INTRODUCTION

  Development Land and Planning Consultants have been requested to make this submission on behalf of Hallam Land Management Ltd and William Davies Ltd with particular reference to the Deputy Prime Minister's comments regarding Milton Keynes. Our clients have interests in two areas of land which are considered to be fundamental to the future growth of Milton Keynes and as such to the achievement of the Deputy Prime Minister's stated objectives in his speech of 18 July 2002.

  The first area is to the east of the City and is contained by the M1 within the existing boundary of Milton Keynes and currently identified in the emerging Local Plan as "Strategic Reserve" land within The Eastern Expansion Area (EEA) of Milton Keynes. This is an area of land is within relatively few land ownerships and is capable of being brought forward on a phased basis starting if planning permission was granted in 2004 and would continue to provide dwellings to and beyond 2011. This site is identified as being developed in all of the scenarios of the Sub Regional Study and as such there can be little question as to the long-term development of the site it is more a question of both when and how. At present the site is identified as strategic reserve land to be brought forward as and when required. However it is our opinion that if the Deputy Prime Minister is to tackle the serious under provision that is occurring in the region at the present time then he should act to release development land in locations that are able to provide the ability to build new sustainable communities. As this area is already identified for future development his intervention to bring such sites forward in accordance with his stated role for Milton Keynes represents a positive action which could be regarded as actively attempting to resolve the problems identified in his speech of the 18 July 2002. By requiring the whole of the site to be planned comprehensively the Deputy Prime Minister could achieve an integrated and sustainable development.

  The second area of land in which our clients have an interest is "Area eight" at Bletchley. It is this land which forms a large part of another opportunity to rapidly deliver further sustainable communities for Milton Keynes, albeit land which falls within Aylesbury Vale District. The Milton Keynes and South Midlands Study 2002 recommends substantial westerly expansion of the city into Aylesbury Vale District in each of its spatial development options for growth. In reviewing the Buckinghamshire Structure (1991-2001), Milton Keynes Council (MKC), Aylesbury Vale District and the County Council jointly commissioned a study by Llewelyn Davis of land on the periphery of the city in order to identify expansion opportunities. The "Milton Keynes Expansion Study" identified this opportunity to the south of the city.

  It is our opinion that if the Deputy Prime Minister is to tackle the serious under provision that is occurring in the region then he should act to release development land in locations such as these which are able to rapidly deliver new sustainable communities. His intervention to bring such sites forward in accordance with his stated role for Milton Keynes represents a positive action which could be regarded as actively attempting to resolve the problems identified in his statement of the 18 July 2002. The statement underlines the importance of achieving "quicker growth" and "accelerating proposals". The conclusions and recommendations of the Milton Keynes and South Midlands Study are clear especially the realisation that the time frame for implementation is critical if a meaningful impact on patterns of development is to take place. It sets out that 2011 is the date from which new patterns of growth should begin to be put in place although planning for any change of direction will need to be put in place well before hand.

  With such an onus on beginning this "planning to deliver" process sooner rather than later, it is disappointing that both MKC and Buckinghamshire County Council appear to be driving on with their development plan reviews without giving due weight and consideration to this emerging sub-regional vision.

DEFINING THE PROBLEM

  It is important to note in any assessment of housing requirements to 2016 the changes that have taken place since the 1992 household forecasts on which the RPG figure is based.

  First it is now well accepted that the overall level of housing provision for the South East and by implication this county, set out in the RPG is substantially below that now forecast for the Region. The further reduction in the level of housing provision made in the final version of the guidance from 43,000 to 39,000 dwellings (a 9% reduction) is a short-term requirement as is recognised by the guidance which explicitly states that this figure is to be reviewed by 2006. Even if the figure is reviewed at that time it will take a further four years to be incorporated in new development plans and new allocations are unlikely to be granted planning permission to accommodate any additional need until after 2011. It must be assumed that without intervention the low rate set in the RPG will continue throughout the next 10 years.

  The difference between the numbers of new households forecast for the South East by the 1992 projections of 807,000 compared to the figure of 870,000 in the 1996 projections is 63,000 households (DETR Projections of Households in England 2021). This is an 8% increase in the level of additional households above the 1992 projections.

  Further information in the 1998 population projections indicate that the overall level of under provision for the region will have increased by a further 73,000 by 2016. This represents an increase of 9.7% from the 1996 projected figure of 753,000 (A Holman's 1999).

  In the region as a whole the increase of demand above supply taking into account the most up-to-date information is approximately 26%.

  This under provision is reflected at the lower level in that the published government household projections for Buckinghamshire 1996 to 2016 (DETR 2001) are 75,000 households or 3,750 new households a year. Allowing for a 3% vacancy rate this increases to 3,860 dwellings per year for the county. This new projection is again some 20% higher than the current level of proposed provision for the county in the RPG (3210 dwellings per year) and would require an additional 630 dwellings a year. This new projection takes no account of the enhanced role that Milton Keynes is supposed to fulfil within the region with regard to the accommodation of growth from outside of the county.

