03/00866/FUL COMPREHENSIVE DEVELOPMENT COMPRISING

03/00866/FUL COMPREHENSIVE DEVELOPMENT COMPRISING DEMOLITION OF EXISTING BUILDINGS AND ERECTION OF (1) MULTI-PURPOSE SPORTS AND SPECTATOR EVENTS STADIUM/ARENA (INCLUDING COMMUNITY HUB AND CONFERENCE FACILITIES); (2) RETAIL SUPERCENTRE; (3) RETAIL NON-FOOD (DIY) STORE; (4) PETROL FILLING STATION; (5) MEDIA VILLAGE (B1 SPACE, HOTEL, HEALTH AND FITNESS CENTRE, AND RESTAURANTS); AND (6) TWO DRIVE THROUGH RESTAURANTS; TOGETHER WITH PARKING, PEDESTRIAN/CYCLE/MOTOR VEHICLE CIRCULATION, ROAD JUNCTIONS AND EXTENSIVE LANDSCAPING. FULL PERMISSION IS SOUGHT FOR ITEMS (1) TO (4) AND OUTLINE PERMISSION FOR ITEMS (5) AND (6).

At: Land West of V7 Saxon Street (Denbigh North), Saxon Street, Bletchley, Milton Keynes For: Milton Keynes Stadium Consortium

1.0 INTRODUCTION 1.1 The application site is situated at Denbigh North. The site boundaries

are formed by existing dual carriageway and distributor roads: A5(T) to the north, Grafton Street (V6)/Bletcham Way (H10) to the west and south, and Saxon Street (V7) to the east.

1.2 The site is approximately 29.5ha. The north western part is allocated in

the adopted Local Plan for employment development, and currently lies undeveloped. The south eastern part is occupied by several large buildings in commercial leisure use (indoor go-karting, nightclub, children’s activity centre, etc). The rest is occupied by playing fields, with a single club house/pavilion and associated car parking. There is a single detached house (now vacant) close to the leisure buildings at the southern end of the site. The leisure buildings, the club house/pavilion and its car parking, and the house are accessed from Goslington, a minor road that links the V6 and V7.

1.3 Much of the site comprises mown grassed areas divided by hedges

and paths, with small pockets of scrub and tree groups. Most of this area is laid to sports pitches, although smaller areas comprise derelict pasture and scrub. The site also has a wet area with three small ponds, a wet ditch and scrub vegetation towards the south western boundary, with undulating ground conditions. East of this is a pavilion, at present occupied by the Irish Centre, and car parking, which serves to support existing sporting activity on the site.

L:\Development-Control\03-0866-FUL.doc

1.4 The site generally slopes from south to north, with Denbigh Roundabout being the lowest point and land adjacent to the A5 the highest.

2.0 PLANNING HISTORY 2.1 The site has the following planning history: Table 1: Planning history of Denbigh North Date Application

Number Description Decision Date of Decision

1953 BL/145/53 UDC industrial development Withdrawn 09/02/55

1954 BL/57/54 Industrial development: no

decision

Not

Proceeded

with

-

1955 BL/110/55 Industrial development Limited

approval

13/12/55

1955 BL/112/55 Industrial development Approved 25/10/56

1957 BL/30/57 Advertisement Approved 25/06/57

1960 BL/69/60 2 Nissen huts Approved 20/09/60

1964 BL/2/64 Shed for sailing dinghies Approved 16/01/64

1964 BL/181/64 Industrial development of land Refused 10/12/64

1968 BL/40/68 Filling station car showroom Refused 02/04/68

1971 BL/220/71 OH and VG Cables Withdrawn -

1972 BL/410/72 Denbigh Sports Ground Withdrawn -

1973 BL/264/73 Advertisement Withdrawn 10/05/74

1973 BL/433/73 Terrapin building Approved 19/02/74

1974 BL/3/74 Terrapin building Approved 10/05/74

1981 MK/566/81ADV Four illuminated logo signs Approved 28/05/81

1982 MK/750/82ADV Advertisement board Approved 09/08/82

1982 MK/767/82 Extension to clubhouse and

erection of floodlight pylons

Approved 17/02/83

1983 MK/953/83 Petrol filling station including

pump islands, canopy

underground storage tank and

vehicular access.

Refused 17/11/83

1985 MK/157/85ADV Illuminated lettering and signs Approved 04/04/1985

1985 MK/491/85ADV Erection of three flag poles Approved 30/05/85

1986 MK/187/86 Rear extension to factory Approved 13/03/86

c.1980s - Mercury Motor Inn LPA record missing

1990 MK/403/90 Change of use from indoor Approved 28/06/90


bowls to indoor go karting

1990 MK/529/90ADV Erection of two illuminated

letter signs and two logos

Approved 26/06/90

1990 MK/598/90ADV Erection of non illuminated

directional hoarding signs

Approved 18/09/90

1991 MK/1376/91 Change of use of unit within

indoor go karting building for

retail use

Approved 12/02/92

1992 MK/16/92ADV Erection of internally

illuminated fascia signs

Approved 11/02/92

1992 MK/1062/92ADV Erection of two internally

illuminated box signs and two

externally illuminated flag

poles

Approved 27/11/92

1992 MK/1221/92ADV Internally illuminated free

standing gantry sign

Withdrawn 21/05/93

1993 MK/64/93ADV Erection of internally

illuminated fascia signs

Approved 01/03/93

1995 MK/529/95 Change of use from

landscaping to surface area

for use for additional car

parking and outdoor go

karting track

Refused 27/07/95

1996 MK/233/96 Construction of fast food

restaurant on parking spaces

(outline)

Approved 28/08/96

1997 97/943/MK Change of use from indoor

karting to use class D2,

assembly and leisure use to

allow use as an indoor

football centre

Approved 08/10/97

1997 97/1071/MK Externally illuminated

elevation signs

Approved 04/11/97

1997 97/1168/MK Change of use to allow indoor

karting

Approved 16/12/97

2000 00/2004/FUL Indoor go kart track Approved 24/01/1

2002 02/479/FUL Change of use from tenpin

bowling allay (use class D2)

Refused 04/11/02


to a craft retail centre (use

class A1)

Note: The applications listed above are those that were determined by the Milton Keynes Council only

While not relating to this site, 03/01880/FUL was submitted on 24.10.2003 BY Tesco Stores Limited, for a redevelopment of the current Tesco/Matalan/Carpetright stores on Watling Street, Bletchley to increase the gross floorspace 6,584 sq.m. to 17,480 sq.m. in total, including a new Tesco food store of 10,221 sq.m. This application is undetermined. . 3.0 CURRENT APPLICATION 3.1 The proposals, which have been submitted in the form of a hybrid (part

full, part outline) application, involve the comprehensive development of the site. They comprise six elements:

1) Multi-purpose sports and spectator events stadium and

arena (including community hub and conference facilities). 2) Asda-Walmart retail supercentre. 3) Retail non-food store. 4) Petrol filling station. 5) ‘Media village’ (B1 space, hotel, health and fitness centre,

restaurants). 6) Two drive-thru restaurants.

In addition, there is parking, access roadways and pedestrian/cyclist surfaces, and extensive landscaping.

3.2 Full permission is sought for items (1) to (4), and outline permission

for items (5) and (6). Items (2) to (6) are put forward as the ‘enabling development’, intended to provide the funds required to develop the stadium/arena.

3.3 The Stadium would have capacity for 30,000 spectators for sporting

events and 35,000 for spectator events, though it has been designed such that it would be capable of expansion to 42,000 for sporting events and 47,000 for spectator events in the future. Such expansion would need to be the subject of a further planning application, and is not for determination now. The seating areas are all roofed, but the pitch (which would be a permanent installation) would be open. The stadium is approximately oval in overall plan, with the auditorium being closer to rectangular, with curved corners.

3.4 It is intended that the Stadium would become the home of

Wimbledon Football Club, who are now operating temporarily from the National Hockey Stadium. The business plan and the deal with the National Hockey Foundation which has enabled the Club to


move to Milton Keynes is understood to be predicated upon the Club being able to take up residency at the Stadium before the start of the 2005/2006 season.

3.5 In addition to the main auditorium, the Stadium would incorporate a

performance arena: a self-contained, roofed space, located at the southern end of the complex. It would have the capacity to seat 6,500 people or up to 5,000 for sports events.

3.6 The Stadium would also house a ‘community hub’, comprising a

children’s activity centre and learning centre. Conference facilities for 500 diners are also provided in the Stadium building along with a retail unit of approximately 420 square metres (gross floor area).

3.7 The stadium building has been designed as an ‘open’ and

‘permeable’ structure allowing views out of the building to the surrounding areas and glimpses in and through the building. In detail, within the stadium/arena the following facilities are proposed:

• 30,000 seat total capacity in football, rugby union and rugby

league configuration, and 35,000 capacity in major concert mode;

• Stages which can be laid out in various configurations, such as end stage for concerts and centre stage for boxing events;

• Scoreboards, Video screens; • 68 suites; • Changing/Dressing/Locker facilities for various modes to be

agreed; • General support facilities, including administrative offices, goods

delivery, toilet accommodation, storage facilities, plant rooms, maintenance rooms, medical/first aid suites, control and security rooms;

• Catering facilities including hospitality levels, dine and view restaurants, concourses and offices;

• Press and media facilities – in agreement with latest codes (eg. FIFA & UEFA guide), Wimbledon Football Club administration offices and arena/stadium managers offices

• Ticket offices • Merchandise shop • Community hub, including a learning centre with teacher study

support and children’s activity centre • Facilities for disabled access.

3.8 The Asda-Walmart Supercentre would have a floorspace of

approximately 13,990 square metres gross floor area (gfa). Modelled on the store that enabled the Commonwealth Games stadium in Eastlands, Manchester (now the home of Manchester City F C), it is a rectangular building of contemporary appearance,


intended to be used for the sale of both food and non-food goods. The petrol filling station (located close to Bletcham Way) would be operated by the supercentre operator.

3.9 The non-food store (designed primarily with a view to occupation by a DIY

retailer) would have a floor area of 10,410 square metres (gfa) and would also have a garden centre of 2,787 square metres (gfa) and a bulky materials store of 1,858 square metres (gfa).

3.10 The ‘media village’ comprises business space (Class B1: office/light

industry/research & development) of 24,850 square metres (gfa), together with a 200 bedroom hotel, a health and fitness facility of 2,485 square metres (gfa) and restaurants totalling 1,495 square metres (gfa). This part of the development is submitted in outline, but illustrative drawings indicate a series of 3 to 4 storey buildings of rectangular or L-shaped plan. The built form would include a series of different floor levels to respond to the existing contours and proposed infrastructure. It is envisaged that the Media Village and associated development would be a high quality development providing a suitable gateway statement to the northwest corner of the site.

3.11 Two freestanding drive through restaurants of approximately 250

and 350 square metres (gfa) also form part of the proposal. They would be located close to Bletcham Way.

3.12 It is proposed that the whole development other than the media

village and drive through restaurants would be developed as a single main phase.

3.13 The proposed stadium/arena, retail supercentre and non-food retail

unit are sited in a staggered line running approximately north-west to south-east. All their main entrances face a pedestrian spine that runs from a crossing of Bletcham Way, parallel with and close to the frontage of the Asda-Walmart Supercentre, directly towards the entrance to the arena/community hub, then merges into the pedestrian circulation area around the stadium.

3.14 A new signalised junction is proposed on Grafton Street to serve the

Stadium/Arena and Media Village which links via an internal “loop” road to a “left in/left out” junction on to Saxon Street. A signalised junction would replace the existing Granby roundabout on Bletcham Way to provide access to the retail supercentre and link to a “left in/left out” junction on Saxon Street by means of an internal loop road. Managed gated access points are provided between these two internal loop roads to give flexibility and assist traffic management at peak times. The principal vehicular access to the non-food store would be via a new traffic signal controlled junction on Bletcham Way between Granby Roundabout and Denbigh Roundabout. The provision of a traffic signalised junction at this location, with pedestrian/cycle phases incorporated into the phasing


of the signals, would facilitate pedestrian and cycle crossing of Bletcham Way to complement the existing subway facility.

3.15 Provision has been made for a further vehicle access from

Bletcham Way, which would provide access/egress for buses and taxis.

3.16 A number of secondary vehicle accesses into the site are proposed

from Saxon Street. These include:

• A left in/left out junction with signalised right turn in from Saxon Street for buses only, providing access to an area of land adjacent to the stadium car parking area which is identified as the coach parking area for stadium events and has the potential to operate as a park and ride facility at other times.

• A left-in/left-out junction between the stadium and the Asda-Walmart Supercentre providing access to an employee car park and entry for buses and taxis. This junction provides the opportunity for managed access/egress from both the stadium and Asda-Walmart Supercentre car park on major event occasions, and provides an emergency access for the site generally.

• A left-in/left-out junction providing access to the Asda-Walmart Supercentre and non-food store service areas and also, potentially, by means of signalised ‘bus gate’, providing a right turn entry into the site for buses only.

3.17 The existing public highway across the site (Goslington) would need

to be closed. 3.18 Four existing Redway connections into the site would be retained as

part of this proposal. These Redways would connect to a hierarchy of footpaths linking all the main entrances and provide pedestrian related spaces around the stadium/arena. The central axial footpath, to be known as ‘The Approach’, is an important structural element and provides, via a new at-grade crossing, an important link to the rest of Bletchley. Redways are red macamite to normal standards. A range of blockwork types and colours will be selected for other footpaths to indicate hierarchy and places of emphasis.

3.19 A total of 1944 car parking spaces, including 163 spaces for special

needs, are located adjacent to the stadium. There would also be 87 coach parking spaces. A further 820 car parking spaces, including 55 spaces for special needs, are to be proposed adjacent to the Asda-Walmart Supercentre and a further 535 (28 spaces for special needs) adjacent to the non-food retail store. Adjacent to the media village to serve the offices and hotel would be a further 615 spaces, including 36 spaces for special needs. It is assumed that there would be a degree of sharing between the various uses. The restaurants would together have 50 spaces.


3.20 Initially it was proposed to remove all of the existing landscape and

other semi-natural features presently on the site to accommodate the new buildings, roads and parking areas. A new landscaping scheme including planting and water areas would be implemented. Following negotiations it is now proposed to retain a number of landscape features in the proposed scheme, including some existing hedgerows, trees and wetland areas.

3.21 An Environmental Statement was submitted with the application.

Additional supporting documents include a Design Statement, an Enabling Development Report and a report addressing the community impact of professional football in Milton Keynes. This was supplemented by the submission of further information on 17th and 30th September and 11th November 2003.

3.22 The applicant has submitted a draft S106 agreement in support of

the application which covers (amongst other things) provision of off-site transportation improvements; facilitation of regenerative projects in Bletchley Town Centre; and the provision of new recreation facilities to compensate for those displaced from the site.

3.23 Discussions on the content of the draft Section 106 agreement,

including financial contributions towards the provision of relevant infrastructure and facilities off-site, have been taking place since the application was submitted and will be referred to later in this report.

4.1 MAIN ISSUES 4.2 Whether or not the development would accord with national planning

policy guidance PPG6 (Town Centres and Retail Developments), PPG13 (Transport) and PPG17 (Sport and Recreation), the Adopted Milton Keynes Local Plan and the Milton Keynes Local Plan Second Deposit Version, and the relative weight which should be attached to each.

4.3 Whether or not the development would comply with the site specific

policy L13 in the Milton Keynes Local Plan (Second Deposit Version), and in particular:

(i) Whether it would produce significant social and economic

benefits to Bletchley and the remainder of the Borough of Milton Keynes.

(ii) Whether or not it would significantly undermine the vitality and viability of Bletchley Town Centre.

(iii) Whether or not the proposed replacement recreational facilities are adequate to replace those lost by the site’s development.

(iv) Whether of not the transport arrangements are satisfactory both in terms of safety and convenience.


4.4 The effect of the development on environmental sustainability both in terms of built development, transport and ecological effects.

