Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Object

Representation ID: 6673

Received: 14/09/2021

Respondent: Milton Keynes Borough Council

Thank you for consulting Milton Keynes Council on Bedford’s Draft Local Plan 2040. At this stage in your local plan process, our comments are limited to those matters which have potential to give rise to cross-boundary impacts upon Milton Keynes, namely the quantum and location of housing and employment growth and the corresponding impacts these have on transport and movement between Bedford and Milton Keynes.
Milton Keynes is a regional service centre as a destination for work and leisure for communities living in Bedford and further east along the A421 corridor (and planned EWR rail corridor). Having considered the Draft Plan document, and those documents made available alongside it, we do not raise any objection to the Draft Plan in relation to these matters. However, we have some concerns and have provided comments where it is considered necessary in the interests of Milton Keynes borough in order to inform further work and iterations of the plan. We look forward to working with Bedford as and when needed during this process as part of the Duty to Cooperate and in the interests of good planning.
Housing and Transport Strategy
It is encouraging to see that the Draft Plan (in addition to the Local Plan 2030) is seeking to meet the Local Housing Need (LHN) of 26,000 dwellings for the period to 2040 in full. As outlined below, there appears to be potential appropriate spatial options available for meeting LHN. However, there are some concerns with respect to certain options being consulted upon, and it is clear that further evidence is needed to justify any chosen spatial strategy for meeting housing needs.
Our main interest lies in how the different spatial options may affect car-based trips to Milton Keynes versus trips made by other modes (principally rail-based). The effects of different strategies on how people living beyond Milton Keynes may travel to Milton Keynes for work or leisure could have consequential impacts for Milton Keynes.
Planning and Placemaking
Civic, 1 Saxon Gate East, Central Milton Keynes, MK9 3EJ
01908 691691
www.milton-keynes.gov.uk/planning-and-building
It is noted that the Draft Plan includes four preferred strategy options (options 2a-d). These appear to be a hybridisation of the seven strategy scenarios set out within the Development Strategy Topic Paper June 2021 that accompanies the consultation, primarily by combining new settlement options with growth along with A421 and/or rail corridor-based and urban based growth. However, it is noted that the higher density urban-based option (1b) has not been reflected in the Draft Plan options. It is understandable that seeking to meet the LHN in full from urban sites may result in significant impacts to existing communities. However, there may still be opportunities for higher density on an area by area, or site by site, basis. This would help to reduce the amount of housing that needs to be met through a more dispersed strategy that is likely to result in greater car-borne trips. This is particularly the concern with options 2b and 2d which have significant amounts of growth (1500 dwellings) that are likely to rely on private vehicles for greater than local trips to regional service centres, including Milton Keynes.
The Bedford Borough Transport Model Local Plan Assessment (BBTM) reports provide a high-level appraisal of the impacts of four development scenarios. These BBTM scenarios do not all correlate with the four preferred options set out in the Draft Plan or the seven scenarios set out in the Development Strategy Topic Paper June 2021. It appears that only one of the four options has been assessed (option 2a). It is of some concern that the cumulative impacts of Draft Plan options 2b and 2d, which blend new settlements to the east of Bedford with A421 corridor and rail corridor-based growth have not been assessed in the BBTM. The BBTM therefore cannot be seen as a direct assessment of the Draft Plan options, although some results and conclusions could be inferred from the BBTM scenarios and applied to the Draft Plan options at a more granular level. For clarity, our comments are based on the understanding that:
• The Grey BBTM scenario equates to the proportionately-based ‘dispersed growth’ option put forward during the Issues and Options consultation in 2020. This appears to have been discarded as an option in its own right as no ‘dispersed’ option is described in either the Development Strategy Topic Paper or in the Draft Plan being consulted upon.
• The Pink Yellow and Brown BBTM scenario most closely resembles Option 2a set out in the Draft Plan and Development Strategy Topic Paper, with most growth focussed on the EWR corridor and lower but still significant levels of growth along the A421 corridor and within or adjoining the Bedford urban area.
• The Red and Orange BBTM scenario (consisting of four new settlements and growth in/adjoining the Bedford urban area)) seems to equate to Option 3a set out in the Development Strategy Topic Paper, however it does not match any of the four preferred scenarios set out in the Draft Plan itself.
• The Brown BBTM scenario appears to resemble Option 1b, higher densities of growth within and adjoining Bedford. However, the BBTM scenario also appears to include growth at St Neots. If so, this scenario does not correlate with any of the scenarios in the Draft Plan or Development Strategy Topic Paper.
The BBTM scenarios are assessed against a range of metrics. It is clear from the assessment that options which have a rail-based and/or urban-based focus perform best across the metrics overall, but in particular traffic growth. This is understandable and to be expected, as a greater proportion of trips generated by growth in those locations will be capable of using new rail services provided by EWR. Whilst new rail stations have been represented in the model, it is not clear how the new services themselves have been represented and whether this is a factor in how the model assign trips and to what extent this is limiting traffic growth. It is noted there are some differences in the number of jobs included in each of the BBTM scenarios, but it is not clear to what extent the quantum is a factor in the results, as opposed to where they are located.
Nonetheless, the indications from the BBTM reports indicate that a rail and urban-centric strategy for housing (more than the 1500 dwellings in the Bedford urban area indicated in the Draft Plan) would mitigate against traffic growth and support a more sustainable mode share and modal shift. Such a strategy would likely result in a lower proportion of car-borne trips to Milton Keynes and a greater proportion of rail travel into Milton Keyes than other strategies with greater growth along the A421 corridor or in new settlements. This creates greater opportunity for sustainable first/last mile connectivity within Bedford but also at destinations like Milton Keynes, visited for work and leisure by residents and businesses within Bedford. Given the possible implications for Milton Keynes, we consider a rail and urban-centric strategy would be preferable in this regard.

