1. Introduction

EXAM 113
CBC’s entire local plan seems to be predicated on several of its neighbouring local authority areas (including but not only Milton Keynes) continuing to meet the needs of large numbers of CBC residents for jobs, major destination shopping, commercial leisure/culture, and beautifully managed parks and lakes. I am entirely content that this expectation underpins CBC’s Local Plan (and that MK currently plays such a large part in the lives of many CBC residents).
I believe CBC’s Local Plan would be more transparent, and make more sense to non-specialist audience if this significant activity was stated explicitly and the consequences also made explicit within the Plan.
I therefore ask that, to make the document and process fair and transparent (rather than the document being dependent on facts that are largely unstated, this highly significant aspect of the situation should please be made explicit, with the ramifications (for both CBC and those neighbouring authorities) properly explained.
I believe that the proposed 24,000 new jobs within CB is most unlikely to meet the needs of 39,000 new households (0.6 jobs per household). Therefore these people will need to commute to or through neighbouring authorities, to jobs outside CBC’s boundaries. MK’s data shows that new-build areas generate about 1.5 “workers” (individuals wanting to be economically active in some way) per household. CBC’s Plan therefore depends on those new jobs being available in neighbouring Authority areas.
I therefore ask that this be made explicit within the CBC Local Plan, with numbers (which probably amount to 25,000 additional outbound commuters on every weekday).
I believe that the transport links between CBC and neighbouring authorities – particularly those places with the major economic attractors (employment, retail & commercial leisure/culture) – have not been properly assessed and are unlikely to have the capacity to meet the likely (but currently implicit) dramatic increase in numbers, let alone do so with a desirable modal split.
I therefore ask that numbers should be added to the plan, to show likely total additional outbound commuter numbers (arising from building houses without also building the associated
number of additional jobs locally), the split of this number between the main destinations (including MK), and the proposed road, train and cycle routes at CBC’s borough boundaries where these commuters will cross out of CB.
I ask that CBC shows the evidence that those neighbouring authorities are planning to create all these additional jobs for CBC residents.
I also ask that the Plan shows the arrangements CBC has made or is in negotiations about, with those key neighbouring authorities, to ensure CBC pays for the necessary highways (including cycle route) infrastructure outside its borders, and the necessary bus services, to get large numbers of CBC residents to their destinations (not merely getting them to CBC’s administrative boundaries).
These views are my personal opinion, as an individual member of Milton Keynes Council. They do not purport to represent the views of MK Council or of the MK Conservative Group of Councillors.
The area I represent, Broughton Ward, has a small section of boundary with Central Bedfordshire. My ward also has a number of major urban roads that will probably be affected by any significant increase in commuter travel from Central Bedfordshire into Milton Keynes. The impact of this increase in commuter numbers on weekdays (and shoppers at weekends) needs to be mitigated, and for this to happen, the likely numbers need to be made explicit in the body of the CBC document, rather than buried in the technical appendices.

I am submitting these objections on behalf of Harlington Parish Council. The Parish Council met 6th July to consider the issues raised by the additional documents and responses prepared.
The seriousness, depth and range of the Parish Council’s concerns do not lend themselves to the online consultation response format.

I note that the on-line system requires comments on the legality, soundness and co-operation for the Local Plan before seeking 100 word comments,

The parish council did not consider the issues of legality or whether the required level of cooperation had been achieved via these additional documents – however there were serious concerns expressed over the way that the Council’s own application for the M1 / A6 link was self-approved, and the response by Luton Borough Council to this approach must bring into question the cross-border co-operation.

The Parish Council does not consider the Local Plan in its current form – with the additional documents, to be sound. The documents are selective in the material changes, the housing needs are now considerably out of date and do not reflect likely scenarios regarding projected economic downturn, and the Plan has not demonstrated that reasonable alternatives have been considered nor the required exceptional circumstances met to justify proposals to develop areas of the green belt and the AONB.

The seriousness, depth and range of the Parish Council’s objections exceeded the limitations of the on-line system hence they are submitted in this format

My letter requesting the removal of Policy SE2: M1 Junction 13 – Marston Gate Expansion from the Central Bedfordshire Local Plan in order to protect the historic Greensand Ridge landscape and heritage assets, which are vital community assets, is attached. This development would have a devastating impact on the local area without economic justification. I would be grateful if you could ensure it reaches all relative parties and is considered in the decision-making process.

