Art in CMKEDAW Consultation ReportCB Hillier Parker Implementing the new Development Framework: Property Issues

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APPENDIX C

Noise and Mix of Uses

The Council’s Environmental Health Team has received numerous complaints regarding noise in the Hub and the Theatre District. There are 2 different kinds of complaints:

a) Ordinary Living Noise

This is the major issue because it can’t easily be actioned/enforced. It refers to the transfer of noise from one property to another which although might be termed as ‘ordinary living noise’ is not expected to be heard by occupants which can be an annoyance and not necessarily acceptable, but not necessarily a ‘statutory’ nuisance that can be acted upon.

The Council get lots of complaints of what conceivably can be termed ‘ordinary living noise’ from purpose built flats, these are noises which people do not expect to hear in modern buildings. Complaints are routinely received from people occupying flats regarding disturbance from people walking about in the flat above, children playing, using the toilet, laughing and talking all of which can be deemed ‘ordinary living noises’ and are by and large not actionable under the EPA. There has always got to be a bit of ‘give and take’ with occupants of high density housing and we do have to manage their expectations as to what is reasonable and what isn’t, nonetheless, this creates a notable stream of complaints.

Non-absorbent, non-cushioned hard floor coverings (i.e. laminate flooring) do not help in reducing sound transfer between floors in apartment blocks.

While the above is not an issue for the DF, it could be investigated whether building regulations could require floor coverings that off better protection against sound transfer

b) Noise from Bars / Restaurants

At the outset it is recognised that there will always be noise in this situation and there must be some ‘give and take’.

When domestic properties are situated in close proximity to premises designed to be licensed entertainment venues we are more likely than not to receive noise complaints relating to either loud amplified music, noise from patrons coming and going, or form people outside smoking / talking / shouting / fighting and stock deliveries. Retrospectively there is legislation that the Council can use to prevent statutory noise nuisance (EPA) if it occurs due to poor management of the premises and can control noise with licence conditions at the licence application stage and by reviewing the licence once it is in place. To some degree, people living in the vicinity of licensed premises can expect to hear activities, but they do not have to be subjected to a statutory noise nuisance.

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There have been issues regarding noise from Ground floor “bar” units, such as Park Lane at The Hub and V-Lounge at the Theatre district. These units were designed as restaurants/bars, however the occupiers have used DJ’s playing amplified music resulting in complaints about noise from residents. In these cases legislation allows the council to intervene and take action against the uses of the premises. Conditions can furthermore be added to a premise licence to ensure they are compliant with uses and associated noise levels.

Enhanced construction standards to incorporate triple glazing of all premises constructed in such areas can help mitigate noise for residents living above bars and restaurants.

While the above is not an issue for the DF, it could be investigated whether building regulations could require floor coverings that off better protection against sound transfer.

Environmental Health has also received numerous complaints about delivery and maintenance noise to commercial properties, mainly from The Hub.

Taxis

Taxi’s have been a major issue at the Hub. There are two hotels and a number of restaurants / bars that tend to close at the same time. The taxi rank provided was small and not placed appropriately. This has led to high numbers of taxis arriving and causing congestion outside the hotels and drinking venues. Midsummer Boulevard has taxis queuing on it and vehicle accidents are common. Emergency vehicles have little chance of reacting to an emergency in this area at this time, due to the level of queuing and parked vehicles.

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APPENDIX 2

Results of survey of CMK Residents, October 2011

Central Milton Keynes (CMK)RESIDENTS SURVEY

RESULTS

There were 95 respondents to the below questionnaire

Background

Milton Keynes Council are currently reviewing the Central Milton Keynes Development Framework, a document intended to set out what the city centre should be like over the next 20 years and how to achieve it. The City Centre covers the area from the railway line in the west to the canal at the eastern end of Campbell Park and from the H5 to the H6.

We are particularly interested in understanding the future residential requirements for CMK and what sort of homes we should be building, both for sale and rent.

With this in mind we believe it is important to ask you as residents of CMK for your views and experiences of living in your homes and whether the housing meets all your needs.

Your time in completing this short survey would be appreciated and extremely beneficial to us in developing this understanding and using it to build the right city centre homes in the future.

Name (you may remain anonymous)Address

Please mark the relevant box

Q1. Are you a:

a. Homeowner

b. Tenant

c. Other (please specify)

Q2. What is the makeup of your household?

a. Single Occupant

b. Couple

c. Couple with child(ren)/family

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49%

40%

3%

42%

35%

13%

d. Single parent family

e. House share

f. Other (please specify)

Q3. Do you live in a:

a. Townhouse

b. Apartment

Q4. Why did you choose to live in CMK?Comment

Q5. Why did you choose to live in this type of home?Comment

Q6. Does your accommodation meet all your / your family needs?

a. Yes

b. No

Q6a. If ‘Yes’ to above - has it always?Comment

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3%

2%

40%%

59%

76%

24%

5%

Had no Choice it was all that was offered to me or all that I could afford - 10% It was affordable / good value for money - 10% It was spacious / rooms are big - 3% To downsize – 3%

Needs more storage space - 2% Parking is limited - 1% Water leakage problem - 1% Noise pollution - 1% Would like a shower - 1%

Q6b. If ‘No’ - why not?Comment

Q7. What do you like about the area immediately surrounding your home?Comment

Q8. What do you dislike about the area immediately surrounding your home?Comment

Q9. Are there any other comments you would like to make? Comments

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Noise insulation - 6% No garage - 3% Expensive - 1% Maintenance problem - 5% over occupied - 1% Small - 10% Storage - 3%

Parks / Greenery - 54% Outlook - 3% CMK - 54% Theatre / Restaurants - 21% Buses - 10% Train station - 14% Lakes - 2% Canals - 2% Exscape - 10% Amenities - 22% Quietness - 13%

Other developments - 10% Poor Parking - 23% Anti-social behaviour / Noise - 35% Himos - 11% Street lighting - 3% Cars speeding - 9% Litter - 15% Maintenance - 8%

People from Campbell Park responded - 23%

People from CMK responded - 76%

APPENDIX 3

Notes from meeting about future residential market in CMK, January 2012 “Failing to plan is planning to fail” – the future housing market in Central Milton Keynes (CMK)

Monday 30th January 2012

AttendeesJulian Buttel David Coles

Architects Catriona Morris MKC Councillor

Leslie Clarke Guinness Rod Pearson Guinness

David Coles David Coles Architects

Paul Quelch Connells

Robert de Grey MKCCM Stacey Rawlings Bidwells

Simon Elcock Places for People Jane Reed Housing , MKC

Clive Faine Abbeygate Ian Rhodes Crest Nicholson

Nick Fenwick Planning, Environment & Development, MKC

James Robinson Skanska

Paul Gibson Housing, MKC Neil Sainsbury Planning, Environment & Development, MKC

Bob Ham HCA Gary Sharp Crest Nicholson

Paul Hammond HCA Peter Smettem Milton Keynes Council

Chris Hatfield David Wilson Homes

Diane Webber Planning, Environment & Development, MKC

John Kerr Bellway Homes Peter Williams Lambert Smith Hampton

Rebecca Kurth CMK TC Catriona Morris MKC Councillor

Mike Moore Policy, MKC

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What types of housing will be attractive and appropriate for a city centre in the next 5-10 and 10-20 years?

Who would move into the 5,000 homes planned for CMK?

People’s needs are paramount and should override urban design objectives – what need is CMK housing meeting?

SRQ: Issues The proportion of family housing planned for the SRQ was questioned Much of the older family housing already provided in CMK has been turned

into HIMOs This raises the question, do families with school age children avoid city

centres? Social housing in CMK is not necessarily appropriate for many people needing

affordable housing (it’s not in the right place?)

Lessons from elsewhere: eg Upton, Northampton, where large townhouses have proved unlettable to the intended family market – too large and not enough parking resulting in social problems

Key messages: Height and family housing don’t mix well – keep family housing to 2-3 storeys

maximum. Churn – high levels experienced in the CMK market. CMK seen as a ‘gateway’

where newcomers to Milton Keynes arrive and first base themselves, then they move on to somewhere else once they have found their feet.

Other types of accommodation needed for – students; serviced apartments meeting a demand for interim housing.

Recent experience of large, flatted development s in CMK is that many of them went straight to buy-to-let, meeting a temporary market demand for short term accommodation.

Need for good schools to attract families Council needs to control the quantity of land coming forward for

development in order to generate competition in the housing market locally.

NB: It is no longer the case that major house building firms are land banking sites – they cannot afford to do this any longer. Also the HCA land deals required sites to be developed within a set time, which was a very powerful tool for bringing sites forward.

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Where in CMK would residential development be most appropriate?

Think of who will live in the area and what their needs are

There is a difference between the approach to development needed for CMk versus the sustainable urban extensions.

Mixed use: Empty office space: create mixed uses in existing developments Conflicts: people want access to mixed use developments but there are

associated problems of noise and late night disturbance to address.

Campbell Park: Create a destination: eg Campbell Park marina Focus residential in Campbell Park rather than seeking mixed use in CMK

itself. There is about a 3 year supply of housing land in Campbell Park at present.

SRQ: SRQ has planning permission for 600 dwellings – this is likely to reduce to c

490.

Market issues: Market demand currently constrained by lack of availability of mortgage

finance. Flexibility and a light touch needed from the development framework – guide

but don’t restrict Need for more townhouses and houses; but there remains the HIMO issue

(should be partly addressed by new policy/ Article 4 direction) and there is still demand for flats.

In order for the PLCs to invest, they need certainty ; the availability of land; clarity on planning obligations and infrastructure needs and requirements. The tariff has been very helpful in other areas providing certainty at the outset.

Problem in MK is a lack of supply as the land tap was turned off around 18 months ago (Post Meeting Note: MKC planning officers would query this point – MK has a considerable supply of housing sites in the pipeline. The hiatus arising from changes to housing targets and the core Strategy might possibly affect the supply further down the line, but should not be affecting sites currently. )

A spread of locations is requires in order to give choice to purchasers We have a new market reality, developers can only sell so many new homes

each year (and much less than previously), therefore sites, especially flats, are being mothballed.

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High rise buildings and flats in particular give rise to cash flow issues for developers at present (more so than individual houses) eg The Hub – this type of development would not happen in today’s market conditions (Post Meeting Note: There is no reason that developments of flats cannot work if consideration is given at the design stage to the delivery to ensure that only an appropriate number of properties come to the market in line with demand.)

Buy-to-let underpinned cashflow of development like the Hub previously Buy-to-let no longer viable (Post Meeting Note: this is this is not strictly the

case - rental yields are good, the point being made at the meeting was that the days have passed where one was able to sell large numbers of units off plan to buy to let investment companies. This was what enabled large flatted schemes to be delivered in the good old days - that and lack of alternatives for buyers)

People are buying but slowly and at a reduced price Need a new model for large scale development

High rise issues: High density and high, on-site parking requirements affect viability of

schemes (another reason for not building high density large scale flat/apartment schemes.

Once a development rises above 4 storeys then the additional requirements of an internal lift; additional land for parking; construction methods (concrete frame needed) make the schemes increasingly unviable and even if built, service and management charges can be punitive, making the development unattractive and unaffordable for many.

Looking at the SRQ and Campbell Park, do these areas cater for different markets? What is required and desirable for one may not necessarily be appropriate for the other.

SRQ represents city centre living Campbell Park represents lower density, parkland living.

So yes, they cater for different markets.

Campbell Park, has potential for: Elderly persons accommodation Family housing (with appropriately sized private gardens – remember the

lessons from Upton) On-plot parking increases saleability

It’s a buyers market at present – people won’t compromise on what they want. Developers are risk averse.

Townhouses – a solution to an urban problem,, BUT

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They don’t sell off-plan Layout is rarely family friendly Developers moving out of the market of large townhouses – don’t see a

market for this type of accommodation returning anytime soon.

1970s.80s developments elsewhere MK – not particularly good quality but offer large plots and good value for money – more attractive to families than CMK.

Specific note from representatives from Guinness Housing Association – experience of Upton is that they are having to deal with and manage anti-social behaviour.

Welfare reform will lead to a need for smaller units Welfare capping on larger units will present challenges to the RSLs

Is an average net density in the order of 100 dwellings per hectare achievable and desirable?

The changes to PPS3 provide greater freedom over density.

Lots of developers won’t bid now for high density schemes.

If MKC were to throttle the supply of land, then that might increase interest in higher density schemes but only because there would be no other alternative.

Issues around on-site parking in high density schemes – hard to provide unless go to basement parking .

SRQ: higher densities appropriate there due to city centre location and

juxtaposition with other developments. Success of residential schemes are partly dependent on there being a certain

quantum of development/ a critical mass Would struggle to better 50 dph on low rise flats. (Post Meeting Note: SQR -

50 dpha being exceeded is mentioned as unlikely but Barratts proposal for the site opposite Vision is at 130 dpha and with the right phasing of delivery is an appropriate density for this central site - especially if the aspiration for a vibrant City Centre is to be supported.)

Campbell Park: more potential for lower density. Won’t be viable to build more than 50 dph in Campbell Park, although that

might be possible in CMK. Feels more remote/ suburban What is its USP compared to the developments say, in the Expansion Areas?

Why would people choose to go to Campbell Park?

Mixed use:

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Office conversions – the purpose built modern offices in CMK do not convert well or particularly easily to residential.

Mixed use creates vibrancy but can also create disturbance, so care needed Mixed use can be delivered across a larger site (eg across the whole SRQ) Need to focus on management (contrast between the differing management

regimes at the Hub and Vizion)

The tenure mix of new residential development

Key points:

Flexibility: Need for more flexibility in affordable housing provision in certain areas Financially, it doesn’t work to seek affordable housing in high rise / high

density schemes (over 5 storeys)

Mixed use: in order to make small, non-residential units work, development must

compromise on cost.

Affordability : Depends on the availability of finance to the RSLs and hence to the developer Social rent now attracts £0 finance High rise developments bring with them higher management costs and

service charges Over 3 storeys, RSLs would ideally have a lift included in the development,

which again is reflected in higher service charges 30% affordable housing, especially with 25% social rent just doesn’t add up in

the current economic climate. Affordable rent doesn’t work on 1-2 bedroom units – just about works on 2-3

bed units, if the site is otherwise ok. There is demand for social rent in CMK as the area is attractive due to jobs,

facilities, accessibility etc. To achieve 25-30% affordable housing in current market conditions a lower

car parking standard is needed

Services in CMK: Broadband CHP roll out expensive Campbell Park road infrastructure – will it work with a new layout?

How will new housing development in CMK be financed?

First question – is it viable? Cashflow a key issue

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Need small schemes that float on their own The HCA traditional approach worked

In CMK there is a viable housing model, but more low-rise is needed.

Financial market outlook grim for the next 5 years Traditional sources of lending are no longer there Major housebuilders are in good health, but roll out of new development

based on profit line Housing – no pre-lets or pre-sales. Banks are risk averse. Demand from volume housebuilders for viable land packages in bite-size

chunks – 150/200 units viable; 2000 unviable

In Milton Keynes we can make it work (in terms of selling for more than it costs to build), but can’t over-burden the housebuilders with standards:

affordable housing requirements briefs need to be clear design codes – don’t be too prescriptive; developers know what sells design codes should promote coherence when there are several

housebuilders on site

Implications of a potential relaxation in planning rules for change of use from commercial to residential (as per CLG consultation mid 2011)

Change of use from commercial to residential likely to be a non-starter in CMK – purpose built office stock does not necessarily convert easily.

Plenty of other choice of residential development – no need to pursue conversion from commercial.

Business owners would rather refurbish and reuse for lower rents.

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APPENDIX 4

Notes from stakeholder workshop, March 2012 CMK Development Framework - Stakeholder Workshop29 March 2012

Topic 1: Key Structuring elements and other urban design objectives/principles

Q1.1 Should the focus of pedestrian routes be around blocks (following streets) rather than through blocks (which would link up directly with Portes Cocheres)?

The CMK public and private realms need to be clearly defined. The difficulty is when each affects the other ie. routes straight through the Centre:MK or Midsummer Place.

In cases where the private realm takes over parts of the public realm, there should be a clear public benefit resulting from that change.

However, there was also a concern that rules around public/private realm could be too prescriptive so this would need some care to get right.

The DF should encourage people to venture into and through development blocks rather than around them as this is fundamental to maintaining active frontages. However, it might not be feasible to split development blocks to accommodate pedestrian “desire lines” so linking access to blocks with the existing Portes Cocheres might not be feasible in all cases. Access to the main entrances to the Centre: MK etc. would, however, need to be protected i.e. Portes Cocheres retained as now but it was felt that this was not so important for the rest of CMK. To pursue this it was suggested that the “science of pedestrian movement” should be explored though the focus of most people continued to be “street based”.

The group also felt that block frontages should all be protected from the weather via colonnades or other means. The presumption should be to retain covered walkways.

Other constraints discussed included the limitations placed on development and changes to access by listed buildings and that Portes Cocheres were important for wayfinding and for identifying crossing points.

Questioned whether the options (pedestrian routes following streets or blocks) were necessarily exclusive ie: can we not seek to accommodate movement through both streets and blocks and encourage greater freedom of movement?

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Q1.2 Density of new development – is 100 dph appropriate in CMKQ1.3 Density of new development - is 50 dph appropriate in Campbell Park?

Mixed use developments are difficult as institutional investors do not want to have residential uses above office space.

Qualitative issues: large amounts of office space already exist and much is empty as these are designed for large companies. But the demand in CMK is from small to medium employers (SMEs) whose needs are for significantly smaller office units and these are in short supply in CMK. CMK does not have the mix of uses that other city centres have – why is this? Land ownership (limited number of large land owning interests); relative youth of the city; costs?

CMK remains important not just for enabling clustering of like specialisms, banking, accountancy, and estate agencies etc. but also to allow companies to attract the right staff (a comparison was made with Soho in London as a high cost location but attractive to staff who work in the film and TV industries).

Developers do not favour low or high density developments. They favour what’s profitable at a particular point in time. Currently, low density housing is the only profitable route. But this should not discourage planners from setting a framework that provides a meaningful longer term perspective as the industry’s desires could change very quickly with a change in market conditions. One suggestion was to impose maximum rather than minimum densities, but warning from commercial sector that without the minimum densities it will be difficult to force through the amount of residential development required.

Parking is also difficult with 100 d/ha densities unless specialist underground provision is made as surface level parking cannot cope with anything greater than 50 d/ha.

Residential may be beneficial as can enable other commercial development. However, there was a feeling that the type of housing offered would be important. Comments were made that there should be more affordable housing in CMK.

Section 106 liability and viability was also discussed as it can prevent sites from being attractive to developers.

There may be too much focus on the CBD part of CMK. CMK doesn’t stop at Marlborough Gate but goes on down to the Canal. Also planning for CMK tends to disregard the “Do-nut” estates such as Fishermead and Conniburrow. In effect the CMK grid roads become moats i.e. there is no local centre in Conniburrow to take the overspill from CMK.

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Unclear as to who would live in CMK and whether it is desirable to continue to plan for more residential development in the city centre. Reference made to the NPPF which still encourages mixed use developments.

Q1.4 A finer grain of development is not a necessity in its own right; the existing street network in CMK is already fine grained.

Some smaller block sizes might be required to facilitate the development of “character areas” that people can find for themselves. But there was no consensus on whether this could mean that more streets were needed or just an increased number of smaller buildings such as have been developed in areas of Amsterdam.

A finer grain of ownership would be desirable to move away from large institutional owners to allow in smaller owners and create something more diverse. The DF would therefore need to relax its approach to mixing uses which would allow this to happen.

Q1.5 Is the retention of all portes cocheres sacrosanct?

Porte Cocheres (PCs) were felt to be sacrosanct as a unique symbol of CMK across the country (world?), though they do all look the same and can make wayfinding more difficult. Perhaps they could be painted in different colours?

There was a discussion about the wisdom of turning off lights within the PCs and the lack of maintenance carried out on most of the PCs. Further work was necessary to look at how the PCs are maintained and who is responsible?

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Post workshop comments: Minimum housing densities useful but maximum densities

are even more important ‘Exclusive’ properties are in short supply in MK, preventing

company directors from living here and potentially form locating their businesses here.

Post workshop comments: New developments can have a finer grain, in context with a

town centre and High Street scale A finer grain may well be possible and appropriate with regard

to future development at Midsummer Boulevard East.

Q1.6 Could we justify bringing building lines forward if this helped to deliver multi-storey car parks (MSCPs)?

Some concern about the implications of retaining the existing building lines on the viability of new schemes.

Raised boulevards impact on the ability to bring forward building lines – though there was doubt about whether these had actually been raised or the parking lowered? Underpasses also dictate the road level. There needs to be a clear process for changing the use of plots. The building line gives a clear impression of MK.

We need to increase public transport use but people will still want to use their cars. So how to increase parking capacity?

We need to maintain character and vistas but everything else can be changed so long as we manage the additional demand.

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Post workshop comments: Vehicular and pedestrian routes and circuits are vital to the

health and vitality of a town centre Opportunities to create dwell time within the network and

which improve accessibility should be supported This may be facilitated by changes to building lines in

appropriate circumstances balanced against size and scale of buildings and opportunities to grow the town centre.

Multi-storey car parks are the only answer to car parking issues – people will not park and ride – they just won’t come to CMK to shop.

Topic 2 - Key public spaces and landscaping

Q2.1 Should a key principle be to improve Midsummer Boulevard East in its entirety (or parts of it) as a key public/civic space, reflecting its location in the heart of the core shopping area?

Q2.2 Does CMK needs a new public /civic square?

Be clear at the outset what is required by way of public space – its use, functions, the constraints. Is it public space that functions as a destination or as a space that leads the visitor somewhere else (ie linking up with other public spaces to create a pedestrian route through the middle of the city centre)? Experience of businesses at the Hub is that it is difficult to draw visitors down from the shopping centre end.

There was general agreement that the environment of the Midsummer Boulevard East (MBE) area needs to be improved. There are sites awaiting development and the area has an ‘empty lot ‘ feel and is not pedestrian friendly. It was also suggested that the design such as that used in the Tuileries gardens in Paris that allows many different routes across the site and creates many different spaces could be adopted. It was also suggested that recent developments in Bordeaux (Allees de Tourny1) could be a good model for MBE.

The EDAW plan identified six key areas for public open space that should not be forgotten. In addition the links between MBE and Campbell Park should not be left out as there needs to be a better connection between the two parts of CMK.

If Midsummer Boulevard East (MBE) became a public open space it could improve the connections between the north and south of CMK. There remained enthusiasm for retaining linkages north to south via Secklow Gate. But there was also a need to consider public transport that now uses MBE to provide ready access to Midsummer Place and the centre:mk. Any reduction in the availability of access to the centre of the shopping would be detrimental.

1 http://www.google.co.uk/imgres?imgurl=http://www.geo.fr/var/geo/storage/images/photos/reportages-geo/bordeaux/bordeaux-allees-tourny/422838-1-fre-FR/les-allees-de-tourny-en-1979_940x705.jpg&imgrefurl=http://www.geo.fr/voyages/guides-de-voyage/europe/france/aquitaine/bordeaux/(onglet)/photos&usg=__p8DgU6ipq3RdH1zkHc0aDuAwPtA=&h=705&w=940&sz=131&hl=en&start=13&zoom=1&tbnid=ZUn8IZo7LpksyM:&tbnh=111&tbnw=148&ei=9kGFT8vkJsrG8gP-1KDjBw&prev=/search%3Fq%3Dallees%2Bde%2Btourny%26hl%3Den%26safe%3Dactive%26sa%3DX%26rlz%3D1T4ACPW_enGB403GB402%26biw%3D1366%26bih%3D432%26tbm%3Disch%26prmd%3Dimvns&itbs=1

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Other thoughts were that the purpose of areas needed to be made very clear and their links with other parts of CMK clearly defined. The quality of the shopping and pedestrian experience would be affected by the quality of this experience but a successful open space would increase interest and therefore the “dwell time” in CMK.

There was some doubt that CMK was missing out on any events that would be resolved by the creation of a new area of civic open space in MBE. There was also a thought that we should be reviewing the open space that is already available within CMK to determine whether that could be used for different purposes. For example, could Queens Court and Middleton Hall be used more fully to enhance the experience and attractiveness of CMK?