Object

Representation ID: 6674

Received: 14/09/2021

Respondent: Milton Keynes Borough Council

Employment strategy
It is understood that the Employment Land Study identifies a need for an additional 53 hectares of land for B8 warehousing and logistics for the period through to 2040. However, the consultation documents explain that the Draft Plan would not seek to make any further provision for B8 warehousing and logistics over and above existing commitments and allocations. The focus of the Draft Plan is creating jobs within other sectors, which is understandable. However, the lack of provision for B8 is likely to be problematic.
The Draft Plan relies upon existing commitments and new allocations now made within the Central Beds Local Plan 2035 to accommodate this demand. It is stated that Central Beds are content with this approach as their plan’s allocations are partly intended to accommodate such ‘foot loose’ demand. However, it is noted that their plan only covers the period to 2035 and that Central Beds will be embarking upon an imminent review and production of a new Local Plan.
Reference is also made within the consultation documents to the fact that the Milton Keynes East allocation within Plan:MK makes additional provision for B8 use for the period through to 2031 and beyond. Whilst this is correct, the precise quantum of B8 land to come forward within Milton Keynes East is still to be determined and, in any event, would be assigned to meeting Milton Keynes’ own demand for such land uses over that period, rather than seeking to meet demands arising beyond Milton Keynes for the period to 2040. It is not clear if that is the intention of the Draft Plan, but if so then this would need to be agreed on a cross-boundary basis as part of the Duty to Cooperate following further technical work and discussion as to how such demands could be met through a ‘larger than local’ strategy for employment land, but in particular land for B8 warehousing and logistics.
There may be merit in pursuing a ‘larger than local’ strategy for meeting B8 demand taking in not just Bedford and Milton Keynes, but also Central Beds and adjacent authorities along the M1 corridor. Such a strategy would be able to take account of how retail and associated warehousing/logistics trends may be shifting as a result of the pandemic and new international trading arrangements for England and the UK, both of which will have effects for businesses within the M1/A421 and A1 transport corridors. It is suggested that this could be raised as a matter for SEMLEP to lead on given the geography it covers.
Notwithstanding the above, based on the Draft Plan as it exists today, we are concerned that a lack of provision to meet the demand for B8 warehousing and logistics land within Bedford through to 2040, with a reliance on provision elsewhere, would ultimately undermine the Local Plan 2040 without the agreement of neighbouring authorities via the Duty to Cooperate. The lack of provision in Bedford over this period is likely to create additional demand for land in neighbouring authorities connected via strategic transport corridors for B8 warehousing and logistics, which may not be capable of being met or would be contrary to their own Economic Strategies.