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You may be aware that Ridgmont has been objecting to Central Bedfordshire’s Local Plan, and Policy SE2, a huge allocation of warehousing, along the A507 towards the Ridgmont bypass turnoff. As a local resident I would also like to oppose these plans due to the following:-
• The 2005 Mid Bedfordshire Local Plan designated the land east of the railway as an “Area of Great Landscape Value”.
• CBC’s 2016 Landscape Character Assessment states the need to ‘safeguard open land at the foot of the ridge to provide for the setting of the ridge & the associated villages’.
• CBC’s 2017 Employment Site Assessment states that it is ‘important to retain development west of the railway and not allow spread into open countryside’.
• Historic England stated in January 2019 that the allocation would ‘affect the setting and significance of a number of designated heritage assets in the surrounding area’.
• The Local Plan Inspectors said in September 2019 that the allocation is ‘not justified due to the harm that would be caused to the landscape character of the area’.
LANDSCAPE IMPACT
• In 2005, the land was designated an “Area of Great Landscape Value” in the 2005 Mid Bedfordshire Local Plan.
• In 2007, Bedfordshire County Council’s Landscape Sensitivity Study concluded that ‘this area itself is very sensitive as the setting to the [Greensand] Ridge’.
• CBC’s 2016 Landscape Character Assessment recognises the need to ‘safeguard open land at the foot of the [Greensand] Ridge to provide the setting for the ridge and the associated villages’ and ‘restrict expansion of development associated with J13’.
• CBC’s 2017 Employment Site Assessment states that it is ‘important to retain development west of the railway line and not allow spread into open countryside’. The Assessment went on to score the site ‘red / amber’ for landscape character.
• The Inspectors charged with examining the Local Plan highlight in their September 2019 letter that ‘Policy SE2 is not justified due to the harm that would be caused to the landscape character of the area.’
• The Inspectors also stated ‘Given the size of buildings proposed, the visual impact of the allocation would not be mitigated by additional landscaping.’
HERITAGE IMPACT
The proposed allocation site at Marston Gate is in close proximity to a large number of heritage assets:
• Ringwork at The Round House, Brogborough a Scheduled Monument, All Saints Church, Segenhoe Church, Segenhoe Manor & Maltings Spinney, Ridgmont – 3 Grade II* Listed Structures & an Ancient Scheduled Monument
• There are four designated Conservation Areas within close proximity of the allocation site, at Ridgmont, Husborne Crawley, Husborne Crawley Church End and Aspley Guise.
• Historic England has concluded that the Marston Gate allocation would erode the rural character of the surrounding countryside that forms the vital setting to all these Conservation Areas, detracting from, the appreciation of this setting and ultimately harming the significance of the Conservation Areas.
• Historic England have stated that the Marston Gate allocation would ‘harm the significance’ of these assets on account of ‘visual impact as well as intensification of noise and artificial light’.
• Because of the harmful impact on the setting and historic significance of these designated heritage assets Historic England considers the ‘development would not achieve the NPPF’s overarching aim of promoting sustainable development’.
• Historic England also affirms that even if the scale of the development is reduced, they remain ‘unconvinced this would remove the impact on the conservation areas and in particular on Brogborough ringwork therefore find the proposed allocation is not justified nor consistent with national policy under paragraph 35 of the NPPF’.
• The council has since reached a Statement of Common Ground with Historic England in January 2020; and this document confirms that Historic England still, ‘maintains its objection in principle to the allocation of Marston Gate’.
OTHER REASONS TO REMOVE THE PROPOSED WAREHOUSE
M1 Junction 13 is defined as a ‘hotspot’.
Currently, Highways England and Central Bedfordshire have yet to produce modelling or potential solutions to address this hotspot.
Congestion A507 The Marston Gate allocation site would be accessed from the A507, a key east- west route across the district. The council already expects the A507 to experience ‘high levels of congestion’, however, no modelling or potential solutions have been devised as of yet to address them.
This is also an allocation, which the council does not need to make. In other words no need is expressed in planning policy for this allocation. It is therefore not required economically or for reasons or economic growth. The Councils Functional Economic Marketing Assessment (FEMA) and Local Employment Land Review (ELR) reports show there is currently an over supply of employment land and alternative brownfield sites are available.
CONCLUSION:
REMOVE POLICY SE2 - KEEP DEVELOPMENT WEST OF THE BLETCHLEY-BEDFORD RAILWAY LINE, PROTECT THE GREENSAND RIDGE AND PROTECT DESIGNATED HERITAGE ASSET

I would like to make the following comments, in support of my objection to the additional evidence which was prepared as part of the examination of the Central Bedfordshire Local Plan.

Fails to address material changes since the Local Plan was submitted in 2018.
The additional evidence is silent on changes the Plan should address including: the latest ONS projections of population growth which are much lower than they were in 2018; the adoption by Milton Keynes of its Local Plan which includes development east of the M1; and the Government’s decision to abandon the commitment to the East West Expressway which undermines the justification for development on the proposed scale in Marston Vale.
Not included all the reasonable alternative sites in their review.
NLP 190 in particular has capacity for 13,000 houses and is west of Cranfield and would be ideally placed to take advantage of the Government’s investment of £95m to build a new road bridge over the M1 and a mass public transport hub to access Milton Keynes as part of the now committed development of East Milton Keynes on this side of the M1.
Assessment of the relative merits of available sites does not stand up to the evidence.
Marston Vale is assessed as ‘strongly positive’ on sustainable transport. Building 5,000 houses would more than double the number of car journeys which begin and end here. ‘Sustainable’ transport means that strategic and local roads can cope with the increased traffic and moving people out of cars and onto public transport, cycling or walking. There is nothing in the additional evidence which would support that happening. There is insufficient weight given to the designation of this site as part of the Community Forest of Marston Vale which functions effectively as a valued environmental amenity and an important contribution to managing climate change.
Fails to achieve the optimum balance and distribution of development.
The Plan involves delivering 25% of the overall need for development from Marston Vale on the grounds that it is located along a strategic route despite the decision to abandon the East West Expressway and ignoring sites on the A6 – M1 – A5 strategic route which has planning permission and is committed to delivery. It also involves the permanent loss of AoNB, green belt and community forest land whilst ignoring opportunities to develop options for expanding existing towns in Area D with access to existing facilities.
Thank you for taking the time to consider my objection.

This is one of multiple submissions. The attachment letter covers all submissions. The documents are submitted against each consultation document as a separate submission SEE ATTACHMENTS
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