VALP Main Modifications
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VALP Main Modifications
Representation ID: 3184
Respondent: Nash Parish Council
Legally compliant? No
The extent of the changes and the predicted need for early modification suggests previous consultations are invalid and an ineffective use of resources.
The introduction of Shenley Park (MMM076) is strongly opposed. It threatens the MK/AVDC boundary; promotes the extension of MK and could potentially destroy Whaddon Chase.
Alternative areas for MK development and boundary changes are suggested.
Comments on the VALP modifications based on the documents "MASTER Draft Submission VALP - FINAL with maps low res", 318 pages, "All modifications 011019", 169 pages, and "Corrections to Mod table rev 011019", 76 pages, from AVDC.
As a general observation, the extent of the changes, involving some 245 pages of notes, to an original document of 318 pages, surely strikes at the very heart of the validity of the VALP and distorts it to an extent where the previous public consultation is surely now invalid. The publicly acknowledged admission by AVDC that when approved VALP would have to be modified within 5 years, well before its expected scope termination of 2033, would seem to indicate that the whole exercise is a waste of time and resources. If this exercise is to be continued Nash Parish Council needs to register its dissatisfaction with the modification listed below in particular. This does not mean Nash Parish Council is in agreement with all the other modifications but merely that this change introduces the most glaring lack of consistency and connected planning in the 245 pages of changes.
MM076 introduces Shenley Park as a necessary site for over 1100 houses, with a potential of 2000, and also promises a defensible Milton Keynes boundary - which it clearly is not. Nash Parish Council rejects any proposal to develop this area.
The importance of a well-defined Milton Keynes boundary has previously been tested during the "development over the ridge" planning action in 2004, when the inspector supported the view that Milton Keynes development should not extend beyond the North Bucks Way. This boundary is included in the current Milton Keynes adopted plan, Plan:MK Adopted Version (March 2019), where it is further confirmed by policy to leave the area to the north of Shenley Park as open countryside. The importance of a well-defined boundary was reiterated in the VALP under the Salden Chase proposal, a paragraph since deleted under MM072, but reappears at several new points in the examination changes. Any development by AVDC, or the subsequent Buckinghamshire Unitary, on their side of the boundary produces an unsustainable situation where council tax and house build premiums are diverted to Buckinghamshire which should clearly go to Milton Keynes whose facilities will be used by residents of such development. Even rubbish collection will be inefficient, going only to the boundary from where another organisation continues. This can only lead in the long run to acknowledgement of the situation and the extension of the Milton Keynes boundary to include such development. Thus, far from providing a defensible boundary it actually promotes the extension of Milton Keynes. In the Shenley Park case, as the development fills the space between Milton Keynes and the Whaddon residential area, there would then be a good case to include the whole of Whaddon Parish within Milton Keynes, which would completely destroy the historic Whaddon Chase.
In a well-ordered planning system, it would be acknowledged that there will inevitably be areas on the edge of Milton Keynes where the original boundary was incorrect for political reasons, and now, due to developments, should logically be expanded. For example, in the Eaton Leys area, south of Milton Keynes, where Milton Keynes proposes to develop their part of what is logically a much larger development opportunity, the remainder is 'owned' by AVDC. Similarly, Newton Leys could logically be extended. But wherever AVDC places development on the edge of Milton Keynes it will produce conflict. Milton Keynes, as a separate planning authority, will have organised infrastructure to cater for only its own planned development. Developments close to Milton Keynes distort the approved local plans. A well-ordered planning system would acknowledge this and cede weak areas to Milton Keynes so that development is made to Milton Keynes standards, with taxes supporting the correct authority, and facilities and infrastructure supplied by the correct authority. In exchange AVDC should receive a credit for the house numbers Milton Keynes built on the land so they do not suffer the housing shortfall. Thus, where there is a strong logical boundary, such as Shenley Park, this should be maintained, and where the boundary is weak, such as the Eaton Leys, Newton Leys and Salden Chase, areas should be offered to Milton Keynes for development as Milton Keynes extensions in exchange for house number credit.
Nash Parish Council also believes that the legal grounds for introducing the Shenley Park development proposal at such a late stage are dubious. It is certainly an unfair and unjust move. The area has been selected in a panic driven bid to increase house numbers. It was previously rejected as unsuitable during the preparation of the VALP but is now proposed as the obvious choice with minimal investigation of the alternatives. The site sustainability has only been reinvestigated now after its selection. A current sustainability survey should have been made to compare alternatives in order to select the best not in order to confirm a dubious decision. At the very least this proposal should be given a public examination due to the far-reaching implications for the geographical area.