4.5 Whether or not the development would make a positive contribution

to the visual quality of the locality. 5.0 PLANNING POLICIES

The following policies are of most relevance to the consideration of the planning application:

National Policy: PPG1 General Policy and Principles PPG6 Town Centres and Retail Developments

Parliamentary Statement dated 10.4.2003

PPG13 Transport

PPG17 Sport and Recreation

Buckinghamshire County Structure Plan 1991 – 2011 Adopted 1996 The following Policies are relevant to this application:

Economy and Employment E1 Major Employment areas E2 Other Significant Employment areas

Transport TR1A Traffic in Towns and Villages TR1B Targets TR2 Milton Keynes TR3 Urban Highway Schemes TR4 Parking in Towns TR6 Ameliorating the Impact of New Roads TR8B The County Council’s objectives for Highway Investment TR13 Bus Services TR14 County Rail Network TR15 Re-Opening/Restoration of Rail Lines for Passenger and Freight

services TR16 Integration of Bus and Rail Services TR17 Pedestrian Routes and Bridleways TR18 Cycling TR19 Strategic Cycle Routes TR20 Road Safety

Shopping S1 General Requirements S2 Retail Hierarchy S3 Central Milton Keynes


S5 Out of Centre Shopping Developments

Town Centres TC1 Strengthening the Vitality and Viability of Town Centres TC2 Major Development Proposal in Town Centres TC3 Major Non-Retailing Development Outside Town Centres

Landscape LS1 Protection and Enhancement of the Landscape

Nature NC1 Protection of the Key Sites NC2 Minimisation of Development Impacts NC3 Management and Enhancement

Sports and Recreation SR1 General Policy SR3 Other Sports and Recreation SR4 Dual use of County Council Facilities

Energy EN1 Energy Conservation EN2 Renewable Energy Water W1 Protection of water Resources W2 Protection of the Water Environment W6 Surface Water Run-Off Pollution P1 The Precautionary Principle P2 Noise Sensitive Developments

Infrastructure IN1 Balancing New Development with Necessary Infrastructure

Environment Assessment EA1 Provision of Information About the Environmental Effects of

Development.

Adopted Borough of Milton Keynes Local Plan (1995)

The following policies are relevant to various degrees:

Policy LR2 Protection of Existing Recreation and Open Space, and

Recreation and Leisure Facilities

Policy LR4 Recreation and Open Space Standards


Policy LR5 Proposed New Outdoor Facilities

Policy LR8 Informal Countryside Recreation

Policy LR17 Visitor Accommodation

Policy LR18 Sites for Hotels in Milton Keynes City

Policy EM1 Milton Keynes City: Protection of Employment Land

Policy EM2 Milton Keynes City: Sites Allocated for Employment

Policy DC1 Impact of Development Proposal on Locality

Policy DC2 Impact of Development Proposal on Site

Policy DC3 Scale and Character of Development

Policy DC5 Landscaping

Policy AM2 Primary Distributors

Policy AM3 District Distributors

Policy AM8 Highway Reservations

Policy AM9 Design Standards for New Roads/Accesses

Policy AM10 Off-site Highways Works

Policy AM11 Roadside Services

Policy AM12 Parking Provision

Policy AM18 Public Transport Provision and New Development

Policy SH2 Bletchley and Wolverton District Centres

Policy SH8 Retail Warehousing

Policy SH10 Major Retail Proposals on Non-Allocated Sites

Policy DC22 Sites of Importance for Nature Conservation

Milton Keynes Local Plan, Second Deposit Version (2002)

Policy L13 Multi-purpose Sports and Spectator Events Stadium is of

most obvious relevance. However, the following policies are also

relevant to varying degrees:

Policy TC14 Bletchley town centre




Policy L2 Protection of Public Open Space and Existing Facilities

Policy L4 Sites Allocated for New Facilities


Policy L9 Arts, Entertainment, Tourism and Commercial Leisure

Facilities

Policy D1 Impact of Development Proposals on Locality

Policy D2A Design of New Development

Policy D2 Design of Buildings (New Development)

Policy D4 Sustainable Construction

Policy T1 The Transport User Hierarchy

Policy T2 Access for those with Impaired Mobility

Policy T3 Pedestrians and Cyclists

Policy T4 Pedestrian and Cyclists

Policy T5 Public Transport

Policy T6 Transport Interchanges

Policy T7 Park and Ride

Policy T9 The Road Hierarchy

Policy T10 Traffic

Policy T11 Transport Assessment and Travel Plans

Policy T14 Roadside Services

Policy T15 Parking Provision

Policy R1 Major Retail Proposals

Policy R2 Retail Warehousing

Policy R4 Forecourt Shops at Petrol Filling Stations

Policy NE1 Nature Conservation Sites

Policy NE3 Nature Conservation Enhancement

Policy NE4 Conserving and Enhancing Landscape Character

Policy HE1 Protection of Archaeological Sites

Policy S5 Central Milton Keynes

Policy S6 Bletchley

Policy CC5 Office Development

Policy PO1 Planning Obligations - General Policies

Policy PO2 Planning Obligations - General policies


6.0 CONSULTATIONS 6.1. Highways Agency confirms that following consultations with the

applicant’s traffic consultants in June, it had been hoped that the Highways Agency would be in receipt of a supplementary Transport Assessment addressing the concerns of the Highways Agency. However this is not the case and as such a form TR110(2) is submitted by the Highways Agency which includes a holding direction valid until 7th February 2004. This directs that the planning authority shall not grant permission for this application for the time period given. The reason for the direction is that there is insufficient information presently available to the Secretary of State to determine whether the proposed development would generate traffic on the trunk road to an extent that would be incompatible with the use of the trunk road as part of the national system of routes for through traffic in accordance with Section 10(2) of the Highways Act 1980, and with safety of traffic on the trunk road.

6.2. Environment Agency wish to make the following advisory comments:

Drainage/Conservation: Any culverting or works affecting the flow of a watercourse requires the prior written consent of the Environment Agency under the terms of the Land Drainage Act 1991/Water Resources Act 1991. The Agency seeks to avoid culverting, and its consent will not normally be granted except as a means of access. Suitable mitigation for the loss of habitat must be considered. The mitigation suggested in this application is to create two new ponds, but no detailed information is provided on design of these ponds or the surrounding terrestrial habitat to enable a judgement to be made on whether or not the habitat creation will be successful. Although the Environmental Statement provided with the application states that an Ecological Management Plan will be produced prior to construction, it would have been desirable to have more information at the planning stage in case for example there is not enough terrestial habitat in the vicinity of the ponds but planning permission has already been granted.

It is very disappointing and concerning that mitigatory habitat for amphibians will only be created and the amphibians moved to it if it fits with the construction schedule as stated in the Environmental Statement. No explanation is given as to what will happen to the smooth newts, common frogs and common toads that currently inhabit the existing ponds if the construction schedule doesn’t allow creation of new habitat first. No consideration is given to the fishery at Mount Farm Lake in the environmental statement.

On site surface water attenuation will be required. The balancing volumes stated in the Environmental Statement, do not make any allowance for dilapidation. The balancing volumes will need to be revised, however, this may be dealt with at the detailed design stage. All drainage systems must be adopted or demonstrate their maintenance will be formally established in perpetuity with the development.


Pollution Prevention: Surface water drainage from under the canopy forecourt areas and refuelling /delivery points, of the petrol filling station must pass through a full retention Class 1 oil/petrol separator. Full details of the underground storage tanks/pipework should be submitted. Any vehicle wash water including steam-cleaning effluent should be contained in a sealed vessel and either recirulated or disposed of off-site. Any facilities, above ground, for storage of oils, fuels or chemicals shall be sited on impervious bases and surrounded by impervious bund walls. Only clean, uncontaminated surface water, should be discharged to any soakaway, watercourse or surface water sewer. A second letter from the agency, written after receipt of further information supplied by the applicant in September, reiterated the need to retain the wetland areas and adjacent corridor habitats or at least to create a new habitat on site and transfer the resident amphibians before destroying the existing ponds. Any further comments from the agency in response to the further information submitted in November will be reported separately.

6.3. Buckingham and River Ouzel Internal Drainage Board confirm that they

have no objections to make on the application. 6.4 English Nature has the following comments:

Wildlife Sites and Corridors: Concern is expressed about the potential effects of the development on the Mount Farm Lake SINC site. Environmental Statement recognises that run-off from the Stadium site may reach the lake via the stream. This could impact on both water quality and on water level at the Mount Farm Lake wildlife site, both of which could be damaging to the SINC. There is potential for pollution and disturbance during construction through dust, noise, and accidental spillages on site. It is therefore strongly recommended that appropriate mitigation is employed to remove or minimise these effects. Construction noise could be particularly disturbing to breeding birds, although it is accepted that background noise level already includes traffic from Saxon Street.

Concern is also expressed on the fact that the development will result in the loss of wildlife corridors within the site boundary, which are protected within the Local Plan. In a heavily urbanized area such as Milton Keynes they are important routes for movement and dispersal of species, and may function as valuable foraging areas. English Nature would like to see the wildlife corridor incorporated into the masterplan, or provision of a suitable alternative to provide the same or similar function.

Protected Species: No objection to the conclusions reached on protected species. The buildings will need to be rechecked for bats prior to demolition. It would be preferable to retain existing ponds, scrub and


hedgerow habitat within the site, although the site plans suggest that this would not be feasible. UK BAP Species: Environmental Statement states that there are a small numbers of UK BAP bird species likely to be breeding on the site, which are fairly widespread and therefore any loss of breeding habitat is of only local significance. However it is incremental loss of breeding habitat, which threatens these birds. If habitat cannot be retained within the site masterplan, suitable compensatory habitat should be created elsewhere. Other Matters: On a development of this scale, it would be nice to see greater emphasis on the opportunities for biodiversity gain, both through management of existing habitat and new planting. It is noted that some planting of native species is proposed, but there needs to an agreement to secure appropriate management of these areas in the longer term. The intention to compensate for the wet woodland, which would be lost, is welcomed provided that this compensatory habitat will be of a similar type, and of similar or greater value to that lost. With the regards to the bat survey report, the supervised felling of certain trees by a bat ecologist is welcomed and that should bats discovered during felling, the supervising ecologist should advise on appropriate action. Again English nature have been consulted on the most recent amendments and submission of additional information and any response will be reported separately.

6.5 The Countryside Agency confirms no formal representations to make on

this application. 6.6 Federation of Stadium Communities (FSC) comments that as a general

principle, the FSC believes that those living and working in the shadow of established or propose stadia should be an integral part of the planning process, as well as being involved with the monitoring of the effects of the stadium operation. To this end, FSC would encourage all those involved to note the recent recommendations of the Greater London Authority, in relation to stadia in the capital, which have applicability nationwide. Their ‘Away From Home: Scrutiny of London’s Football Stadiums’ report outlines a number of ways in which professional sports clubs should engage with local communities, in order to fulfil their duties as good neighbours, minimising event day disruption, and encouraging the use of stadia as community resources. The report:

Recognises that football stadium operations do bring disbenefits to areas, and that clubs should seek to minimise the impact on the ‘local community’s streets’. It is also stated that clubs have an obligation to fulfil their role within the community, recommends that in depth research into the ‘dynamic between clubs and their communities’. Recommends the setting up of residents liaison committees to discuss and address event day problems.


Recognises the frustration of clubs who wish to redevelop their ground, or build new ones, but disagrees that they should be treated more favourably when it comes to assessing their planning application.

On the application itself the FSC comments that: the stadium is only 400m west of Granby Court, and residents concerns are understandable. Has consideration been given to the Granby Shia Mosque? The proposed CPZ referred to as ‘match day’ should be in operation on ‘event’ days and that the CPZ should be wide enough to acknowledge the rippling negative traffic impact that stadia operations create, and must be vigorously enforced. There is little compelling empirical evidence to support the theory that stadia regenerate areas. The type of employment created by such developments is often unskilled, low paid and not filled by local people. The examples of economic gain to Bletchley are examples of the often vague and unsubstantiated nature of claims made about the positive economic impacts that stadia have on localities, in order to support applications.

The use of park and ride is encouraged provided that the facility will not create disturbance to residents in other areas. The use of the stadium for other events is noted and as such attention is drawn to the GLA report which flags up residents’ negative views on shared use of stadia. Main stadium car park access via a new roundabout reflects a significant rise in traffic volume in the Granby Court area. The main access to the proposed Asda Wal-Mart is via Granby roundabout, with the cumulative traffic on match days having the potential to impact negatively on nearby residents. Vehicular access to non-food retail close to the Granby roundabout with proposed developments’ cumulative traffic effect having a potential to impact on nearby residents. There is an assumption that landowners close to the site will provide parking spaces, which is discomforting, and the FSC would suggest that sites are identified and agreements formalised before permission is granted. It is essential that there is regular monitoring of residential areas to deter fans from parking illegally to avoid paying on site parking fees. The decision to assess off site parking once stadium is operational is surprising as this means that stadium users travelling to the venue by car are not being encouraged to park responsibly from the outset. Identification of such car parking sites prior to commencement of stadium operation is vital if pedestrian movement from such car parks to the stadium is to avoid impacting upon the amenity of local residents. The ‘lay up’ spots for coaches dropping off concert goers are not identified creating the potential for drivers to seek spaces which may impact upon local residents.

Mention is made of mitigation for disturbance to habitat etc. In terms of replacement pitches the FSC urge that replacement facilities created are affordable and accessible to the local community. Concerts held are likely to finish later than football matches and as


such will adequate marshalling and public transport provision be made to cope. In a second letter, written after the circulation by the applicant for further information, the Federation questions the comparison in the traffic study with Southampton F C’s new stadium. They also make the point that formal agreements should be made with owners of adjacent sites where parking is likely to take place before the site becomes operational, to allow stadium users to plan their travel and parking in advance, and enable the prediction of pedestrian routes taken by stadium users once they have left their vehicles.

6.7 Sport England welcomes the principle of this application and the

related direct and indirect benefits to sport that it will bring to the local community. Nevertheless, as the site is on playing field land at Denbigh North Sports Ground Sport England has considered the application in light of its Playing Fields Policy. This policy is to ensure that there is an adequate supply of quality pitches to satisfy the current and estimated future demand for pitch sports within the area. Sport England has had close involvement with the Council in the development of the emerging Milton Keynes Playing Pitch Strategy which indicates an overprovision of senior playing pitches and an under provision of both junior and mini pitches within the area. Given this point the strategy suggests that the loss of the 6 senior pitches at the site would not have a significant impact. Nevertheless, the loss of an extensive area of playing field land, which Sport England believes to be of above average quality for Milton Keynes, does represent a significant impact on the ability of the area to adequately cater for future demand both in terms of the quality and quantity of provision. In recognising this, Sport England is pleased that both the strategy and the supporting information to this planning application propose that adequate mitigation should be provided should planning permission be granted. Given this it is apparent that the applicant is committed to the principle of providing such mitigation for loss of the playing field provision at the Denbigh North site. Consequently, Sport England does not wish to raise an objection to the principle of the proposed development. However it is unable to clarify its position until the extent of the contribution required for mitigation is agreed by all parties.

6.8 Commission for Architecture & the Built Environment state that they

find it disappointing that a scheme including a civic element of this significance should have a paucity of design information attached to it. Therefore find it difficult to comment on the architectural qualities of the stadium itself, although it is acknowledged that the planning appears to be competent.

6.9. The Council’s retail consultant CB Richard Ellis – Critique of Retail

Assessment: There are a number of significant weaknesses in RPS assessment of quantitative need for the proposed enabling retail development. The most important of these are:


RPS make too small an allowance for outflow of expenditure from their study area, thus overestimating available catchment area expenditure; Underestimated the sales capacity of the existing convenience goods floorspace, through applying incorrect, and in some cases inconsistent company average sales densities, and assuming too low a proportion of trade drawn from the study area; Under estimated sales capacity of the existing comparison goods shops and stores in Milton Keynes, particularly CMK, Bletchley town centre and the comparison goods floorspace in the existing food superstores, mainly through under estimating sales densities for these shopping locations; Have not made any allowance for increases in sales densities in real terms in existing shops and stores in the town, despite the fact that sales densities have increased in real terms in recent years; Under estimated the potential sales in the enabling retail development itself; Failed to take account of certain committed new retail warehouse developments. Have taken no account of other committed or proposed developments which are supported by the Council and English Partnerships, i.e. the proposed new food store on Block C4.1 in CMK (supported by the Council and English Partnerships); and the proposed Homebase store at Winterhill and B&Q Warehouse at Rooksley (both of which the Council resolved to grant planning permission).

As a result, RPS has substantially over estimated the capacity and need for additional retail floorspace, for both convenience and comparison goods. Our own amendments to RPS’ figures show that the convenience goods floorspace in Asda Wal-Mart store will not be fully supportable in addition to the proposed new convenience goods floorspace in CMK until about 2007/8. They also show that the additional convenience goods floorspace which would result from a new or extended large food store in Bletchley town centre would not be supportable in addition to the Asda store until about 2010/11.

Our amendments to RPS’ figures show that the comparison goods floorspace in the Denbigh North scheme would not be fully supportable by available expenditure in addition to the committed and proposed developments in CMK until about 2010/11. Our amended figures, and our September 2003 report, show that even on this basis, there would be significant impacts on the existing food stores and comparison goods shops and retail warehouse, as their sales are reduced to estimated company average levels.