Other views were that the open space would help to complete the string of pearls from the Station to Campbell Park and that to make Midsummer Boulevard, a pedestrian only area would be going back to the original concepts for MK – which had been lost in recent years.

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Post workshop comments: Support for the creation of a ‘grand’ civic square for the city –

it must be special. Midsummer Boulevard East should be improved There are opportunities to create private and public spaces,

covered and open areas, considered in the context o surrounding uses.

This will need to be masterplanned in light of existing activity and to support the existing shopping centres.

The approach to town centre transport should be considered across CMK (linked into outer areas) as a whole and how transport infrastructure can support land uses and add to the vitality of CMK and the shopping area in particular

The development of a dedicated carriageway along Midsummer Boulevard has the potential to create movement restrictions and conflict with the connection of pedestrian circuits

There needs to be an appropriate long-term solution to the market and the right mix and balance of uses across the boulevard.

Q2.3 Should we be seeking to improve existing and underused or isolated spaces by improving access to them; or is their charm due to their relative isolation?

The key problem was thought to be the lack of effective wayfinding. Progress is already being made with improved wayfinding at Station Square through to Campbell Park

However, it was also considered important to include “secret spaces” that could be sought out and explored by the public. Wayfinding would not be appropriate in such cases so some care would be needed to ensure that wayfinding was appropriate and not over blown. Important to consider existing pedestrian desire lines – minor improvements might be possible to certain public spaces to encourage more people to make use of them.

When considering the open space structure of CMK, the H5 and H6 grid roads function as transport corridors and also as landscaping corridors framing the city centre. Further thoughts included how to better integrate the Grand Union Canal and the Portway and Childs Way corridors into the “offer”? In the future could access on a main route (perhaps the Portway) be restricted to small cars or personalised transport? This links with a current idea in LTP3 for development of a “Taxi Bus” – which would enable small numbers of people to travel to many different places. Possibility of EU funding was currently being considered.

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Post workshop comments: CMK street furniture and landscaping should be enhanced and

maintained. Currently some would say that the standard of maintenance in CMK does not reflect well on the city and could deter future investment.

Topic 3 – Access, movement and parking

Q3.1 Do you agree that in recognition of the desire line they represent, there should be pedestrian provision where streets meet boulevards?

The discussion started by considering the issues – how to accommodate additional parking spaces within CMK proportionate to the planned level of growth and how planned improvements to public transport could mitigate the need for additional car parking.

Description of the original transport structure and hierarchy of routes – visitors arrive in CMK on a grid road; transfer to a ‘blue’ boulevard and then onto the ‘slow streets’ where surface car parking is located.

A query was raised in respect of the CMK transport hierarchy as described in para 4, page 12 of the workshop topic papers. In the adopted Milton Keynes Local Plan (MKLP). there is a disparity between the text in para 7.28 and Plan T1 in the MKLP which shows the primary and district distributor roads. Although para 7.28 in the MKLP describes the ‘gates’ in CMK as corresponding to District distributors, only the V6 (Grafton Gate); V7 (Saxon Gate) and V8 (Marlborough Gate) are shown on Plan T1.

The view of MKC officers is that the lower case text in para 7.28 is incorrectly drafted and Witan Gate and Secklow Gate are not and should not be classed as district distributors as unlike the former three gates they are not grid roads.

Discussion followed of the multi-modal transport model. So far the model has looked at the situation in 2026 based on the development projections in the Core Strategy. The modelling done so far is high level and strategic and does not include site specific or individual junctions. Further modelling at this smaller scale can follow.

Returning to the question, there was a feeling that there are already considerable opportunities for pedestrian and vehicular conflict and that we should not be encouraging more crossing points where conflict could be a problem. The worst area for pedestrian and vehicular conflict is Avebury Boulevard between Xscape and the Theatre District.

There was a request for information about pedestrian casualties.

Q3.2 Should there be an aspiration still for 24hr access through the centre:mk ?

Originally two pedestrian through routes were promised when the doors were added to the shopping centre. General agreement that there should be some access through the shopping centre at key locations as the building is

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just too large for people to walk around (throught Midsummer Place; Queens Court and then around John Lewis) . The Town Council gets regular complaints that there is no clear or well-lit path around the outside of John Lewis – so improvements to external paths and lighting might help to improve access around that part of the building.

The extent to which the centre should be opened up to public access varied, from access to enable shorter north-south routes to more longitudinal access, creating a public space, like a High Street for people to stroll and ‘promenade’.

The original idea for 24 hour access to the shopping centre came about when the planning applications were submitted for the extensions to the centre. These have now lapsed. Some of the walkways within the shopping centre are covered by walkways agreements and these could be renegotiated to achieve more accessibility.

From a management point of view, 24 hour access presents huge security and management issues. The shopping centre is not a High Street but an enclosed shopping centre and different conditions therefore apply. It is essentially private, not public space. There are huge costs associated with 24 hour access and there would need to be a convincing argument that extending public access into the night would, in some way, provide financial benefits over those additional costs. So far, the centre:mk has had limited success encouraging retailers to trade to 8pm at night, let alone stay open later.

Wider issues of making CMK feel safe and more welcoming at night, eg for people leaving the theatre. Some criticism of the approach of security guards in the shopping centre around the Queens Court food area and Pizza Express at night.

Further issue is the difficulty in accessing some fo the shops from the outside of the shopping centre. The shop units are increasingly turning their backs on the external access from the colonnades and restricting access only from within the malls. This might be due to security (easier to monitor activity at only one point of entry rather than two) but again inhibits the permeability of the shopping centre from the surrounding external space.

Q3.3 Are there any other pedestrian routes / desire lines that should receive targeted attention for improvement ?

Links felt to be lacking between: Campbell Park and CMK, including links to the canal Lack of public land link between Xscape and Campbell Park (though

there are routes from Fishermead to Xscape which are planned to be adopted by MKC)

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Need to do more in respect of cycling – the redways go to the edge of the city centre then stop. Need to expand the cycle routes east-west and north-south through CMK. There are nearly 20 connections with the redway system but only 1 route through the centre. Sustrans route 51 runs along Midsummer Boulevard.

Q3.4 Do you agree future parking for new development should be provided on site (rather than the current provision of 30% max) ?

Current parking policy in CMK is that the developers cannot provide more than 30% of car parking requirements on-plot. The question is whether or not we want to continue that restriction. There was a view that greater flexibility was appropriate – even up to allowing 100% of parking requirements to be met on-site. .

Agreement that any public spaces lost to development needed to be replaced.

Warning that 100% of parking on-site would affect viability of schemes – undercroft or MSCP parking is expensive and such an approach might limit the amount of floorspace that can be achieved.

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Post Workshop comments: As recognised in the EDAW study, although MK has a well

developed redway cycle network, the system does not extend well into CMK

Anecdotal evidence suggests that, notwithstanding some partial improvements (eg completion of the north-south Saxon Gate redway link) cycling in CMK remains hazardous. The aspiration of creating an environment where the cyclist can safely share carriageways with motor vehicles has not been realised.

Proposals to complete the ‘cruciform’ (ie a redway running up Midsummer in the central median) and to upgrade other strategic redways arriving in CMK eg H5, H6, V6 and V8, are supported and are consistent with Policy T1 of the MKLP. These proposals are also consistent with MKC’s low carbon agenda/ aspirations.

Pursuing and implementing such measures in the short terms will provide the best opportunity of providing genuine transport choice and the potential for modal shift through the creation of a safer environment for cyclists.

Need to consider whether the amount of car parking on a site is a key issue for firms moving into CMK?

Need an understanding of how much car parking is currently available in CMK and at what point it will be fully utilised.

Alternatives to car parking? Commercial park and ride Staff parking outside CMK, with courtesy bus. Customer behaviour for retail is changing – increasing online

purchasing; high fuel costs mean that fewer people are driving to CMK. Christmas 2011 saw a drop in car borne visitors from 81% of visitors previously to 71%.

Can employers be encouraged to open up private parking to the public? First need to be clear what need there is for private parking to be used. The use of private parking is unlikely to be acceptable to many businesses and institutional investors.

Additional question/ discussion – CMK movement network and links to surrounding residential areas

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Post workshop comments: Car parking is critical to the success of CMK. Basement car

parking is unviable currently. Some schemes may, however wish to secure more than the 30% on site maximum and there should be flexibility to achieve more or less parking.

All on-plot parking will increase costs (especially if MSCP or undercroft parking is required) and this will impact on viability of schemes and on the built form and densities.

100% on plot parking would also go against the long term parking policies for CMK where public parking has taken its share of the burden of parking demands from new developments.

The ring of MSCPs as proposed in the EDAW study and the Adopted MKLP are unlikely to come forward due to cost and also sustainability factors

The Framework should recognise that a future doubling of the population does not result in double trips and double demand for parking.

Some concern at the possible removal of the public transport route through Midsummer Boulevard. There is a clear relationship between the movement network in CMK and the rest of Milton Keynes. The role of the Development Framework is to make the best decisions for how traffic flows within CMK.

Is there a conflict between the different roles of CMK – both as a sub regional centre and a district centre for the surrounding estates? There are issues for through routes into the surrounding estates. There are strategic routes into CMK from the north, south and west, but poor access from the east.

Funding infrastructure – the MSCPs as proposed by the EDAW plan would have cost in the region of £40 million to develop and would have created 20,000 parking spaces.

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Post workshop comments: Agree that there should be a relationship between CMK and

access/interchange with the surrounding estates. The scale of growth proposed for CMK requires an appropriate transport

solution Given MK geography and layout it lends itself to multiple hopper services

and not one or two larger interchanges. As the current characteristics are for a small number of people going to numerous destinations as opposed to large numbers of people going to limited destinations.

Whilst any increase in population would increase pressure on the transport network it would also drive demand and increase the customer base for more public transport services

A comprehensive strategy would need to be set out in CIL through the Charging Schedule and Infrastructure Plans.

Topic 4 – Districts

Q4.1 Is it agreed that the West End/ SRQ is not included as a particular district and hence has the flexibility to accommodate a variety of uses?

The approach being suggested seeks to balance flexibility with prescription over land uses. Flexibility is needed to allow for creative applications where they will complement the CMK offer.

Views expressed that Campbell Park should be made predominantly residential.

Concern that the DF should not be silent on what uses are appropriate in those areas not currently identified on the plans as falling within a distinct ‘district.’

Is it more appropriate to talk about destinations within CMK rather than districts? Destinations are about people, pedestrians and movement.

Perhaps some areas within CMK should be protected – eg core shopping centre; leisure/entertainment area. The rest could be left open to the market but with criteria to require mixed use; a mixture of small and large footprint uses and active frontages.

As an alternative to districts use performance criteria to determine why a particular use should be in a specific location.

Alternatively retain the concept of districts but produce something more narrative in style, describing in qualitative terms what the area looks and feels like; what its character is, so that future land uses can be judged for their contribution to that character.

Cultural provision in CMK does not sit well with the commercial leisure and entertainment sector. . Cultural provision should be spread throughout the city centre.

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Post workshop comments: The framework should be flexible in order to adapt to changes from how we live,

work and spend our leisure time whilst reflecting the “Basic Principles “ of CMK development. Flexibility is key to CMK’s success but this should be reinforced by some basic rules/ principles. We should not be trying to reinvent the “ basic principles “ every time at a review. To continually review will hold back development and deliverability as some would suggest happened in the last development cycle ?

APPENDIX 5

CMK Development Framework Review SPD – Consultation Comments and Officer Responses

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Consultee Comment Officer ResponseMKC Highways and Transport

The comments below specifically relate to section 3.4. However, the comments apply equally to other references to the same topics elsewhere in the Review. The subsequent PT comments relate to the document more generally.

General transport-related commentsPara 3.4.2 – confused wording:

It is titled “Strategic Principles”, then refers to “these objectives” and then lists 3 key challenges.

Suggestion: List the objectives in 3.4.1 principles are the 8 bullets listed later in this section. Sub headings would help.

The last word in the 3rd key challenge should be “pedestrians” not ‘passengers’.

In the bullet list of principles:1st bullet – remove reference to MK Star. Improved PT is a sufficient principle on its own.2nd bullet – change to add Arrive & Ride. (P&R is away from CMK i.e. Coachway, A&R is on edge of or within CMK).3rd bullet – this would be better combined with bullet 1, e.g. “Improved PT into and around CMK…”.5th Bullet – should say retain the majority of or something similar; simply retaining all of it does not allow flexibility.

Accepted – will delete word principles in first section

Accepted – will change

Accepted in part

This is referring to Park and Ride – this is about PT beyond just CMK

Para 3.4.3 -The street hierarchy set out in 3.4.3 and shown in Figure 2 is not correct. The description should be as follows:

Accepted – will amend

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“The street hierarchy in CMK consists of Primary Distributors, District Distributors, Local Distributors and Access Streets.

H5 Portway is a Primary Distributor.

V6 Grafton Street and Grafton Gate, V7 Saxon Street and Saxon Gate, V8 Marlborough Street and H6 Childs Way are District Distributors.

Silbury, Midsummer & Avebury Boulevards, and Elder, Witan, Secklow, Marlborough, Skeldon, Enmore Gates & Overgate are Local Distributors.

All other “Streets” and “Rows” are Access Streets.

This hierarchy is shown in Figure 2.”

This could be followed with a modified descriptive text about how traffic uses these streets. The bullet point at the end of this section should have the reference to “pedestrian links” removed – it suggests that the pedestrian network is currently acceptable.

The principle at the end of this section is more of a statement and does not really help developers understand the requirements for new proposals. A principle should be along the lines that “this movement framework will be retained unless changes or additions are consistent with the overall structure.”

Figure 2 needs to be amended as per the comments above. Additionally, the two stubs of Marlborough Gate (into Xscape and

Accepted – will change

Accepted in part – will change

Accepted – will change

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into block E1) need to be removed from the Local Distributor designation and shown as Access Streets.

3.4.4 Principle 1.c. Although the wording is technically correct, it is potentially confusing and will lead to criticism for not connecting boulevard Portes Cochere with those on the Rows. This would be better as part of principle 1.b. and drop the long reference to Portes Cochere.

Accepted – will change

3.4.4 Principle 2.a. The comment in brackets is unhelpful here. The document already states that mid-block routes are not required. There is no harm in other routes linking to mid-block Portes Cochere.

Accepted – will change

3.4.4 A further principle (2.f.) should be added for “Car Parks”. Accepted – will change

3.4.4 Principle 3.g. These are not necessarily desire lines. They are more akin to priority routes and should be in the first list. People have to cross at overbridges / underpasses, but these may not be precisely on desire lines.

Accepted – will change

3.4.4 Principle 4. In the first sentence delete “following”. Accepted – will change

3.4.4 Principle 5. This needs more text about what is involved in being compliant with the Equality Act 2010 (not the DDA 1995). Routes require consideration of crossing locations & types, tactile paving, street furniture and planters, kerb upstands etc. etc. to provide suitable and safe routes. A series of sub-principles might be more appropriate.

Accepted – will change

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3.4.4 Principle 6. Signing and Wayfinding needs more explanation and a description of what could be implemented, where, when and how. Wayfinding is sufficiently important to warrant a section on its own. This could also pick up on associated elements such as street furniture & RTPI.

Accepted – will add further detail

3.4.5 This section is disappointingly brief. This section should replicate the detail of the pedestrian section. The principles are very weak and are quite specific; some broader principles would be better (numbered as per the pedestrian section) and more at the aspirational level.

Principles should include:• Provision of high quality, safe, segregated cycle routes at all entry points to CMK;• Improvement of cycle movement within CMK on new and improved north-south and east-west routes;• Provision of safe, secure and covered cycle parking around CMK, incorporating associated facilities such as showers, cycle repair and information;• Provision of improved Wayfinding for cyclists and better route information.

In addition, the sentence “Future longer term proposals include:” should be deleted. The schemes referred to are not less important – particularly over the life of the Framework timescale. These should simply be listed as “cycle schemes” or something similar.

The last bullet (Dedicated changing facilities…) should be phrased as “additional”, because we already have the ‘Gearchange’ facility.

Accepted – will amend as suggested

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An additional element should be added to the bullet list covering a cycle-hire scheme for CMK.

In terms of the Council’s priorities, Public Transport should follow Cycling, with Car Parking being the final sub-section. As Wayfinding cuts across all elements the section should be structured as follows:• Wayfinding• Pedestrian Movement• Cycling• Public Transport• Car Parking

Accepted in part – will include something on wayfinding.

MKC Highways and TransportMKC Highways and Transport

3.4.7 “Public Transport” As with the cycling sub-section, this should be structured better to have a set of aspirational broad principles such as:• Improve PT access to and around CMK;• Improve the quality of interchanges and stops in CMK, including waiting and associated facilities;• Provide better Real-Time and other Passenger Information;

The two principles listed (MK Star and Bus Hopper Service) are not principles. These are proposals that will enable us to achieve the principles above. Colleagues in PT have provided further comments on this part of the Review.

The role of the Hopper Service and its viability and impacts on existing services needs to be explored. We would undertake feasibility work first to determine whether a Hopper Service could be run in CMK. The Review should scale-back the comments on the

Accepted in part – is the Hopper service not included in LTP3?

Agreed – similar comments have been made by Transport colleagues on the CMK Alliance Business Neighbourhood Plan consultation draft.

Amend the text to clarify that although the reference is made to the implementation of a “CMK shuttle service” as the shuttle or hopper service is one of the short term LTP3 interventions, the Council has not yet carried out any work to establish the precise demand for such a service, how a

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Hopper Service and indicate that this is one of a number of areas we will be looking at.

Figure 3 should not show the Hopper Service – particularly as we have not done any feasibility work to establish what a route might be.

The last paragraph about cleaner fuels etc. is not relevant to this planning document.

service would be delivered, what infrastructure support it would need (stops, shelters, signs, road markings etc.) and where the funding would come from. Although it is listed as a short term intervention in LTP3, the delivery of a shuttle service would need to go through a prioritisation process to assess it against other interventions and transport services.

Will remove from fig 3 the proposed annotation for the Bus Hopper serviceInclusion as an intervention in LTP3 does not guarantee the delivery of this scheme, and, given the current financial constraints on the Council, budget pressures mean that there is a very strong likelihood that no or insufficient funding will be available from MKC in the near future.

3.4.6 “Car Parking” As already stated, this should be the last sub-section. The principles listed are lengthy and too detailed without being aspirational. Principles could be:• All new development in CMK will provide car parking in accordance with the Council’s Parking Standards;• Public parking spaces lost as a result of new development will be replaced on a 1:1 basis;• Parking will normally be provided within the development site, or, where this is not possible, it will be provided in an agreed location and at the developer’s expense;• Where possible, new parking should be provided either in basements or in decked car parks within new developments;• Enhanced VMS and Wayfinding systems will assist drivers to an appropriate parking location and to their ultimate destination;

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• A range of parking options will be utilised to encourage a mix of short-stay and long-stay parking as well as parking for disabled users, electric vehicles and other more sustainable alternatives.

Passenger Transport CommentsGeneral points: The structure, formatting needs to be more consistent. There

are a lot of contradictions between Section 2 and Section 3 when it comes to Transport, and even in Section 3 alone.

Need to consider in perhaps greater depth the impact of some of the principles on how CMK could grow and development in the future, such as change to infrastructure, space and development form.

Should there be more ‘future-looking’ at Campbell Park, development type and access provision?

How do the maintenance related items, particularly where granite setts are involved, balance with Council budget pressures. There needs to be some management of expectation.

Although pointed out in my comment in 3.4.4.5, this should look at updating CMK where possible and relevant, addressing access problems such as this.

Will check for contradictions and amend as necessary.

Detailed comments:

Para 2.2• 1) Safeguard tree lined Boulevards and Gates ~ At the expense of development and further improvements to pedestrian/cyclist/bus user environment?

This is a general/ high level principle, clearly in individual cases there may be some need to remove trees

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• 4) First item is “Recognise the role of the car” ~ Should this really be first? Is that a core value to ensuring ease and choice of access for ALL? – This doesn’t fit with the existing User Hierarchy outlined in the Local Plan.– What does a multi-modal approach really mean? Are these just buzz words?– Taking a holistic view on city centre parking surely would mean a view across all modes and then managing this in the most equitable way in terms of priority/land use?

Will move this bullet further down the list to reflect hierarchy

Para 3.1.2• 6 ) Retaining Boulevards and gates on existing levels ~ Possibly alter to “retaining the current gates and boulevards on existing levels is supported unless there are compelling reasons for a change which benefit the other aspect of the framework principles/aims”.

• 9) By acknowledging that MSB from Station Square to Campbell is the top level pedestrian route, this is exactly why MSB should be the public transport spine to access buses most easily.

No change proposed – presumption implies some flexibility

Agree

Para 3.4• Much of the introduction and Strategic principles section is contradictory to that in 2.2 (see above).

Para 3.4.2 • Primary point should be improving the pedestrian/bus stop facility within CMK and not the MK Star, as this is Borough Wide.

See earlier comment

Agree – will change

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The facilities and environment in CMK are what this document influences. • Park & Ride in CMK is NOT P&R. This is Arrive & Ride and should be aligned with the views in LTP3. • Should focus on central access to public transport and this should link to the Public Transport Spine…and this should link back to the point in 3.1.2 9 (above). • States that improved interchange modes will be developed. Where would this occur other than Station Square…which has already been improved? I think this is perhaps misleading. • This section really should focus on the pedestrian environment/scale from the outset.

Disagree – this does refer to Park and Ride

Agree

Agree – will delete reference

Disagree – it is concerned with all modes of movement

Para 3.4.3• This should be structured in the same order as the user hierarchy in the Local Plan.

Agree in part – will leave street hierarchy here but will reorder other sections

Para 3.4.4• 5) This should also refer to the Equalities Act 2010, as well that is a priority to address this issue across the whole of CMK.

• 6)Mentioning Wayfinding scheme here (and elsewhere) should make mention of the approved scheme.

Agree – will amend

Will include Wayfinding in a section in its own right

Para 3.4.7• Based on user hierarchy this really should come before car parking. • 1) This section on MK Star should focus on CMK, making

Agree – will amend

See comments on the MK Star and hopper service in the

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mention of the quality stopping locations, primary transport corridor and the ability to provide links to CMK and beyond. Emphasise that this is about through routes.

• 2). The Bus Hopper service needs to be reconsidered. Despite being in the LTP3, it has no identified financial backing and limited officer backing. Funding for this would either have to come via prioritisation of the Local Bus Contract subsidy budget or third party/one off funding. It is difficult to justify the described level of importance that this service plays within the document/future of CMK whilst it is still so uncertain.

• The section at the end of the Station Square bit needs deleting. There is no need for another interchange and everything after “commuter parking.” can be deleted.

• the end sentence regarding future aspiration probably doesn’t add anything to the section and could be deleted.

• Fig 3 needs to remove the coloured shading on the old bus station referring to it as a Primary Public Transport Interchange.

• Consider referring to Station Square as a Multi-Modal Public Transport Hub and instead of Super Stops referring to them as Enhanced Public Transport Hubs…or similar.

General Transport comments above.

Agree – will amend

Agree – will amend

Agree – will amend

Agree – will amend but need to discuss terminology

Andy Swannell, MKC Development Management Highways

P9, 2.2 (1) bullet point 1 Retain the geometry of the grid – the grid is in place and provides the whole structure around which the rest of CMK is built. The grid should remain but allowances can be made for interruptions to it as long as these don't create adverse

Comment Noted – but this would result in too much detail for this section

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highway capacity issues elsewhere.

P9 2.2 (4) I agree with all the bullet points made but they should probably be re-ordered to accord with road hierarchy principles. Should 'recognise the role of the car' be changed to 'recognise the presence of the car' i.e. do we need to accept that we are never going to remove the car from CMK to a greater extent as other cities have been able to via the introduction of 'park and ride ' facilities?

Agree – will amend

P11 3.1.1 bullet point 8 – It may not be possible to maintain CMK roads with Asphalt/Silver chippings. I agree that this should be our endeavour but I just warn that this may not be possible in the long term.

Comment noted

P12 3.1.1 point 2 – 'slow moving traffic' is not a principle that has been maintained in CMK and in order to reinforce this I believe that some parts of CMK (core shopping area) should be subject to a 20mph speed limit/zone. This will hopefully go some way to ensuring that pedestrians can move about in relative safety. It would also help further define the 'Zone of Enhanced Pedestrian Experience' areas shown on the plan on page 23.