  In light of this most recently published information it must be concluded that the present rate of house building proposed in the emerging structure and Local Plan is unlikely to meet the requirements generated by local needs and past patterns of migration let alone the Deputy Prime Minister's strategic objective for Milton Keynes of accommodating increased levels of demand from outside of the county. If the "reduced RPG rate" effectively remains in force for the next 10 years then the Deputy Prime Minister's objectives will remain unfulfilled.

  The situation is not just that the RPG figure is, in light of much more recent information, substantially under supplying the housing needs of the county, but that other changes to the economy have also impacted upon household formation since even the 1996 household forecasts were published. The household projections are not estimates of total need but forecasts of effective demand for housing under recent socio-economic conditions. As such these forecasts are likely to fluctuate depending upon a number of variables including:

—  Increase in GDP Per head of 0.25% per year may result in an increase of 5% in the household projections to 2016.

—  Decrease of mortgage rate by 1% over period of the projection may result in an increase of 7% in household projections to 2016.

—  Decrease in unemployment by 1% over period of projection may result in an increase of 1% in household projections to 2016.

Source: "Projections of households in England to 2021" Annex G.

  These variables may not be independent and their results can not be summed. The following changes however all suggest that the economic conditions are moving in the direction of increased forecasts of demand. Since 1996 the following has occurred:

—  The continued support for the economic growth of the region.

—  A decrease in mortgage rates of 1.5%

—  A decrease in unemployment in the South East to 3.4% by 2000 the lowest rate in the UK.

  The impact of all these factors is to increase the effective housing demand. It is therefore highly likely that with economic conditions favourable to housing need becoming effective housing demand that the levels of household formation from the same population may increase by up to 7%.

  It will no doubt be a strong part of the submission of the anti development lobby that the recent findings of the 2001 Census should be interpreted as requiring a further reduction on the rates of housing provision suggested in RPG's and in particular in RPG9 (South East). Extreme care should be taken of such suggestions. The difference between the mid year estimates 2000 and 2001 (the later being corrected in line with the census) is some 295,000 less people than expected being resident in the South East (London and SE). Therefore the emerging housing crisis is occurring despite a lower than projected level of total population this provides strong evidence that the original levels of housing provision determined in the RPG are far too conservative and are seriously under providing for the needs for the even this lower level of population.

  Taking into account the economic factors set out above then Buckinghamshire would need to supply 4,130 dwellings a year simply to accommodate its own locally generated housing needs and past patterns of migration.

  This assessment of demand is wholly consistent with Buckinghamshire Councils own research regarding house prices and build rates. It is no coincidence that in a period of increasing prosperity and greater access to funding that the county is experiencing substantial growth in property prices.

  In light of the above assessment even a substantial increase in the level of provision at Milton Keynes would only result in the county as a whole performing as it has done in the past and would not allow Milton Keynes to perform any greater role than previously in the region.

  It is our evidence that the short-term undersupply suggested by RPG9 has, together with the impact of PPG3, lead to an undersupply of housing far greater than the 10,000 dwellings required by RPG9. The solution not only requires the making up the shortfall but the bringing forward the reassessment of the RPG figure now rather than wait to 2006. As stated above any reassessment published by 2006 is unlikely to result in additional dwellings until after 2011.

THE ABILITY OF MILTON KEYNES TO MEET ITS EXISTING COMMITMENTS AND TO PROVIDE ADDITIONAL DWELLINGS TO MEET THE CURRENT GROWING SHORTFALL

  The inability of Milton Keynes to deliver the level of housing proposed in the extant Structure Plan is acknowledged by the Buckinghamshire County Council (paragraph 19 Structure Plan Housing Background Paper). Between 1991 and 2011 Milton Keynes was to provide some 36,700 dwellings (1,835 dwellings a year) by 2001 only 16,743 dwellings have been completed and there is currently a shortfall of 3,257 dwellings compared to the extant Structure Plan. This indicates a serious under performance of Milton Keynes and this performance has decreased particularly in the last five years when completions have fallen from an average of 1,800 a year to 1,545 a year.

  The Council state that this shortfall which has emerged due to low completion rates particularly in the period 1996 to 2001 may not be made up in the remainder of the plan period as it would require an annual completion rates of 2,000 dwellings per year. The Council have previously stated that the reduced level of completions for the end period of the Structure Plan may not be exceeded to accommodate this recently acquired backlog of need. It should of course be recalled that the Structure Plans lower level of housing provision towards the end of the plan period (2001 to 2011) was based upon the previous RPG which considered that Milton Keynes should be completing its planned expansion and would only need to accommodate its own development needs. From the evidence above it is suggested that the proposed level of provision is only likely to accommodate past patterns of migration and not meet the wider strategic function that was either envisaged for the City in the 1990s or as now being proposed by the Deputy Prime Minister for the next decade.