RPS’ retail impact forecasts are unreliable, particularly, in relation to the impact on Bletchley town centre. In the case of CMK, we consider that the impact will be marginally greater that RPS’ forecast (2.8% on combined convenience and comparison goods sales in 2006),


compared with RPS’ forecast of 2.3% in 2005. In the case of Bletchley town centre, RPS forecast an impact of 5.8% in 2005; whereas we forecast a cumulative impact in 2006 of 8.4% and an additional impact from the Denbigh North scheme alone of 6.5 %. Whilst unlikely to cause closure of any of the main anchor stores in Bletchley town centre, they will tend to undermine its vitality and viability to some degree. In addition, Asda Wal-Mart store would effectively prevent the development of a new or extended food store in Bletchley town centre until about 2010/11. RPS’ has not adequately addressed the commercial realities of such an affect, neither have they considered the implications of failure to attract a DIY goods retailer to the Denbigh North scheme.

Overall we conclude that RPS’ conclusions on quantitative need are unsound, and that there is only limited need for the proposed enabling development. RPS have not fully addressed the issue of qualitative need. However, they have identified potential regeneration benefits, which might flow from the overall scheme at Denbigh North. The sequential approach assessment is sound as far as it goes; but it should also have considered off-site enabling development. As a result, the enabling development cannot yet be said to comply fully with the sequential approach. Whilst there is not currently a strong need for the enabling development in retail terms, in the medium to longer term, by about the end of the Local Plan period to 2011, the scheme will be fully supportable by growth in expenditure, as a result of accelerated growth of Milton Keynes. At that time, development of a new or substantially improved food store in Bletchley town centre may become justified and achievable, if retailer support is forthcoming. As a whole the Denbigh North scheme including the Stadium will be likely to bring social and economic benefits to the Bletchley area. Some may help improve the vitality and viability of Bletchley town centre. The magnitude of such economic benefits to the town centre is impossible to predict; and in our opinion, is probably unlikely to be as great as the alternative of developing a new or substantially enlarged food store in the town centre.

6.10 DTZ Pieda Consulting - StadiumMK - Economic Impact Review

Overall, the review of the economic impacts of the StadiumMK project confirms that it is a significant scheme that offers the potential for a flagship development for Milton Keynes and large-scale employment and regeneration opportunities for deprived areas. Moreover, the attraction of professional football to the stadium is an opportunity that is unlikely to be repeated (the Football League have reiterated their general opposition to clubs moving from their traditional locales) and needs to be taken without delay if it is not to be lost. Wimbledon cannot keep playing at the National Hockey Stadium in the long term since the size of the ground means that the club will continue losing money.


Some of the estimates (e.g attendance at concerts, likelihood of attracting large-scale conferences, etc) used to assess the employment impacts should be considered optimistic unless market research is made available to substantiate some of the data provided. Similarly, there is no objective assessment of the likelihood of B1 employment, nor the realism of this being created and at what speed from 2007 onwards. A risk assessment would be useful to assess these uncertainties to demonstrate the socio-economic impact if less favourable conditions applied (if, for example, Wimbledon attracted less than crowds of less than 68% capacity, prospective retailers were to pull out, etc). Nevertheless, the forecast total of 2,400 gross FTEs (excluding double counting) has the potential to offer substantial employment opportunities to Milton Keynes as a whole and Bletchley in particular.

However, the key sensitivity of the development is around the retail element. CB Richard Ellis highlight that the application may understate the initial mismatch between supply and demand. Given forecast levels of population growth, this should only be a short-term impact for the first 4-5 years of the development, whilst the direct employment benefits of the scheme should be realised by 2005. This retail element is essential if the stadium and professional football are to be secured. Therefore, consideration of the planning application needs to decide whether developing the stadium and football club (with their attendant potential long-term benefits) outweighs any short-term negative impacts of the retail element of the scheme. In particular, the stadium offers the potential to catalyse projects in Bletchley, such as the development of Bletchley Park, which could have long-term regeneration benefits of a scale greater than the retail impacts.

COMMENTS FROM DEPARTMENTS WITHIN THE COUNCIL 6.11 Urban Design comment as follows:

Concerned that the enabling development (i.e. ASDA – Warlmart) will have a negative impact on attracting food retail to Bletchley and the realisation of one of the key objectives of the emerging Local Plan and Regeneration Strategy. In addition, we are concerned that the impact of this major retail development on the District Centres of Kingston and Westcroft, which rely on car-based custom from the same catchment area as this will attract.

The Stadium MK has the opportunity to offer a positive contribution towards the regeneration of Central Bletchley. The development is not only economically significant, but culturally and socially as well, as the Stadium MK will provide additional social, cultural and sporting interests to Milton Keynes’ second centre. The Stadium MK if approved has the opportunity to create a positive image for Bletchley, by significantly changing peoples’ attitude towards the town and


therefore setting the foundations towards the first signs of regeneration. It could be a key opportunity for Bletchley.

Currently, the Bletchley town centre environment is out dated, creating a negative image for the town and community within and reducing its ability to attract significant investment, leading to a poor environment and quality of retail and employment space. This in turn leads to less people using the centre, creating lower expenditure and investment. A poor environment that is run down and a lack of diverse shopping choice that fails to meet peoples’ needs is creating a vicious cycle of decline.

In order for the Stadium MK to positively contribute to the regeneration of Bletchley, there are a number of fundamental developments and issues that will need to be approached before development takes place. The emerging Regeneration Framework prepared by EDAW, clearly states that the stadium proposals must go further in supporting links between the Stadium and the town centre to create positive benefits from the development. It is crucial throughout the development and management of the Stadium MK that there is a close working relationship between the parties combined with an undisputed support for the principle and reality of regeneration in the Town Centre.

Before the stadium is operational there are a number of issues and projects that will need to be addressed;

• Improved Railway Station access. • A new transport network. • The downgrading of Saxon Street into an urban street – “Stadium

Way”.

Improved Rail Station access from the East

It is anticipated that the majority of spectators and visitors will be travelling to the Stadium by train. In order to direct pedestrians/cyclists from the Station onto either public transport or to the new Stadium Way (Saxon Street), a new access to the east of the Station is required. The access will also act as a gateway into the town, creating a sense of arrival for visitors as well as a landmark building assisting in legibility through the town.

The emerging Regeneration Strategy identifies the improved eastern access to the station as a priority project, as is the delivery of projects that provide activity around the station and substantially reduce the impact of severance between East and West Bletchley.

A new transport network

An improved eastern access from the station will support a new transport interchange, providing easy and direct access to buses, taxis


and Stadium Way (including pedestrian/cycle provision to the town centre and Stadium). The interchange is identified within the emerging Regeneration Framework as Bletchley Crossways Interchange.

The downgrading of Saxon Street into an urban street – “Stadium Way” The downgrading of Saxon Street will play an important part in the regeneration of Bletchley Town Centre. The realignment of Saxon Street from Buckingham Road to the railway bridge (“Bridge Gateway”) is key to the successful downgrading of the Street. Careful planning and implementation of facilities, services and public realm improvements along the Street will draw visitors and users of the stadium into the town centre and increase the spending power within the centre.

As a result of the downgrading, a defined redway and pedestrian network will be developed to provide eastern access to the station and a new pedestrian access route from West Bletchley to the town centre, in addition to improved links under railway bridges. Ideally creating a 10 minute cycle and 15 minute walk time from the Station to the Stadium, Saxon Street will therefore offer an improved economic and environmental opportunity to draw people into the town centre.

The route between the town centre and the Stadium is highlighted in the sub-regional strategy as an important transport corridor and an area for urban intensification.

Developments at Stadium MK create opportunities to deliver regeneration objectives positively through;

1. Cycle and pedestrian routes that are clear, direct and high quality

from Stadium entrance down Saxon Street into town centre and the new eastern entrance of the Railway Station. New “Stadium Way” as focus for pedestrian/public transport that is busy, active and attractive during stadium events, encouraging movement between Stadium and town centre.

2. Clear public transport routing for events. Shuttle buses to Stadium MK and transport interchange on Saxon Street, to improve the relationship between Stadium and town centre.

3. Positively contribute and key driver to deliver eastern access to

Bletchley Railway Station and improvements to public realm. Create a point of arrival and manage people at peak flow.

4. Stadium to positively support public transport on event days and other times, enhancing accessibility to the Station and functions/services in Central Bletchley.


Stadium MK and Developments The Stadium MK will create additional opportunities for Bletchley Town Centre to capture and develop the evening economy of the town. It will have a significant impact and catalytic effect, especially with respect to drawing in an evening economy into Central Bletchley.

The development of the Stadium on Denbigh Sports ground will result in a loss of playing fields. Replacement provision could be contributed to alternative leisure provision that supports regeneration aims in the Town Centre. For example outdoor provision in the form of a Multi-use Games Area (MUGA) and indoor provision as part of the proposed relocation of Bletchley Leisure Centre (clarification that this is an acceptable route for alternative provision required from Sport England).

Conclusions and Recommendations In order for the development to positively contribute to the regeneration of Bletchley Town Centre and crucial to the success of the Stadium MK development, improved access, connections, physical and socio-cultural infrastructure must be substantially in place and operating before spectators and visitors arrive.

6.12 Landscape Manager:

The bulk of the site area is designated as Recreation and Open Space, both in the adopted Local Plan (Jan 95) and the second deposit Local Plan (Oct 2002). Policy LR2 and L2 respectively apply. Both plans also indicated a Reserve Site (RS/20) within the site area, but this is shown within the Local Plan proposed changes document, as part of the "Site for multi-Purpose Sports and Spectator Events Stadium". The application area conflicts with the V4 Watling Street Wildlife Corridor. Adopted Local Plan, Policy DC22a and 2nd Deposit Local Plan, Policy NE1 give a clear presumption against any Wildlife Corridor loss.

Landscape Master Plan

The Master Plan (Drg no 602G Layer 6) proposal is a "broad brush" approach to the intended landscape structure, with the specific landscape detail to be agreed. The Master Plan contents I have no real problems with overall, however there are a number of ecological issues, which must be addressed and incorporated with the Master Plan layout.

Many mature tree species are present on site, some of which could be retained and incorporated within the overall landscape structure. Neither E.S. Volumes 1a or 1b, indicate in detail the specific tree coverage, and I request that a tree survey of the entire site area is provided. The survey must follow the guidelines as listed BS 5837 1991 "Trees in relation to construction. Section 5.2


Landscape and Visual

Section 5 refers to the landscape and visual assessment resulting from the development proposals. This information is shown in a written statement. photo views and photomontages. I have ascertained each section and have no real issues with each.

Appendix 5.11 show photomontages of the height of the potential future enlarged stadium. The anticipated visual impact would be significantly greater than the present proposals, and any such proposals would have to supported with another comprehensive visual appraisal.

Any further comments following the provision of amended plans and further information in November will be reported separately.

6.13 Countryside Officer

1. Ponds and willow woodland

Major concern is loss of the ponds/willow carr complex in the SW of the site. This is a small late C19 brickyard. Under the proposals, this area would be lost in entirety, to be replaced with the Asda Wal-Mart petrol station, access road and an area of car parking. The site is not a Biological Notification Site or County Wildlife Site, and until recently appears to have been overlooked by recorders. However, it is included within the V4 (Watling Street) Wildlife Corridor where it was one of only four features identified which “adds to the diversity of the WLC” (Wheeler: Wildlife Corridors Study (1996) p96). It certainly has potential for a Local Wildlife Site as defined in the emerging Local Plan (2nd Dep. Draft). This is incompatible with the statement (6.6.15) that its loss would be insignificant in context of the WLC as a whole. The V4 corridor is narrow and confined largely to roadside habitats along most of its length.

The site is unusual as a complex of ponds linked by marshy channels, within the “humps-&-hollows” topography of the former brickyard. Pond clusters are especially valuable for amphibians, but relatively uncommon. Only one similar site, also a former brickyard alongside Watling St, is known: at Kiln Farm 7.5 km away.

The flora is impoverished due to over shading by the willow woodland, but the ES correctly notes this could be rectified with straightforward management. The amphibian survey found no evidence of great crested newt, but noted the habitat is suitable. Common frog, toad and smooth newt were present. This is an extremely productive habitat for birds, which I can confirm from my own brief visit. It appears relatively undisturbed. It was not entered on the bat activity survey due to “safety and rough terrain”. Therefore the (in my view, considerable) potential


for foraging bats is not recorded. However, trees suitable for bat roosts were noted. It is stated that “the large amount of rubbish in the ponds detracts from their value” (6.5.84). This was not the case at my visit (photos on file) and in any case is easily rectifiable.

1.2 Other habitats

1) loss of existing rough, damp grassland and scrub in the NE and NW

parts of the site. I agree it is likely these are tumbled-down agricultural land no older than 20 years: they are also designated Reserve Sites in the emerging Local Plan. However, such areas often support a range of fauna. This includes protected species e.g. Grass snake and “conservation priority” birds to which Policy NE3 of the emerging Local Plan is applicable.

2) loss of existing mature trees on site, including some identified as

potentially suitable for bat roosts

I endorse the statement (6.6.16) that:

“In the absence of appropriate mitigation measures, the loss of habitat proposed as a Wildlife Corridor is considered to be negative, long-term, reversible, and of moderate significance”.

However, I contend that the development as proposed cannot accommodate effective mitigation and will result in a net loss to nature conservation rather than the enhancement required by policies NE1 and NE3 of the emerging Local Plan.

1.3 Evaluation of proposals

Balancing ponds

The development would include two ponds/water features. These have been offered (verbally but not in writing) as mitigation for loss of the existing ponds. These ponds are unsatisfactory in both amenity and ecological terms. They are consigned to the extreme north and south limits of the site, where they are exposed to the grid road environment, and will not be enjoyed by most visitors. The ponds are semi-formal in character. It is most unlikely their immediate context could include sufficient areas of semi-natural vegetation to substitute for those around the existing ponds. Balancing ponds are subject to major fluctuations of level, and poor water quality especially where draining parking areas. There is, in any case, uncertainty about the viability of the ponds due to Anglian Water restrictions on open water discharge to the sewage system.


The existing woodland includes mature willow pollards with fissures and cavities, ivy or bramble cover increasing their value to wildlife, e.g. bats or nesting birds. I estimate these would take 80-100 years to replace, in the unlikely event such trees were permitted in this location.

I contend the proposed ponds will not substitute for loss of the existing ponds and their surrounding habitat. Therefore I propose that the existing ponds and willow woodland are retained. Failing this, sufficient semi-natural wetland-woodland habitat must be created to provide effective compensation.

1.4. Other proposals

It is proposed that peripheral areas could be planted with scrub/rough grass to substitute for the loss of similar of the reserve site areas (6.8.1) and appropriately managed (6.8.11). However this is not apparent from the landscape layout (e.g. Drwg 602G, layer 6), which, though lacking in detail, indicates a more formal outcome. Any substitution will be at best an approximation, as the present habitats result from neglect unlikely to be acceptable as the outward face of such a prestige development. Careful management would be needed to achieve a balance between competing priorities, not least as this peripheral zone falls within the grid-road corridor. Nevertheless, the grid-roads too are identified as Wildlife Corridors.

There is public criticism of “over-tidy” grid-road management: however, it is unlikely any more relaxed management would be acceptable here. Any such proposal must certainly include sufficient extent outside the “dualling reserve” built into existing grid-roads, most notably V7 Saxon Street. The landscaping depicted appears to extend into the grid-road corridors where in public ownership. The issue of management responsibility remains to be resolved.

An Ecological Management Plan for approval of MKC staff would be produced in advance of construction. This would detail design, construction and management of mitigation measures e.g. ponds and naturalistic planting (6.8.13).

I have concerns whether the required naturalistic approach can be achieved in the context of this particular development. Detailed information is lacking. Therefore I recommend the Ecological Management Plan, with precise details of location and extent, be provided forthwith, not relegated to a late stage. However, the greatest ecological benefit would be achieved by simply retaining the ponds/willow carr, forgetting other habitat creation measures.

2. Impacts on species

Bats


Although considerable attention has been paid to bats, there are certain shortfalls in the survey.

• Buildings were only examined externally (App.6.9/2.1.2). The flat-

roof of the Pavilion/Irish Club building is not amenable to internal examination but has numerous external crevices (e.g. around soffits) which could conceal bats. I therefore disagree with the statement that “the flat-roofed buildings are unlikely to support roosting bats” (App. 6.6/3.4.14, 4.2.14).

Therefore I recommend further daylight visual examination and emergence surveys on at least two suitable evenings this summer.

• A single emergence survey was done of the house (Bate’s

Holding). The standard recommendation is for three visits.