Will discuss 20mph limit

3.1.2 – I agree with paragraphs 1 and 2.

2.1 – Streets should only be removed or relocated where evidence can be shown that their removal does not negatively affect capacity elsewhere.

Comment Noted

Comment noted – will include

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6 – to this paragraph should be added the comment 'and only when it is clear that any lowering will not affect the movement of traffic/pedestrians or cyclists and that the highway capacity of any of the roads involved (including the 'slow streets') will not be significantly affected'.

9 – There are legibility issues concerned with the movement of pedestrians along Midsummer Blvd from Station Square to Campbell Park, notably at Marlborough Gate.

Comment noted – will include

P15 3.3.5 I think there could be logistic issues in limiting service access to streets only.

P18 3.4.2 (1) Are you sure this is correct? Surely we have just been through an exercise that tells us development can be maintained with little increase in car parking provision. That said, improvements to sustainability should always be sought through an encouragement of modal transport shift.

(2) Doesn't this contradict the necessary change in modal shift? It also goes back to the question I raised initially regarding the 'recognition of the car'. Perhaps debate is required.

3.4.3 (1) – Are you sure you want to say that Secklow and Witan Gate are equally important as Grafton and Saxon Gates? We currently aren't objecting to the removal of part of Secklow but would probably object to the removal of part of V6 or V7!

This has been discussed in the General Transport Comments section above. Revised text has been provided by the Transport team.

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(Bullet point) – the problem here is that the linking bridge crossings don't line up with the streets on the north-south axis so ped and cycle access into CMK is compromised in terms of legibility.

P20 3.4.4 – Sorry I can't agree with the last paragraph.

I agree with most of the principles but there needs to be recognition that the underpasses are still considered by some to present personal safety issues; how can surveillance be improved at these? I can't imagine that anyone uses the current routes to or through Campbell Park (other than on the boulevards) as routes from Campbell Park into the shopping area during the hours of darkness and therefore question the pedestrian desire line at 'd' under Pedestrian desire Lines. In general does enhancement need to include improved street lighting?

Noted

Unclear what this means?

P21 3.4.5 future long term proposals – There appear to be several insurmountable constraints to achieving a Route 51 on the central median of Midsummer Boulevard. The route may be feasible from Station Square to Saxon Gate (although Grafton Gate itself presents a difficulty) but the central median of MSB through the Core Shopping Area is punctuated by both Midsummer Place and would be further disrupted by the current centre:mk proposals. Further east the route through Marlborough Gate presents difficulties. Transport's current thinking is that the route should possibly run on the outer roads of CMK and then be brought into CMK through an increase in the number of north/south links such as that now established to the immediate east of Saxon Gate.

Will couch this in more general terms

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3.4.6 Car Parking Principles – bullet point 2 states that a more flexible approach will be taken regarding the level of parking that can be provided on plot as part of any development. How is policy on this to be formed and how are criteria to be established. Any increase in on-plot parking will reduce revenue's to the council for CMK car parking. I'm not convinced this is the way we should be going. I agree with the basic principle at bullet point 4. Bullet point 5 speaks of integral garages but currently the car parking standards do not allow these. However, if development can be designed such that there are no alternative places to park then this may be acceptable.

Bullet point 9 talks of an improved VMS system. The only way that this will be of benefit to motorists is for the VMS to be placed on grid road approaches to CMK and at strategically placed locations, otherwise they will be of no worth to motorists.

This relates mainly to new commercial development. Parking Standards will have to be met, but if a developer chooses to put the parking all on plot then this should be seen as acceptable. A key issue to be resolve though is how to make them publicly accessible in say the evening or on weekends (the importance of this will depend on the location, the more central to retail areas, the more important it will be to allow public use.Why do parking standards currently not allow integral garages

Comment Noted – will include

P22, 2 – The bus hopper service proposal is a worthy inclusion in the public transport realm, although personally I feel any area of CMK within a 10 minute walk should be feasible. However there are pedestrian journeys of longer duration than this in CMK and the bus hopper service will provide an alternative and convenient mode for these. The service though will not overcome the anecdotal reports of shoppers moving their car from one end of the Core Shopping Area to the other depending on what shops they wish to visit.

Comment noted – no change needed

P23 – The plan shows the previous bus station as a Primary Public No, this is a typo

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Transport Interchange. Is this feasible?

Chris Jarman, MKC Passenger Transport

Put simply, from the PT perspective we want to retain the Midsummer Boulevard public transport spine (inclusive of lower Ninth Street) and enhance the existing stopping areas. A 2nd interchange is not required, would be inefficiently used and would be restricted in size and not allow future enhancement when required.

Alteration of existing should be seen as the way forward, keeping public transport central to the majority of CMK and within visual proximity to visitors. This was the concept behind enhancing the existing infrastructure back in 2005 when we were discussing it with Arriva and HCA and this has not changed. An interchange is not needed - with improved signage, people can change from bus to bus or foot to bus right now. Station Square is a modal interchange, something that’s not relevant in the rest of CMK.

Agreed – will amend SPD to delete reference to 2nd

interchange

CMK Town Council 1. The boundary of CMK shown on page 6 goes beyond the

boundary shown in the Core Strategy and the similar boundary shown in the 2005 Local Plan. Whilst the pre-consultation draft CMK Business Neighbourhood Development Plan (BNDP) adopts a wider boundary than the Core Strategy covering the whole of the CMK Town Council’s administrative area, the boundary of this draft SPD goes beyond even that. The town council believes that the SPD boundary needs to be consistent with either the Core Strategy or the BNDP.

The geographic area of the CMK Development Framework SPD is drawn slightly wider than the extent of the CMK Development boundary in the Core Strategy and in the MKLP as it includes both sides of the greenframe. The reason for this being that both sides of the greenframe need to be considered if trying to make connections between neighbouring estates and CMK better and safer. This point was discussed and agreed at the cross-party Member briefing on 29 November 2012.

2. Also on page 6, what is the picture of CMK meant to convey? Will add text to caption – “illustrating some new developments as well as vacant development sites”

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There is no explanation in the page 6 text.

3. Section 2 page 9 – whilst the Master Plan goals are listed, the 10 objectives of Core Strategy CS7 are not. A legal planning check is needed to ensure that the values and principles are fully consistent with the Core Strategy objectives.

Will review/check – although as the CMK Development Framework is to be adopted against the MKLP, it will be checked against the Vision and Aims of that plan for now.

4. Introduction paragraph 3.1.1, the council is responsible for the ‘public realm’. The third sentence needs to change to read “Milton Keynes Council will nurture and maintain the public realm to the highest possible standard.”

It might not be MKC in the future –other bodies could be involved.

5. Section 3.1.2 in summary requires the retention of the public infrastructure ‘unless significant public benefit or existing outline approval overrides this’. This needs to be strengthened and greater clarity provided as to what constitutes the ‘infrastructure’, ‘significant’ and ‘public benefits.’ In line with NPPF, we believe public benefits must include economic, social and environmental benefits that are delivered together – it is not sufficient to have only economic, for example, without social and environmental. The infrastructure of CMK is its key critical success factor and this section does not adequately capture how critical this is to the functioning of the city centre – any loss of the functionality provided by infrastructure should be wholly exceptional.

In the section on the Protection of the Key public realm infrastructure (3.2), the text makes it clear that the public realm is the key to the unique identity of CMK. The text also makes it clear that public benefits do not imply just economic benefits, but equally encompass social and environmental factors. We consider that the proposed wording saying “that changes to the infrastructure will only be considered and permitted if significant public benefits result” would on the one hand offer enough protection of the public realm and give a clear message that the presumption is to protect it but on the other hand would also allow flexibility for alterations to occur.

6. In addition, paragraph 4b was added late in the drafting The reference to “a development seen as important to CMK” relates to what is seen as important to local residents

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process (we had not seen it previously) and it is even weaker than the ‘significant public benefit’ statement above – every development that wishes to expand its footprint will claim that it is ‘important’ to CMK and should be allowed to build over the public infrastructure (car parking in this case). Again, economic, social and environmental benefits would have to be delivered simultaneously and such footprint expansion over parking permitted in only highly exceptional cases. As written, the Framework is allowing development that will erode and eventually destroy the accessibility that has made CMK successful. CMK will end up like other town centres, plagued by congestion and lack of parking.

and the town council not the developer, hence the reference to Waitrose.

The reference to Waitrose and indeed any development seen as important to CMK will be removed

7. Figure 1, page 13 is a plan of key structuring elements which identifies what is to be protected. The plan needs to provide greater clarity re: building lines, grid structure and underpasses to be retained. Also the drawing is not consistent with proposed policies and needs to be brought in line. For consistency, building lines in B4 and Campbell Park development blocks should be set back in order to protect the public realm, promote walking and cycling, respect the setting of Campbell Park, and keep future transport routes open on H6 and H5 grid road corridors.

Agree in part – The building lines in B4 and Campbell Park shown in Figure 1 reflect the extent of extant planning permissions. Should developers of these sites seek to revise the current planning permissions then the guidance in this SPG would be used in the discussions.

8. Pages 18 and 19, street hierarchy - the CMK road hierarchy diagram at figure 2 contains a number of inaccuracies that require correction. A new category of road has been

Agree will amend the road categories used to follow those in T9 of the MKLP. There remains some disagreement over the interpretation of the road hierarchy. It is proposed to amend

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‘invented’, that of "Primary District Distributor". All the grid roads through and surrounding CMK have been placed in this category. However, no such category of "Primary District Distributor" exists in the national planning and transport vocabulary. H5 Portway is a primary distributor and all the other grid roads around and through CMK are district distributors. Additionally, paragraph 7.28 of the Local Plan 2005 also defines the CMK 'gates' as 'district distributors’, whether or not also a grid road. This SPD should be consistent with the Local Plan, which is the only council policy document to define the MK road hierarchy.

the text in the Development Framework a follows:

“H5 Portway is a Primary Distributor.

V6 Grafton Street (and Grafton Gate), V7 Saxon Street (and Saxon Gate), V8 Marlborough Street and H6 Childs Way are District Distributors.

Elder, Witan, Secklow, Skeldon & Enmore Gates, as well as Overgate, are Local Distributors; however, the Local Plan requirements for District Distributors apply to them.

Silbury, Midsummer & Avebury Boulevards and Marlborough Gate are Local Distributors.

All other “Streets” and “Rows” are Access Streets.

Primary ‘Gates’ of V6 and V7, which run north-south between the H5 and H6, are the entry points into CMK and also provide via the surface level car parking, access to development blocks, service access as well as access to North and South Row. The V6 and V7 are part of the wider CMK grid road system. Elder, Secklow, Witan, Skeldon & Enmore Gates and Overgate are also important for access into CMK but are not part of the wider grid road network.”

The final paragraph above explains the reason for the differentiation between the Grafton and Saxon Gate and the other gates in CMK and Campbell Park.

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9. Car parking – the second paragraph of 3.4.6 should be removed. It doesn’t add anything to the document and should not be part of an SPD. It simply refers to an internal study that is incomplete. Likewise, under principles, the last bullet should be removed and the penultimate bullet should also be removed since this bullet point is covered in its correct wording in the council’s Local Transport Plan 3. A clear strategy is needed to identify what parking goes where; there needs to be robust policies for implementing the necessary increase and relocation of spaces.

Disagree – this paragraph has been drafted in discussion with MKC Highways.

Will amend penultimate bullet

10. Page 22, MK Star – Local Transport Plan 3 (LTP3) the council’s principal transport policy document does not state that the MK Star routes are proposed to run along Midsummer Boulevard. In the same way that this SPG has to be in conformity with the Core Strategy and the Local Plan, it also has to be in conformity with LTP3.

Agree – will delete the link between MK Star and Midsummer Boulevard. The text is proposed to be amended to say

“One of the key ways of improving public transport into CMK is via the MK Star. This is a high frequency network of bus routes operating along arterial corridors and other corridors of high demand, providing excellent network coverage across the city with all routes passing into and through CMK.

The network in CMK, particularly at Midsummer/Saxon intersection, Saxon/Avebury and Avebury/Lower 9th (but not exclusively) needs to support and maintain appropriate access for pedestrians and cyclists and support reliable journey times for public transport. This may require future junction improvements.”

11. Page 23, figure 3 – the access, movement and parking The route of the walkway agreement through Midsummer

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diagram, should show the primary pedestrian route through Midsummer Place which is protected by both a walkway agreement and a section 106 agreement. The public transport arrangement shown on figure 3 is out of date. It is the interim arrangement taken from the Bus Strategy that formed part of LTP2. LTP2 and its accompanying Bus Strategy expired on 31 March 2011 and both were replaced by LTP3, a comprehensive document that dealt with all strategic transport matters for the period to 2031. What should be shown in this SPG is the public transport arrangement that are needed to be put in place by 2031 to achieve the step-change in public transport that other policy documents recognise is required, and the phasing of how to get there.

Place as well other documented walkway agreements will be shown on Figure 2 .

The council’s transport policy team have commented on the draft SPD and their comments have now been included, so the guidance should now be correct.

The proposed alignment of the bus hopper service will be deleted from figure 3

12. Page 24, boulevard and gate trees – the need to remove trees in the public realm if public or economic benefit can be demonstrated is not accepted. The test should be the same as that for trees subject to a preservation order, which can be removed in certain exceptional circumstances.

The presumption is to retain trees and any trees removed need to if / where appropriate be replaced.

The wording proposed does imply retention unless exceptional circumstances exist.

Wording has been added to say trees can be removed if diseased and need to be removed.

13. Page 25, civic square – the idea of a central public space is supported, but if the SPG is to properly perform its function,

Agreed in part – it is proposed to amend the Development Framework to identify a site for a new civic square south of

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the location and size of the space needs to be clearly shown. Midsummer Boulevard within a portion of the existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people This will be identified via an asterisk on Figure 4

14. Page 28, character areas - there is a need to define preferred land uses plot by plot, rather than drawing a line around areas, as this will tend to discourage mixed use and encourage zoning; flexibility in land use is essential.

Disagree in part. It is considered too prescriptive to define land uses plot by plot. Text is very clear that mixed use is still needed and the emphasis is on predominant use and character which is believed important for investor confidence

Cllr Ferrans Vision and PrinciplesGeneral lack of vision to move us forward. More of the same or blank sheet.

Clear intention to retain the central shopping building as the key retail area, but no response to business needs to resolve parking and access problems or to resolve the need for larger units for key shops combined with a better offering of smaller units to provide more diversity, and a good marketplace.If this goes ahead, CMK shopping building will decline, leaving us with a dead heart to the city centre.

No up-front vision for transport to solve the problems it

The Values and Principles do, to an extent, outline a vision.This document is furthermore a refresh or review of the EDAW plan and so does not cover everything - it is about outlining high level principles

Disagree – these issues are covered within the section on ‘Grain of Development and Variety in Building Typology’

The SPD responds to Business Needs in terms of parking by encouraging greater amount of on plot parking

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acknowledges exist.

This SPD sets high level principles, from which detail to solve transport problems will flow

Principle 2.1 is confusing - not clear that this is vehicular and it appears to give virtually no clarity on the vehicular framework and it is not clear whether it maintains routes purely into or through the CMK area. This cannot be left to individual site development as it is essential to maintain coherence and connectivity for legibility and traffic flow. This is a key requirement of the framework and it fails.

It should be specific about what it is protecting and what it is leaving open to proposals so that key traffic flow can be tested, service access strategies developed, and waymarking designed.

However, principle 9 is much clearer. Suggest that they should be put together so that they are read together. About right for pedestrians.

The principle has been amended to include reference to impact on highway capacity.

The first part of para 2.1 is not a principle and has been moved to the first bullet under 3.1.1

It is proposed to rework the Key Principles section to address these and other comments.

principle 8.d is either misworded so that it is restrictive rather than permissive, or overly restrictive as it means the linking of plots in completely different zones.

Ideally if underpasses/overbridges are to be made to feel safer then overlooking development should occur on both sides of the overbridge/underpass.

Buildings of Heritage.The plan does not match the text!Protection of heritage buildings in a city centre needs to be for

Agree – the section and plan will be amended. All buildings in ‘blue’ will be removed with only the centre:mk being retained

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very good reasons, and we need to be convinced that they are viable and will not create dead spaces in our centre.How on earth does MK Library get onto the text list? (and not the plan). it is surely a fairly mundane 80s building?The food centre is shown on the plan but has little architectural merit that I know of, is not overly viable and not in the text.Lloyds Court similarly has not proved overly viable in its current form.Similarly the bus station - not aware of any bids and it's never been a very pleasant building to use.

Please sort this out and put it out again for consultation.

This section is proposed to be reworded to refer to the possibility of preparing a Local List of both heritage assets and public art.

Existing Public Art - not clear which items are protected, and whether this is only the early stuff or includes later pieces too. Policy is OK but scope totally unclear.

This section is proposed to be reworded to refer to the possibility of preparing a Local List of both heritage assets and public art.

Block structure.There is a general blurring of discussion between blocks and their interior spaces, and public squares. The Hub for instance, was specifically designed to provide a new public square, protected from the weather that makes outdoor spaces in MK generally unusable for much of the year. It should not be viewed as a normal block. The Block structure section does not address such elements. Does this mean that we are returning to unusable outdoor spaces such as the old city square which was abandoned because it was unusable due to the high winds?

The issue with the Hub is not the central square itself but rather the fact that it is public which made it very difficult to achieve active frontages facing Witan Gate and the square.

Will include text to provide background to the problems associated with public space internalised to older blocks (eg City Gardens)

I am disappointed to see the protection of the 4-lane parking by the boulevards - but then there is no strategy for parking and

Does this refer to 2-lane parking? 4 lane parking is along the Gates.

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access generally. It has been demonstrated that current provision will not meet the requirements of CMK going forward and this is not addressed at all.

Following the recent CMK Parking Study depending on which scenario is selected there maybe sufficient parking going forward (currently there are 7000 vacant spaces in CMK)

There is then a perpetuation of the wish for the Gates to be active frontages. while this is sensible for the Midsummer - Silbury block, and in active areas Avebury-Midsummer, and for the corner sites that lead to underpasses, applied throughout, this is nonsense. Elsewhere, the Gates are the least important in the hierarchy of active frontages. Most have far too little facing onto them to be attractive to pedestrians, and several lead to dead ends, so there is simply insufficient passing pedestrians to warrant this. Further, the levels are such that many can't be seen from the roads, and its the first floor that needs to be animated in these cases. Since the deadest part of the frontage of the outer corner blocks is the back corner facing the Gate/grid road, it might make sense for these to be the service access, eg the theatre block approach of servicing from this area and an attractive public square in the centre.

Streets are more attractive because they generally lead to more places. Fine for these to be animated. But walking past rows of office workers doesn't add much interest!

A maximum height of 3-3.5 m for the protected walkway from ground level is nonsense! Which is it? And where the walkway is itself elevated, does this mean from the outside level or the walkway level? Also elevation and height needs to be agreed for the whole block if possible, to avoid constant disruption of pedestrian walkway.

The aim is for buildings that front the 3 most important pedestrian routes – Midsummer, Avebury and Silbury Boulevards – to be designed so as to allow for an active ground floor frontage to be included.

It is agreed in the SPD that gates are less important than boulevards

It is difficult without actual pedestrian counts to know which pedestrian routes along gates and streets are used more – it all depends on a person’s eventual destination. Pedestrian counts at overbridges and underpasses into CMK are also broadly pretty similar so it is difficult to glean much from them

See above comment

It is proposed to delete reference to the height requirement and include instead principles to guide the design of pedestrian weather protection features.

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3.3.5 Agree for many units but absolutely disagree for the outer Gate blocks - see above.

Further guidance is proposed to be included for servicing and waste collection

Gates are considered important because of the amount of parking to the front – they are visible therefore from these car parks and therefore servicing should be excluded from these frontages as much as possible.

3.3.6/3.3.7While some finegrain development is desperately needed, we also need larger retail units that are not supported by the current shopping building. Most places have some very large units achieved by 4-6 storey development, but ringed by small units on the outside to maintain diversity and active frontages. It is disappointing to see no permission for this. The guidelines given in 3.3.7 look about right except that I'd look for first floor animation if the site overlooks a Gate at lower level, but will be restrictive for retail development, which, as far as I understand it, is where they are most needed.

Although it is believed that the SPD covers this issue, will include some wording to say that large units should where possible be fronted by small units to retain a lively and active frontage with diversity in uses facing the public realm

3.3.8 No indication of what sort of care needs to be taken where apartments are adjacent to existing housing and no indication of care to be taken about location of apartments close to businesses.

What do we do if the neighbourhood plan fails, as there is no site allocation of housing numbers here?

Agree – can add something about neighbourly uses

These are identified in the Core Strategy – it is not the role of this plan to allocate housing to certain sites

3.3.9No mention of noise issues which were a major component of the

Agreed – will amend

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feedback.We surely don't need to put the bit about viability here. That is for the developers to argue. We simply need to say that it's not always practical and is therefore not mandatory.

Agree – will delete this section

3.4 Again unclear about the status of the Gates between Avebury and Silbury. and I note earlier that the two underpasses into the central shopping building were not protected. If this is being deliberately left open, make that clear.

Refers to the MK Star, but whenever I have seen diagrams of the MK Star I have been told that they are illustrative only, and consultation on a specific diagram will follow. But it hasn't. We can't plan on that basis. Can we please have a proposal to discuss?

Will correct this‘Underpasses’ into centre:mk are not underpasses but rather voids created by bridges

Propose the following wording regarding MK Star: “One of the key ways of improving public transport into CMK is via the MK Star. This is a high frequency network of bus routes operating along arterial corridors and other corridors of high demand, providing excellent network coverage across the city with all routes passing into and through CMK.

The network in CMK, particularly at Midsummer/Saxon intersection, Saxon/Avebury and Avebury/Lower 9th (but not exclusively) needs to support and maintain appropriate access for pedestrians and cyclists and support reliable journey times for public transport. This may require future junction improvements.”

In other words the SPD won’t directly link the MK Star with Midsummer Boulevard

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Traffic framework – this whole chapter reads very badly, relates even worse to the rest of the document, and is generally a mess. It contradicts some of the key principles at the start of the document, it doesn’t explain what change it is going to make to balance the transport equation, it enforces little or nothing specific on developments that will actually help, blurs its terms and requirements and generally does not move us forward.

It exemplifies my general concern that it is not at all clear what parts of the document actually comprise the policy or the standards. There are many other elements mixed up throughout the document – cross references, principles, policies already stated, aspirations, etc. But the one thing that needs to be clear and is not at all, is what policies or standards this document is actually laying down.

And as a result it is very difficult to assess whether this is reasonable detailing and padding out of the Core Strategy policies or whether it embodies new content and should be a DPD. I don’t think it would pass as a DPD for the reasons given previously, but I suspect it needs to be, because there is new content in here, though not content that moves us forward much. This is important as this is the most likely of all our planning documents to be challenged formally so it needs to be able to stand up.

Comment noted, will revise this section following comments from MKC Transport

The SPD can’t fix the ‘transport problem’ it can just highlight principles that the council will be delivering on in the future

None of the SPD is policy – it expands on local plan policyThe SPD has been written to try and follow a format that has an introduction and pre-amble for each section but then followed for each section with a ‘Principles’ section that is really what provides the high level guidance to developers and the council.

It is a refresh/review based on Lessons Learnt from the EDAW plan

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Landscaping – very uninspiring, not clear that it says anything new, and therefore not clear that it’s needed. It could have talked about the balance between wildlife corridors and secure habitats, versus good looking landscaping for public viewing, any desire to link the spaces, which should e “secret” and which opened up more publicly, etc. But it doesn’t.

This section has been rewritten just to focus on Key Public Spaces. The Landscaping element has been moved into the section on ‘protection of public realm infrastructure’

Open spaces. I have said my piece about the viability of open unsheltered spaces in our windswept city centre often enough, Evidently a new generation needs to make the mistake for itself. Also see what I wrote earlier about the hub.

Comment noted – colonnades are required along gates and boulevards

I don’t support the new large space along Midsummer Boulevard, but it is at least given a reasonably clear role. However, without an attractor at the Campbell Park end, and more reason for traffic along it, it seems unlikely to succeed to me. The passing pedestrian traffic to the deadest end of the centre is not sufficient I’d have thought.