  In a way the situation at Milton Keynes is a microcosm of the failings of the planning system. The extant Structure Plan envisaged Milton Keynes being a focus of growth in the 1990s and then slowing down its rate of growth in accordance with the previous RPG. The emerging Local Plan although based upon this previous guidance is debating whether it is necessary to fulfil the housing requirements specified in that plan. In the meantime the Deputy Prime Minister has approved a reduced housing figure for the period 1998 to 2006 in the RPG which is to be reviewed with reference to the outcome of the sub regional study, including suitability of Milton Keynes as a centre of growth. This study has now been completed and the Deputy Prime Minister has confirmed the status of Milton Keynes. Notwithstanding this the Local Plan is being processed effectively on the basis of the 1992 RPG (including the tailing off of development in the post 2001 period) the Structure Plan review is progressed in accordance with the new RPG (including its reduced housing figure for the period 1999 to 2006 extrapolated over the whole of the plan period).

  The problem facing the Deputy Prime Minister is that the existing Structure and Local Plan reviews, which do not include a rate of dwelling provision commensurate with his decision on the status of Milton Keynes, will not be complete prior to 2005 at the earliest. Even if RPG9 can be revised by 2006 this will require the review of these development plans presently being promoted through the system. Even accepting the increased speed that may result from the adoption of Development Frameworks and Action Area Plans the implications of RPG review with its increased provision for Milton Keynes will not be incorporated into development plans until 2008 at the very earliest. Allowing two years for the granting of planning permission on the new allocations made to meet the Minister's decision on the 18 July 2002 then the earliest dwelling completions can be expected to achieve the increased role for Milton Keynes will occur in 2010.

  Unless the Deputy Prime Minister is willing to intervene either to approve an amended RPG within the next two years or to increase the level of provision to be made in Milton Keynes via the Structure or Local Plan process then his recent announcement will have little impact on meeting housing needs prior to 2010.

  The inability of the development plan system to respond to changing circumstances is well documented however in the case of Milton Keynes the delivery of the identified housing provision through the Local Plan is also problematic. In adopting the sequential approach the planning authority in its 1st Deposit Local Plan policies have restrained the release of strategic sites. The impact of the proposed policies is to delay the start of the site and the policies fail to take into account the build rates that may be achieved on any one site. The implication is that although in theory the land has been identified to meet the housing needs its release and the timescale for construction are such that it will not actually provide the dwellings within the time period required. Table 1 was submitted in response to the 1st Deposit Local Plan and demonstrates that the implications of the phasing policies as then drafted would be a shortfall of 4,400 dwellings.

  It is possible that the Local Plan may be revised so that the start dates of both expansion areas are brought forward to 2004-05. A realistic build rate on these sites will still result in an under provision of 2,500 dwellings (table 2). Again table 2 was submitted as part of our representations to the first deposit of the Local Plan and actually required applications to be submitted for both expansion areas by now. This has not happened and a period of two years has transpired and unless any subsequent applications are dealt with quickly then there is likely to be an increase in the shortfall by 2011.

  The emerging policies of the draft Milton Keynes Local Plan will fail to deliver even the reduced housing figure of the extant Structure Plan which is commensurate with the winding down of the city's strategic role. By 2011 there is likely to be a level of under provision of approximately 3,500 to 4,400 dwellings unless alterations are proposed to the phasing policies in the 1st Deposit of the Local Plan.

  The ability for the area to deliver the 8,700 dwellings in the period 2011-16 would require a build rate of 1,740. This is an increase in the level of activity over that which is presently occurring. It is important to recall that this level of provision is that required in light of the slowing down of the rate of growth and Milton Keynes no longer performing a regional role. This is not the future now identified for the city.

  The implication of emerging changes to Milton Keynes Local Plan are illustrated in table 4. This demonstrates if the second deposit removes all the phasing policies and the council are willing to grant permission for both areas in the next three years then the under provision within the time period of the emerging Local Plan will be reduced to 1,300 dwellings. To achieve this, the council will also have to be successful in bringing forward all of their urban priority sites. Failure to achieve bring forward all these urban sites will increase the shortfall.

  Action is required to be taken immediately if the emerging Local and Structure Plans are not to proceed in accordance with the extant policy for the area which is a planned slow down of development and a reduction in the city's strategic role.

MAKING THE MOST OF OPPORTUNITIES TO DELIVER HIGH QUALITY SUSTAINABLE COMMUNITIES

  In light of the above analysis it is suggested that the Deputy Prime Minister consider the long-term planning of areas so that the planning system may provide the development needed and these developments may in turn deliver the benefits required. The five year timescale of development plans for identifying sites is counter productive in terms of bringing forward the type of development that the Deputy Prime Minister wishes to see. Large well planned city and town extensions require time to be planned and delivered so that appropriate levels of infrastructure maybe provided.