Therefore I recommend an internal examination (if possible) and a further emergence survey on at least two suitable evenings this summer.

• The ponds area was not entered on the bat activity survey

(App.6.9/2.2.4) due to “safety and rough terrain”. Therefore the (in my view, considerable) potential for foraging bats is not recorded. However, trees suitable for bat roosts were noted. Substantial use by bats would create a statutory requirement either to retain this area or to create effective compensation (App. 6.9/1.4).

Therefore I recommend a flight survey of the ponds area takes place on at least two suitable evenings this summer.

The retention or recreation of hedgerows, which form flight-paths for bats, is recommended (App.6.9/4.2.4, 4.3). In my view, the proposed grid-planting, with standard trees, of extensive at-grade car parks, is more likely to confuse the bats than to satisfactorily recreate this feature. However, the Bat Activity Surveys suggest the existing playing fields are not at present a major bat foraging/commuting area (App. 6.9/4.2).

• The Consultant advises that potential roost sites (trees and

buildings) be searched for bats immediately prior to destruction (6.5.101). If bats are found, work must cease pending advice from English Nature.

I endorse pre-demolition/felling survey as advised.

Badgers The survey, which found no evidence of badgers, appears adequate.


Great crested newts The survey, which found no great crested newts, appears adequate. However, the standard conclusion in this case is not absence but “probable absence”. The surveyor notes that the existing ponds constitute suitable, though not ideal, habitat (6.5.45). That, and the presence of three more common amphibian species, strengthens the case for their retention.

Reptiles The survey found no reptiles. Of possible species Adder and Slow-worm are not recorded from Milton Keynes, and Common lizard is rare. However the Grass snake is widespread, and was possibly overlooked in the ponds area due to fewer refugia having been placed (App. 6, fig. 6.2) and the availability of alternative refugia in this area. The conjecture (App.6.6/3.4.8) that reptiles may be scarce due to recent reversion from agriculture is clearly not applicable to the former brickworks.

Birds A range of widespread bird species was noted. Species additionally seen by myself included some dependant on dense cover e.g. Wren, Blackcap, Willow warbler, Long-tailed tit.

I must contest the implication that local populations of BAP species are dispensable (App. 6.6/4.2.9, 6.5.97). The cumulative effect of such local losses is national decline. I do not understand how, within the context of the proposed development, loss of nesting habitat is “reversible” (6.6.4).

3. Impacts on Mount Farm Lake

Surface-water drainage from the site will pass to Mount Farm Lake (MFL). However, Anglian Water severely restricts the permissible discharge, such that on-site attenuation will be required (7.3.2). MFL is a former gravel-pit, now a District Park managed by Milton Keynes Council. Priorities are biodiversity, public amenity and a club fishery. The lake is leased from Anglian Water Services Ltd. It is stated “MFL does not provide any flood storage” (7.2.5). AWSL does in fact regard it as part of the surface-water drainage system, although, with just a simple overflow, the level remains roughly constant. The lake is fed from several surface-water drains having been a source of pollution in the past. It is also fed by a ditch, which upstream bisects the application site, and by groundwater, which may correspond to the “minor aquifer” within the SE corner of the application site and also near the proposed petrol station. This aquifer is “a potential conduit for contamination”.

MFL is no longer, as stated throughout, a proposed Site of Nature Conservation Interest (County Wildlife Site). It was reviewed but not accepted for CWS status in January 2003. However, it is a valued


amenity, and reasonably productive of breeding birds, both waterfowl and passerines. Heron bred in 2003. The most important areas are the emergent vegetation fringe. To enhance this “non-angling” areas were extended, fish-stocking regulated, and the (now non-statutory) “closed season” from March to June maintained. Canada goose and Mink are controlled by Milton Keynes Council. The emergent vegetation fringe, and its use by breeding birds, depends on the relatively stable water-level in MFL. The lake is also threatened by silting. Particular risk is identified during the construction phase.

The proposed plant species for the ornamental ponds include some non-native to the area, or not now present in Mount Farm Lake, which could cause problems if propagules are carried in drainage. Therefore assurance is sought that both during the construction and operation phases:

1. Changes to the run-off regime will not increase the frequency or

extent of water-level fluctuations within Mount Farm Lake.

2. Run-off entering the lake will not increase contamination over present levels.

3. Silting will not increase over present levels. 4. No major physical changes will be required to the lake.

5. Plant species selected for the new ponds will exclude any likely to

prove invasive in the lake.

Following negotiations during October, revised plans and amended information ere submitted. The Countryside Officer has given these further comments on the submissions:-

1. Tree & Hedgerow Survey I am very concerned this was not done until November ’03—such a survey should be part of the baseline site assessment, not a last-minute add-on.1 I am concerned the survey identifies several good trees and hedges which are not retained: • Trees 37, 38 and 66 which are “Category 1” (the best) Oaks of “long”

Useful Life Expectancy and whose location would apparently permit their retention. Tree 66 in particular is described as “a dominant tree in the landscape”.


• Hedgerows L (Cat. 1) and M (Cat. 2) which parallel the circulation routes NE of the stadium, and could therefore have been assimilated in the design.

Against these losses, proposed retention of Hedgerow B is of small import. I am also concerned the tree survey does not quantify losses around the pond area, which was my main reason for seeking it. In the survey the pond area is treated as an aggregate area of habitat. Therefore I cannot accept the survey as it stands. 2. Wildlife corridors—grid-roads I remain deeply concerned about the principle of a developer providing landscape or habitat mitigation substantially dependant on the grid-road corridor—including the dualling corridor. How do we protect such provision in perpetuity against dualling, road-widening, underground services installation or other infrastructural constraints? I also remain concerned the landscape outcome will be essentially formal (e.g. Amendments to Design Statement 2.24: “new planting…in dramatic sweeps…highlight the approaching entrances to the Stadium…). This is entirely appropriate, but does not square with the promise to provide substitute semi-natural habitat within those same corridors. On Drwg 602R/6 I cannot find the “grass areas with a variety of management and maintenance regimes”. 3. SUDS corridor The realignment is good, but is the rather narrow corridor (10m) compatible with the amount of “cut” required, or will it just be a deep, rubbish-filled ditch? Redways are not my prerogative (only as a user!) but how will we protect the narrow one here (and elsewhere) from vehicle-overhang?—a typical problem where redways divide parking areas. 4. Statutory agencies--response The creation of new ponds before the destruction of old, as recommended (letter to JP of 13/10/03, ring-binder, App. 6.3) by the Environment Agency, is welcome—though I regret the necessity. These new proposals must now be run past EA to test satisfaction on other issues raised in that letter—in particular mitigation for the loss of existing wetland habitat, and the provision of sufficient terrestrial habitat for amphibians.


In this context I note the Landscape Master-Plan (Drwg 602R/6) has the new pond in the NW corner surrounded by “white land”. The Revised Phase 1 Survey Report (ring-binder App. 6.1) 4.1.3/11 notes that wet woodland is a “priority” habitat in the UK Biodiversity Action Plan and advises satisfactory mitigation. UKBAP is non-statutory so far as planning decisions are concerned. However the non-objection of English Nature (e.g. 6.3.4) should not be taken as support: EN normally only objects on statutory grounds. 5. New ponds not for stormwater storage Good to have this cleared up. 6. Protected species surveys—quality I note (6.5.5) there will be pre-demolition bat surveys of buildings as advised (App. 6.4) by English Nature. However, I am not reassured (by 6.3.3) that the existing surveys were of sufficient duration. On grass snakes, I remain concerned there was insufficient survey of the ponds area, and the assurance (6.3.6) reptiles “are absent” unjustified. The need for further survey, trapping and relocation of grass snakes is advised prior to destruction of the ponds area if it occurs. Grass snake habitat is not protected against deliberate destruction, but the animal itself is. 7. Tree planting—car parks The species-list (ring-binder 2.2.31) is short on natives and contains some (Lime, Conker, Cherry) notorious for dropping muck on cars.

6.14 Development Plans Manager (DPM)

1. Stadium Car-Parking (a) PPG13: Transport [March 2002]

This guidance suggests a maximum parking standard, for stadia above a threshold of 1500 seats, of 1 space per 15 seats [Annex D].

(b) New Local Plan [DV1 & DV2]

Supporting text to Policy L13 [Multi-Purpose Sports & Spectator Events Stadium] states that the Council aspires to achieve a lower level of on-site parking provision than the maximum suggested in PPG13, with correspondingly more visitors using public transport.


(c) MKC Parking Standards [2003] Draft consultative parking standards were produced by MKC in July 2003. The period of consultation on this document closes on 30 September 2003. The document proposes parking standards according to a number of ‘zones’ and use types. Denbigh North is categorised as ‘Zone 3’. The maximum parking provision for stadium development in ‘Zone 3’ is specified as 1 space per 18 seats [i.e. a lower level of provision than the ‘maximum’ standard in PPG13].

The applicant’s asserts that the overall level of car parking for the entirety of the site and for the various elements of the development is below the maximum standards sought. Paragraph 4.2.27 states that for occasions when there is an ‘event’ at the stadium an ‘off-site’ parking demand will arise.

Comments:

Car Parking Provision - Ratios of Spaces to Seats:

30,000 Capacity Sports Stadium Scenario Provision @ 1:15 [PPG13 maximum] 2,000 spaces Provision @ 1:18 [MKC Draft Parking Standards maximum]

1,666 spaces

35,000 Capacity Spectator Events [Stadium & Arena] Scenario Provision @ 1:15 [PPG13 maximum] 2,333 spaces Provision @ 1:18 [MKC Draft Parking Standards maximum]

1944 spaces

Based on a 30,000 capacity the proposed provision of 2,000 dedicated car parking spaces would: - Equate to provision at the maximum standard advised in PPG13; - Exceed the maximum standard [1:18 ratio] set out in MKC’s Draft

Parking Standards [2003].

Assuming Wimbledon remain in Division 1, the attendance at most ‘home’ games is likely to be well below the proposed stadium capacity of 30,000. In this scenario, the number of car parking spaces, expressed as a ratio of those actually attending games, could be much higher than the maximum ‘standard’ in PPG13. For example, if WFC were to attract the average gate for a First Division side - based on 2002-2003 attendances - 2,000 dedicated car parking spaces would equate to provision at a ratio of 1 space for every 8 supporters.

On balance, it is felt that consideration should be given to revising the level of on-site parking provision downwards to dovetail with: - The Council’s aspirations to achieve a lower level of on-site parking

provision than the maximum suggested in PPG13, with correspondingly more visitors using public transport ; and,


- The maximum ratio set out in the Council’s Draft Parking Standards [i.e. 1:18].

A reduction in the level of on-site parking provision could: - Reduce ‘land take’ and so facilitate an improved scheme layout

which would better embrace other policy objectives [e.g. retention of ‘Wildlife Corridors’ - also refer comments under 2. below];

- Encourage a greater number of visitors to utilise public transport; and,

- Help to avoid surplus or under-utlised ‘on-site’ parking areas in a scenario where attendances fall.

Following negotiation the amount of stadium parking has since been reduced to 1944.

2. Loss of Wildlife Corridors

Wildlife areas are linear pathways containing habitats that encourage the movement of plants and animals between important wildlife sites.

(a) Local Plan Designation BMK Local Plan [Adopted 1995] Policy DC22a states: “Planning permission will normally be refused where development would cause significant damage to the viability of a wildlife corridor. The Borough Council will identify a network of wildlife corridors and seek to enhance their wildlife value by appropriate management”

MK Local Plan – First Deposit Version [September 2000] Areas of the allocated stadium site [notably to the north and south-west] are designated as wildlife corridors in the emerging Local Plan. An objection was received from P. J. Winkelman [Inter MK], at the First deposit Stage seeking deletion of the Wildlife Corridor allocations on Denbigh North unless clear evidence of wildlife value is provided [ref: MAP/1043/7]

MK Local Plan – Second Deposit Version [October 2002] Policy NE1 [Nature Conservation Sites] provides more information regarding the general characteristics and designation of Wildlife Corridors [WC]. Inter alia, it states: “Planning permission will be refused for development if it is likely to harm a Local Nature Reserve, Milton Keynes Wildlife Site (MKWS), Wildlife Corridor or Regionally Important Geological Site (RIGS), unless the reasons for the development clearly outweigh the harm to the substantive nature conservation value of the site”. It asserts that: “In any case where the development is permitted, harm to the nature conservation interest must be minimised. Planning obligations or conditions will be used to protect and enhance the nature conservation


value of the site and to provide compensatory measures and site management.”

13 objections were received in respect of proposed changes to Policy NE1 at the Second Deposit stage.

(b) The Wildlife Corridors of Milton Keynes [1996] This document provides the basis for the WC designations in the in the emerging Local Plan.

More particularly, in the context of this planning application, it provides detail on the: - A5(T) Wildlife Corridor [wildlife corridor to the north of the

stadium site] - Grid Road Parkway Wildlife Corridors [wildlife corridor to the south-

west of the stadium site]

Comments WC designations within the site boundary constitute a planning ‘constraint’. However, such designations do not, necessarily, preclude development from taking place. Policy NE2, as proposed in DV2 states, that where development is permitted it is expected that harm to Wildlife Corridors must be minimised.

The proposed development will have an impact on WCs within the site. An area to the north of the site forms part of the A5(T) Wildlife Corridor whilst an area to the south-west forms part of the ‘general’ Grid Road Parkway Wildlife Corridor. The application explicitly acknowledges that the proposal will ‘harm’ or ‘affect’ the Wildlife Corridors within the site. However, it states there will not be significant damage to the viability of these Wildlife Corridors; it is argued that mitigation measures will successfully offset the proposed loss of these ‘corridor’ areas.

The document Wildlife Corridors in Milton Keynes [1996] identifies 6 ecologically rich sites / potential SINCs along the A5(T) Wildlife Corridor. None of these sites are located within or adjacent to the stadium site. It may be prudent to seek the views of other organisations such as BBONT and/or MKPT as to the nature conservation value of the WC areas within the site and how significant their ‘loss’ would be. Little consideration, or importance, appears to have been given to retention of the ‘Wildlife Corridor’ areas within the scheme layout; the impression gained is that the scheme has not sought to respond to this particular constraint. Rather the loss of, and harm to, these areas is conceded, presumably on the grounds that the reason for the development outweighs the harm to the WC’s and that proposed ‘mitigation’ measures – to include on-site planting - will offset any harm.

Given that the WC areas are located at the periphery of the stadium site it is considered that a reduction in the provision of on-site parking –


as recommended in Section 1 above - could enable production of a revised layout, which incorporates retention of the WC areas.

Following negotiations some of the affected wildlife corridor areas have been re-instated inasmuch as the layout has been revised to retain them and some new planting has been introduced to strengthen them.

3. Loss of Recreational Facilities

(a) PPG17: Planning for Open Space, Sport and Recreation [2002] States:

“Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space or buildings and land to be surplus to requirements. For open space, ‘surplus to requirements’ should include consideration of all functions that open space can perform.” [Para.10]

(b) BMK Local Plan [Adopted 1995] Policy LR2 of the Adopted Local Plan provides broad protection against the loss of open space used for leisure and recreation, including playing fields. Standards for the provision of leisure and recreation facilities, including playing fields, are set out in Appendix LR1.

(c) MK Local Plan – Second Deposit Version [October 2002] Policy L2 of DV2 provides broad protection against the loss of open space used for leisure and recreation including playing fields. Standards for the provision of leisure and recreation facilities, including playing fields, are set out in Appendix L1. Supporting text to policy L13 [Multi-Purpose and Spectator Events Stadium] states: “The loss of playing fields will need to be compensated for by new or improved provision elsewhere, in accordance with Policy L2. The Council’s approach to the loss of playing field space will be consistent with guidance in PPG17: Sport and Recreation.” [Para.13.53]

Policy L13 states that planning permission will be granted for a stadium at Denbigh North providing a number of criteria are met, including: vii. In the case of existing recreation facilities being lost, equivalent

recreational facilities are provided.