Following a discussion with Members, it is proposed to identify an area for a new civic square south of Midsummer Boulevard within a portion of the existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people.

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The character areas part is a good idea – wasted. I would have expected some additional definition of the character aspects felt key to achieving a good environment to support each of the types of activity, or of the restrictions to be met to achieve good neighbourliness, but there is nothing here. Quarters do not develop and thrive simply because they are named as such! And if I owned land near the edges, I would be seriously worried that this lack of clarity and support would mean piecemeal development of areas that never found their role.

Comment noted – the rest of the Guidance in the SPD should however provide the ‘comfort’ you are seeking

There is nothing here to define what CMK as a whole actually needs to encompass, and what will be moved elsewhere in the city and what discarded. Nothing to clearly specify what must be provided in each area to make that type of development work. And as a result, there will be little confidence that any particular ideas or types of idea will happen, since nothing is protected or provided to support them. And developers looking at this framework will get very little clarity from it.

Beyond the scope of the SPD. Core Strategy highlights high level quantums of developmentsThe Business NP and the new Local Plan is intended to provide further clarity

Sorry, but I’m very unimpressed. It needed to provide a framework that the CMK alliance could then detail. It doesn’t provide anything with any clarity.

Too many contradictory cooks with insufficient bringing of them together to actually agree common positions, and no clear sequence of decision-making!

David Lock 1. I think the draft has shown very great improvement over earlier working editions.

Comment Noted

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2. As it is hoped that your document will end up incorporated as a Chapter or Annex to the CMK Alliance Business Neighbourhood Plan, I think that the consultation draft should now be revised to take into account the content of the draft CMK Alliance Plan, where it is at variance from your draft;

Following discussions with the CMK Alliance team it is pleasing to note that the major differences between the two documents are relatively few. One of the main areas of disagreement is the weight to be given to the protection of the CMK infrastructure. Discussions with Members on the Development Framework have concluded that the proposed wording saying “that changes to the infrastructure will only be considered and permitted if significant public benefits result” would on the one hand offer enough protection of the public realm and give a clear message that the presumption is to protect it but on the other hand would also allow flexibility for alterations to occur.

3. In particular, the “exceptions” policy by which proposals to harm the “classic CMK infrastructure” (as defined in the CMK Alliance Plan) should be re-drafted to the much higher standard of test set out in the CMK Alliance plan. Your draft sets the bar far too low – to the extent that I notice you have advised the Council that the loss of the Market Square and its replacement by two flower beds and the city’s second Primark store is an enhancement of public space and therefore acceptable. If that is your assessment, there can be no doubt that your document must be revised to reflect the CMK Alliance view which, I should remind you, was drafted and agreed upon by the CMK Alliance Steering Group at the time it still included the representative of thecentre:mk.

See above comments

Following a presentation of the Development Framework Review to members of the Milton Keynes Forum, this is the resulting response.

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We welcome the review of the Development Framework: it was pointed out that the draft Framework that we were shown did not make it clear what it is replacing nor the implication that the 2002 Framework adopted by the Council will be nullified by this review document. Members of the MK Forum would like it clarified that this review is a forward plan for the future development of Central Milton Keynes. Forum members are aware that there is a raft of SPG/SPD’s pertaining to CMK, in addition to the Framework adopted in 2002, all of which the current consultation SPD is in conflict in one way or another. When all the observations on the current consultation are assessed, what will be the process that the council will undertake to bring all CMK SPG/SPG into line?

Agreed – this will be clarified. It is proposed that the SPD will replace the EDAW plan, the SRQ SPG, the Campbell Park SPG and the Central CMK SPD

It has been pointed out that the 10 objectives of Core Strategy CS7 are not listed. A legal planning check is needed to ensure that the values and principles are fully consistent with the Core Strategy objectives.

The document will be amended to exclude reference to the 10 objectives of the Core Strategy as the CS is not yet adopted so legally an SPD can’t be adopted against un unadopted CS. When the CS is adopted some minor changes are proposed to occur so as to adopt it in line with the CS

In the introduction, it is explained that the council is responsible for the ‘public realm’’ but it should also add that Milton Keynes Council will nurture and maintain the public realm to the highest possible standard.

But it might be that others in the future maintain it?

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Where the public infrastructure is considered, we would suggest that privatisation of public infrastructure should not be permitted, and that considered alterations to the infrastructure would only be allowed if kept in the public domain.

Disagree. Does this mean the public square to the front of Network Rail is not acceptable? It could be argued that although privately owned the public realm might be improved through being privatised (so long as it is still publicly accessible)

Development in the green frame should not be permitted unless it provides additional transport infrastructure: it has not been proved that building in the green frame improves linkages, and the green frame should take precedence and kept intact.

SPD identifies criteria that need to be met form development to be permissible in the green frame

The plan needs to provide greater clarity re: building lines, grid structure and under-passes to be retained. Also the drawing is not consistent with proposed policies and needs to be brought in line.

Agreed – plan will be amended

The Forum approves of the CMK Alliance plan for Central Milton Keynes, and notes the following differences, where the preference is for the CMK Alliance solution: The Neighbourhood Plan stresses mixed uses in all areas, and the creation of interesting, active street level uses. Therefore the zoning of ‘character areas or districts’ is in the opinion of the Forum not necessary, and may encourage the ghetto like development of certain areas, and prevent the introduction of social and cultural uses. The creation of a recognised central area for civic use and social and cultural interaction is very much needed in Central Milton Keynes. The idea of a central public space is supported, but if the SPG is to properly perform its function, the location and size of the space needs to be clearly shown.

Is it viable to have mixed uses in all areas?? The SPD requires active frontages along the priority pedestrian routes and at least animated frontages along other routes

While character areas with predominant uses are highlighted in the Development Framework, this does not preclude a mix of uses along key pedestrian routes. The few character areas that the DF does identify are important for investor certainty about potential neighbouring uses. Character areas already do exist and character areas provide a degree of order, structure and clarity to the ongoing growth of CMK.

It is proposed to identify an area for a new civic square south of Midsummer Boulevard within a portion of the

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existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people.

The most important difference is in the treatment of new buildings in Central Milton Keynes: The CMK Alliance plan stresses that any new major buildings, particularly if they are in a significant position or in any way transgress the over-riding core design of the centre, should be at least nationally if not internationally significant. We strongly feel that the centre of Milton Keynes needs to host attractive world-class designed buildings that will in turn enhance the reputation of Milton Keynes as a leader.

Discussions with Members on the Development Framework have concluded that the proposed wording saying “that changes to the infrastructure will only be considered and permitted if significant public benefits result” would on the one hand offer enough protection of the public realm and give a clear message that the presumption is to protect it but on the other hand would also allow flexibility for alterations to occur.

This SPD should be consistent with the Local Plan, which is the only council policy document to define the MK road hierarchy. The street hierarchy diagram at figure 2 is wrong and requires correction. There is no such national animal as a ‘primary district distributor’. H5 Portway is a ‘primary distributor’ and all the other grid roads through and surrounding CMK are ‘district distributors’. The Local Plan at paragraph 7.28 additionally explains that “In CMK, the ‘gates’ correspond to District Distributors and the same requirements apply.” A clear strategy is needed to identify what

Agree – plan will be amended

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parking goes where; there needs to be robust policies for implementing the necessary increase and relocation of spaces. This SPG has to be in conformity with the Core Strategy and the Local Plan; it also has to be in conformity with LTP3.

The access, movement and parking diagram, should show the primary pedestrian route through Midsummer Place which is protected by both a walkway agreement and a section 106 agreement. What should be shown in this SPG is the public transport arrangements that are needed to be put in place by 2031 to achieve the step-change in public transport that other policy documents recognise is required, and the phasing of how to get there.

The route of the walkway agreement through Midsummer Place (and others)will be shown on Figure 2.

The annotation for the Hopper Service will be removed from figure 3.

The remainder of the section on public transport does reflect comments from MKC transport policy

In the opinion of MK Forum, no boulevard and gate trees should be removed unless absolutely necessary, and the test should be that same as that for trees subject to a preservation order, which can be removed in certain exceptional circumstances.

Comment noted – suggested wording could be used (eg if trees die or are seriously diseased they may need to be removed)See earlier response to same comment by CMK Town Council

Xplain Xplain is a grassroots campaign born in 2009 out of public dissatisfaction with recent development which largely followed the EDAW Development Framework. Fortunately, in the last few years there has been increasing recognition of the unique urban design characteristics of Central Milton Keynes, both locally and nationally. Unfortunately, since developers are still taking EDAW as their cue, this continues to bring local people into long and sometimes bitter conflict with would-be investors.

Comment noted

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Given this background, Xplain welcomes the publication of the CMK Development Framework Review which recognises lessons learned and sets out to provide revised, clear and positive ‘house rules’ that both would-be investors and local people are likely to sign up to.

We would like to thank MKC officers for listening to the disinterested voice of the public during the drafting of the current document out to consultation. Overall, we feel the revised CMK DF is far more likely to result in quality development that brings social and environmental benefit as well as economic benefit to Milton Keynes.

Naturally, there are some details we wish to comment on.

The following notes represent feedback from Xplain supporters throughout Milton Keynes and are consistent with the campaign’s position to support development that is true to the founding principles of what English Heritage describe as “Britain’s most ambitious and, in urban planning terms, most innovative new town.”

1. pg 1.2 Role and Scope

We fully endorse the document’s focus on protecting key structuring elements of the public realm infrastructure. The city’s extensive infrastructure has a clear track record of delivering growth and wide public benefits. While buildings may come and go, the infrastructure is designed to serve the needs of present and future generations, and will continue to give MK the outstanding

Comment noted

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advantage of accessibility over traditional, congested city centres2. Pg 6. photo captionCentral Milton Keynes, 2012. Since this is view of block B4 lacks the typical landscaping of the Green Frame, we suggest the caption is changed to read – prime development block B4 available for development.

Agree – will add a caption to state that the photo illustrates the growth potential of CMK

3. Pg 9, 2.2.1 Maintaining and enhancing the city as a distinctive place

Point 3 – ‘Safeguard’ tree lined Boulevards and Gates.Instead of ‘Safeguard’ should read ‘Retain’ (see notes, re pg 24 below)

Disagree – safeguard is more pragmatic – what about diseased trees that need to be removed?

2.2.2Point 3. Instead of ‘appropriate’ should read ‘possible and more sustainable’.

Point 4. Ambiguous. We prefer to see more mixed development and less zoning, otherwise, for example, one gets too many commercial premises clustering together which creates dead zones at night.‘Understand and respond to the different character areas in CMK’ could mean many things.

Disagree

The intention is not to zone CMK, but mixed uses can’t be expected everywhere.

It is a high level principle and gives a degree of clarity to investors about land use expectations

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2.2.9, Fostering creativity, learning & success

Point 1. This does not set the bar high enough.

Within the basic rules built around the protection of the existing public realm infrastructure allow some flexibility so that CMK can benefit from exceptional, one-off development opportunities in line with the plan’s overarching ambitions

Point 3. Focus on the development of the knowledge based economy and creative industries

Agree – will amend wording

Agree – will amend wording

4. Pg 11. 3.1.1 Introductory paragraph is well expressed and we fully support this.

Photo caption, top left. Suggest amending to read “Surface level parking including slow streets”

Agree – will include suggested wording

5. Pg 12, 3.1.1 Introduction

Point 2, last sentence suggested addition:The carefully designed mixture of parking, slow streets and pedestrian routes has proved its value in that it delivers the key principle for CMK of “combining the vitality of traditional city centres with the unhindered accessibility of an out of town centre”

Point 5. Accommodate corridors for common trenches and ducts for utility services thereby avoiding disruption to CMK traffic routes

Comment noted, but proposed wording is believed to sufficiently address this point. I don’t think there is evidence to prove its value in delivering the key principle…..

Agree – will include proposed wording

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of inconvenient road-works to access utilities.

6. Pg 12, 3.1.2 Key Principles

Point 2. Having recognised the importance of the infrastructure this para is too weak and In order to protect public infrastructure and guarantee appropriate development the bar needs to be set higher.

Retain the connectivity and integrity of the grid road system by retaining all boulevards and gates at existing levels. However certain changes may be considered if both of the following can be clearly demonstrated and if public infrastructure remains in public ownership and is not sold into the private domain:

a. an exceptional standard of access remains to serve the city in the long term

b. there is clear evidence that wider and significant public benefits**will result

3. b There is an exceptional proposal where significant public benefits** can be demonstrated

4. b A development seen as important in CMK (eg Waitrose)

Discussions with Members on the Development Framework have concluded that the proposed wording saying “that changes to the infrastructure will only be considered and permitted if significant public benefits result” would on the one hand offer enough protection of the public realm and give a clear message that the presumption is to protect it but on the other hand would also allow flexibility for alterations to occur.

Will delete reference to Waitrose

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cannot demonstrably meet its floorspace requirements without building on existing parking.

Suggest ‘Waitrose’ is deleted as this could be misconstrued as a leading example and precedent.

7. pg 12, 3.1.2 Point 6. Presumption is to retain boulevards and gates on existing levels and retain all existing trees.

We fully agree with above but do not agree with the rest of the sentence which opens the door to removal which starts “unless it can be clearly demonstrated…”. The definition of ‘public benefits’ is too vague and the criteria required to protect these public assets should be much higher.

The starting point should be clear: that removal of infrastructure and trees should not be permitted because the public benefits of retaining the same are always likely to outweigh their loss.

However if some flexibility is considered necessary, and desirable, we suggest the following amendment:

Presumption is to retain boulevards and gates on existing levels and retain all existing trees. In rare and exceptional cases, changes may be considered where it can be clearly demonstrated that substantial public benefits will be delivered by alterations. However CMK’s fundamental design principles including excellent accessibility, interconnected transport routes, safe pedestrian access, and a high quality public realm must be adhered to and not be lost whatever the development.

See above comments, the Development framework is seeking a balance between protection of the best and flexibility to allow for new development.

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Definition of Public Benefits, suggested amendment in line with NPPF definition of sustainable development and local transport targets

** Public benefits means at least two or more of the following: major improvements to public realm, improved access for pedestrians, cyclists, public and private transport, enhanced public transport, additional parking in appropriate location. Public benefits do not imply just economic benefits but equally social and environmental benefits.

In order to recognise lessons learned and avoid issues such as currently beset the WEA, this should be changed.

The SPD does include the wording “but equally social and environmental benefits”.

8. Pg 13, Figure 1

Food Centre should have brown line round it in line with other buildings.

While underpasses are suitable protected with ‘purple’ rings, their equivalent at the busy junctions of Midsummer Boulevard & Secklow Gate, and Silbury Boulevard & Secklow Gate are not marked. This must be an oversight otherwise the diagram and text lack consistency.

Dotted lines for Building Lines permitted to come forward.

Agree – will amend diagram

Disagree, these are not underpasses but bridges with spaces underneath

The dotted lines on B4 and Campbell Park are factual and

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We strongly resist the figure showing Building Lines moving forward on the important site of Block B4 and on the large number of remaining development blocks in Campbell Park.

The HCA was both seller and planning authority on these major sites and followed the EDAW guide with building lines moved forward. However it is now generally acknowledged this experiment has failed.

In view of Localism, and the widespread public condemnation of the Hub, for example, we know that residents strongly object to ‘back of kerb’ developments and incursions into the Green Frame. It permanently blights the boulevards and gates.

MKC will become landowner when HCA transfers these sites in Dec 2012. In order to retain and improve public land values failed design guidelines must be jettisoned.

For consistency with these draft Principles, building lines in B4 and Campbell Park should be set back in order to protect the public realm, promote walking and cycling via more attractive pedestrian routes, respect the outstanding location of Campbell Park, and keep future transport routes open by leaving the grid road corridors at H6 and H5 intact.While revised Principles clearly set out to protect the grid road corridors, promote better pedestrian routes, retain surface level parking and existing infrastructure, the diagram in Figure 1 acquiesces in delivering the opposite in Block B4 and all remaining development blocks in Campbell Park.

reflect the extent of extant planning permissions

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9. Pg 13, fig 1, Heritage Buildings.We question the Food Centre’s value as a heritage building on the diagram and suggest marking out the Conran Roche designed buildings flanking Christ the Cornerstone Church (Northgate and Southgate House).

Agree – will delete the Food Centre (in fact are deleting all ‘heritage’ buildings except the Grade 2 star listed building the centre:mk)

10. Pg 14, 3.2.1 Existing Buildings and Public Art of Significance – Heritage Assets.

We fully support the description in the Introduction, 3.2.1.

3.2.2 Principles.Examples of building that adhere to a minimalist approach and [delete ‘could’] should be considered of local significance include:

Please add Northgate and Southgate House to the list of quality, minimalist architecture.

Suggest adding reference to a survey, eg:

In recognition of the individual, and group value, of many outstanding buildings typical of their era in one city centre, MKC is working on a ‘Local List’ of buildings that are worthy of special protection.

There is also a need to protect the setting of significant buildings eg:

The approach to Heritage assets and public art is propose to be amended to seek the preparation of a local list of heritage assets including public art by the council and for it to be kept under review. This local list should include considering the setting of the building or piece of public art

Disagree. These are not examples of minimalist architecture like Norfolk and Ashton House

Similar wording to this will be included

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These buildings and their settings, where they incorporate quality public realm elements such as courts, squares, gardens, public art and landscaping, should be protected (and where appropriate refurbished) unless it is demonstrated with evidence that it is not commercially viable to refurbish them.

Agree – wording to this effect can be added, but we can’t in this document specify exactly what the setting of each of the buildings is

11. Pg 15, 3.3.6

We question assertion that the ‘coarse grain’ “has undermined the vitality of CMK” and suggest amending to read “This can undermine the vitality of CMK.”

A fine grain is not automatically successful, for example the Theatre District has a number of drawbacks such as long back alleys with rubbish bins next to the theatre due to its ‘fine grain’.

Agree, wording will be replaced with the suggested wording

Agree, fine grain can cause problems if overly permeable and backs of buildings face the public realm as in Theatre District

12. Pg 16, 3.3.7

Argument that as-built density has led to a “very homogenous nature to CMK that has been argued as lacking a sense of lace and vitality” needs qualifying. It has also been argued that CMK is remarkably harmonious (eg by Owen Hatherley in The New Ruins of Modern Britain), and harmony also has a place in modern life and in CMK in particular.

Agree in part – will say that it contributes to a lack of vitality

Principles, point 5.

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Agreed that tall buildings “if located and designed appropriately, can enhnace the quality of CMK” but please delete rest of sentence about tall buildings “demonstrating economic success”. This is unnecessary, debatable and highly contentious in the context of MK.

Disagree, taller buildings can help demonstrate economic success (or course other factors play a role as well)

13. Pg 16, 3.3.8 Housing DensityPrinciples, point 2.Disagree with need to encourage a greater percentage of family homes/townhouses in Campbell Park. Townhouses lend themselves to HIMO issues and Campbell Park has no space for family amenities such as schools, medical centres, nurseries etc. All these can be better provided in rest of MK

The wording will be amended to say that family housing is not generally to be encouraged in CMK

14. Pg 18, 3.4.3 Street Hierarchy

Point 1. It is not helpful to describe Secklow and Witan Gate as ‘not part of the wider grid road network.’ Every link in the grid is part of the wider road network.

It is important to explain this to people unfamiliar with MK therefore please add a sentence that summarises the inter-dependency of each element in the grid and how the whole was carefully designed to work together and a reminder that it was designed to be permanent; while buildings come and go over time the grid remains.

We have never heard of a Primary District Distributor before. Is this a proposed new category of road, and if so, what is the purpose?

There remains some disagreement over the interpretation of the road hierarchy. It is proposed to amend the text in the Development Framework as follows. The final paragraph below explains the reason for the differentiation between the Grafton and Saxon Gate and the other gates in CMK and Campbell Park.

“H5 Portway is a Primary Distributor.

V6 Grafton Street (and Grafton Gate), V7 Saxon Street (and Saxon Gate), V8 Marlborough Street and H6 Childs Way are District Distributors.

Elder, Witan, Secklow, Skeldon & Enmore Gates, as well as Overgate, are Local Distributors; however, the Local Plan requirements for District Distributors apply to them.

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Silbury, Midsummer & Avebury Boulevards and Marlborough Gate are Local Distributors.

All other “Streets” and “Rows” are Access Streets.

Primary ‘Gates’ of V6 and V7, which run north-south between the H5 and H6, are the entry points into CMK and also provide via the surface level car parking, access to development blocks, service access as well as access to North and South Row. The V6 and V7 are part of the wider CMK grid road system. Elder, Secklow, Witan, Skeldon & Enmore Gates and Overgate are also important for access into CMK but are not part of the wider grid road network.”

15. Pg 22, Principles, MK Star

If MK Star routes also run along Midsummer Boulevard it becomes increasingly crowded with buses.

Will revisit this section with the following wording: “One of the key ways of improving public transport into CMK is via the MK Star. This is a high frequency network of bus routes operating along arterial corridors and other corridors of high demand, providing excellent network coverage across the city with all routes passing into and through CMK.

The network in CMK, particularly at Midsummer/Saxon intersection, Saxon/Avebury and Avebury/Lower 9th (but not exclusively) needs to support and maintain appropriate access for pedestrians and cyclists and support reliable journey times for public transport. This may require future junction improvements.”

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The SPD is in other words is not making a link between MK Star routing and Midsummer Boulevard

16. Pg 23, fig 3

The reserved low-emission PT route through Midsummer Place in line with Midsummer Blvc is not on the map but should be marked out

Pedestrian priority route through Midsummer Place is also missing

Why are there no North-South pedestrian priority routes through CMK except at the boundaries with the surrounding estates?

A pedestrian priority route is needed through the shopping building at night, for example.

The ‘junction improvements’ for buses are potentially harmful of infrastructure and we question their place in this document

Will include

The difficultly is to show it on a plan – which route gets selected. Will include some text on this though

Amended in line with comments from MKC Highways

17. Pg 24, Trees on boulevards and gates.We do not agree to the removal of trees in the public realm if “public or economic benefit” can be shown. The rest of the document paints an accurate picture of the widespread benefits of the street trees in CMK therefore the bar should be set higher, only allowing limited trees to be removed in exceptional circumstances.

Disagree – the presumption is clearly to retain them and if they are diseased or public benefits can be realised through their removal there should be replanting where appropriate

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18. Pg 26, fig 4

While we appreciate the interest in creating a new public square in CMK, why is the ‘area for new public square’ shown as if it spans both sides of Secklow Gate? This could be interpreted as an invitation to develop the area at the expense of public infrastructure, which would clearly be problematic.

The whole of Campbell Park is marked up as an area to “Improve Access to, Integration and Overlooking of Green Open Spaces”. Presumably a mistake, as one would not over-development in and immediately around the park.

Following members briefing will amend SPD to say that a square should be included within the HCA temporary car park with 1 side facing Midsummer Boulevard East. Will include an asterix symbol on fig 4

Disagree – once development occurs on each side it will be better integrated into CMK. It also implies improved connectivity/access via Campbell park link Development on each side will also provide overlooking of the park

Boulevard trees are missing from the ‘stub end’ of Midsummer Boulevard west of Midsummer Place.

Disagree - There are no boulevard trees in this area

19. Pg 28, 3.6.2 Character Areas.

Mixed messages. We question stated need to “reinforce” these character areas if the “overall approach” is to have more mixed land uses throughout CMK. For example, this could lead to problems in the reinforced Business District where streets are empty at night.

Is it realistic to expect mixed use throughout the entire city centre? It is important along the pedestrian priority routes but not along every street. If some of the Business District is empty at night – is that a problem, London’s CBD is also empty at night.

While character areas with predominant uses are highlighted in the Development Framework, this does not preclude a mix of uses along key pedestrian routes. The few

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character areas that the DF does identify are important for investor certainty about potential neighbouring uses. Character areas already do exist and character areas provide a degree of order, structure and clarity to the ongoing growth of CMK.

20. 3.6.2 Point 5. Campbell Park (north & south)

We agree that block F1 should be kept in reserve for a major investor. However we think Campbell Park grid square is too valuable a location for attracting jobs and investment to CMK to be given over to residential development. While appreciating the requirements of conforming to Core Strategy housing targets, we actually think they are unhelpfully high in CMK. Campbell Park is the ideal location to attract knowledge-based or creative industries. The opportunity is too valuable to ‘spend’ on high-density residential development.