  Enclosed is a Master Plan reference (ENK001/001/revisionD) prepared by David Lock Associates. Up-to-date Surface Water Drainage and Transport strategies have also been prepared for the site. Hallam Land Management and other consortium members are currently using this work to promote the comprehensive development of the city's Eastern Expansion Area (EEA) through the Local Plan preparation process. It demonstrates how such a high quality site is readily available now to provide a sustainable community for the future. English Partnerships have fully endorsed this comprehensive approach to site assembly.

  Prior to the 18 July Statement, Milton Keynes Council (MKC) have deliberated over which of two Expansion Areas (East and West) should accommodate the majority of their housing requirement. Notwithstanding English Partnerships call for the East to be comprehensively planned via a consortium, MKC have only allocated less than 50% of this 360 Ha site, placing the majority in strategic reserves for future needs. Such a piecemeal approach to this strategic site will prejudice is overall deliverability and infrastructure provision. With Milton Keynes identified as an important growth area but with a legacy of failing to deliver housing to meet Structure Plan requirements, such "ready to go" sites as the EEA should surely now be reconsidered for comprehensive development within the next plan period to 2011.

  In order to achieve the new "living communities" agenda, the step change in both quantity and quality of new development in such growth areas requires deliverability in a comprehensive manner. Such deliverability can be achieved in the EEA and so justify its identification as a development opportunity, which the news release—"Key Regeneration Role for English Partnerships" of 24 July 2002, wishes to see expedited. In line with the wishes of MKC and English Partnerships, the EEA has already been comprehensively planned via a small and viable consortium of land interests controlling the Expansion Area and working together in partnership.

  The EEA is a good example of how the City's original master plan has "open edges" which have been left to enable the city to grow in any number of different ways both east and west within the Borough. The logical growth of Milton Keynes is however still restricted by more than just physical boundaries.

  The statement on behalf of MKC into the RPG9 Public Examination—"The Milton Keynes Sub-Region 1999" refers to the constraint of administrative boundaries.

  In reviewing the Buckinghamshire Structure Plan (1991-2001), Milton Keynes, Aylesbury Vale District and the County Council jointly commissioned a study by Llewelyn Davies of land on the periphery of the city in order to identify expansion opportunities. The "Milton Keynes Expansion Study" identified an opportunity to the south of the city known as "Area eight" and it is this which forms a large part of the land in question. The 1998 review of this study identified Area eight as a medium term development opportunity.

  The main body of Area eight is an 80 Ha site on predominantly low-grade agricultural land bounded by the A421 to the north, the disused Bletchley-Aylesbury railway line to the south and the hard edge of Bletchley Milton Keynes to the immediate east. This is shown on the enclosed plan ref: DWB6. Whilst the land abuts the south western fringes of the City and development would no doubt serve the City, the site falls completely within Aylesbury Vale District.

  Notwithstanding the following merits of the site, the current review of the Buckinghamshire Structure Plan 2016 has failed to even consider land adjoining Milton Keynes as a potential strategic development option:

—  Its proximity to the Bletchley-Aylesbury/Oxford railway line forming part of the East West Rail scheme and incorporating a new rail station.

—  A public transport interchange and express park and ride service to central Milton Keynes.

—  Its ability to fund in part the proposed Bletchley Southern Bypass linking the A4146 Fenny Stratford bypass and A421 Buckingham Road.

—  The absence of substantial technical or physical constraints.

—  The ability to rapidly deliver comprehensive development.

—  The inherent sustainability of the land given its proximity to employment, educational, cultural and leisure facilities in Milton Keynes and Bletchley.

  The failure of the Structure Plan to consider land adjoining the city seems inconceivable given the context provided by RPG9 and the Milton Keynes and South Midlands Study 2002 which identifies Milton Keynes as a growth area and emphasises the need for cross-boundary co-operation. The Study clearly recommends substantial westerly expansion of the city into Aylesbury Vale District in each of its spatial development options for growth.

  To achieve a step change in both the quantity and quality of new development in Milton Keynes, it is considered essential that some as of yet unallocated but readily deliverable sites are reconsidered for meeting the short-to medium-term growth needs of the City. Two such sites are the EEA and Area eight at Bletchley. I trust that in the light of your policy statement you will emphasise to MKC the importance of a comprehensive approach to the EEA, otherwise the lack of a robust framework for inevitable growth will see the City "stumbling into it" via short-term land allocations in successive Local Plans.

  My clients consider that action is required now rather than attempt to rely on the subsequent reviews of RPG's and development plans which will not deliver any change on the ground in this important location until 2010 at the earliest.