(d) MKC Playing Pitch Strategy [2003] The PPS has been endorsed by Sport England and was formally adopted by the Council in June 2003. The strategy identifies the potential loss of the following facilities as a consequence of stadium development at Denbigh North. (a) Denbigh North Sports Ground:

- 6 senior football pitches - 1 junior football pitch - 1 mini football pitch


- 2 cricket pitches (b) Denbigh Irish Club

- 1 senior rugby pitch [All the above facilities are categorised as being ‘local’ in terms of strategic importance]

Deprivation The strategy cites that the Wards Woughton and Eaton Manor rank amongst the most deprived wards in the country. More specifically it states: “Within the Woughton and Eaton Manor Wards particular attention needs to be paid to the spread of playing pitches. Those areas with high levels of deprivation will generally have lower levels of car ownership, which means that many participants will walk or cycle to reach their local playing pitches.” [p.15]

This highlights the potential implications of the loss of playing fields at Denbigh North as a consequence of the proposed stadium development; Denbigh North is located in the Bletchley and Fenny Stratford Ward, adjacent to both Woughton and Eaton Manor Wards. The Woughton and Eaton Manor Wards are identified as Priority Areas for the Sport England Lottery Sports Fund and many other external agencies. In addition to assessing the borough-wide picture the PPS also addresses the sporting requirements of different geographical areas. The strategy has devised 7 ‘sub-areas’ based upon established sports development areas and grid square boundaries. Denbigh North is located in the ‘South MK’ area’. With regard to ‘South MK’, the assessment indicates: - An existing and projected deficit of pitches for mini-soccer; and, - An existing and projected surplus of pitches for senior football.

(e) The Proposal The application states that proposed development will result in the removal of a number of sports pitches and a pavilion building. Whilst it concedes that this represents a ‘negative impact’ it claims that this loss is tempered by: i. A surplus of playing fields in the locality at the present time [as

confirmed by the MK Playing Field Strategy]; and, ii. Proposals that the stadium scheme will fund the provision of new

[and/or the improvement of existing] sports pitches and other facilities in the area.

The statement alludes to discussions that are currently taking place between MK Stadium Consortium, Sport England about the most appropriate forms of mitigation. Potential projects that are cited


include, the provision of drainage, other pitch improvements [the creation of mini and junior pitches] and changing facilities to enable increased usage at Tattenhoe Lane, Bletchley, and contributing to the upgrading of Bletchley Leisure Centre. It further asserts that projects such as these have the potential to provide recreational facilities better located in relation to the requirements of residential communities in the area, and thus a potential positive impact.

Comments Principal considerations: Does the Playing Pitch Strategy demonstrate a surplus of pitch

provision/ Do the pitches and facilities at Denbigh North serve a ‘local’ or

wider need? Are the measures proposed to offset the pitches and facilities at

Denbigh North adequate? How far should the application go towards providing real and

useable, alternative facilities to serve ‘deprived’ wards. Playing Pitch Strategy

The PPS indicates that there is currently an excess of senior football pitches at a borough-wide level. However, the assumption on which this conclusion is made - that on average 2 matches per week could be played on all pitches - is questioned.

The PPS additionally indicates: - there are too few mini & junior football pitches - there are too many cricket pitches - rugby clubs are close to capacity

At the more ‘local’, sub-area level [i.e. ‘South MK’], the Strategy indicates:

- An existing and projected deficit of pitches for mini-soccer; and, - An existing and projected surplus of pitches for senior football.

Denbigh North Pitches: A ‘Local’ or Wider Need? Whether when calculating playing field requirements the facilities at Denbigh North should be treated as a local facility or one serving the wider City / Borough is a moot point. It is acknowledged that teams frequently draw their members from a wide area and that they are prepared to play at sites away from the resident areas of team members. Moreover, the facilities at Denbigh North are located some distance from residential areas. On the other hand, the strategy does categorise the facilities at Denbigh North as ‘local’ in terms of their strategic importance. Indeed, the geographical sub-area ‘South MK’ is effectively construed as a ‘local’ area for the purposes of playing pitch provision.

The PPS would seem to indicate that the facilities at Denbigh North contribute to a surplus of senior football pitch provision, whether assessed at a local [MK South] or City-wide level. At the local level,


research conducted by the present writer [August, 2000] suggested that, when assessed against the standards of playing field provision in the Local Plan, the Bletchley area had a surplus provision of playing field space equivalent to 2.25 hectares. It was concluded that any significant development of the playing fields at Denbigh North would, in all likelihood, result in a deficiency of playing fields in Bletchley. Following the recent development of playing field facilities at Emerson Valley and Tattenhoe, it may be argued that such facilities serve to increase the availability of facilities to residents of West Bletchley.

Proposed Measures to Offset the Loss of Pitches The proposed measures to offset the loss of playing pitches at Denbigh North would appear to be somewhat tenuous. The application refers to ongoing discussions about the most appropriate forms of mitigation and potential projects but appears to make no concrete proposals. Such proposals will need to be clarified before they can be assessed. The application hints at the improvement of existing pitches at other locations within Bletchley. However, an appeal decision involving Sefton MBC [1998] suggested that improvements to remaining pitches would not offset any loss of pitches to development.

N.B. It should be noted that discussion with the Council Leisure Services officer have resulted in firm proposals to provide more pitches at Derwent Drive and to relocate the Irish Club and Gaelic football pitch to Manor Fields.

The Provision of Alternative Facilities to Serve ‘Deprived’ Wards Local facility provision that enables ease of access to pedestrians and cyclists is considered important in terms of achieving greater social inclusion. Notwithstanding the apparent surplus of pitch provision - both at the local and city-wide level - it is considered that alternative facilities should be sought in respect of the deprived areas, ostensibly on the grounds that a local and accessible recreational facility has been lost. The PPS ‘Strategy Areas’ could be used to argue this case; for example, Eaton Manor Ward is located in the same ‘South MK’ sub area as Denbigh North. However, it should be noted that whilst Woughton Ward is geographically closer to Denbigh North than Eaton Manor Ward, it falls within the ‘Central MK’ strategy area.

Policy comments on the Retail Assessment provided by the applicant are provided under paragraph X within the consideration section of this report.

4. Retail Issues

DPM has also commented in some detail on the retail issues with particular emphasis on the effect on Bletchley Town Centre. His comments are attached to this report at Appendix A.


6.15 Senior Highway Engineer, Development Control had a number of detailed concerns about the scheme as submitted and about the Transport Assessment (TA).

In summary his views were as follows:

The trip rates proposed in Appendix 2 of the TA are low and do not appear to be acceptable. Assumptions about the amount of shared and new traffic around the site and at the junctions need to be clarified and agreed. The addition of the generated traffic on the network and the use of the traffic model need discussion and agreement. Some of the assumptions made are unclear, some are not acceptable. Although the TA includes a description of the predicted impacts at the junctions most affected by the proposal, the possible impacts might be revised as a result of changes to the preceding matters. The only notable contribution to non-car modes of transport in the TA is the proposed pedestrian/ cycle link from Buckingham Road to the site. There are mentions of possible additional bus services and the facilitating of the use of the site for Park and Ride but no firm proposals are put forward for funded improvements.

As submitted the proposed layout of the site and the surrounding roads is not acceptable and nor is the Transport Assessment. I would expect to meet with the applicant's transport consultant (PFA) to discuss the issues raised in this response, I also envisage meeting with PFA and the main bus operator to discuss on site/ off site provision and a further meeting with PFA and the Highways Agency to discuss the Red moor roundabout and the Bletcham Way/ A5 junction.

On learning of those concerns the applicants have engaged with the Council in detailed discussions and have updated the TA and the scheme. As a result of those changes the Senior Highways Engineer has submitted revised observations which are set out below. In response to my earlier comments the applicants have prepared and submitted a substantially revised Transport Assessment (TA). Due to the volume of information that has been provided, our review is not yet complete. I can, however, update you as follows; The main elements of the TA are now agreed and the majority of the traffic modelling assumptions are satisfactory. I have much more confidence that the likely impact of development traffic on the highway network as shown in the TA is realistic. There remain some points that will need discussion or clarification with the applicants transport consultant and this is still to take place. From what I have seen however, the further discussion/review should not significantly affect the overall picture of the impact of the proposals on the network.


In terms of the details of the scheme layout and highway, there are some key points that have yet to be agreed; In order for Park and Ride to operate efficiently from this site the junction used by P&R vehicles (buses) needs to be signal controlled. The layout of P&R facilities within the site remains unacceptable, the proposed location of stops/shelters is too remote from the bulk of the parking. The revised junction at the current location of the Granby Roundabout does not indicate how the 'Enigma Bridge' link road would connect to Bletcham Way/Watling Street at this point. The extent of highways works off-site. In particular the works at the Watling Street / Saxon Street double-roundabout During the last few weeks we have discussed with the applicants the extent of off-site highway works that are required and the contribution that will be required towards public transport services. Much like the TA, the main points and principles of the highway works and public transport contribution are agreed but the details need further discussion. I have indicated in the table below, the expectation of the highway authority and the current proposal from the applicants;

MKC requirement Proposal by applicant Comment Action Provision of / funding for Hopper bus service (5 years)

£225,000 to fund service for 3 years

£75,000 p.a. is acceptable subject to no requirement to return revenue.

Period of funding to be discussed.

Enhancements to Service 14 evenings and weekends (5 years)

£450,000 to fund service enhancements for 3 years

£150,000 p.a. is not sufficient to fund required enhancements.

Amount and period of funding to be discussed.

Design of site and inclusion of features to permit Park & Ride operation.

Not yet clarified, but acceptance of main elements.

P&R access junction with Saxon St requires signals. Provision of stops, shelters, WC's, CCTV and clarification of management still required.

Details of scheme to be discussed.

Provision of high quality redway link between Bletchley Rail station and site.

Extension/ enhancement of existing route.

Quality of route through subways and under railway flyover is poor. Crossing points require higher quality solution.

Details of scheme to be discussed.

Realignment of existing redway alongside Saxon Street to go over A5 on Saxon St bridge not under A5 in underpass.

Proposed by applicant Agreed. None.


Improvements to walk/cycle routes between West Bletchley and site.

Not yet clarified. Quality of existing route needs raising including security and lighting issues. Route along and across Watling St also a major issue.

Awaiting firm proposals from applicant.

Junction Improvements as identified by TA and as agreed with MKC.

Signalisation of A5 Redmoor R/B Plus, £100,000 to fund works at; V4/H8 'Elfield Park' R/B V7/H9 'Ashland' R/B Bond Ave/H10 R/B V7/H8 'Coffee Hall' R/B V6/H8 'Bleak Hall' R/B Watling St/V7 'Roman' R/B

The signalisation of Redmoor is agreed. £100,000 for the remaining works is unlikely to even be close to the actual cost of the works required. The principle of taking a contribution towards works at these junctions is accepted.

No action required on Redmoor. Discussion to reach agreement on sum towards other highway works.

Traffic management, speed limits and parking enforcement.

Not yet clarified. Linked (managed) traffic signals, introduction of lower speed limits and introduction of parking controls required.

Discussion of these issues required.

In addition to the above matters, the issues of on-site and off-site parking have yet to be resolved. Following agreement on the level of on-site parking the amount of parking available to the P&R site will also need agreement. I have agreed in principle that the P&R site should continue to operate unless a 'trigger' size of match/event on the site occurs, where all of the parking would be used for the match/event. I feel that to ensure a reasonable level of P&R service and to restrain match/event parking to encourage other modes of travel this should be at least a 20,000 spectator match/event. The TA currently proposes a 6,900 match/event, which is not acceptable. There are also a number of minor issues that will need clarification and agreement prior to any consent being issued. Summary • I am now reasonably satisfied with the traffic modelling work and

expect to reach agreement on this in the near future. The anticipated impact of the proposal on the highway network is now broadly agreed.

• Some layout issues, both on the site and on the highway network

have yet to be resolved. • The negotiations for contributions towards public transport and

off-site highway works are continuing as outlined above.


• Subject to reaching agreement on these three areas I would have no objection to planning permission being granted.

6.16 Chief Environmental Health Officer comments as follows: Contaminated Land: Satisfied that the investigations already carried out show the site to be essentially uncontaminated, and therefore no further investigation or planning condition is necessary. Air Quality: Results from air quality modelling assessment predict a small impact on air quality during construction and operational phases mainly due to increased traffic flows. There are no predicted exceedences of air quality objectives at any of the modelled sensitive receptor locations. No grounds for opposing this development on account of air quality. Noise: Application should not be refused on noise grounds. However would recommend a number of mitigation and noise control measures will be required. Therefore recommend conditions be attached to any planning permission. Regulatory Implications Safety Certification: If granted permission the stadium will require a General Safety Certificate for spectator sports that are proposed.

Regulatory Implications Safety Certification: If granted permission the stadium will require a General Safety Certificate for spectator sports that are proposed.

6.17 Leisure Services Officer welcomes the clear recognition of the Council’s strategies for playing Pitch and wider leisure facility provision. The Playing Pitch Strategy is now an adopted strategy of the Council and all of the recommendations contained within the Stadium MK application are in accordance with the aims and recommendations contained within.

6.18 Acting Leisure Youth and Community Manager comments as follows: Development is key to achieving the long-term aspirations for development of leisure, sport and cultural activities within Milton Keynes as well as being a major regeneration project for the north Bletchley area. The application and impact assessments address the major issues around the stadium development however the following points need to be emphasised: Links to existing activities


The plans link into the wider regeneration of Bletchley and it is essential that they take into account and the wider needs and aspiration for the area and take into account the work so far undertaken by EDAW and Bletchley SRB partnership, Bletchley Board and the two parish/town councils.

Economic Impact

Impact can be very positive in bringing new employment, social and cultural leisure and sporting activities to the area. This will generate new jobs, but it is important that these utilise the local labour market. The development will also bring with it other new facilities including indoor arena, supermarket and restaurants etc. Again all of these may benefit the local community and economy but a strategy must be in place to work to achieve this objective otherwise there is the potential for local people to be further excluded form the economic social and cultural activities.

There is a need to ensure that the proposals for commercial activity on the site do not add to the decline in retail heart of Bletchley in the Queens way area.

Leisure Cultural and Sporting Impact

The new facility will make Denbigh Stadium a major venue for activities in the north Bletchley area and all activities, football, basketball, concerts, conferences etc will increase opportunities for local, regional and national events to take place. This will add to the life experiences of people. However the impact of increased activities and traffic need to be managed and effective links have to be made to public and private transport providers. There is also a need to ensure that there is not an adverse environmental impact from increased activity in the area. The loss of the current facilities on the sports ground need to be considered alongside the criteria established within the council’s approved Leisure Facilities strategy and developing Playing Field Strategy.

Environmental Impact

The development will enhance the Denbigh area with its high quality design. However there is the potential for detrimental effects to arise and these need to be reduced wherever possible by appropriate design, planning and monitoring.

6.19 Archaeologist raises no objections subject to condition requiring the

employment of an archaeological contractor.


7.1 REPRESENTATIONS 7.2 Granby Residents Association object on the grounds that access to

homes will be impossible at times, parking difficulties, noise problems, possible violence from spectators, damage and rubbish after every event, and would make their lives hell.

7.2 Shenley Brook End Parish Council have expressed concern that the

traffic study reports the effects upon the immediate junctions and roads, but not the full area influence. They suggest the next ring of junctions should also be studied with particular thought to locally generated traffic using the stadium and retail centre. The junction at Elfield Park is already busy and traffic will exceed capacity by 2005, but the study claims the development will have only a marginal effect. The junction is already a pinch point with queuing times of 8 minutes, with action needed to discourage rat-running through adjacent estates. There is no mention of the proposed greyhound stadium and events at Elfield Park, nor the events at The Bowl. These may clash with football dates. They suggest improvements on Standing Way and Watling Street junctions be sought. They also require measures to prevent parking on surrounding estates.

7.3 The Wimbledon Independent Supporters Association (WISA) have

written a detailed objection letter under four main headings though they signal their intention to write further detailed objections covering ‘a number of important issues’. Their main points are: • The football stadium is being used to evade planning restrictions

on out of town retail developments and the football stadium is in fact being used to enable the ASDA/Walmart store to be built in the face of those restrictions.

• The site is too far from Bletchley Town Centre to have any beneficial effect on its regeneration.

• It would be wrong for MK Council to grant permission in the light of the fact that Wimbledon Football Club is “insolvent”.

• There is no need for a big football stadium in Milton Keynes; there is no research to say that crowds will exceed the 7000 or so who came to Wimbledon’s first two games at the Hockey Club and therefore planning permission for such a “white elephant” is unwarranted.

In a further letter, WISA expand on the first bullet point mentioned above and maintain that the development would in effect result in the creation at Denbigh North of a third town centre. They say that the relationship of the site to the centre is distance and convenience will prevent it benefiting Bletchley and that the suggested regeneration projects are superficial, minor and that their realisation is uncertain. Finally they point out that the development would not accord with the adopted Local Plan and must therefore be treated as a departure.


7.4 Bletchley & Fenny Stratford Town Council positively support the application in principle. They have submitted a list of projects which they feel should be discussed when considering ‘Planning Gain’ under the Section 106 Agreement. Their list is attached to this report at Appendix B.

7.5 The Bletchley Development Board has also put forward a list of

proposals for inclusion in the S.106 Agreement. These are attached to this report at Appendix C.