CMK is already very big – is it realistic for employment uses to spread all the way down into Campbell Park.

3.6.2 Point 6. Campbell ParkLast sentence, please add a rider about restricting the quantum of development. There is a fine balance between attracting “even more people” and retaining the tranquillity needed as the city grows

Will reword last part of sentence

3.6.2 Areas Open to Variety of ProposalsBlock B4. Agreed. This is an exceptionally valuable site and should be reserved for major employment opportunities, not given over to residential development.

Noted

Newport Pagnell Our Town Planning and Management Committee has considered

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Town Council the consultation documents in respect of the draft Central Milton Keynes Development Framework Review Supplementary Planning Document. Two members of the Committee (Cllrs Ian Carman and Phil Winsor) also attended your briefing session in October.Very little appears to have changed from ten years ago in terms of how it is envisaged that CMK’s development framework and, in particular, its retail strategy will develop. The impact of the change in shopping habits and the trend towards internet shopping does not appear to have been addressed in the draft SPD.

Beyond the scope of the Development Framework. Notwithstanding the increase in internet shopping there is still a need to expand to improve and diversify the Primary Shopping Area

We are aware that this document has been compiled for over a year and takes into account a wide range of MKC officers' comments . Unfortunately it appears to have missed the point completely in that the CMK by virtue of its original design is not that easy to change as there are already character areas that do limit future developments . Mixed use with commercial units under residential is known to bring about problems hence the vacant units in the Theatre District (although the residents above can sleep now!). Such matters are referred to in the SPD but with no real 'weight'.

Comment Noted The SPD aims to reinforce character areas and will include text about neighbourlu uses.

The SPD already states that care needs to be taken regarding the mixing of residential uses and the night time economy

This is an opportunity for the planners to be as visionary as MKC has been with its Low Carbon Prospectus and provide a 'Wow'

Can understand this comment – but it is beyond the scope of the SPD (it was always meant to be a light touch) focussed

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factor within the SPD that will enthuse and encourage potential investors and developers. The comparison document produced states that in many respects there are no fundamental changes planned, whilst accepting the errors made since 2002 such as filling in the subways!

on Lessons Learnt

Underpasses are not proposed to be filled in

We would encourage the drafting team to have one more look at the document and ensure that it really is 'fit for purpose' so that all the character areas can be developed successfully as the land area in CMK is finite, although MK does have a legacy of redeveloping sites that didn't work out e.g. hockey stadium to Network Rail Offices and MSCP's.

Note comment on character areas – we take this as support for them

CMK will need to be quite different in the years ahead to satisfy all relevant parties, and as a consequence this document should be the blueprint for this transformation.

The Development Framework is not intended to be a blueprint but rather a set of guidance which provides clarity on certain aspects but flexibility elsewhere.

Hammerson CMK Development Framework Review Draft SPD: Representations on behalf of Hammerson plc.

Hammerson own The Point and take an active interest in the future direction of Milton Keynes City Centre. Hammerson welcomes the opportunity to be involved in the preparation of the Development Framework for Central Milton Keynes.

Hammerson is committed to investing in Milton Keynes city centre through the redevelopment of The Point. We consider that this is a key piece in the jigsaw that will allow improvements to the way

Comment noted

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that the heart of the city centre operates. Milton Keynes city centre has had little significant investment since Xscape and it has an urgent need to respond to the substantial improvements that have taken place and are planned in competing regional centres, including Northampton, Aylesbury and Oxford. Hammerson is planning to invest in the future of Milton Keynes by creating a high quality destination to serve the next generation of the Milton Keynes community and complementing the existing retail offer.

Hammerson’s plans to move Milton Keynes forward will help improve the shopping experience and increase the time shoppers stay, which we anticipate will create several hundred new jobs in retail, restaurants and construction.

Section 3.2: Existing Buildings and Public Art of Significance – Heritage Assets

Hammerson supports the exclusion of The Point from Figure 1 and section 3.2.2, as it is not a building of heritage for CMK. This approach is consistent with evidence contained within detail appraisals of the architectural and heritage merits of the building. The building has reached the end of its useful life and no longer meets the needs of occupiers, as such the building need to be redeveloped.

The proposed approach within the SPD enables the regeneration of this part of the heart of Milton Keynes City Centre. It is essential that development of this site comes forward.

Built in the mid-1980s, The Point is a building of its time, designed

Noted.

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to meet the needs of leisure operators in the 1980s. However, The Point is physically unable to respond to changing needs; it is unable to evolve due to the design constraints of the shape and fabric of a building that no longer matches the needs of today’s leisure and retail operators. Leisure and retail operators now require more flexible outward facing formats and The Point has been superseded by more recent developments (for example Xscape) which can meet the demands of leisure operators – accommodation in The Point building can no longer compete effectively.

Most significantly, The Point suffers from poorly configured and constrained floorspace and from a lack of visibility and accessibility which simply does not meet retailer and leisure operators’ standards. Other problems include the reflective glass which reduces views into the building, changes in the pavement levels, positioning of mechanical plant installations, cluttered approaches and signage and poor quality landscaping. We therefore support the acknowledgement within the Development Framework that the building is not worthy of protection and should not be retained.

Section 3.3: Urban Design Elements and Principles

Hammerson generally supports the urban design elements and principles set out in Section 3.3, specifically encouraging development with active ground floor frontages (section 3.3.3) and promoting taller buildings within the central retail area (section 3.3.7). Hammerson supports the recognition that site constraints will mean that not all sides of a building can achieve active or

Noted

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animated frontages, and servicing requirements need to be considered.

Section 3.4: Access, Movement and Parking

Section 3.4.6 includes a requirement that any “lost” public car parking must be replaced on a 1:1 basis as part of the development for public use. Hammerson consider that this could unnecessarily constrain development, and this requirement should be amended to relate to any significant loss of car parking, rather than a blanket policy applying to loss of any spaces. The acceptability of reductions in car parking should also take into consideration the existing provision of car parking spaces and the amount of new development proposed. If a development already exceeds the Council parking standards then this may justify some minor loss of parking.

Replacement parking for that lost in a development could be provided off-site where it is not possible to accommodate it on-site.

Section 3.5: Landscaping and Key Public Spaces

Section 3.5.1 states that a landscape and public realm management and maintenance strategy must be prepared that has a viable and ongoing funding regime.

It is not clear who and when this landscaping strategy will be prepared and how the funding will be achieved. Developers and landowners can only control landscaping within the curtilage of their ownership. The Council will need to be responsible for preparing a landscape strategy for public areas. This strategy must be realistic, deliverable and viable.

Comment Noted – it is a general point, clearly developers can’t control anything outside their land ownership

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Developments are currently required to contribute towards public realm improvements relating to their proposals, as set out in the Council’s SPD on planning obligations. It is important that any contribution derived from future investment is realistic and does not become an impediment to that investment. The SPD should make it clear that the Council will prepare a landscape and public realm strategy and that this strategy will be the subject of future consultation.

Section 3.5.2 includes the aspiration for a new public space at Midsummer Boulevard East.

Figure 4 identifies the area for the new public square. The defined area includes The Point, which is the only built development within the designated area. It will not be financially viable to demolish commercial floorspace to create a public space. The Point must be excluded from this designated area.

The exclusion of The Point will not undermine the Council’s objectives of creating a public square. The designated area is vast (about 40,000 sq m). By way of comparison Red Square in Moscow and Trafalgar Square in London are around 23,000 sq m. It is unnecessary to designate an area of this size and this will cause uncertainty for investors. Hammerson does not object to the principle of creating a civic space within the city centre, however the location and space created must be deliverable and fit for purpose, and not so large that it becomes a wasted or unused space. With proper planning, a new useable public area could becreated within this space that improves the public realm and landscaping. In conjunction with the redevelopment of The Point,

Comment Noted. It is now proposed to identify an area for a new civic square south of Midsummer Boulevard within a portion of the existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people.

Fig 4 will identify the site with an asterix to support the text

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this will achieve the objectives of enhancing the heart of the city centre, and needs to be developed further with Milton Keynes Council.

Section 3.6: Character AreasHammerson support the definition of the core shopping area within which retail uses should be concentrated. However the core shopping area should exclude the surface car parking to the east of the John Lewis store. Further expansion of retail uses in this area would result in an unacceptable elongation of shopping facilities within CMK. This area should be identified an area where car parking may be intensified.

The priority for further retail expansion should be to the south of centre:MK where a more compact shopping circuit can be provided for pedestrians. The core shopping area correctly does not extend south of Avebury Boulevard. This must not be altered because it would unnecessarily dilute retail provision in CMK and jeopardise planned investment within the shopping core, which would be contrary to the NPPF. Enhanced retail provision within this revised quarter should be prioritised as the sequentially preferable location for retail development, as set out in the NPPF.

The redevelopment of The Point as a retail destination, creating active frontages along Lower Tenth Street, would achieve the objective of better linkages between the retail core of the city centre and the leisure and entertainment district.

#Disagree. The Milton Keynes Local Plan, policy CC1 defines the Primary Shopping Area which includes this parking area. – the PSA covers the area between Avebury and Silbury Boulevards; Marlborough and Saxon Gates.

Agreed - the area for further retail expansion suggested by Hammerson falls within the PSA.

We note that for the “leisure and entertainment area”, the predominant land use is identified as “mixed use retail and

Noted – we will change to the wording suggested

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leisure”. We consider that this should be amended to read “mixed use leisure and entertainment, with only ancillary/small scale retail use”, as the core shopping area should be maintained as the focus for retail development.

Central Bedfordshire Council

No Comment Noted

Environment Agency

No Comment Noted

X-Leisure Indigo Planning acts on behalf of X-Leisure Limited, which owns and manages Xscape Milton Keynes, a leading entertainment destination in the south east.

Xscape offers a unique combination of extreme sports and leisure activities for all age ranges including real indoor ski slopes, a body flying tunnel, rock climbing walls, bowling, multiplex cinema, health and fitness centre, bars, restaurants, nightclubs and shops.

Xscape is located within the Central Milton Keynes (CMK) area and is a key asset in the city, contributing significantly to the local economy (through consumer spending and employment opportunities) and the vitality and vibrancy of the city centre.

The Council has published a draft Supplementary Planning Document entitled ‘CMK Development Framework Review Draft’ and this letter sets out our comments on the draft document. For ease of reference, our comments are made under a series of sub-headings which correspond to those within the draft document.

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Section 3.2.2 ‘Principles’

Xscape supports the principle of identifying buildings of local importance, which should be protected from inappropriate development (e.g. poor quality extensions and alterations). The Council could consider locally listing these buildings to ensure appropriate controls over them.

Noted

Section 3.3.9 ‘Mix of Uses’

Two types of mixed-use development are defined: the multiple use of development blocks, and multiple uses within individual buildings. The draft CMKDF confirms that mixed-use development is encouraged within the CMK area. Xscape supports this approach, but it is important to ensure that particular areas (such as, for example, the central business district, civic core and core shopping area) do not see their primary function/use diluted with anover-concentration of other uses which could be inappropriate in such locations, and change the established character and function of these parts of the centre.

The above-mentioned areas perform important roles within the overall centre: for business, civic facilities and shopping. Consequently, they should continue to perform these functions and proposals. Whilst it is appropriate to have complementary and supporting uses in these areas, larger-scale developmentsinvolving a significant amount of other uses should not be permitted. Instead, other parts of the centre, where such uses are established, should be the focus for such developments.

Comment Noted – it is for this reason that where existing character areas exist they should be reinforced with the use that makes up that predominant character

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The draft CMKDF’s identification of ‘character areas’ (see below) confirms the established nature of the different parts of the centre, and this is supported by Xscape.

Section 3.6 Character Areas

Six distinct character areas are identified within the draft CMKDF, including those mentioned above. A ‘Leisure/Entertainment Area’ is identified as including blocks E3 and E4 (Theatre District and Xscape respectively). The draft CMKDF acknowledges this part of the centre as being mainly for ‘mixed use retail and leisure’.

Other character areas are identified as being primarily for offices (central business district), civic functions (civic core), retail (coreshopping area) and residential (Campbell Park).

As such, the draft document should contain wording to the effect that development proposals should be directed to those character areas depending on the use proposed. The draft document should state that it would not be appropriate, for example, for the Leisure / Entertainment area to accommodate large office developments, or for the core shopping area to accommodate significant leisure facilities.

In summary, the draft document should make expressly clear that applications for planning permission will be considered against the permissible types of use for each character area. The Leisure / Entertainment Area is identified for mixed-use retail and leisure

Noted – support for Character Areas

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developments. Consequently, applications for such uses, within this area, should be considered favourably by the Council (subject to other policy considerations such as design, transport etc).

SummaryThe draft CMK Development Framework is, on the whole, supported by Indigo Planning on behalf of X – Leisure.However, the section of the draft document which identifies specific character areas would benefit from additional wording to reflect the fact that development proposals and planning applications for particular types of use should be considered primarily against whether such proposed land uses accord withthose identified for each character area. This would ensure that the established character, nature and function of each component area within the centre would remain, and not be lost, changed or diluted through an over-concentration of other uses which would be more appropriately directed to other parts of the centre.

We trust that the above comments will be taken into account in the progression of the draft CMKDF, and we ask that we be kept informed of the next stages of the process.

Comment Noted, the SPD is intended to reinforce the character areas as per your comment, but allowing for mixed use along priority pedestrian routes

Cllr Douglas McCall

Additional comments to those made at the briefing session.

Page 5, Para 1.1I fully agree with the comment “A key aim was to build upon the economic success of Milton Keynes”. It is very important, especially in these difficult economic times, that Milton Keynes continues to be seen as ‘open for business’ and to continue to attract inward investment and not to draw up the drawbridge.

Comment Noted

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I also fully agree with the comment “Creating a more secure, friendly, walkable environment. Currently, it is not easy to walkabout CMK. Pedestrian linkages are poor and way finding is almost non-existent.

Pedestrians are encouraged to cross at grade, which they prefer to do, but at non-safe places, apart from between Sainsbury’s and the Hub for example. As CMK grows and there are increasing vehicle and pedestrian conflicts the issue of pedestrian safety needs to be addressed.

There is a comment “There was a view among some that insufficient development had been delivered since 2002 and this was due to the Development Framework”. Yet, there is no evidence to support this “view”. Many people would have a view that this was due to the recession – yet this ‘view’ is not mentioned.

There is a typo in point one in the third column; it says “which has been” instead of “which has been”.

Comment Noted

Agree, but this was a view expressed

Will amend

Page 9Para 2.2The ‘founding fathers’ of MK were innovative in their day, daring to consider new things. This paragraph seems to want to keep EVERYTHING exactly the same as it was in the 1970s and not consider any innovation for the future. With this very restricted approach where would a future Network Rail or even a Stadium MK go?

This is a general principle, the DF does outline where exceptions can be made. A future Network Rail type development could still occur and not break any of the original principles. Fig 5 identifies sites where a variety of opportunities would be seen as suitable

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Para 4“Ensuring ease and choice of access for all” – VERY surprised that there is no mention of public transport.“Improve the pedestrian experience” – A must as it is extremely poor at present.

Multi-modal implies public transport, but this will be reworded to make clearer

Para 6“Make clear distinction between public and private spaces” – How?

This is developed further throughout the Development Framework, for example in the sections on Design and Key Public Spaces.

A key way would be by not redeveloping Blocks like Witan Court which has public space in the inside that does not necessarily feel public

Para 9“Maintain CMK as the city’s primary location for business, retail and leisure”. That means sending out signals that MK is ‘open for business’ and that we do actually want companies to come to MK, and especially CMK. That may require thinking outside the 1970s ‘box’ this document is trying to build.

Don’t believe this SPD is preventing outside the box thinking. As said above, the ‘rules’ can be broken if significant public benefit can be demonstrated

Page 11 Para 3.1 Pedestrian access from the large areas of surface level car

parking could be improved. The issue of safety, eg of lone women returning to their cars late at night distant from activity needs to be considered and addressed.

If the Council is going to continue to encourage the high

Agreed. The SPD will be amended to reflect the concerns with parking in North and South Row as you have alluded to.

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quality, expensive public realm materials to be used then it needs to make sure that the funding to properly maintain these is in place.

Page 12, Para 3.1 cont My comment on Page 9 para 2.2 applies here two. Why does everything have to be in straight lines and boxes?

What is wrong with curves, circles ,etc? No Royal Crescent here in CMK.

No change/innovation could mean no growth and no new jobs.

CMK is based on a rectilinear grid – curved shapes will create awkward leftover spaces and won’t be an efficient use of space. Straight lines also increase legibility

Don’t believe straight lines imply a lack of innovation

On the other hand the SPD is not either suggesting curves or other are entirely ruled out

Para 3.1.2 Do planners believe that a large volume of surface car parks

are sustainable in the long term as CMK grows and the value of land in CMK increases? Will there not be pressure to move to multi-story car parks in the future, such as are currently at Sainsbury’s, Waitrose, Debenhams and the Theatre?

In a cold, wet winters night would visitors to CMK prefer to return to their far away car in the cold, dark and wet or into a well lit, dry, warm and secure multi-story car park? Why does the document assume visitors prefer the former?

An improvement to pedestrian permeability is required, especially between the Shopping Centre and Theatre District. Innovative ideas are needed to achieve this in a safe way.

There is a balance to be achieved between the protection of the public realm and unique infrastructure of CMK and the need to meet future parking needs. The provision of public car parking in multi-storey car parks as part of commercial development such as has occurred in Midsummer Place and at Network Rail will be encouraged.

The SPD acknowledges this

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Page 14, Para 3.2. Very concerned that you seem to want all new buildings in

CMK to be boring boxes, and preferably boring glass boxes. No room for interesting, different buildings. So, Church of Christ the Cornerstone wouldn’t be built as it is not a square box – the dome clearly would be ‘bad’ under these proposals. And what about the India Restaurant that looks a bit like a temple. Most visitors to MK comment on it – they don’t comment on all the boring square boxes.

Please, please, pleased don’t insist that all new buildings in CMK are boring boxes.

The SPD certainly does not want boring buildings built, but it is important to where possible preserve buildings that reflected the architectural thinking of MK in its early years. The SPD does not say we want buildings such as Norfolk and Ashton House

Comment noted and agreed

Page 15, Para 3.3.3I agree with the comments about needing ‘active’ frontages. The document gives one example of an inactive frontage, but doesn’t even mention that the worst offender is the Centre MK, which is very inward looking and needs to improve its outward looking face.

Could potentially include the centre:mk

Page 18, Para 3.4 “The encouragement of walking and cycling…..” – Yes, I agree,

but WHEN? Point 3 middle column has a typo – says “passengers” instead

of “pedestrians”.Agreed – typo

Page 21, Para 3.4.5 Cycling I strongly support improving walking and cycling in CMK. Need to consider conflict between pedestrians and cyclists, eg

I don’t think the current route of National Cycle Route 51 on the pavement between The Centre MK and Midsummer Place is sensible.

Will reconsider this proposal

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The north – south redway through CMK alongside Saxon Street is very good and gives pedestrians a safe route into and out of the surface car parking, rather than the usual avoid the cars routine.

Page 26“Improve hard open spaces” – I agree with that .It you WALK around the area between Campbell Park, Centre MK, The Theatre District and Midsummer Place it is in a desperate need of improvement and an improve experience for pedestrians.

Comment noted

Paul Griffiths, Resident from Wolverton

I would like to submit a comment on the CMK Development Framework document that is currently out for public consultation. In particular I am seeking appropriate acknowledgement of the role of Powered Two Wheelers in considering the future development of the city centre and ensuring that appropriate consideration will be given to the future needs of PTW users.

This is an extract from the Local Transport Plan [LTP3] (pages 65-66)"Powered Two Wheelers Powered two wheelers (i.e. motorcycles, scooters, mopeds and cycle motors) can play an important role in the development of a fully sustainable integrated transport system. They can offer an affordable and flexible form of personal transport for journeys. Although powered two wheelers are not totally ‘green’ they offer significant environmental advantages over the private car.The council recognises that powered two wheelers are a separate class of road user with their own particular perspectives and needs. They offer similar flexibility to the car but are generally cheaper to

Will include a paragraph that ensuring appropriate provision (e.g. covered) being made in strategic locations would be helpful. Don’t think we need to give too much detail as PTWs can park in car spaces and they make up less than 1% of travel. We could also add that MSCPs should include PTW provision on the ground floor

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buy, tax, and insure, and have lower operating costs. Within urban areas they can move freely and are able to park in small spaces. They are an affordable way to increase mobility and widen access to employment and local services.

HTo11 Refresh of Powered Two Wheeler Strategy The council developed its Powered Two Wheelers Strategy in 2003 and it is still largely fit for purpose and the council continues to support its aims of improving conditions for and increasing promotion. This includes the provision of safety, training, improved design and implementation of schemes, improved maintenance, parking provision, security and community engagement. The strategy will be refreshed with further community engagement and in light of the latest policy and evidence available. Interventions emerging from the review will need to be incorporated into further revisions of the Transport Vision and Strategy.

Delivery Time – Medium Term"

While the LTP Review June 2012 is silent in the main report on the continued role of PTWs in an integrated transport strategy, it is acknowledged in the "Table of revised list of proposed interventions for 2012/13" point 5 that a refresh of the Powered Two Wheeler Strategy has not started and is "overdue". Following recent correspondence with Cllr John Bint, I have had confirmation from Brian Matthews that this refresh will be undertaken during 2013.

In the absence of a refresh and given the statements in LTP3

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acknowledging the 'important role' that PTWs can play in 'the development of a fully sustainable integrated transport policy' and that the strategy as it stands 'is largely fit for purpose and the council continues to support its aims', I feel that it is important to recognise this in the CMK Development Framework Review and it would therefore be appropriate to make suitable references to PTWs in section 3.4 Access, Movement and Parking.

Although the Powered Two Wheeler Strategy covers many areas including road safety and rider/driver training, I feel that the two areas that should be highlighted in the CMK Development Framework Review are:

1) an acknowledgement of the role that PTWs can play in a sustainable integrated transport strategy and they should therefore be mentioned alongside other transport modes: walking, cycling, public transport and the car.

2) an acknowledgement that, as with cycling, there are specific needs around secure parking and other facilities required by PTW users. I would like to draw your attention to one particular section of the Powered Two Wheeler Strategy which states:"Major attractions, such as the Railway Station, Xscape, The Centre: MK and Midsummer Place could benefit from additional facilities such as storage for clothing and helmets. Combined stands and lockers have been installed by other authorities and are worth considering when planning parking for these areas.In older district areas, free parking for all vehicles is likely to remain. There is still, however, the need to provide secure parking for PTWs. Any scheme that involves parking or the opportunity to

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include secure parking (e.g. town centre enhancements or pedestrian schemes) should try to include facilities for PTWs. Encouraging developers and employers to provide secure parking for PTWs is very important. This may form part of the work of the Sustainable Transport Manager in Milton Keynes and could be incorporated into Travel Plans. Planning approvals and parking standards for proposed developments can also be used as a way of ensuring adequate parking provision." (section 6.5 page 12)

I feel that this commitment by the Council has been overlooked for some time and in particular in the recent redevelopment of Station Square.

I am not in a position to suggest specific wording that might be inserted into the CMK Development Framework but trust that you will accept the veracity of my observations and make the necessary amendments as part of the consultation process.

Campbell Park Parish Council

The Planning & Policy Committee of Campbell Park Parish Council considered the SPD at its meeting on the 5th November 2012. The Committee would like the following comments to be considered.

The Committee welcomed the plan to improve the pedestrian links with Fishermead and Oldbrook, and suggested improvement of the pedestrian links between Springfield and Campbell Park.

The Committee asked Milton Keynes Council to note the existence of the well used pedestrian route in the North West corner of Oldbrook to the station via the ice rink and suggested that this should become a pedestrian priority link, properly signposted and

Will add these connections

The pedestrian/cycle survey does not show this as significantly higher than any other pedestrian connection from surrounding estates into CMK, so no change proposed. It is however included as a connection to be improved

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maintained as such.

The Committee commended the plan’s retention of grid roads in Central Milton Keynes especially Secklow Gate and the plan’s retention of the existing building line rather than advancing it to the edge of the roads.

Comments Noted

The Committee asked for the following suggestions to be included in the Plan.

Improving the bus links from adjacent grid squares to Central Milton Keynes destinations, especially Fishermead to the station and superstores,

improving or relocating the market; include further cultural provisions eg expanding the library

and setting up a museum and make every effort to retain the commercial attractiveness

of the city centre.

While these comments may well be valid,they are all detailed proposals beyond the scope of the Review (eg other bus links may also need to be improved) They could however be included in the Business Neighbourhood Plan or the new forthcoming Local Plan

Aylesbury Vale District Council

The only comments we would like to make are supportive comments to the proposals as follows:-

1. to improve public spaces and routes/priority for bus services in CMK. Thinking about bus services coming in from rural hinterlands including northeast Aylesbury Vale, we support the improvements to the bus and train station area improving the range of facilities and comfort of customers.

Comments noted

2. It is important that the improvements to the train station area and the station itself consider the East –West Rail scheme and the interchange between train and bus services.

Noted. The redesigned Station Square improves the interchange between rail and bus passengers and is well placed to address the future needs for interchange for those

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passengers using East-West rail.

3. We also support the improved cycle access proposals. An improved network and priority for cycling will be important to attract users to cycle in where feasible from the outer suburbs and even beyond such as into Aylesbury Vale.

Noted

Cllr Paul Williams Can I first thank you for the hard work put into the Draft CMK Development Framework. It certainly looks to be a very detailed document, which should hopefully be very useful in guiding the future development of Central Milton Keynes.

The Point should be designated a "Building of Heritage for CMK". While I understand there are very good arguments for redeveloping the building, The Point is clearly an iconic building much loved by many people in Milton Keynes.

Point taken, but the consensus is that it is not a building that reflects the modernist, ‘Miesian’ principles that say Norfolk and Ashton House portray.

The proposal is to exclude all ‘heritage buildings’ except the centre:mk which is a listed building

I welcome the idea of improving connections between CMK and surrounding estates. There needs to be a firm commitment to improve pedestrian access into Milton Keynes to encourage workers and visitors to cycle or walk to CMK. This should include the repairing of paving and bridges leading to CMK, as well as improving the pedestrian experience for those entering CMK. The bridges leading from Fishermead are a perfect example of this.

Will include the importance of repairing as well

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The steps leading from Porthleven Place are in a poor state and lead people to a rather uninspiring part of CMK at the back of Xscape. I believe more could be done to improve this area for pedestrians. The same is also true once pedestrians cross the bridge leading from Pencarrow Place to the front of Xscape. Although the steps in Fishermead have recently been repaired to an excellent standard.

Will include this area at the back of Xscape as ‘zone of enhanced pedestrian experience’

I should also add, access into the section of CMK west of Witan Gate from Oldbrook, should also be carefully considered. I would not welcome any development similar in character to Petersfield Green, where there have been a number of issues. Inadequate fencing next to the grid road, making the area quite dangerous to children and insufficient parking being the main concerns.

The SPD does not state exactly what sort of interventions are permissible within the greenframe, it rather states what the principles would be that should inform what sort of development may be permissible

I welcome the bus hopper service proposal. However I would like to see this better integrated with the existing infrastructure and the proposals for 'super stops'.

Comment noted – but the text is being amended following consultation to say that the hopper service is a not a proposal as such but is just 1 potential way of improving PT within CMK

I also feel more should be done to improve the City Gardens. At present the area is rather unloved and I feel more should be done to encourage people to visit this area.

Comment noted – this issue is already addressed in section 3.5

Lastly I am concerned that the plans for the development of Secklow Gate and Midsummer Place may make this document

These developments would not make the document obsolete, the SPD does currently allow for these

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obsolete. I would therefore ask that a review takes place to "reassess" if necessary.

developments to occur so long as certain conditions are met

James Cassidy (resident)

a) The breaking of Midsummer Blvd. for more retailing space means that the chance is lost to have a significant open linear space, leading into the middle of Campbell Park. This could be made into the Champs Elysee of CMK, and enhance the listed building which is the shopping centre.

The continuation of Midsummer Blvd. would provide a visual break between the older CMK and the newer development to the south. It will also have an impact on vehicular traffic.

The Boulevard is already broken by Midsummer Place

b) The Point is a significant landmark, and should be adapted for another use if not used for leisure. The architecture of the West End of London has buildings of many styles which provide visual diversity. (More locally this can be seen in Cambridge St. in Wolverton, which has houses from the 1890s to 1960s along its length.) This can be compared to the City of London in which buildings are being demolished and rebuilt according to the current fashion, without thought to preserving diverse facades of different styles.

Comment noted, but this is a subjective point. The SPD will remove all ‘heritage builldings’ except for the centre:mk

c) Concerning parking: thought must be given to the security of shop-keepers and others who deed to deposit cash in banks. There should be adequate short-term parking provision near banks. Multi-story car parks do not give a sense of security, unlike street-level parking near the banks.

Lessons Learnt suggest suggest that surface level parking should be retained

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Cllr Rex Exon Develop the open space around the Eastern end of the shopping centre before building on public open space. Encourage Lower floors and more upper floors.

This is acknowledged as a development site

Secklow Gate Bridge is a Sacred Cow. However it should only be removed once a satisfactory application is put forward. (i.e. one that recognises and overcomes the consequences of closing the bridge).

The Development Framework outlines conditions by which the grid can be broken

The Bus station buy the railway station is a white elephant. This site should be redeveloped to increase the useable floor space 10 fold.

Comment noted – will be removed from Fig 1

CMK railway station needs better publicly accessible toilet facilities.

Comment noted – but beyond the scope of the DF

Western end of CMK needs better publicly accessible toilet facilities.

Campbell Park end of CMK needs better publicly accessible toilet facilities.

Comment noted – but beyond the scope of the DF

Encourage higher density / taller building developments to increase functional floor area.

It is believed that the SPD does sufficiently address

A “castle” should be built on the Xscape car park. The main tower would face out over Springfield roundabout. It would look like Windsor castle standing above the tree line. A castle wall would disguise the 1000 space car park, conference centre, hotel, banquet hall, retail, pub, restaurant, offices and service access etc.

Comment noted – but beyond the scope of the DF. Will include a section on the requirement for buildings of exceptional quality

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University of Milton Keynes should have a Campus on the South West corner of CMK. High density High rise, include 2000 units of student accommodation, and a conference centre.

Comment noted – but beyond the scope of the DF, but this is all permissible within the DF

Anti light pollution policy should be enforced. Comment noted – but beyond the scope of the DF. The DF has the flexibility to allow this

Multi storey car parks to be built behind the Civic Offices / Saxon Court / Westminster House and the Library. (Protecting the trees of course). Underground car parking should be encouraged. Ground floor should have outward facing retail / office / catering / community functions to increase an active public frontage.

Comment noted – but beyond the scope of the DF, but this is all permissible within the DF

A character development within Campbell Park. E.g. a pub / restaurant (including public hygene facilities). Sympathetic development (not over development).

Encourage higher density development of the northern edge of Campbell Park. I.e. like apartments facing onto Central Park in NYC. More than 4 visible stories and underground car parking. Note sunshine onto the par is not affected by this development. Development to the southern side of Campbell Park should not exceed 4 visible stories. Note quality of design and appearance should be exemplary for buildings facing onto the park.

Beyond the scope of the SPD

Comment noted – but beyond the scope of the DF, which currently does not identify individual development sites.

Land currently including The Point complex and the surface car park to the east of The Point should be developed at the same time.

Comment noted – but beyond the scope of the DF, which currently does not identify individual development sites.

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This development should include an underground bus station / taxi rank sufficiently large to remove all public and private vehicles from Midsummer Boulevard and thereby permitting the creation of a public open space / City Square. An underground bus station / taxi rank would be warm, dry and well lit 24 hours a day. It should also be fully accessible to all regardless age and disability.

Park and Ride should be created in the South Western sector of CMK. (until it is itself developed). The “city hopper” bus service would allow free access to all areas of CMK. The bus service would be paid for by a nominal car parking charge (e.g. green standard).

Park and Ride should be created in the Northern sector of Campbell Park. (until it is itself developed). The “city hopper” bus service would allow free access to all areas of CMK. The bus service would be paid for by a nominal car parking charge (e.g. green standard).

Beyond the scope of the SPD

Beyond the scope of the SPD

Extension of the clearly identifiable redway net work should be continued. Is there not already on to the East of the theatre?The Proposed redway from the station, up Midsummer Boulevard to Campbell Park should be completed. This should be clearly marked as a component part of the National cycle network (which it is).

The actual delivery of this is complex though and it is not the role of the DF to prescribe the exact route – it does however include a principle saying that and east-west route is needed

Wholly pedestrianise the length of Midsummer Boulevard between Marlborough Street and Saxon Gate. This would be our “High Street”.

This has a lot of merit to it, but where would the buses go?The SPD does highlight this area as needing to be improved from a pedestrian experience point of view

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Peter Hall (architect)

May I say immediately how encouraged I feel having read the new Framework document - you may recall the battles I was involved in for a Client in CMK in opposition to the inanities of the EDAW Plan and its ridiculous consequences. It's re-assuring to read your rejection of that "Plan" and the return to the basic principles of the Masterplan .. well done !

There is one issue which I believe needs still greater emphasis - the provision of a proper Civic Space - and to that end I've committed my thoughts to a short written piece - attached ( which I have also sent to the CMK Alliance as the issue is also underplayed in their Plan ).

CMK : CIVIC SPACEAs a long term user of CMK – as a place of employment in the pioneering days of the mid ‘70’s and early ‘80’s, as the base for my Architectural Practice from 1985 to 1999, as my home for two years and as a centre for shopping and leisure for over 30 years – I have watched and participated in the growth of CMK at first hand and have experienced the full range of emotional responses to it – anticipation, excitement, enjoyment, admiration, anti-climax, disappointment and ultimately frustration as a series of catastrophic decisions made by people who clearly didn’t understand the essence of the original Masterplan allowed deviations that have resulted in appalling mistakes.

The current exercises undertaken by both the Council and CMK Alliance have stemmed this growing disillusionment with the

Comment Noted – but can the SPD provide anymore detail in a high level document without a masterplan to inform it which is beyond its scope?

It is now proposed to identify an area for a new civic square south of Midsummer Boulevard within a portion of the existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people.

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future of CMK and have my wholehearted support BUT I believe they both overlook a significant opportunity to add to the experience of CMK and correct a serious omission. Both the Council Development Framework and the CMK Alliance Plan 2026 make reference to the need for the creation of a Civic Space but without, in my opinion, giving this element appropriate importance.

In 1998 the Council, in the person of John Best, commissioned a dozen design practices to undertake short feasibility studies to generate ideas for the future development of CMK which would address the perceived shortcomings of the developed area. My contribution to that exercise put forward as its central idea the introduction of a properly scaled, appropriately sited Civic Square. With the continuing discussions about density and character and the physical ways to generate the necessary changes ( which led ultimately to the disastrously ill-conceived Hub and its irreversible damage to the CMK plan ), the element that seemed to me to be missing was a focus – a place where people gravitate to stop/meet/watch/participate. The CMK Masterplan as realised provides a discipline, routes, and defines movement patterns but without any change of emphasis to announce the arrival at a “Centre” – a real hub. The previous excursions away from the Masterplan – Midsummer Place, the Theatre District, the hideous Hub – all resulted in irrelevant, uncomfortable space, confused circulation patterns and the loss of the rigour which exemplified the original design. When events need space in CMK they are confined to car parks or pushed into Campbell Park. Even the opportunity presented by Queens Court has been wilfully destroyed with the loss of its potential for future use as a

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significant public space, a situation probably made inevitable by the policies of the building’s owners and management, a situation which highlights the inappropriateness of creating public spaces within privately owned premises. As time goes on and the population of the City continues to expand, the absence of a Civic Space becomes both more critical and more difficult to counter as further development absorbs available space. HOWEVER, it is my contention that there still remains one opportunity, and it is the best opportunity that ever existed in the CMK development, to introduce a truly public space, a focus for the City which will acknowledge the finest elements of the Plan, solve some of the existing problem sites and open new opportunities for further growth – and with only one “bitter pill” to swallow.

It is noted that the Council’s Development Framework includes in its Civic Space section the suggestion that such a space can be incorporated on Midsummer Boulevard East including part of the Point site ( D.3.3 ), its adjoining empty site ( D.3.4 ) and includes the area currently occupied by the Open Market. I suggest that this is not a good site in its current form because although central to public activity in CMK, it would be disadvantaged by its relationship with the inhospitable side of Midsummer Place, its arbitrary relationship with the Shopping Building and the presence of Secklow Gate on its Eastern boundary. I suggest that CMK’s Civic Square should not be an accidental space squeezed into an ad-hoc area chosen solely due to its availability – to truly function as a civic focus it needs to be a positive, deliberate statement and command a direct relationship with major buildings on all sides, as is evident in the civic spaces created in our Victorian city centres such as Manchester and Birmingham, where the major spaces are

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fronted by the major buildings – a true focus for the citizens of the City.

The CMK Alliance Plan 2026 makes reference to the proposal of a major civic space as part of Policy CMKAP SS2, item f, but couches it in terms that make it a secondary, supportive feature to the Market Square (9.12) I believe this is crucially the wrong emphasis and once more demonstrates that the pressures of commerce are frequently given priority over the need for civic amenities – a mistake that we should all learn from and recognise as one of the root causes of the “failures” to date of the CMK City Centre.

My suggestion, first tabled in 1998, is to create the Civic Square on the North/South centreline of the Shopping Building and the East/West centreline of Midsummer Boulevard – geometrically and organisationally at the centre of Milton Keynes. This solution necessitates the removal of the Secklow Gate elevated road South of the Shopping Building and further disruption to Midsummer Boulevard but the following benefits should be noted:-

With Secklow Gate bridge removed an opportunity is created for an additional centre piece to the Shopping Building to be designed to address the new Civic Square.

The Shopping Building already has an inset in this location and the Southern Mall will overlook the Square without any alteration.

The Food Centre, a building which has never positively contributed to its surroundings, can be

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altered/extended/rebuilt with a better relationship to its surroundings and facing onto the new Civic Square.

Vacant site D.3.4 offers a further opportunity for major development designed to front the Square and with the removal of Secklow Gate can be designed to link with a redeveloped Food Centre building to enclose the Civic Square from the South.

With its position against the South side of the Shopping Building and new development potential to the East, West and South, the Square can benefit from good orientation, be sheltered and be large enough to accommodate all types of public use.

Redevelopment on three sides will offer opportunities for multi-level activity which overlooks the Civic Square giving grandstand coverage for larger events and spreading activity into the edge of the Square.

Site D.3.3 (the Point), which is already the subject of redevelopment speculation, will offer the opportunity for a public transport connection point immediately adjacent to the Civic Square.

By restricting service access to the Shopping Building to Secklow Gate North, delivery traffic through CMK will be removed.

Positioning the Civic Square on this central intersection

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creates a close relationship with the Theatre/Gallery and Campbell Park crossing thereby setting up an essentially pedestrian-dominated area in this axial position which can be developed as more Park than Centre and strengthen the link between CMK and the Park by bringing the landscape into the City Centre.

The loss of Secklow Gate to the South of the Shopping Building (the one “bitter pill”) does not lead to the “wall of steel” referred to by some commentators – the Shopping Building was not conceived as a wall – it was intended as a permeable building allowing free movement throughout. Only vehicles will be “inconvenienced” and people driving into CMK – and by definition this is a finite number due to the developing parking situation – will largely enter by the Gates that link to the Grid roads. People wanting to drive from North CMK to South CMK or vice versa will still have four major roads and any number of side streets to filter through on.

Finally I am attaching an extract from the 1998 Study – it graphically illustrates the creation of a Civic Square in its context. It is included to assist in identifying and orientating my proposals and is not intended as a design.

I believe the lack of a fully integrated Civic space is a fundamental weakness of the original Masterplan and none of the subsequent reviews or framework studies have given its absence proper consideration. A Civic Space that the citizens of Milton Keynes can relate to and identify as the natural focus of community response

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would energise and concentrate community involvement in City events, however, simply providing an area without putting it into the right context would be a waste of resources. The proposed Civic Space has to be the focus of a properly designed climax to the City Centre and could be the single most important addition to CMK and the City of Milton Keynes.

Cllr Bint JB1) Page 6 contains a poor choice of picture to illustrate CMK – please find a better picture.

The intention is to keep the picture but have a clearer caption that depicts what it is saying ie recent new development as well as vacant land representing the development opportunities in CMK.

Could include additional picture to illustrate other aspects of CMK

JB2) Section 1.2, the paragraph after the two numbered paragraphs is grammatically poor, and was perhaps intended as a continuation of the previous paragraph. Please re-word.

Agree – will amend

JB3) Section 1.2, second subsection, third paragraph (in its entirety and particularly the final sentence): it is not for MKC and this SPD to imply how CMKTC should proceed with its Neighbourhood Plan. The last sentence seems to be irrelevant to this SPD. Can I request that the paragraph is please re-written to describe the consequences for the SPD if the NP is subsequently adopted, and nothing else.

Will reword

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JB4) Section 1.3, second paragraph is not true (although it was true, prior to changes to CMKTC’s boundary in April 2012), or if it is true, the differences are trivial. Please correct this.

Don’t understand comment as there is no 2 nd para, but the area covered by the SPD was discussed with members and what is proposed was agreed as the way forward

JB5) Section 2 (throughout): Although I welcome the inclusion of the values and principles, I think the ten objectives of CMK (as set out in CS7) are at least as important. I therefore request that Section 2 is re-titled “Objectives, values and principles”, and the objectives are quoted in their entirety, as a new section 2.2 (with the current 2.2 being renumbered as 2.3)

As the Development Framework is to be adopted against the local plan, reference is made in the new Planning Policy context section to the relevant policies – especially S5. The objectives for CMK as set out in Policy S5 are summarised in 1.3.3 and the full policy text is reproduced in Appendix B to the document.

JB6) Section 3.3.7 (opening paragraph): this paragraph presents one side of a contentious debate (that CMK is lacking a sense of place and that this is the result of CMK buildings being all of a similar density) as if it was the only credible viewpoint. Please reword this paragraph to remove the attack on CMK’s sense of place.

Agree will amend – CMK in fact has a strong sense of place is some areas, especially if you are on any of the boulevards and gates.

JB7) Section 3.3.7, Principles, first bullet: Please remove the text from “due largely” to the end of the sentence, so that the sentence conveys a desire for the reducing densities mentioned, rather than implying this is an unwelcome constraint!?

Agree will amend to say “…..to complement the existing building heights of existing properties”

JB8) Section 3.3.8, Principles, all 3 bullets: The term “CMK” is used twice in the first paragraph to mean “CMK sections A-E”, ie, only as far as V8 Marlborough Street. In the second paragraph, “Campbell Park” seems to mean sections F-H,

Agreed – section 1.4 clarifies the approach to be taken to the use of CMK and Campbell Park to describe the different areas covered in the Development Framework.

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although the term Campbell Park is defined differently in Fig 5 (which if not rectified could be interpreted as meaning that the lower densities only apply to the central subset of sections F-H, not the residential areas)! In the third paragraph, the term “CMK” seems to mean the entire SPD area, ie, a different meaning from the first paragraph. Please can all three paragraphs be revised for clarity of meaning and consistency of terminology

JB9) Section 3.4.3, item 1, states that Secklow and Witan Gate are “not part of the grid road network” (implying they are in a lesser category). This conflicts with para 7.28 of the Local Plan which states that the CMK “Gates” are in the same category as most grid roads. So please can the last sentence of this paragraph be replaced with the following sentence:

‘Secklow and Witan Gate are also in this top category of the CMK movement hierarchy (defined as “District Distributors” in the 2005 Local Plan). ‘

I am familiar with the argument from officers that para 7.28 of the Local Plan is inconsistent with, and over-ridden by, Plan T1 on p60 of the Local Plan. However, as 7.28 deals explicitly with CMK’s Gates, and Plan T1 is a small-scale map showing the entire Borough area (at very low level of detail), I believe this argument has very little merit. I am also familiar with the argument from officers that when 7.28 refers to “Gates”, it only intended to refer to Grafton and Secklow Gates (ie, V6 and V7). However, para 7.28 has already stated that grid-roads (which includes V6 and V7) are District Distributors, so when the paragraph goes on to say that CMK’s “gates” are in the same category, it is clear that it must mean

There remains some disagreement over the interpretation of the road hierarchy. It is proposed to amend the text in the Development Framework as follows. The final paragraph below explains the reason for the differentiation between the Grafton and Saxon Gate and the other gates in CMK and Campbell Park.

“H5 Portway is a Primary Distributor.

V6 Grafton Street (and Grafton Gate), V7 Saxon Street (and Saxon Gate), V8 Marlborough Street and H6 Childs Way are District Distributors.

Elder, Witan, Secklow, Skeldon & Enmore Gates, as well as Overgate, are Local Distributors; however, the Local Plan requirements for District Distributors apply to them.

Silbury, Midsummer & Avebury Boulevards and Marlborough Gate are Local Distributors.

All other “Streets” and “Rows” are Access Streets.

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Secklow & Witan (because Grafton & Saxon Gates/Streets have been covered already). I understand there is no evidence to support this officer assertion of what was “meant” by para 7.28. So I find that this argument also has little merit, and hence my request that this SPD must be consistent with 7.28 of the Local Plan!

Primary ‘Gates’ of V6 and V7, which run north-south between the H5 and H6, are the entry points into CMK and also provide via the surface level car parking, access to development blocks, service access as well as access to North and South Row. The V6 and V7 are part of the wider CMK grid road system. Elder, Secklow, Witan, Skeldon & Enmore Gates and Overgate are also important for access into CMK but are not part of the wider grid road network.”

JB10) For consistency with the above point and for soundness with para 7.28 of the Local Plan, Fig 2 on page 19 of the SPD should be corrected, to show Secklow Gate and Witan Gate as Primary District Distributors.

See above commentWill amend term Primary District Distributor which does not exist

JB11) Section 3.4.6, Principles, second bullet: to avoid giving any greater policy weight or longevity than is necessary to this “current policy”, I suggest that this paragraph is revised to avoid restating/re-adopting the restriction on developers building as much parking as they choose. I support the flexible approach proposed.

Agree – will amend

JB12) Section 3.4.6 (or elsewhere) I think the SPD should say that when any developer proposes to build an insufficiency of parking for their projected demand (from staff & customers), they should be expected to make a realistic financial contribution to the cost of meeting the shortfall as some other location – and I understand that £10,000 per space is considered a realistic cost for multi-storey car parks.

The financial contribution for required but unprovided parking spaces is currently £2,500 in the CMK Planning Obligations SPD. Under the future CIL regime, new public sector provided multi-storey car parks would fall under strategic infrastructure and therefore would need to be funded for CIL. A project to deliver multi-storey car parks would need to be included in the Local Investment Plan in order for there to be any chance of funding from CIL.

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JB13) Section 3.4.6, Principles, penultimate bullet: I am opposed to the entire presumptions and intent of this sentence, on the grounds that it would open the floodgates to measures that could undermine the entire viability and attractiveness of CMK. I therefore recommend removing the point entirely, but if absolutely necessary, I could support a replacement bullet-point saying something like:

‘Promotion of smarter travel choices including modal-shift, time-shifting of “rushhour” travel, and other carrot-based measures to reduce demand for CMK parking and reduce peak highways demand’

That bullet is proposed to be deleted. Text to be added to promote an approach involving demand management.

JB14) The area of MK covered by this document is defined/shown inconsistently within the document (and described differently in officers’ presentations to Members). As I understand it, the area is intended to be area bounded by the railway line, H5, the canal, and H6 (ie the entirety of the CMK Parish area), PLUS the green frame area shown in colour in Fig 1. If this is correct, then the definition in para 1.3 is wrong, and the redlines on p6, p13, p19, p23, p26 and p29 are also wrong.

The geographic area of the CMK Development Framework SPD is drawn slightly wider than the extent of the CMK Development boundary in the Core Strategy and in the MKLP as it includes both sides of the greenframe. The reason for this being that both sides of the greenframe need to be considered if trying to make connections between neighbouring estates and CMK better and safer. This point was discussed and agreed at the cross-party Member briefing on 29 November 2012.