7.6 West Bletchley Council wholeheartedly supports the plan and would

like to see: upgrading and refurbishment of sports facilities, under Section 106, in particular at Rickley Park and Tattenhoe Lane; the relocation on uncommitted sites of the Irish Club within the Bletchley area and improvements to the highways and infrastructure in the Bletchley Area.

7.7 An objection has been received on behalf of Wm Morrison

Supermarkets Ltd which in summary considers:

• The retail assessment has adopted an over-extensive study area based on 15 minute drive time, which incorporates all of Milton Keynes urban area and extensive rural hinterland, whereas the household survey results show that the majority of shoppers to Bletchley’s existing convenience shops live within zones 1 – 4.

• Because of the over-extensive study area, the applicant’s capacity assessment over estimates the amount of expenditure on convenience goods theoretically available to support new floorspace specifically in the Bletchley area.

• Our revised assessment based on a more localised catchment area shops some capacity for new convenience floorspace (2779 sq.m by 2005) but this is not sufficient to support the net 4,645 sq.m within Asda Walmart for which there is no quantitative need.

• National and local planning policies require that a sequential approach is followed, with the first preference being sites within town centres.

• The Second Deposit Local land shows there are more sequentially preferable sites likely to be available in Bletchley, namely allocated site MK8 at the Brunel Centre Bletchley.

• The convenience floorspace element does not accord with PPG6 or PPG17.

• The provision of an Asda Walmart supercentre on this out of centre site, located 1.9km to the north of Bletchley Town Centre is inconsistent with the emerging retail strategy in the Second Deposit Local Plan.

• The development, if permitted would significantly harm the development plan strategy, and prejudice one of the key objectives for the regeneration of Bletchley.

• The convenience floorspace element would significantly harm the vitality and viability at Bletchley town centre.


7.8 Two letters have also been received from agents acting on behalf of

Safeway Stores plc, objecting to the ASDA/Walmart Supercentre (but not to the non-retail elements of the scheme). Summarising their views in the first letter, they do not accept that either a quantitative or qualitative need for the proposal exists. They say that the applicant’s approach to the sequential test is fundamentally flawed and does not accord with current Government guidance. Furthermore, they say the proposal will have a significant impact on the Safeway store and consequently the Westcroft Major District Centre. The second letter was written after they had seen the critique by the Councils retail consultants CBRE. Whilst agreeing with much of CBREs assessment they are critical of his approach to the Governments retail planning policy guidance and in particular they say his critique focuses on the unadopted emerging Local Plan rather then the adopted one and this is inaccurate and premature. Referring again to the sequential test they agree with CBRE that the applicants should have considered cross subsidy initiatives which could be achieved through arrangements involving other sites. They repeat their view that the proposal will damage the Westcroft District Centre but consider also that the vitality and viability of Bletchley Town Centre will be affected.

7.9 Three letters from local companies and 2 letters from a resident have

been received raising the following objections:-

• The development is contrary to the adopted Local Plan designation for recreation and leisure.

• In the First and Second Deposit Local Plans the land is retained for recreation, open space and employment.

• To grant permission for large scale leisure, retail and commercial uses would be contrary to adopted and emerging Local Plan policy.

• The Council own the land and have a prejudicial and pecuniary interest.

• A development of this scale would seriously harm the amenities of residents and businesses in the area.

• The traffic implications would be great upon surrounding businesses.

• The large food store and retail warehouses would seriously undermine the viability of the Bletchley town centre, which the Council is seeking to regenerate.

• A stadium/arena provision is best suited at The Bowl. • There is no need for retail development of this scale. • To demolish existing buildings after such a short life is a waste of

previous resources. • The Council have their mind on the planning gain. • The town has enough superstores and Tesco dominate. ASDA

would be good for competition but only if one Tesco disappeared. • The town has enough drive through restaurants, filling stations and

fitness centres.


• Any football stadium should be sited at the existing Wolverton site. • Enabling development is contrary to guidance in PPG6, para 3.24. • If additional retail development can be justified, it should be located

within existing retail locations, to maximise the opportunity for linked trips.

• The size of the enabling development will have a great impact on the Kingston centre.

• Access is from Saxon Street or Grafton Street/Bletcham Way. At peak times the Saxon Street/Bletcham Way roundabout becomes very congested. On a Saturday when the stadium, Asda and DIY store will be busy, it is conceivable that up to 50,000 visitors will arrive by road.

• Traffic pressures will increase on the already busy V7 from Bletchley to H7 which needs duelling.

• Denbigh North should be developed but roads, cycleways and footpaths should be improved before development commences, and the developers should bear a significant proportion of the costs. The required improvements include dualling V7 from H7 to H10, dualling V4 from V6 to H8, dualling V6 from V4 to A5 roundabout, constructing the missing link from Mount Farm V8 roundabout to H10, dualling H10 from V7 to A5 north of Fenny Lock, re-thinking the double mini roundabout at Watling Street/Saxon Street, and a road link from the stadium to Bletchley station.

7.10 A letter has recently been received from one of the above local

companies saying that, although the development is contrary to both adopted and emerging Local Plans, if the planning gain are substantial and the scheme would not undermine the regeneration of Bletchley, most of the scheme would be acceptable. He is still concerned however that the scheme would harm existing hotels and conference facilities in the area.

7.11 One letter from a local business supports the development of a

stadium, which provides a major project as a catalyst for the Bletchley area, and a vital missing part of the city’s social infrastructure. If Milton Keynes is to grow in a balanced and sustainable way established locations such as Bletchley should not be neglected. All major schemes focus over recent years on CMK. The comprehensive stadium scheme can be the catalyst for renewed prospects for the Bletchley area. To reject the scheme would condemn the area to a downward spiral.

7.12 The applicants have written to say that they conducted their own

public consultation exercise. This is understood to have taken the form of an exhibition in the MK Central Shopping Centre, where visitors were invited to fill in cards asking if they were generally in favour or opposed to the Stadium MK and ASDA development proposals, having been appraised of the benefits. The results were:-


(a) Returned Cards In favour of the proposed development – 1937, (89% of the total response) Against the proposed development – 235, (11% of the total response)

(b) Emails In favour of the proposed development – 122, (81% of the total response) Against the proposed development – 25, (19% of the total response)

An analysis of the reasons for the people opposing the scheme provides the following breakdown:

• Football hooliganism, 21% • No comment, 21% • Yes to ASDA, No to stadium 16% • Enough supermarkets already, 14% • Traffic concerns, 9% • Want a local team – not Wimbledon 6% • Adverse impact on Bletchley, 5% • Additional local costs, 5% • Wrong location, 3%

7.13 A letter was received on 21st November from agents acting for

Tescos which, among other things, expressed concern that the Council are seeking to determine the stadium application in advance of the closure and reporting of the Local Plan Inquiry. Determination of the application, they say, would be premature and could prejudice the outcome of the Inquiry.

8.0 CONSIDERATIONS

This section of the report sets out and comments upon the main factors and arguments which need to be taken into account in dealing with the application and includes details of the proposed contents of a Section 106 Agreement. The section comprises: • Context of the application from the applicants viewpoint. 8.1 • Government Policy on Town Centres and Retailing. 8.2 • Government Policy on Transport. 8.3 • Government Policy on Sport and Recreation. 8.4 • The Local Plan Context. 8.5 • Policy L13. 8.6 • Sustainability and Visual Quality. 8.7 • Summary of matters to be included in a Section 106 agreement.


8.1 Context of the application

The planning application has been submitted in the context of the site at Denbigh North being identified in the emerging Local Plan under Policy L13 as being appropriate for a multi-use sports and spectator events stadium/arena. Denbigh North is now seen as being the only suitable site for the stadium. On site enabling development is referred to in the Policy and will be allowed provided it does not significantly undermine the vitality and viability of Bletchley town centre.

The applicants have confirmed that the objectives of the development

are twofold. Firstly, they say the introduction of the Stadium/Arena will provide

Milton Keynes with a major sports and spectator venue, and bring top quality professional football to it from the outset. The need for a stadium was identified in the early stages of planning the new city in 1973. In 1999, the Denbigh North site was the site identified by the Council’s consultants, Chesterton, as the one best able to accommodate such a stadium, together with enabling development. The city has now grown to a population size of approximately 210,000 (Source: 2001 Census) and recent pronouncements from ODPM mean that large scale growth in the future is almost inevitable. Securing the relocation of a First Division football club would be a major achievement for the city and provides a major incentive for the delivery of the Stadium.

Secondly, they say, the development will give impetus to the

programme for the regeneration of Bletchley Town Centre. There is general recognition of the fact that this centre has progressively declined since Central Milton Keynes started to be developed in the late 1970s. A first phase regeneration study was undertaken by EDAW in 1999, and a second phase study by the same consultants is currently under way and shortly to be published for public consultation The regeneration of the Town Centre is a strategic objective of English Partnerships.

Whilst the stadium scheme itself is considered by the applicants to be a

major catalyst for the regeneration of Bletchley Town Centre, they also consider that it should not be seen in isolation. In particular, it has been designed with regard to the plans for the development of Bletchley Park and the upgrading of Bletchley Station.

The Stadium is being constructed at a significant cost (at present it is

estimated at being around £55 million). Once in operation, the stadium is unlikely to generate significant revenue beyond that required for its ongoing operation. Hence, the capital cost must be covered by external funding.


Various possible funding options have been examined, but it is understood from the applicants that the only available one is enabling development. This conclusion corresponds with the conclusion of Chesterton when they undertook their viability study for the Council and English Partnerships in 1999.

A number of possible forms of enabling development have been considered. The applicants have produced a valuation report to demonstrate that the only one that generates the required value is the one that is now proposed, which is an Asda-Walmart Supercentre and a non-food retail (DIY) store together with the media village and two drive-through restaurants. Other types of development, such as non-food retail and/or housing, do not generate sufficient value to enable the stadium development.

The applicants have drawn attention to a number of precedents for sports stadia being enabled by major retail development. One is Warrington RLFC, where the Secretary of State granted permission in December 2001 for a large Tesco store on an out-of-centre site, on the basis that he was satisfied that it was enabling development essential to securing a much-needed new stadium for the principal local sports club. Another is Arsenal FC, where some 13,000m2 of retail/leisure floorspace (together with other development) has been permitted by the London Borough of Islington, out of centre, on the basis of it enabling the building of a new stadium and a large-scale regeneration scheme around it. A third is East Manchester, where an Asda-Walmart Supercentre (very similar to that proposed at Denbigh North) was allowed out-of-centre as enabling development required to secure the Commonwealth Games stadium (now being converted to its long-term use as the home of Manchester City Football Club). A fourth, very recent precedent is the new stadium for Cardiff City F C, to be enabled by nearly 4,000 m2 of retail space in an out-of-centre location. This has been approved by the local planning authority and endorsed by the Welsh Assembly during the last few weeks.

8.2 Government Policy on Town Centres and Retailing.

8.2.1. This is set out mainly in PPG6 and was clarified in a Parliamentary

Statement on 10th April, 2003.

8.2.2 Key features of the above guidance include the need to:

• Sustain and enhance the vitality and viability of town centres • Adopt a “sequential approach” to selecting sites for development

for retail, employment, leisure and other key town centre uses • Adopt a plan-led approach to promoting development in town

centres, both through planning policies and the identification of sites for development

• Promote more sustainable transport choices and reduce the need to travel, especially by car.


• Promote more mixed – use development and retention of important town centre uses

8.2.3. The Parliamentary Statement can be summarised in the following terms.

Policy Tests

The purpose of the policy is to sustain and enhance the vitality and viability of town and other existing centres by focusing retail, leisure and other key town centre uses, which attract a lot of people within those centres. PPG6 emphasises the plan-led approach to promoting development in town centres, both through plan policies and the identification of locations and sites for development. It sets out a number of tests that must be satisfied if applications to develop retail or leisure facilities are to be successful. In summary, applicants must:

• Demonstrate that there is a need for the development; • Having established that such a need exists, adopt a sequential

approach to site selection; • Consider the impact on nearby centres; and • Provide evidence on the site’s accessibility by a choice of means

of transport, as demonstrated by a transport assessment (see PPG13), the likely changes in travel patterns over the relevant catchment area, and any significant environmental impacts.

All these tests apply equally to proposals for extensions as well as to new developments.

Need

Proposals which would be located at an edge of centre or out of centre location and which:

• Are not in accordance with an up to date development plan

strategy; or • Are in accordance with the development plan but that plan is out of

date, is inconsistent with national planning policy guidance, or otherwise fails to establish adequately the need for new retail and leisure development and other development to which PPG6 applies,

Should be required to demonstrate both a retail need for additional facilities and that a sequential approach has been applied in selecting the location for the site.

The Government recognise need can be expressed in quantitative and qualitative terms, but they place greater weight on quantitative need for


new retail provision to be defined in terms of additional floorspace for the types of retail development distinguished in PPG6, which are comparison and convenience shopping.

For the avoidance of doubt, the First Secretary of State does not regard regeneration or employment creation as aspects of retail need for the purposes of the tests set out in PPG6 and subsequent statements but they may be a material consideration to be taken into account in determining a planning application.

Sequential Approach

PPG6 seeks to promote sustainable development by locating major generators of travel in existing centres, where access by a choice of means of transport, not only by car, is easy and convenient.

PPG6 requires a sequential approach to be adopted in selecting sites for new development. Both local planning authorities and develops should be able to demonstrate that all town centre options have been thoroughly assessed before less central sites are considered for development for key town centre uses. This means that the first preference should be for town centre sites, followed by edge of centre sites and only then out of centre sites in locations that are accessible by a choice of means of transport.

Where a class of goods is capable of being sold from a town centre location, that is the preferred location for the retail development and he will expect to see flexibility in the scale and format of a proposed development to meet that objective. A retailing format that can only be provided at an out of town location is not regarded as meeting the requirements of this policy.

Bulky Goods

PPG6 recognises that some types of retailing, such as large stores selling bulky goods, may not be able to find suitable sites either in or on the edge of town centres. The Government considers that it rests with developers and retailers to demonstrate that a majority of their goods cannot be sold from town centre stores. Developments involving the sale of bulky goods are not exempted from meeting the policy tests in PPG6 and subsequent clarifications.

8.3 Government Policy on Transport 8.3.1 This is contained in PPG13 which sets out as its objective the

integration of planning and transport at all levels of Government to:-

• Promote more sustainable choices for people (and freight) • Promote accessibility to jobs, shopping, leisure facilities and

services by public transport, walking and cycling, and


• Reduce the need to travel, especially by car. 8.3.2 The guidance note advises Local Authority (among other things) to

• Actively manage the pattern of urban growth to make the fullest use of public transport, and focus major generators of travel demand in city, town and district centres and near to public transport interchanges.

• Ensure that development comprising jobs, shopping leisure and services offers a realistic choice of access by public transport, walking and cycling.

• Give priority to people over ease of traffic movement and plan to provide more road space to pedestrians, cyclists and public transport.

8.3.3 PPG13 also refers to the promotion of the vitality and viability of Town

Centres and emphasises the sequential approach in similar term to the Parliamentary statement mentioned at Para 8.2.3 above.

8.4 Government Policy on Sport and Recreation 8.4.1 PPG17 sets out the Governments policy on sport and recreation and in

particular provides national policy guidance on stadia and the loss of playing fields. Planning permission for stadia accommodating large numbers of spectators should only be granted when the area to be located in areas with good access to public transport. Planning permission for additional facilities such as retail and leisure uses should not be granted for out-of-centre developments unless they comply with the policy in PPG6 Town Centres and Retail Developments.

8.4.2 PPG17 encourages Local Authorities to undertake robust assessments

of existing and future needs of their communities for open space sports and recreational facilities. (Milton Keynes Council has adopted on April 2003 a Leisure Facilities Strategy 2003 – 2008 and has prepared a Playing Pitch Strategy in June 2003)

8.4.3 PPG17 advises that existing playing fields should not be developed in

advance of an assessment unless.

(i) the playing fields that would be lost as a result of the proposed development would be replaced by playing fields of equivalent or better quantity and quality in a suitable location.

(ii) The proposed development is for a sports facility of sufficient benefit to the development of sport to outweigh the loss of the playing field.


8.5 The Local Plan Context 8.5.1 PPG1. Para.40 advises that where an adopted or approved

development plan contains relevant policy, section 54A of the Town and Country Planning Act 1990 requires that applications be determined in accordance with policies in the Development Plan unless material considerations indicate otherwise. The adopted Local Plan is the Borough of Milton Keynes Local Plan 1995 (MKLP). This contains no policy relating to the development of a football stadium as it predates recent work on the provision of such a stadium at Denbigh North, which has been included as part f Policy L13 in the emerging Milton Local Plan Second Deposit Version 2002 (DV2) and which is currently the subject of a Public Inquiry. The Adopted Local Plan is therefore of limited relevance in this case in that it contains no policy relating to a stadium at Denbigh North but other policies listed in section 5 of this report are still relevant.

8.5.2 MKLP policy SH2 identifies Bletchley Town Centre as a district centre where new developments and/or redevelopment proposals which increase the amount of shopping floorspace will normally be permitted.

Policy SH8 identifies the Watling Street/Saxon Street of Bletchley and redevelopment sites within Bletchley town centre as locations where planning permission for retail warehousing will normally be granted. Policy SH10 Planning permission will normally be refused for major retail development on sites that have not been allocated for retail purposes on the proposals map, unless they satisfy the following criteria. - proposal will not seriously affect the vitality and viability of any

nearby town centre as a whole This issue is dealt with later in this section of the report.

8.5.3 With regard to leisure policies in MKLP no material conflict is seen, taking into account the significant proposals for provision of enhanced sports facilities at Derwent Drive and Manor Fields, described under section 8.6.4 below.

8.5.4 An objector has made representation against the hotel aspect of the

scheme. Policy LR18 allocates specific sites for hotel development and Denbigh North is not one of them. The policy does not, however, preclude Hotel developments elsewhere in this borough and it is not considered that there are supportable planning objections in principle to the hotel aspect of this application. A hotel close to the stadium could prove a useful benefit for spectators and possibly performers too.

8.5.5 No significant conflict is seen with other policies in MKLP, subject to

transport issues being resolved. See 8.6.1 below.


8.5.6.The emerging local plan is a material consideration but the weight

attached to it should reflect the stage in the process that it has reached. Paragraph 48 in PPG1 provides the following advice regarding the weight that may be afforded to emerging local plan policies:

‘Planning applications should continue to be considered in the light of current policies. However, account can also be taken of policies in emerging development plans which are going through the statutory procedures towards adoption (or approval). The weight to be attached to such policies depends upon the stage of plan preparation or review, increasing as successive stages are reached.’

Where a plan has been deposited but no objections have been lodged to relevant policies, then considerable weight may be attached to those policies because of the strong possibility that they will be adopted (or approved) and replace those in the existing plan. The converse may apply if there have been objections to relevant policies. However much will depend on the nature of those objections and also whether there are representations in support of particular polices’.

8.5.7. The emerging Milton Keynes Local Plan, Second Deposit Version

(DV2) is currently the subject of a Public Inquiry, due to end in April 2004. The Inspectors report on the Plan will take several months and it is unlikely that the plan will be adopted before late 2005. This Plan contains a number of policies relevant to this application and theses are also listed at Section 5 of this report. There is a specific policy in that Plan (Policy L13) devoted to Denbigh North. This policy was included in DV1 and was amended in DV2. There are 22 objectors to this policy in DV2 but few of these relate to the principle of a stadium on the site; the majority are about the wording of the policy. Nevertheless the weight which can be afforded to Policy L.13 is not as great as an adopted Local Plan policy which has undergone the full statutory process. Taking all the above matters into account it is considered that in this particular case DV2 carries more weight than the Adopted Local Plan, and hence it is relevant to examine the application in further detail against this policy

8.6 DV2 Policy L13 8.6.1 Multi-purpose sports and spectator events stadium

This policy states that planning permission will be granted for a multi-purpose sports stadium at Denbigh North provided that:-


• The proposal would not result in additional traffic inappropriate to or exceeding the environmental or highway capacity of the local road network

• The proposal would have no significant adverse effect on the amenity of residential areas.

• The proposal clearly indicates how development could be phased to

increase the capacity of the facility to a stadium capable of accommodating at least 40,000 people.

• In the case of existing recreation facilities being lost, equivalent

replacement facilities are provided

On-site retail enabling development will be allowed provided that: (a) It would not significantly undermine the vitality and viability of

Bletchley Town Centre (b) The potential social and economic benefits arising out of the

development of Denbigh North are fully taken into account.

Planning applications for stadium proposals should be accompanied by a transport assessment and may also require a full environmental impact assessment. The four bullet points above are dealt with in order below, followed by comments on (a) and (b).

8.6.2 Traffic and Highway Capacity

Following the submission of the application and the Transport Assessment that accompanied it a number of concerns were raised, not only by the Council but also by the Highways Agency in relation to the A5 Truck Road. The Highways Agency met the applicants transport consultants in June and requested that more work be carried out to demonstrate that the proposal would not generate traffic on the trunk road that would be incompatible with its use as part of the national system of routes. On 19 September HA directed the Planning Authority not to grant permission in an Article 14 direction valid until February 2003. This was issued because they had not received the required supplementary information. Additional information has more recently been submitted in two batches and further discussions have taken place with the applicants new transport consultants. The Council’s reservations (see 6.15) have been the subject of extensive discussions between the Councils officers, the applicants and their consultants and considerable progress has been made.


Clearly, however there are still some matters that require resolution and discussions are continuing. The table at 6.15 above sets out the position at the time of writing this report and indicates that there is still work to do in agreeing: • Contributions to public transport enhancements • Design of the Park and Ride area • Details of the pedestrian/cycle routes to Bletchley Town Centre

and West Bletchley • Contributions to junction improvements • Traffic management arrangements • A ‘trigger’ crowd level at which the Park and Ride facilities revert

to providing parking for the stadium.

Members will be updated on these issues at the Committee meeting.

8.6.3 Amenity of residential areas

The site is surrounded by grid roads beyond which are mainly commercial uses. Granby Court to the west is about 150m from the site at its nearest point and 400 metres from the proposed stadium. The Granby Residents Association are opposed to the application citing access problems, parking difficulties, noise problems, violence, damage and rubbish. The applicants have agreed to submit a traffic management and spectator plan and this should deal with the first two issues. Any noise problem will be infrequent and intermittent. They will in any case be the subject of a stadium management plan, to be agreed with the Council. The last three issues are not strictly planning issues and are subject to control under other legislation.

8.6.4 Phasing

The application states that allowance has been made in the design for expansion up to a capacity of 42,000 for sporting events and 47,000 for spectator events.

8.6.5 Recreation Facilities

Much of the site is currently occupied by playing fields, providing 6 senior football pitches, 1 junior and 1 mini football pitch, 2 cricket pitches, and 1 Gaelic football pitch with pavilion. The southern part of the site contains commercial leisure uses including The Sanctuary nightclub, the Children’s Activity Centre and indoor go-kart track. The stadium proposal will include a community hub, including a children’s activity and learning centre, and arena for 6,4000 spectators, in addition to the stadium for 30,000 for sports events / 35,000 for spectator events.


Sport England are a statutory consultee on developments involving the loss of playing fields, and has had close involvement in the development of the emerging Milton Keynes Playing Pitch Strategy. Sport England appreciates Milton Keynes’ desire and commitment to develop a multi-use stadium, and welcomes the principle of this application and the related direct and indirect benefits to sport that it will bring to the local community. Nevertheless, as the stadium and enabling development is proposed on playing field land, Sport England has considered the application in light of its Playing Field Policy, whose aim is to ensure an adequate supply of quality pitches to satisfy current and future demand for sports pitches within the area. While MK Playing Pitch Strategy indicates a overprovision of senior playing pitches, an under provision of both junior and multi pitches is recorded. In addition, the general quality of pitches and changing accommodation is often poor throughout Milton Keynes. The strategy suggests that the loss of 6 senior pitches would not have a significant impact. Nevertheless, the loss of an extensive area of playing field land, which Sport England believes to be of above average quality for Milton Keynes, does represent a significant impact on the ability of the area to adequately cater for future demand both in terms of the quantity and quality of provision. As part of their involvement with the MK Playing Pitch Strategy, Sport England agreed with MKC that appropriate mitigations should be two fold and cover a contribution towards:-

(i) new or enhanced playing field provision within the area, likely to

focus on improved drainage, creation of mini and junior pitches and changing facilities to enable increased usage of the playing field land at Tattenhoe Lane, Bletchley and

(ii) the upgrading or relocation of Bletchley Leisure Centre.

Consequently Sport England does not wish to raise an objection to the principle of the proposed development, but is unable to clarify this position until the extent of the contribution required to meet the established nature of the mitigation is agreed by all parties.

Negotiations have taken place with the applicant concerning the nature and extent of the required enhancements to other playing fields and facilities within the Bletchley Area including:-

(i) Manor Fields – Improvements to clubhouse, provision of Gaelic

football pitch for the relocation of the Irish Club. (ii) Tattenhoe Lane Sports Ground/Bletchley Youth Club – redesign

the sports field layout, improve drainage and provide changing rooms.

(iii) Financial contribution to Bletchley Leisure Centre.


With regard to Manor Fields the applicants have agreed to restore the clubhouse to a specification to be agreed by the Council and to provide a Gaelic football pitch for the relocation of the Irish Club. Similarly senior and junior pitches at Derwent Drive together with new changing rooms and other enhancements would be provided by the applicants at their expense, to a specification and to a timescale to be agreed with the Council. Discussions on these two issues have been ongoing and their successful completion would be ensured by a Section 106 agreement. It is understood that the applicants contribution to the refurbishment or replacement of the Bletchley Leisure Centre would take the form of a contribution of £25,000 towards a feasibility study. This too would be the subject of a clause in the Section 106 agreement.

8.6.6 Vitality and Viability

This is a complex issue and a most crucial one for Members to face in coming to a conclusion on the application. To reach such a conclusion it will be necessary to understand the policy background and sequence of events leading to the present wording of Policy L13 in DV2. This is set out in detail in Appendix A to this report. Appendix A starts with four key questions and then sets out the relevant material to enable answers to be deduced. These questions are discussed below.

8.6.6.1Does the enabling retail development for the multi-purpose Sports and Spectator stadium comply with relevant National and Local Planning policies PPG6, PPG17?

The recent Parliamentary statement in summary: sets out that applicants must show there is a need for the development; if there is a need a sequential approach should be adopted to site selection; they should then consider the impact on nearby centres and then provide evidence of the sites accessibility by a choice of means of transport and any significant environmental impacts. According to the work done by the applicants consultants (RPS) by 2005 (the expected year of opening of the proposed retail units), a need for £105.36m of additional comparison goods floorspace is identified (compared with an estimated comparison goods turnover of the proposed shops of £28.03m). By the same year, the need for additional convenience goods floorspace is estimated at £66.14m (compared with an estimated convenience goods turnover of the proposed Asda Wal-Mart supercentre of £36m).


The Council’s retail advisers CBRE have concluded that the applicants have not demonstrated a present need for the retail development which, in CBRE’s view could not be supportable in terms of expenditure on convenience goods until about 2007/8 and that if the ASDA store is built any additional convenience floorspace in Bletchley Town Centre would not be supportable until 2010/11. On need, the point is made by the applicants that the proposed stadium and its enabling retail/commercial development have always been conceived as integral parts of a single entity. Furthermore, the retail/commercial development is needed to achieve a vibrant environment around the stadium; the car parking is to some degree to be shared between the uses; and the whole scheme relies upon the economics of retailing of this scale and nature to achieve the necessary ‘enablement’. Hence, the sequential testing focuses upon sites capable of supporting an integrated scheme of a similar nature. It is noted that a similar approach was endorsed by the Secretary of State in granting planning permission for an integrated stadium/retail scheme in Warrington (anchored by a large Tesco store), and officers are aware that a similar approach has more recently been adopted in Cardiff (endorsed by the Welsh Assembly) in relation to another stadium scheme enabled by retail development including a large Tesco store. The Council’s advisers (CBRE) conclude that the applicant’s sequential approach assessment is sound as far as it goes but, because it does not address the possibility of off-site enabling development, it does not comply with the sequential approach. They say that a full sequential assessment would consider the possibility of a financial cross-subsidy mechanism that would enable the stadium to be separated from its enabling development. However, they say that if such a mechanism is considered by the Council and English Partnerships to be inappropriate or not achievable, RPS’ conclusions on the sequential approach are sound. On impact, CBRE predict a 6.5% impact on Bletchley town centre (compared with RPS’ 5.8%), rising to 8.4% if it is assumed that two new foodstores are built in Central MK. However, even with the highest of these figures, CBRE conclude that the impact is unlikely to cause closure of any of the main anchor stores in Bletchley town centre though it will tend to undermine its vitality and viability to some degree. CBRE accept RPS’ claim that the Denbigh North development would be likely to bring regenerative benefits to Bletchley, some of which may help to improve the vitality and viability of Bletchley town centre. However, they consider that the magnitude of these


benefits is impossible to predict and so, understandably, they avoid attempting any prediction. In terms of adopted Local Plan Policies on shopping the main test is Policy SH10 of the MKLP which says that major retail proposals on unallocated sites will normally be refused unless they (among other things) would not seriously affect the vitality and viability of any nearby town centre as a whole. This is discussed below.

8.6.6.2Does the enabling retail development accompanying this application significantly harm the vitality and viability of Bletchley town centre or any other centre?

The Council has been working for some time to promote a new foodstore on a site known as MK8 in Bletchley Town Centre, the subject of Policy TC15 in DV2 while policy TC16 names the provision of a new foodstore as a priority for improving the Town Centre. Recently the Consultants EDAW, commissioned by the Council, EP, SEEDA and the Bletchley Development Board have been developing a proposal to achieve an enlarged foodstore together with further comparison shopping on an extended Brunel Centre to the south of Queensway and Chandos Place. The Councils retail consultants take the view that the Denbigh North scheme will be likely to bring some social and economic benefits to Bletchley Town Centre but that the magnitude of such benefit is unlikely to be as great as the alternative of developing a new, or substantially enlarged foodstore in the town centre itself. Their assessment shows that, if the ASDA store is built, there will be a significant delay until 2010/11 in achieving the Town Centre food store. The applicants say that the scheme shown in DV2 (site MK8) is unlikely to be taken forward and that the scheme is likely to be replaced by another scheme that will not be implementable for a number of years due to the requirement to assemble a site and overcome constraints. (The EDAW proposal). Hence, they say the Denbigh North scheme can be seen as ‘filling the gap’ pending the implementation of a town centre scheme a little later in time. The Council is therefore faced with a situation where it is trying to improve the vitality and viability of the centre which includes the need to encourage more and better shopping, whilst knowing that the erection of a large store on the stadium site may to some extent have the opposite effect, at least for the immediate future.

8.6.6.3 Is there any realistic prospect of a new food store being provided within Bletchley Town Centre within the near future?

Site MK8, is identified for a foodstore in DV2. So far little progress has been made towards its achievement though Morrisons have


submitted a strong objection to the ASDA proposal, based on what they say is a firm interest in site MK8. The Bletchley Town Centre Regeneration Study, has not yet been published but it is understood that an alternative proposals for a food store and other modern retail units is likely to be put forward by the consultants, EDAW on the site currently occupied by Sainsburys the Brunel Centre and certain properties south of Chandos Place. If the Council favour this suggestion in preference to MK8 it follows that DV2 would need to be amended to accommodate it. Clearly it is too early to say whether either of these proposals will be realised but both require land assembly and therefore neither is likely to get started on site for at least two years. The policies in both adopted and emerging Local Plan would indicate a strong preference for retail developments within Bletchley Town Centre and much work has gone into those policies (see Appendix A). In isolation retail development at the Stadium site would not find much favour, but it is known that funding for the new stadium relies on enabling retail development.

8.6.6.4. What weight and priority does the Council give to retail development accompanying the stadium proposal verses retail development within Bletchley town centre?

Members will need to judge from the above information how far the proposals comply with Government and Local Plan Policies. The Council have invested much time and effort into preparing plans and policies to enhance Bletchley Town Centre and protect other centres from the adverse impact of out-of-town centre retail proposals. There is a need to weigh the obvious benefits of the Stadium against any adverse impact on current centres.

8.6.7 Social and Economic Benefits

The social and economic benefits of the proposal, referred to by the applicants (see section 8.1 above) are principally bringing a national league football club to the city and helping to regenerate Bletchley Town Centre. With regard to the first of these it would undoubtedly be seen by some residents as beneficial to be able to see high class football matches without travelling outside the city. The nearest football league clubs are currently Northampton Town, Luton Town, Oxford United and Rushden and Diamonds. The presence of professional football in this city will help give a sense of identity to Milton Keynes which is one of the largest settlements in Europe without a professional football club.