JB15) Underpasses & Secklow: I believe that Fig 1 should show, as under-passes, the pedestrian routes that exist under the intersections of Silbury/Secklow and Midsummer/Secklow. These serve exactly the same function as all the other underpasses shown: ie, they allow pedestrians to get from one place to another by passing below the roadway.

These are not seen as underpasses as the design is totally different

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JB16) I believe that the apparent exclusion of pedestrians – and pedestrian routes – from the Centre:MK, from Midsummer Place, and from the covered portion of Midsummer Blvd between the Centre and Midsummer Place, as shown on Fig 3, are unhelpful distortions of reality, in that those routes exist and are heavily used during the hours of operation of CMK as a retail destination. I recommend that Fig 3 is redrawn to show the zones of pedestrian experience, and the priority pedestrian routes (with if necessary a footnote saying that these routes apply during retail hours).

Agree – will amend for the centre:mk and include Midsummer Lane

JB17) In para 2.2, item 4, I think there is some coded reference to public transport, but I’d prefer it to actually mention the phrase “public transport”! In item 8, I think the role of MK as a subregional hub for retail, commercial leisure, the evening economy, and long-distance transport, should all be mentioned.

Agree – will amend

JB18) The legend on Fig 2 is wrong: there is no such category as a “primary district distributor”. The term that should be used is a “District Distributor & Primary Distributor” (because H6, V6, V7, V8, Secklow Gate & Witan Gate are District Distributors and H5 is a Primary Distributor.

Agree – will amend primary district distributorThere remains however some disagreement over the interpretation of the road hierarchy. It is proposed to amend the text in the Development Framework as follows. The final paragraph below explains the reason for the differentiation between the Grafton and Saxon Gate and the other gates in CMK and Campbell Park.

“H5 Portway is a Primary Distributor.

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V6 Grafton Street (and Grafton Gate), V7 Saxon Street (and Saxon Gate), V8 Marlborough Street and H6 Childs Way are District Distributors.

Elder, Witan, Secklow, Skeldon & Enmore Gates, as well as Overgate, are Local Distributors; however, the Local Plan requirements for District Distributors apply to them.

Silbury, Midsummer & Avebury Boulevards and Marlborough Gate are Local Distributors.

All other “Streets” and “Rows” are Access Streets.

Primary ‘Gates’ of V6 and V7, which run north-south between the H5 and H6, are the entry points into CMK and also provide via the surface level car parking, access to development blocks, service access as well as access to North and South Row. The V6 and V7 are part of the wider CMK grid road system. Elder, Secklow, Witan, Skeldon & Enmore Gates and Overgate are also important for access into CMK but are not part of the wider grid road network.”

JB19) I propose that somewhere (eg, 3.3, Urban design) there should be some mention of using design and the built form to aid legibility and wayfinding.

Agree – will include a section on wayfinding

JB20) Height of buildings and creating a distinctive skyline (para 3.3.7): I suggest that buildings expected to form part of the skyline, ie any buildings of around 8 storeys, and especially any taller buildings, must be attractive and distinctive.

Agree, but need to be careful of word ‘distinctive’, taller buildings are likely to be distinctive in their own right. Will include wording to emphasise the importance of ‘exceptional architectural quality’ .

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JB21) I would like para 3.3.2 to recognise and permit alternatives to the habitual block structure, by the inclusion of a new sub-para (c) saying something along the lines of “a distinctive, attractive alternative to a block structure”

Disagree – block structure can take on a variety of alternative designs. The wording is included to avoid developments like the Hub from occurring. I am not sure what alternative to the block structure one could envisage.

Richard Peats, English Heritage

Thank you for consulting English Heritage on the draft Central Milton Keynes Development Framework. Martin Small, our Planning Advisor covering the Milton Keynes area, normally leads on planning policy matters and planning policy consultations should generally be addressed to him. However, in this case I am responding on English Heritage’s behalf as I have a particular interest and long-standing involvement with the Shopping Building.

Our principal area of interest is the potential impact that the draft framework will have on the listed shopping building and its setting. In this context the emphasis placed in Values and Principles (2.2) on retaining the geometry of the grid, maintaining the integrity of the ‘green frame’ around CMK, safeguarding tree lined Boulevards and Gates, understanding and respecting the unique qualities of CMK and recognising the value of the twentieth century architecture of the city is very encouraging.

Likewise the key principles set out in 3.1.2 of retaining and reinforcing the rectilinear geometry of the CMK, retaining the connectivity of the grid and retaining the original development block boundaries and surface car parking are welcomed.

Comment noted

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However, we are concerned that the document is rather ambiguous as to the Council’s views on the future of Secklow Gate.

We consider Secklow Gate to be of importance as it makes a major contribution to the significance of the grade II listed Shopping Building, the design of which is shaped by the way in which the road runs over it. It would be impossible to truncate the road without seriously damaging the architectural qualities of the building.

While it is very encouraging that the explicit desire to remove Secklow Gate to make way for a public square set out in the 2005 Local Plan is not repeated, a public square to the south of the shopping building on square D3 remains a desire and the illustration shown on fig. 4 appears to indicate that the truncation of Secklow Gate is still seen as desirable. This appears to contradict fig. 1, which indicates that surface car parking is to be retained either side of Secklow Gate south of the shopping building. While we would be supportive of a civic space on D3 we believe that this could be achieved without the demolition of Secklow Gate. We therefore suggest that this document specifically makes reference to the importance of Secklow Gate to the significance of the Shopping Building and the desirability of retaining it.

The DF is clear that Secklow Gate south can be removed / lowered if significant public benefit would result and the highway capacity would not suffer as a result of its removal.

Will clarify public square – the problem is at this high level it is difficult to get too prescriptive about the exact location of a civic square. It might be that wording is used but no graphic annotation. It is now proposed to identify an area for a new civic square south of Midsummer Boulevard within a portion of the existing temporary car park with at least 1 side facing Midsummer Boulevard. This square would be the focus for day and evening activities, a place for public events, a place for the market and areas to sit out and meet people.

The proposals to raise maximum height of buildings to eight storeys will have a marked impact on the character of the centre of Milton Keynes. While an increase in building heights in what now aspires to be a city centre is accepted as being inevitable, allowing eight storey buildings to be built right up to Saxon Gate will have an adverse impact on the setting of the Shopping Building. We

Comment noted, although with the location of the church it is unlikely tall buildings would ever get located adjacent to it or in its immediate vicinity

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would therefore advise that building heights are restricted to four stories on the west side of Saxon Gate.

Alan Preen (Resident)

To me CMK and the `Shopping Centre’ is a fundamental element in the success of this town but it has been neglected for the last 15 – 20 years and been allowed to `do its own thing’ to the detriment of it’s retail standing within the UK. Personally, I am not in favour of listing commercial buildings (a listing can seriously stifle expansion and restrict the ability of an organisation to keep pace with trend). However, in the case of the MK shopping building it has at least protected the framework from the excesses of ill-conceived development and design activity.

1. The proposed boundary of CMK fails to incorporate Rooksley and the retail areas of Snowdon Drive. These areas should form an integral part of CMK retail strategies, as the needs of these Retail/Leisure centres are complimentary to the shopping centre and Xscape. More so in the future, as land and sites are more freely available in these tertiary yet vital areas!

Comment noted

These areas are classed as out of centre and are outside the CMK Development Boundary as defined in both the local plan and the Core Strategy. Although not included in the CMK Development Framework which is primarily a piece of design guidance, these sites are considered in planning and retail capacity terms when considering the impact of new development.

2. Ref: 2.2.2 I do not believe we should be refurbishing existing building stock within this area. Economic activity should entirely dictate within the parameters and controls of planning (only

Accept point, but the wording does say “where appropriate” and only applies to buildings of architectural value

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quality buildings commensurate with the design philosophy of a new Milton Keynes). Encouraging new but `quality new’ should be the mantra of MK Council. That way we will attract the leading operators of particular fields and markets. What we do not want however are more `Hubs’ and more `Points’ and greater densities at street level which all go together to give a feeling of claustrophobia and cheapness.

3. 2.2.4 You have recognised the vital role of the car but I do not think you have addressed the vital importance of driver and passenger need. The driver and passenger want to be able to park easily at nil or low cost and if need be get into a rapid transit system to connect with Shopping/Leisure. Warehouse retail is different they want (as is) drive to the door. (what is a multi modul approach can we please use plain English).

Who would finance a Rapid Transit SystemParking at nil cost is not viableWill amend multi-modal approach – this in effect implies public transport and other modes of travel

4. 2.2.9. I wholly disagree in locating a University within CMK. Already there is enormous pressure on development space so to add a further university presence into the mix is wholly impractical. With the success of the O.U. and the campus concept what is the argument for locating a university in the centre of MK? We are no Oxbridge and surely we do not want to replicate the problems these cities have by having universities within the core of their economic being – it is a recipe for disaster! Sounds lovely, picture of lovely students punting up and down a river and riding to lectures on bicycles but I ask you? What about expansion, what about anti-social behaviour, what about parking it goes on. You cannot tell me that a university/college will provide a quality architectural solution befitting a modern city centre like MK. Take a

Personal view, others think it would improve the vitality of CMK and make it more socially interesting and active There is in fact significant development space in CMK compared to other city centres

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look at Bletchley and any other college buildings around MK and I rest my case. 2.2.9.(b) is at complete odds with 2.2.8. and 2.2. 9 (d).

5. 3.1.2.4 (b) has to be an issue because by removing access to parking surely this leaves others to contribute at their expense to their customer and or staff parking needs. Evidence of this is in the problems staff have in the `Hub’ complex. Staff have reported to me huge problems associated with parking and the vulnerability females have when going to and from work and particularly during winter mornings/evenings when it is dark! If say a large retailer wants to completely swamp a site in development then at the very minimum staff parking should be provided by the retailer underground.

Comment noted, but this does imply the parking requirement does not have to be met in some other way, it would in underground or MSCP formatWalking to distant surface level parking has been raised as a safety issue

6. 3.1.2.5. Underpasses should not just be retained but improved and added to. We all know they work. Underpasses connecting the surrounding residential areas should be added to wherever possible to encourage more pedestrian local shopping. In addition, cycle access to the commercial areas would be enhanced by more underpasses.

Not everyone thinks underpasses/overbridges are safeWhere else could underpasses be included??

The SPD states that maintenance to the public realm needs to occur and be of a high standard

7. 3.1.2.8 (a-e) should be removed - development within the `Greenframe’ should be prohibited at all costs save for say a spectacular restaurant in the park. It would have to be spectacular with guaranteed continued investment or it gets demolished at the operators cost!

Disagree – there may be instances where it may be acceptable so long as the green character of the greenframe is protected (as well as other criteria identified in the SPD are met)

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8. 3.3.3. The framework should address the likelihood of deteriorating residential properties adversely influencing the appearance of the entire façade of a building. I am thinking here `The Hub’ and how shocking some of the windows look when casting your eyes up a building. Blinds have collapsed; bikes prop up window casings and just general house detritus surrounds odd windows. The design of the building should lesson this effect by perhaps dropping any residential windows back from the buildings road/pavement line. Conditions should be imposed on landlords to prevent abuses of this nature.

Agree with comment, but not sure if this SPD (at the high level that it is at ie focussing on principles) can go into this detail

It will not be possible to include conditions, although lease agreements can assist with balconies

Will include a statement saying that where residential apartments blocks include a significant amount of glazing, coloured panels or obsure glazing should be included to help protect the integrity of the façade.

9. 3.3.4. Wind effects should be accounted for in the design of all buildings within the Central area. Where pedestrian flows are high between buildings then `portes cocheres’ should be required as part of the development cost. Getting drenched when walking up from the station is a problem! Is a 2m depth covered walkway sufficient I would have said not! The creation of adverse micro – climates should be avoided at all costs.

Can add a comment on wind effects

Not sure how portes cocheres will add benefit in terms of wind reduction

10. 3.3.6. (c) to attract small independent traders then something more than a planning principle will be required. Rate relief and or `use’ constraints are called for otherwise we just end up with more of the same and MK is no different than the rest of the UK’s shopping malls. The like of `Costa Lot’ should not be encouraged.

This is just a principle – accept is does not have much teeth – perhaps can add something on rate relief as incentive for smaller independent shops

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11. 3.3.7 Can we add `Quality Architecture and materials being encouraged across CMK particularly if these are high rise (taller) – The Hub fails on so many counts we do not want a repeat building!

Agree – this will be added

12. 3.3.11 Durability of materials is crucial throughout MK never mind CMK. The use of Cedar panels for example as part of the Sainsbury building is another recipe for disaster as the wood gradually deteriorates. It will inevitably lead to a patchwork effect in the medium term as residents and property owners struggle to replace rotten panels! Already the building looks drab and uncared for. A list of none approved materials should be published and materials to be encouraged would not harm the development process

Agree – cedar cladding in my view is not appropriate for city centre, but this is subjective and others might disagree. It is also beyond the scope of the SPD

13. 3.4.1. The use of traffic lights should be halted and reversed if possible, as these do not achieve 3.4.1 (b) they are not generally efficient.

Comment noted – but this is not possible

14. 3.4.1 There is one elephant in this room when it talks about 7 objectives – there should be 8! The missing objective is a unique and 21st century public transit system around the centre! Why not bite on the bullet and get behind the development of say a `Cable Car’ or `Mono-Rail’ rather like San Francisco or Disney circulating around and linking; car parking, station, commercial quarter, shopping building, Council offices/facilities, Law Courts, Xscape etc. Such a scheme would be ambitious and would do more for MK in PR and inward investment than almost anything else. Put

Sounds good – but who will pay for it?

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Winkleman in control of it he would get the thing off the ground!

15. 3.4.2 .3. (e) is at odds with 3.1.2.4 (b) a development important to MK may need to build on existing parking. If this is the case then alternative parking on a ratio 1:2 (not 1:1) should be part of the planning gain. The replacement parking should be within the central area and not in some back wood!

See earlier comment – this development would still be expected to meet its generated parking requirement.

This point (in italics) has in any event been removed from the SPD

16. I cannot help thinking that after the under passes of Avebury, Silbury and Midsummer pedestrian routes in and out of central MK get very hazardous and if we are to enhance and attract more cyclists and pedestrians then this needs a comprehensive almost separate plan. The framework identifies that the present situation between the various modes of transport is unsustainable so why does this framework leave me thinking that yet again it is not getting the attention and investment the subject deserves.

Comment notedAny ideas on how to achieve this??

17. 3.4.4.6. Signage/wayfinding could be more destination orientated rather like that found during the Olympics in London. Continuity from start to finish. Example colour code the quarters then break down the destinations within. On each board it is then easy to direct to a `Quarter’ then the destinations within that quarter. That way, finding your way across specific routes from say the shopping building to a car a park or the station the pedestrian would see their destination on each signpost. It just needs designing and making simple. Similar but different style could be used for the Redways.

A wayfinding strategy is underway in CMK – this will be elaborated on in the SPD

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The Quarters are: Central Business District 1-6, Civic Core, Shopping Building, Leisure Xscape, Campbell Park North, Central & South,

Comment noted

18. 3.4.6 (c) Multi Story parking should be to within a standard capable of being future proof. For example, I cannot park my car at the Theatre multi-story for fear of smashing into the structure of the building. Cars are now getting very large and the parking areas need to reflect that change.

MSCPs need to accommodate all cars

19. 3.4.6. (h) what is meant by reducing unfettered demand – HOW? The framework should not leave questions like this. If that means hiking parking costs still more then this is wrong and discriminatory across the socio economic groups let alone locals and residents of the wider MK (rate payers).

That bullet is proposed to be deleted. Text to be added to promote an approach involving demand management.

20. 3.4.7. 1/2 Could I suggest an even stronger stylising and advertising of this service – we used the Olympic `park and ride’ system to Dorney (rowing) and I was amazed at just how efficient this was however it was nothing like what is being proposed so again lessons need to be learnt and a whole strategy in itself needs to be developed addressing such things as:

a. Visibility b. Novelty (stimulus to want to use it) (child friendly) etc c. Pick up point design and location d. Differentiation between Park & Ride and Arrive & Ride

See earlier comment on wayfinding

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e. Frequency f. Baggage facilities g. Security at night h. Disabled access i. Cost (subsidies) by large stores

21. 3.5.2 (b) This is vital (new public square) however I disagree this should not include a place for the market – this would be entirely at odds with the intrinsic benefit of such a space. It should be green an area for sitting and relaxing. There should be water and art to create an environment for contemplation and relaxation between shops. A place to meet. A place for public events, there should be areas to provide cover in inclement weather. It would be entirely ruined by having a market sited there – I know the reasoning (Primark argument) but it is wrong!

It would not be a permanent market, if it was agreed it would ruin the space

22. 3.5.2 (f) Campbell park to me is the most undervalued asset within the centre. A magnificent gateway should be incorporated as part of the strategy for the central shopping area to encourage visitors to see the other side of Milton Keynes. A separate public transit system could perhaps encourage wider use particularly those in the commercial sectors during lunch breaks. This would have to be fast and efficient!

Agree with comment, the DF does highlight the importance of improving the existing link into Campbell Park from Midsummer Blvd, and ideally it could be accessed via public transit

23. 3.6.2. Character could be built into an area by way of distinctive street furniture and planting. This would assist in creating identities for residents example `Little Venice’ and a sense of belonging to a `smaller tribe’ very much like living in Bow Brickhill. The character just needs developing and building upon.

Comment noted, but a common palette of street furniture is seen as desirable as per the CMK Handbook

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We all want to belong to a small community!

24. 3.6.2.6 Block B 4 (Crown Jewels) this is exactly why the framework should include the southern retail area of Snowdon Drive because this area in particular will impact greatly on Block B4 development area particularly at the corner of the junction. B4 is the ideal place for a landmark piece of architecture which should impose on the entire city – a Milton Keynes `Shard’ or Milton Keynes `Tower

Don’t understand reasoning – Snowdon Drive is segregated from B4 by an enormous roundabout and dual carriageway

Agree and iconic building could be located at corner of B4

West Northamptonshire Joint Planning Unit

No comment Noted

Gill King, MKC Environmental Health

I have had a look at the CMK SPD consultation document and would like to make some comments regarding the management of waste in any new development in CMK. Waste Management in new developments is covered in the Social Infrastructure SPD and the Sustainable Construction SPD, and it is hoped that the CMK SPD will be consistent with those SPD's. The Social Infrastructure SPD is being reviewed and we have supplied the attached document to the review which gives details of what we would expect in relation to Waste Management.

Will include these comments

Regarding CMK there is one issue that is particularly relevant - the need for proper storage areas for waste. In particular we would wish to avoid the situation in the theatre district where bins are stored outside restaurants etc in prominent positions due to lack

Will include these comments

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of adequate storage space inside. This detracts from the image of the area. The bins are also more prone to vandalism and arson when they are so visible. ALL premises, both commercial and domestic, should have waste/bin storage areas which are:

discreet and not visible from the street easily accessible by collectors, avoiding the need for

manouevring bins up/down steps, across areas where they may get stuck, or taken long distances

easily accessible by users e.g. through an internal door lockable on days when collections are not expected adequately-sized to allow separation of wastes for

recycling accessible by collection vehicles. There is one area in CMK

where collection vehicles are expected to go into an underground area. This restricts the sort of vehicle that can be used- vehicles which lift bins over the top of the vehicle cannot be used since there is insufficient headroom. In other areas of Milton Keynes, narrow roads make collection of refuse very difficult. This should also be avoided.

We very much hope that consideration to proper waste management can be incorporated into the planning process and are always happy to advise developers.

Bedford Borough Council

No comment – does not affect Bedford Noted

Dr Andrew Humphries, resident in

Thank you for the opportunity to comment on the SPD. Overall I believe you have got the balance between preservation and development just right.

Comment noted – but not relevant to scope of DF. CMK Handbook outlines guidance on lighting

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Woughton Park However, I note that street lighting is confined to page 17 gets very little coverage. In my opinion there is too much lighting in MK; it might have been fashionable in the 1970s but today it looks brash, stark, uninviting, dated and inefficient .

I have just returned from an extended stay in the US where lower level, warm-effect lights, often using LED technology, provide good visibility for pedestrians and cyclists and a much better, more inviting ambience with minimal light pollution. In the US, roads are rarely ‘fully lit’. Instead motor vehicles rely on their headlights and extensive use of road surface cats eyes with far fewer overhead lights. The overall effect is modern yet friendly, safe yet environmentally considerate. I believe the SPD needs to reflect this important aspect.

Legal and General We write on behalf of our client Legal & General Assurance Society Limited (Legal & General), owners of Midsummer Place Shopping Centre, Central Milton Keynes to submit representations to the draft CMK Development Framework, August 2012, currently out for public consultation.

We submit our support to the Draft CMK Development Framework and its role and purpose to provide an up to date planning and design guide for investors into CMK.

Notwithstanding our support, there some general comments on the detailed provisions of the Framework that we wish to bring to your attention prior to finalisation.

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Timeframe. The Development Framework provides for an expansion of the Core Strategy Policy CS7, However it is unclear whether the timeframe for the Development Framework reflects that of the Core Strategy.

Comment noted. The CMK DF Review is to be adopted now in line with the adopted MKLP due to the delays that have been experienced in finalising the Core Strategy. Following the adoption of the Core Strategy, the Development Framework will be amended to reflect the nuances of the change of strategic policy from local plan Policy S5 to Core Strategy policy CS7.

Pro-growth. Given the transfer of HCA assets, Milton Keynes within the second wave of City Deals, coupled with clear Central Government guidance in delivering sustainable economic growth and seeking to drive further (private) sector investment, more could be made of how the Council is seeking to support the local community and attract inward investment through the provisions of the Framework. That CMK is ‘open for business’.

Agree with comment – will add

Relationship between the Text and Figures. The relationship between the wording of the sections and associated Figures are not, in a number of instances, complementary. In some cases, terminology is different or elements highlighted on the Figures are not cross-referred/explained in the text or vice versa. This should be strengthened to ensure clarity of interpretation.

Agree – these were errors. Will check for consistency

Relationship to other Strategy / Framework documents. Agree – will add

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There exist a number of strategy and guidance documents to guide development in CMK, which have differing status and in some cases overlap. It would be useful to clarify what status these documents will have on adoption of the Development Framework.

Values and Principles. The Values and Principles set out in Section 2 are not carried forward into Section 3; where another set of principles are introduced. It would be helpful for the reader (investor) if the navigation through the principles was more clearly articulated.

Agree – this is confusing – will make clearer.

Figure 1: Key Structuring Elements. The ‘stub’ of highway at Midsummer Boulevard West, which provides a turning circle in front of Midsummer Place Shopping Centre, no longer serves a useful purpose as a local distributor road as shown on Figure 1. Accordingly, this small section should be removed from the image on Figure 1 and Figure 2 CMK Street Hierarchy.

Comment noted - Highways have agreed to remove the stub altogether from fig 2, so will amend SPD to reflect this

MK Star. The proposals indicate that MK Star routes will run along Midsummer Boulevard. The routes of this service have not yet been defined. This section is not clearly associated with the proposals in Figure 3. Given that part of Midsummer Boulevard is no longer public highway, a form of wording to reflect this would be more appropriate, such as ‘proposed to access’ or ‘utilise

Agree – will amend to remove link between MK Star and Midsummer Boulevard

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Midsummer Boulevard’.

Broad Character Areas for CMK. The Core Shopping Area character area does not reflect the Primary Shopping Area as established in the emerging Core Strategy. The boundary should reflect the same as Figure 7.1 of the emerging Core Strategy.

Agree. The Core Shopping Area needs to reflect the Primary Shopping Area as defined in the Milton Keynes Local Plan (ie the area within Avebury and Silbury Boulevards and Saxon and Marlborough Gates)

Paragraph Numbering. It would useful if each paragraph was numbered so the reader can refer to specific text as appropriate.

Agree – will amend as suggested

In summary, Legal & General supports the CMK Development Framework, subject to the matters of clarification and reasons outlined in this letter. We trust that you will take our comments into consideration in finalising the Development Framework.

Noted

Milton Keynes Higher Education Board (MKHEB)

This consultation response is sent on behalf of the Milton Keynes Higher Education Board, a partnership body which has been leading on the vision and strategy for higher education development in Milton Keynes since 2008. The Board is broadly representative of major Milton Keynes stakeholders: Milton Keynes Council; Milton Keynes Partnership until its demise; HE

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providers; education; business; and the voluntary sector. It complements any response from the University of Bedfordshire on behalf of University Campus Milton Keynes (UCMK ) or from Milton Keynes College as the continuing provider of “HE in FE”. Notes:

1. The abbreviation UCMK has previously referred to University Centre Milton Keynes, a Division of Milton Keynes College; it will in future refer to University Campus Milton Keynes, a constituent of the University of Bedfordshire. (To be confirmed following University of Bedfordshire Governors meeting on 22nd November).

2. It is proposed that Milton Keynes Higher Education Board should be replaced by a legal entity, the Milton Keynes University Trust, to lead on the vision and to hold capital assets provided from community sources for the beneficial use of providers of university level education in Milton Keynes.

Consultation Response

The Board endorses the general approach to the CMK Supplementary Planning Document with its emphasis on providing a flexible strategy set within high level structural elements and other high level guiding principles linked to the growth and development of Central Milton Keynes (Section 1.2).The Board welcomes the Values and Principles (Section 2.2) to underpin the SPD including the reference to a university under “Fostering creativity, learning and, success” but urges that the

Comments noted

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university should be a separate bullet point given its major importance to the future of Milton Keynes as a whole and to the spatial development of CMK in particular.

It has one substantive comment on the planning principles. The needs of the university presence and of the potential synergy of this presence with associated developments in research, knowledge exchange, as well as related cultural, leisure, and business developments should be explicit. Its ultimate scope cannot be forecast with any certainty but that it will develop into a substantial element of CMK infrastructure should not be doubted. For this reason, opportunities for a permanent location should be kept under review with the University of Bedfordshire and Milton Keynes College whenever major development or redevelopment opportunities arise. In this regard the reference to “university related uses” under “Areas Open to a Variety of Proposals” (Section 3.6) as one potential use of the undeveloped Block B4 is welcome but should be viewed as one such locational option for a university and related activities, but should not be limited to it.

In short the Board urges that a university presence should be given explicit and special emphasis in the Supplementary Planning Document on a par with other major public activities associated with the central areas of most major British cities and that opportunities for its physical development in CMK should be kept under regular review.

Comments noted – will make this clear and add into section on Character Areas

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The background to this response is set out below.

Establishment of a significant university presence in Milton KeynesThe national context of higher education funding and policy has changed dramatically over the past two years. In light of this and building on the success of University Centre Milton Keynes, the Board and the Council have recently jointly agreed a new interim strategy for higher education development in Milton Keynes in consultation with Milton Keynes College which has successfully driven UCMK to date, and the University of Bedfordshire as the lead HEI for UCMK. This builds on the previously adopted “2020 Vision: towards a University of Milton Keynes” (adopted in 2009 following widespread consultation with a range of Milton Keynes community and sub-regional interests). At the heart of the new strategy is the continuing long term vision for a University of Milton Keynes but with recognition that this may take many years to realise (and will be subject to the vagaries of changing Government policies) and that establishment of a significant university presence is urgent if the city’s economic development plans are to succeed.

Accordingly, the University of Bedfordshire’s proposals for major investment in higher education in Milton Keynes through the establishment of a new University Campus Milton Keynes including a flagship Faculty of Engineering and Technology have been welcomed by the Board, the Council and Milton Keynes College. It is planned that it should be operational from September 2013. Collaboration between the University of Bedfordshire, an

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acknowledged leader in respect of student access, teaching and graduate employability, and Milton Keynes College with its commitment to access, high student satisfaction and successful record in delivering vocational higher education in collaboration with the Milton Keynes community offers a distinctive and innovative model which will capitalise on the strengths of each party.

Scale of teaching provision

The long term ambition is for the scale of university level education in Milton Keynes to be at least 10,000 students. The basis for this long term ambition is that the city would then no longer be a net exporter of higher education students (about 10,000 students domiciled in Milton Keynes study at HE level somewhere in the UK at present). Ultimately it should aim to match that of other like-sized centres of population but that is looking very far ahead. Having regard to likely national trends in the sector, the challenging financial context, and the continuing strict government student number controls for English and EU students, it is an optimistic planning assumption that Milton Keynes should have reached the milestone of 5000 HE level students studying locally (headcount) by about 2025 (excluding students resident in Milton Keynes of the national and international Open University).Research and knowledge exchangeThe knowledge economy is crucial to the future of Milton Keynes and already employs some 40% of its working population. In this regard the city already benefits from the presence of the world leading distance learning Open University and nearby specialist Cranfield University each with research expertise. The ambition is

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for a local university presence with an internationally recognised research capacity in niche areas that will act as a key partner in: local initiatives such as Milton Keynes Gateway and the Innovation Centre (which seek to promote skills, enterprise and innovation); civic initiatives covering such matters as Low Carbon, Smart Cities and Tele-health; regional initiatives through SEMLEP; and wider national and international initiatives relevant to the needs of Milton Keynes. The University of Bedfordshire’s plans for Milton Keynes respond to this need.

Estates StrategyThe estates strategy to support these developments in the medium to long term will be the subject of further more detailed appraisal but the overall position of the Board and the Council is as set out in the following policy statement: “The University of Milton Keynes will have a strong, inspirational, centrally-located physical presence in the city complemented by local facilities and distributed delivery to students and businesses wherever they are located using the power of modern communication and learning technologies and partnership working under the Cloud University model pioneered by UCMK. .….. The central physical presence will act as an intellectual focus and catalyst for innovation and ideas. It will be an exemplar of environmental sustainability. It will contribute to the civic centre vision of the city and be accessible to students by maximising public transport opportunities. The Cloud University model will ensure that higher education is delivered to the students accessibly and effectively wherever they are located. It will be a practical demonstration of the University’s commitment to innovation and

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partnership. The estates provision will be driven by the needs of teaching and research.”

There are opportunities for investment in higher education infrastructure to be directly aligned with associated research and knowledge transfer activity (see above) as well as with cultural, leisure and business initiatives. It is essential that these should be kept under active review by the Council and the providers of higher education. The Council’s Core Strategy for the spatial development of Milton Keynes includes many potential opportunities for such synergy to be exploited and includes the willingness of the Council to modify existing planning guidance within Central Milton Keynes to assist the expansion of university activity.

In the short term the University of Bedfordshire will have to rely on existing rental accommodation in Central Milton Keynes (Milton Keynes College already has a physical presence through 200 Silbury Boulevard) and options for 2013 to 2016 are currently under urgent evaluation. Longer term any opportunity for large scale new development or redevelopment of existing property in CMK should be investigated with the University of Bedfordshire, Milton Keynes College and developers in order to secure a permanent university location.

It is not possible to offer any definitive statement of land and building needs but it may be helpful to refer to the Board’s response to the Council’s Milton Keynes Infrastructure Planning Obligations Policy Review Consultation of June 2011 when an indicative figure of 10000 to 12000 m2 gross internal area for a

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university of 5000 students was quoted (excluding student residential accommodation and based on other stated assumptions). This estimate was derived from work done in the period 2003/04 by consultants Drivas Jonas who estimated the need for 17000 m2 and a land take of c.1 hectare for this scale of university (again excluding student residential accommodation). These figures should be taken as being broadly indicative of magnitude rather formal estimates.

Turleys on behalf of the Joint Owners of the shopping centre

PurposeWe understand that the purpose of the draft SPD is to provide up-to-date planning and design guidance that is important to the development and growth of CMK. The draft SPD is also intended to represent a ‘light touch,’ primarily based on and informed by the lessons that have been learnt since the adoption of the 2002 Development Framework, as well as a review of CMK policy since 1970, which according to Section 1.1, will be linked to the Core Strategy (The SPD expands on the emerging Core Strategy Policy CS7).

Furthermore, and due to the emergence in 2011 of the Business Neighbourhood Plan, it is understood that significant discussion has taken place around the relationship between the CMK Development Framework Review and the Business Neighbourhood Plan. We understand that the Business Neighbourhood Plan and CMK Development Framework Review will be progressed as standalone documents

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Points of ClarificationAs you are aware, the Central- CMK Framework SPD was adopted in 2006 (2006 SPD), providing “additional guidance” to the principles established in the 2002 CMK Development Framework (2002 Framework). Given that the 2002 Framework was adopted prior to 2004 (Planning and Compulsory Purchase Act), the weight it can properly be given must be assessed in accordance with its degree of consistency with the National Planning Policy Framework (NPPF).

In addition, Part 4 of the Town and Country Planning (Local Planning) (England) Regulations 2012, details the form and content of documents and regard to be had to certain matters, including supplementary planning documents as follows:“Part 4, 8 (2) A local plan or a supplementary planning document must contain a reasoned justification of the policies contained in it.(3) Any policies contained in a supplementary planning document must not conflict with the adopted development plan.(4) Subject to paragraph (5), the policies contained in the local plan must be consistent with the adopted development plan.(5) where a local plan contains a policy that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.”Given the provision of the Regulations, as highlighted above, it is considered that the 2006 SPD by virtue of its adoption in line with the adopted development plan (Milton Keynes Local Plan, 2005) is the most relevant and current policy document and carries more material weight in the consideration of planning applications than the 2002 Framework.

The policies in the MKLP and SPDs are assessed against the NPPF when determining planning applications in order to properly consider the weight that can be afforded them

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The review of the 2002 Development Framework in isolation, and as suggested in Section 1.1, in line with Policy CS 7, is not considered appropriate as supporting paragraph 7.9 of that policy states that “Development in Central Milton Keynes will be managed by reference to Saved Local Plan policies (in this instance those contained within the Milton Keynes Adopted Local Plan 2005) and guidance and advice in related Supplementary Planning Guidance/Supplementary Documents. This policy will be revised as necessary through the Development Management DPD.”

Given this, it is considered that the review of the 2002 Development Framework review should give mention to the policies contained within the adopted Development Plan (Milton Keynes Local Plan, 2005).

Furthermore, it is considered premature to review the 2002 SPG in line with an emerging policy (CS7 of the Core Strategy), when that very policy document has yet to be adopted. Moreover, it is understood that the Council are seeking to progress a new Local Plan in 2013 (Plan MK), which adds a further tier of policy/guidance, in turn adding further confusion and uncertainty to the relevant policy position moving forward.

To this end, it is considered that both documents (2002 SPG and 2006 SPD) should be reviewed in parallel given that both are intrinsically linked and, more importantly, the 2006 SPD carries more status and relevance in relation to the adopted development plan, and as such, clarification should be provided from Milton Keynes Council as to the respective weight to be accorded to the aforementioned documents when considering planning

The intention is for the CMK DF Review to replace the 2002 CMk DF and the three SPGs/ SPDs that flowed from that document (the Campbell Park and SRQ SPGs and the Central CMK SPD).

Until such a time as the saved MKLP policies for CMK are updated and replaced by Plan MK (and/or the emerging CMK Alliance Business Neighbourhood Development Plan) they will remain as part of the Development Plan for the consideration of planning applications in CMK.

In the context of the above, it is considered that the replacement of the existing SPGs and SPDs for CMK with the new CMK DF Review is in line with the Delivery section of Core Strategy Policy CS7. We accept that there needs to be a section added to the CMK DF Review to clarify and explain the policy context for the document.

Agreed – the CMK DF Review is to be adopted for now in line with the adopted MKLP due to the delays that have been experienced in finalising the Core Strategy. Following the adoption of the Core Strategy, the Development Framework will be amended to reflect the nuances of the change of strategic policy from local plan Policy S5 to Core Strategy policy CS7.

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applications.

The Development Plan ContextAs stated above the guidance contained within the NPPF, the adopted Milton Keynes Local Plan and the Central CMK-Framework SPD below are of relevance and should be taken into consideration in the formulation of the CMK Development Framework review.

National Planning Policy FrameworkOn 27th March 2012, the Government published the National Planning Policy Framework (NPPF), which does not alter the statutory status of the development plan as the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise (paragraphs 11 and 12).Paragraph 13 states that the NPPF constitutes guidance for local planning authorities and decision takers both in drawing up plans and as a material consideration in determining applications.

At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision taking.

For plan making, local planning authorities should therefore positively seek opportunities to meet the development needs of their area. Local Plans are required to meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

- Any adverse impacts of doing so would significantly and

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demonstrably outweigh the benefits, when assessed against the policies in the NPPF; or

- Specific policies in the NPPF indicate development should be restricted

For decision taking, the presumption in favour of sustainable development means:

- Approving development proposals that accord with the development plan without delay; and

- Where the development plan is absent, silent or relevant policies are out-of-date, granting permission, unless:

o Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF as a whole; or

o Specific policies in the NPPF indicate development should be restricted.

In terms of specific ‘Core Planning Principles’ the NPPF (paragraph 17), requires, inter alia, the following which are considered of relevance to development in Central Milton Keynes’ Core Shopping Area:

- Support the transition to a low carbon future in a changing climate;

- Encourage the effective use of land;

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- Conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations; and

- Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable.

In order to deliver the above, and ‘Sustainable Development’ paragraph 18 states that the Government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future.

To this end, paragraph 19 reaffirms the Government’s commitment to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.

To encourage this, paragraph 21 states that investment in business should not be over-burdened by the combined requirements of planning policy expectations. Planning policies should recognise and seek to address potential barriers to investment, including poor environment.

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Milton Keynes Adopted Local Plan (Saved Policies)As highlighted above, it is considered that the 2002 Development Framework review should take into account, and offer guidance to the delivery of the policies contained with the adopted ‘Development Plan’, which in this instance is the Milton Keynes Adopted Local Plan (2005).

Of relevance to the ‘Core Shopping Area’ or main shopping areas is Policy CC13, which provides the policy framework for this area, as follows: “The City Centre will be promoted as the main destination within CMK and a broad mix of uses will be encouraged including shopping, entertainment, residential, hotels, cultural and civic uses. The design and layout should reflect the following principles:

(i) Integrate existing and proposed development by breaking down the development block structure and reducing the physical separation between buildings

(ii) Create a new Civic Square and market area (following the removal of the Secklow Gate Road Bridge over Midsummer Boulevard) to act as a focal point within CMK

(iii) Create a new Civic and Community buildings and development with active ground floor frontages around Civic Square...”

Moreover, the supporting paragraphs to the policy provide detailed guidance as to the delivery of the policies key aims,

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including paragraph 12.102 which states:“ as part of the City Spine, Midsummer Boulevard east of Saxon Street will become more like a ‘High Street’ with pedestrians, cyclists and public transport users having priority...” Paragraph 12.103 goes further to state that “other significant developments along Midsummer Boulevard, which will also change its character and encourage pedestrian movement and activity include:

- The removal of Secklow Gate over the current market area. With the relocation of an expanded market to the High Street create along Midsummer Boulevard and the square...”

Central CMK Framework Supplementary Planning Document, 2006Similarly, the Supplementary Planning Document (SPD) which was adopted in 2006, provides guidance for the development of the Central Area supplementing and expanding on the planning policies contained within the Milton Keynes Local Plan and builds on the principles established in the CMK Development Framework. The SPD is a material planning consideration for the determination of planning applications within the area and therefore offers guidance for the design, assessment and delivery of future projects.

Of relevance to the ‘Core Shopping Area’ or main shopping area, Section 3.2 states that “Secklow Gate will no longer be a vehicular through route. The elevated section will be removed south of the shopping building and the level of Midsummer Boulevard either side of Secklow Gate is to be adjusted.”

Noted – it needs to be acknowledged that the premise of Policy CC13 is that the removal of Secklow Gate Bridge is contemplated in order to allow for the provision of “ a new Civic Square and market area” - arguably these could deliver the significant public benefits that the Revised Development Framework require in order to justify an exception from the presumption to protect the infrastructure.

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Principle Opportunity Areas 3b and 3c set out the aspirations for the creation of quality public realm, public spaces and alter Midsummer Boulevard East to reduce the dominance and intrusion of private vehicles and improve priority for pedestrians and cyclists.

We therefore consider that the above should be reflected in the CMK Development Framework Review.

New text on the planning policy context and the role of the CMK Development Framework is proposed to be added.

CMK Development Framework Review DraftNotwithstanding the context and appropriateness of progressing a review of the 2002 Development Framework in isolation, as highlighted above, we have reviewed the CMK Development Framework Review Draft and provide comments on specifics relating to the ‘Core Shopping Area’ or main shopping area.

Key Principles (Section 3.1.2, Paragraphs 1 and 2)It is considered that the guidance to “retain and reinforce” the rectilinear geometry of the CMK grid is not consistent with the policy requirements contained with the Milton Keynes Adopted Local Plan and the emerging Core Strategy (supporting paragraph 7.9 to Policy CS 7), as the policy framework stipulates a differing approach to the development of the Core Shopping Area or main

The intention to retain and reinforce the rectilinear geometry does not imply a break in the grid in terms of connectivity of the grid (eg Secklow Gate) cannot occur – it simply implies that CMK remains on a rectilinear format – it does not for example start introducing curved streets!

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shopping area (as set out in Policy CC13 of the Adopted Local Plan and the 2006 Central-CMK Framework) as they advocate the breaking down of the block structure and reducing the physical separation between buildings.

It is also considered that paragraph 2 of Section 3.1.2 is inconsistent with the requirements of the aforementioned policy position and NPPF, especially as the central theme of the latter (paragraphs 13, 18 and 19) is to secure economic growth in order to create jobs and prosperity, especially as planning should operate to encourage and not act as an impediment to sustainable growth.

To this end, and notwithstanding the concerns expressed above regarding the status of the CMK Development Framework review, it is considered that the wording of Section 3.1.2, paragraph 2 should be amended to reflect the spirit of the NPPF and to accord with the adopted development plan and 2006 SPD, especially the guidance highlighted above. Given this, it is considered that reference to the removal of Secklow Gate Road Bridge should be included and reference to ‘significant public benefits’ be amended to refer to the encouragement of economic growth.In general terms, it is considered that the CMK Development Framework review should be reviewed closely in line with the adopted Development Plan and policies contained within the NPPF in order to accord with the requisite requirements of the Act.

It is proposed to amend this wording to bring it into line with the local plan. The Development Framework makes it clear that public benefits do not imply just economic benefits, but reflecting the Golden Tread of sustainable development in the NPPF, need to also take account of environmental and social factors.

ConclusionsFollowing an extensive review of the status of the CMK Development Framework SPG (2002), the Central CMK-Framework

See comments above.

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SPD (2006) and the current consultation draft of the CMK Development Framework Review (2012), in summary we hereby express the following concerns and observations:

Clarification as to the status of the Central CMK- Framework SPD (2006) and the rationale for not reviewing the SPD in parallel with the current consultation draft of the CMK Development Framework;

Whether the current consultation review is premature given that the contents conflict with the current Development Plan (Milton Keynes Adopted Local Plan and NPPF policies). Moreover, and in any event, it is considered that the a review of both the 2002 SPG and 2006 SPD should take place once the Core Strategy is formally adopted to provide certainty and clarity for developers.

The rationale for not referencing back to relevant policies in the adopted Development Plan and the sole reliance on a very general policy contained within the emerging Core Strategy, especially where Policy CS 7 refers back to the adopted Milton Keynes Local Plan for detailed policy consideration in the absence of the preparation of Development Plan Documents (DPD); and

Certain references and guidance contained within the consultation draft are at odds with the aforementioned Development Plan and NPPF, and as such, reference to ingrained planning policy contained within the Adopted Milton Keynes Local Plan and 2006 SPD in respect of the removal of Secklow Gate should be included.

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Mr Murray Burring

1. There needs to be a comprehensive public transport strategy that looks to the future. The city is ideal for fast electric public transport (elevated rail, tramway, guided busway, other innovative ideas). Get the best people to look at what we have and how to use it to best advantage.

Agreed, but beyond the scope of the SPD

2. Grid roads need to be retained and new ones incorporated. This would help with point 1.

Comment noted, but beyond the scope of the SPD

3. The Hub/Sainsburys is an eyesore. Surely architects could have designed better looking buildings (I have seen similar properties being pulled down in London in the seventies).The building lines should never have been allowed to encroach, this has spoiled MK's unique character. Underpasses shouldnot have been filled in, this has impeded traffic flow.

Comment noted – others have said buildings are less important / are transient and it is the public realm that is of most importance

4. There needs to be significant funding for the area's heritage. This was part of the Development Corporation's original plan, but has never been fulfilled (although art seems to get more than its fair share).

Agreed, but beyond the scope of the SPD

Mr Alan Senior I responded to the CMK Alliance draft plan and it has been suggested that I also direct my views towards the MK Council Development Framework team.

The array of confusing titles, plans, committees and frameworks really is a challenge for ordinary mortals but I feel strongly enough about specific planning issues that I permit myself to attach my

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CMK Alliance submission and to reiterate my priority issues here.

The suggestion to close Secklow Gate Bridge to traffic, public transport, cycles and pedestrians is anathema to anybody with a vestige of respect for the Milton Keynes Master Plan. It would further break up our much-vaunted grid system and effectively put a kilometre-long uncrossable wall throughthe middle of our City centre. The increased traffic problems in circumnavigating the centre and the sheer inaccessiblity from North to South would be a massive deterrent to many citizens, residents and visitors.

To sacrifice so much for the sake of retail greed would be an appalling betrayal of what Milton Keynes set out to be.

The DF is not proposing to close Secklow Gate, it would only be permissible is significant public benefit resulted from it

My second major issue is the suggestion that Midsummer Place could be permanently blocked off by a retail structure where Midsummer Boulevard could and should run its full length. The 80-year covenant to keep Midsummer Boulevard intact for pollution-free public transport should surely now be invoked.

We have the No. 7 bus route going electric in 2013 and uninterrupted transit from the theatre to the station would surely be the way we would want our future city centre to look like.

I hope and trust that I am not a lone voice in the wilderness.Please don't be the team and the generation that goes down in history as the "Wreckers"

Comment noted – the Council’s Transport Dept view is that this is not part of the transport strategy

Graham Benjamin In general:

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(resident Stony Stratford)

Regarding the SPD Consultation Statement: I WELCOME the re-assessment in this statement, the lessons learned and the renewed sense of direction.

Regarding the CMK Development Framework Review Draft: I WELCOME the draft with it's clear linkage to the CMKAlliance draft Business Neighbourhood Plan. The Development Framework Review Draft requires some tightening up I believe and my detailed suggestions appear below. However, the two documents are a breath of fresh air in planning for CMK. Of the two, I think it right that the Neighbourhood Plan should predominate, being the more comprehensive, but it is most helpful that there is clear alignment in principle.

In detail:

Regarding CMK Development Review Draft, my more detailed comments are as follows:

Section 1: welcome and agree with the learning from the 2002 Development Framework experience as a foundation for both new documents, from MKC and CMKAlliance.

Comment noted and welcomed

Section 2: welcome all nine values and principles and in particular:- under 1: Protection of Public Realm - this of great current importance as well as core to the Centre's overall design- under 2: Recognition of the value of 20th C architecture in CMK- under 3: Complimenting the district role of the older towns and district centres I suggest that you ADD to this: "Promoting the role of CMK as a

Comment noted

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Regional Centre", which is a distinct and special part of it's design purpose, vitality and growth potential- under 6: emphasis should be placed on all four points

Section 3.1.2 (2) a) & b): I am DOUBTFUL of their efficacy or practicality and suggest that you DELETE these, RETAINING only the first sentence ("Retain...of Boulevards and Gates" [aligned with CMKAlliance plan]) and RETAIN "Public benefits" reference as a paragraph in it's own right, to give the clearest emphasis to this important point.

This was to worded to allow some flexibility if a development ‘breaks the rules’ but offers significant public benefits

Section 3.4.7 Public Transport, map on page 22, Primary Public Transport Spine: this should be shown as a continuous line along Midsummer Boulevard where electric and low-emission public transport is concerned, honouring the covenant to this effect on Midsummer Place. It is ridiculous that this route is not shown, given that the envisaged electric vehicles are now almost ready for service.

Disagree – not the current intentions of MKC transport dept

Section 3.6.2 Character Areas - Principles - no.6 Campbell Park: "Campbell Park is not only CMK's premier park but is indeed for the whole of CMK" - agreed and suggest you ADD "and, indeed, for all of MK". Numerous events attest to this latter point, like the IF Festival, summer activities and concerts, the annual fireworks and so on.

That's it for now. Hope it's useful and will be included in the reckoning.

Agree – will amend

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Very good work overall, thank you, and if you have any questions about my points do please get in touch.

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