Already Wimbledon F.C. has commenced a “football in the Community” programme (FITC) coaching children in Milton Keynes, which they say has already reached 20000 children and 70 schools in the Borough. The target is to involve 40000 children over the next 12 months. Another social benefit is the development of a Study Support Centre, in liaison with Countec, a learning resource for children outside of school hours. Further social benefits will accrue by the provision of facilities at the stadium for concerts and other events and from the separate, roofed performances area at the southern end of the complex. Members should however also be aware of the negative social impacts on local people, mentioned in the DTZ report (see para 6.10) and the FSC comments (para 6.6), namely increases in disorder and car thefts and a ‘rippling negative traffic impact’. The Granby Residents Association has also picked up on these issues. A spectator plan, aimed at mitigating these adverse effects should,, if permission is to be granted, be required by condition or preferably in a Section 106 agreement. On balance the social benefits are considered to outweigh the negative social impact subject to appropriate measures being in place to ensure a Spectator Plan is implemented. In economic terms the key effects are job creation and the spin-off benefits or dis-benefits to Bletchley Town Centre. Gross employment created by the Development would be 2,394 FTE jobs. Allowing for displacement from existing jobs and assuming 50% are employees from outside the area it is estimated that net additional local employment would be 652 of which 60 will be indirectly generated by increased economic activity outside the site. In addition, 1,380 temporary construction jobs would be created. The applicants have agreed to recruit locally wherever possible and a clause to this effect is included in the draft section 106 agreement. Clearly the creation of additional jobs and commercial activity at this site will be seen to be an economic benefit, even though unemployment in Milton Keynes is low. The issue of impact on the retail vitality and viability of the rest of the Borough and particularly of Bletchley Town Centre at 8.6.6.2.

8.7 Sustainable Development 8.7.1 The Government is committed to the principles of Sustainable

Development and issued a strategy in 1994. The Strategy recognises the important role of the planning system in regulating


the development and use of land in the public interest. A sustainable framework should: • provide for the nation’s needs for commercial and industrial

development, food production, minerals extraction, new homes and other buildings, while respecting environmental objectives;

• use already developed areas in the most efficient way, while making them more attractive places in which to live and work;

• conserve both the cultural heritage and natural resources (including wildlife, landscape, water, soil and air quality) taking particular care to safeguard designations of national and international importance;

• shape new development patterns in a way which minimises the need to travel

The Government’s Planning Policy Guidance notes set out the planning framework within which local planning authorities are required to draw up their development plans and take decisions on individual applications to secure these objectives.

Urban regeneration and re-use of previously-developed land are important supporting objectives for creating a more sustainable pattern of development. The Government is committed to concentrating development for uses which generate a large number of trips in places well served by public transport, especially in town centres, rather than in out of centre locations, and preferring the use of urban land to Greenfield sites.

In relation to this application sustainable development principles

need to be considered against three main headings: Sustainable construction and building methods; Sustainable transport and the natural environment.

8.7.2 The emerging Local Plan (SDV) policy D4 includes the following

requirements for developments that exceed 5 houses or 1000 sq.m. of other buildings.

• Improved energy efficiency through siting, design and orientation, to achieve an energy rating equivalent to 10 on the NHER scale

• An element of renewable energy production • Water conservation measures • Sustainable urban drainage systems such that there is no

increase flood risk and no significant impact on local hydrological conditions

• The significant use of building materials that are renewable or recycled.

• An element of construction waste reduction or recycling. • Carbon neutrality or financial contributions to a carbon offset

fund to enable carbon emissions to be offset elsewhere.


The application includes in the Environmental Statement a sustainability appraisal and explains how the development has been assessed against the Building Research Establishment Environmental Assessment Method (BREEAM). The assessment consists of an environmental rating system covering Energy, Transport, Pollution, Materials, Water, Ecology/Land Use and Health. It is however a flexible system which allows the applicable elements of the system to be applied to a particular development. The final stage of the assessment involves awarding an overall rating to the development which should consists of one of the following: Pass; Good; Very Good and Excellent The applicants state that their objective for the buildings is to achieve a BREEAM rating of Very Good. Provided that this objective is achieved it is considered that the development will meet the Councils sustainability objectives in respect of building construction. To ensure that the “very good” standard is pursued and achieved a clause should be included to this effect in the Section 106 Agreement.

8.7.3 The second main sustainability issue the Committee needs to consider is that of Transport. The principal objectives of PPG13 are to integrate planning and transport at the national, regional and local level to:

• promote more sustainable transport choices for both people and freight.

• promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling and

• reduce the need to travel, especially by car.

The site is 1.9 km from Bletchley Railway and Bus Stations and 4 km from Milton Keynes Central Bus and Rail Stations. It is served by a number of bus routes and the applicants have offered £775,000 towards the improvement of Public Transport. The applicants have included the following list of measures or factors that will help to encourage non-car modes:

• Creating a Redway (pedestrian and cycle route) connection to

Bletchley Town Centre, Bus Station and Railway Station including a traffic signal junction on the H10 Bletcham Way;

• Well-lit and attractive routes throughout the site connecting to existing Redways to the northwest, northeast and east as well as the new Redway to the southwest;

• Providing cycle parking in close proximity to principal buildings on the site; and

• Providing changing and showering facilities for employees. • Providing a bus loop into the site to enable pick-up and drop-off

at the proposed development;


• Providing a park and ride facility with the potential to service Bletchley Town Centre, Central Milton Keynes and Milton Keynes Central Railway Station;

• The opportunity to provide a “hopper” bus between the proposed development site and Bletchley Town Centre;

• Providing extended bus stops with shelters and raised kerbs, and telephone and electricity connections to facilitate real-time information as part of the Council’s city wide bus strategy;

• The opportunity to provide an additional stop for the X15 express service currently passing the site; and

• The opportunity to provide “all inclusive ticketing” for events, which would include bus travel as part of the admission price.

• Bletchley Railway Station on the West Coast Main Line and the east-west link to Bedford is located within walking distance;

• The site is serviced by numerous buses linking it to Central Milton Keynes Railway Station only 4km away.

• Employing a Green Travel Co-ordinator to encourage alternative travel methods for employees on the site.

The issue that is not addressed by the above list is the deterrent effect

of reducing parking provision. For the Stadium 2000 car parking spaces were first proposed, which equates to the maximum provision (1:15) advised in PPG13 for a 30,000 capacity stadium. Based on the MKC draft parking standards 1:18, 1666 spaces would be required. The application does not quantify the amount of off-site spaces which are likely to be available, in the surrounding commercial area. This is at present an unknown quantity as is the number of times that a capacity of 30,000 people will occur.

In order to cut down on the use of motor vehicles there should be some deterrent for motorists as well as good provision for other transport methods. Other clubs with new grounds operate with much lower ratios e.g. Derby 1:84 and Leicester 1:66.

A reduction in the levels of on-site parking provision could: • Reduce land take and so facilitate retention of some presently

mature landscaping features and wildlife corridors which are currently shown as removed.

• Improve the external appearance of the site. • Encourage a greater number of visitors to utilise public transport. • Avoid the unnecessary use of resources in constructing car parking

spaces which will remain empty for most of the time.

Discussions took place with the applicants following the first assessment of the application and as a result the number of spaces has been slightly reduced to 1944, though only 1763 would be implemented at the outset. The changes have resulted in re-instatement of landscape features as set out below.


8.7.4 The third sustainability issue concerns the extent to which landscape features and wildlife resources are adversely affected on the one hand and their loss mitigated on the other. Mature trees are excellent absorbers of CO2 as well as being helpful in softening the stark visual effects of new development. The retention of semi-natural wildlife habitat is clearly essential to provide food, cover, nesting sites and so on for wildlife.

The applicants originally intended to develop the whole site (except the Media Village) in one phase and all of the present semi-natural habitat would have been lost. Clearly a new landscaping scheme will be implemented including not only trees but also water features.

It will be some time however before the new trees will be able to perform any useful function as a habitat for birds and of course the majority of the wildlife, invertebrates and mammals for instance, will not return. Members will be aware from earlier sections of this report chapters that these issues were raised by the Countryside Officer and by English Nature who have pointed out that the Wildlife Corridors are protected under policies in MKLP and DV2. English Nature were also concerned about the impact on the water quality and water level at the Mount Farm Lake wildlife site.

The view was taken that the initially proposed balance of the amount of development as against the loss of landscape and wildlife features did not comply with the Council’s sustainability expectations and that discussion should take place with the Council’s Officers with a view to retaining some mature landscape and wildlife features around or near the boundaries. This proposal would fit well with any requirement to reduce car parking and will assist with the visual effects discussed below. Discussions on the issue took place in October as a result of which revised plans were submitted. The main changes included the following, • A reduced footprint to the stadium to allow more of the site to be

left green. • A portion of the existing willow carr and pond habitat has been

retained on the western part of the site. • An existing watercourse is retained and partly re-routed and will

become part of a sustainable urban drainage system (SUDS). • Stands of mature trees will be left around the south east corner of

the scheme to provide a visual screen. • Vegetation will be retained along the eastern and northern

boundaries and a length of hedgerow would now be retained within the site, towards its northern end.

These changes have improved the scheme considerably and go some way towards answering landscape and nature conservation criticisms


8.7.5 Visual Quality.

MKLP and DV2 both include policies which require that developments should be well designed and relate well to the surrounding area and should include landscaping and boundary treatments that integrate with those of the surrounding area. By initially proposing removing all of the existing landscape and replacing it by buildings and or car parking which stretched in several places up to the site boundary, albeit with new landscaping being provided in the highway verges and within the development, the applicants were not complying with these policies. The result would have been stark and very urban and would contrast greatly with the effect achieved generally within the Milton Keynes area. particularly where developments are bounded by grid roads. The new landscaping scheme is extensive in that it involves the planting of a great many trees; nevertheless the trees would not have softened the impact for many years, nor would they do so at all in many boundary locations.

The changes made by the applicants, described above (8.7.4) are regarded as significant improvements to the visual quality of the scheme and have answered earlier criticisms.

8.8 Section 106 Agreement

Any permission that might be granted would be subject to a range of conditions to ensure that the development is carried out satisfactorily.

There are also other matters, mainly related to the provision of works

or facilities away from the site that will need to be the subject of a (Section 106) Planning Obligation Agreement between the Council and the other owners of the land. They all relate to issues covered elsewhere in the report, but for convenience they are listed below.

• Phasing of the stadium/arena to ensure that its provision is certain

before the enabling development is commenced. • A travel plan for each component of the Development, and a travel

plan co-ordinator • A traffic management and spectator plan • The provision at the applicant’s expense of replacement sports

facilities at Derwent Drive and Manor Fields • A stadium plan (controls over the operation of the stadium) • A local workforce obligation (to cover recruitment of employees

firstly from priority employment areas in the Borough) • Funding for a ‘hopper’ bus to and from Bletchley Town Centre -

£225,000 is offered • Enhancements to Service No.14 - £450,000 is offered • Provision of cycle and pedestrian links with Bletchley Centre and

West Bletchley at the applicant’s expense


• Signalisation at the applicant’s expense of the A5/Redmoor roundabout

• Improvements at ‘Elfield Park’, ‘Ashland’, Bond Avenue/H10, ‘Coffee Hall’, ‘Bleak Hall’, Watling Street/V7 and ‘Roman’ roundabout. So far £100,000 is offered.

• Street furniture and paving works in Queensway - £250,000 is offered

• Town Centre Manager for Bletchley Town Centre - £250,000 is offered

• Improvements to Bletchley Railway Station entrance - £250,000 is offered

8.9 Prematurity objection With regard to the letter from Tesco’s representatives (see 7.13 above),

legal advice will be given at the Committee meeting.

9.0 CONCLUSIONS 9.1 In accordance with Section 54A, planning applications should be

determined in accordance with the policies in the development plan, unless material considerations indicate otherwise. The development plan for Milton Keynes is the adopted structure plan and the Borough of Milton Keynes Local Plan adopted 1995, which makes no reference to a stadium in Milton Keynes (other than the Hockey Stadium).

9.2 The adopted Local Plan is being reviewed, and the Milton Keynes

Local Plan Second Deposit Version 2002 is currently undergoing its Inquiry. Policy L13 of the SDV promotes the provision of a multi-purpose stadium at Denbigh North, together with enabling development provided that it would not significantly undermine the vitality and viability of Bletchley town centre, would not result in traffic which would exceed the highway capacity, would have no significant adverse effect on residential amenity, and which provided replacement recreation facilities equivalent to those being lost. However there are unresolved objections to Policy L13, so that the weight that can be attached to this policy is less than if there were no objections to the policy.

9.3 PPG17, Para. 22, advises that planning permission for stadia should

only be granted in areas with good access to public transport. Planning permission for additional facilities such as retail and leisure uses should not be granted for any out-of-centre developments unless they comply wit the policy set out in PPG6.

9.4 PPG6 advises local planning authorities to adopt a plan-led approach,

consider the need for new retail and leisure development, and then if the need exists to adopt a sequential approach to identify suitable sites. PPG6 emphasises the plan-led approach to promoting development in town centres, to enhance their vitality and viability. Applicants must:


• demonstrate that there is a need for the development • adopt a sequential approach to site selection • consider the impact on nearby centres • provide evidence on the site’s accessibility by a choice of

means of transport.

Regeneration and employment benefits can be material considerations, but are not components of retail need. If a quantative need can be demonstrated for new retail and leisure, the sequential approach means that first preference should be for town centre sites, followed by edge-of-centre sites and then only out of centre sites in locations that are accessible by a choice of means of transport.

9.5 The development of the stadium and employment elements of the scheme are in principle supported, but the latest estimates by CBRE indicate that the need for additional floorspace will not be achieved until 2007/8. In addition, the provision of an out of centre retail superstore would be likely to delay the proposed plan-led development of a new food store in Bletchley town centre, by absorbing the available retail demand needed to support such provision until 2010/11. If the stadium proposal goes ahead it is therefore very likely that the provision of a new food store in Bletchley will be delayed by a number of years.

9.6 In the short to medium term, the proposed scale of retail floorspace

provision could have a negative impact upon the vitality of Bletchley town centre, and could set back a number of the regeneration initiatives currently being developed.

9.7 From the information currently available it is arguable that therefore the

application does not fully comply with national planning policy guidance in PPG17 and PPG6, or in some respects with the Second Deposit Local Plan policy L13.

9.8 The applicants have however demonstrated that the development of the

stadium will have large social benefits in terms of providing a strong community focus, enhanced facilities for sporting and spectator events, and through youth development programs. It can also be demonstrated that there will be economic benefits in terms of employment generation, and financial contributions to the enhancement of Bletchley town centre.

9.9 At the time of writing this report the Highways Agency has not

withdrawn an Article 14 direction which prevents the Council from issuing a permission until February 2004, unless it is lifted by the HA before that date. The Council’s Senior Highways Engineer is still discussing with the applicants some issues which are outstanding and need to be resolved.


9.10 Considerable improvements have been made to the scheme in the areas of nature conservation and landscaping, in response to earlier concerns about sustainability issues.

9.11 The principle of the stadium development is supported by Sport

England, subject to agreement on the re-provision of sports facilities which will be lost through the development. The applicant has agreed to provide such facilities to the Council’s satisfaction.

9.12 It is unlikely that there will be another opportunity to secure the

relocation of a first division football club to the city and it is also unlikely that the provision of a major sports and spectator stadium of this size could be achieved in the city without significant enabling development.

RECOMMENDATION At the time of writing this report some transport issues remained unresolved. Discussions with the applicants and their agents are continuing and an oral report will be made at the meeting on the latest position. The Committee with also receive legal advice with regard to the representations made on behalf of Tesco’s. If by the time of the Committee meeting the majority of the outstanding issues have been satisfactorily resolved or appear capable of being resolved quickly, the Committee may wish to indicate whether it is minded to grant permission, subject to suitable conditions, to the completion of a S106 agreement, to the satisfactory resolution of any remaining issues and to the withdrawal of the Highways Agency’s Article 14 direction. This would allow the application to be referred to the Secretary of State, via the Government Office for the South East, for him to decide whether he wishes to “call in” the application for his decision. Reference to the Secretary of State is necessary because the application is a departure from the operative Development Plan and because it is above the threshold specified in the Retail Direction. If the Committee is minded to grant permission it will be essential that the reasons for this decision are clearly specified and are reasonable, given the conflict with adopted Local Plan policies and Government Planning policy guidance. Possible reasons might include the significant benefits to Milton Keynes that a stadium would bring, benefits that the Committee may conclude can only be achieved via substantial on-site retail enabling development. Finally, if the Committee is minded to grant permission, they may wish to consider delegating the final decision to issue permission to the Head of Planning and Transport, in consultation with the Chair. This would minimise further delay, should the Secretary of State decide not to call in the application (assuming also that the Highways Agency’s Article 14 direction had by then been withdrawn).



Documents

03/00866/FUL COMPREHENSIVE DEVELOPMENT COMPRISING