Planning Department, Jones Lang LaSalle Ltd Priory House, 31 Great George Street Bristol BS1 5QD +44 (0)117 927 6691 Monks Walk, , jll.co.uk Shefford, , 4 May 2021 SG17 5TQ.

Dear Sir/Madam,

Main modifications consultation – Local Plan

JLL represent Bedfordshire Land Promotions (BLP hereafter) in the promotion of land at Road, Caddington and we have consistently engaged with the Local Plan process since the draft local plan was first consulted on in August 2017. Throughout the process we have raised our concerns regarding the way in which the role of Caddington has been addressed and how the identified needs of both Central Bedfordshire and are to be met. The Council has addressed the clear errors in assessing the status of Caddington but continues, we feel, not to properly address the unmet housing needs of the area. However, the Inspectors have heard all of the evidence in this regard and we do not seek to reiterate that here.

We do though have concerns with the latest Proposed Main Modifications to the plan, and these are discussed below.

MM109 - Settlement Hierarchy Table

Modification reference MM109 relates to the removal of Caddington from the ‘Large Village’ classification and its’ reinstatement as a ‘Minor Service Centre’ within the Settlement Hierarchy. This finding is consistent with Council’s Settlement Capacity: Initial Study which led to the classification of Caddington as a ‘Minor Service Centre’ in the Draft Local Plan July 2017. However, for unknown reasons that the Council still has not fully explained, Caddington was relegated to the ‘Large Village’ classification between the Regulation 18 and 19 iterations of the Local Plan.

We undertook our own analysis of the services and facilities within Caddington using the Council’s own scoring matrix and the revised score clearly demonstrated that Caddington should be a ‘ Minor Service Centre’ (MSC). We therefore support Modification reference MM109 and the reinstatement of Caddington as a ‘Minor Service Centre’ as we feel this is a truer reflection of Caddington’s status within the Settlement Hierarchy in the final version of the Local Plan.

However, it is noted that all of the other settlements within the MSC category have an allocation for development to support their local communities within the plan period. The temporary (and erroneous) relegation of Caddington to a Large Village appears to have meant that the case for an allocation in the settlement has been overlooked or avoided.

Jones Lang LaSalle Limited Registered in & Wales Number 1188567 Registered Office 30 Warwick Street London W1B 5NH

MM14 - Policy SP1: Growth Strategy

Modification reference MM14 relates to the Growth Strategy through which the Council outline how they intend to deliver the required 39,350 homes, and 24,000 new jobs in Central Bedfordshire over the plan period. In addition to this is the requirement to meeting the unmet housing needs of 7,350 homes arising from Luton.

The Council seeks to meet these needs through the allocation of the following sites:

• (SC1) North (1&2) • (SA1) North of Luton • (HAS05) Land East of Barton le Clay • (HAS07) Caddington Park, Caddington • (HAS14) Land off Eaton Park • (HAS17) Land South West of Road, • (HAS18) Site adj. to Flitwick Garden Allotments off Steppingley Road • (HAS19) Land at /The Pyghtle • (HAS20) Land West of the Midland Mainline Railway, Harlington • (HAS21) Land West of Sundon Road, Harlington • (HAS25) Land at Leighton Road, • (HAS26) A5 , Hockliffe • (HAS28) Bidwell Gospel Hall (Dell Mount) • (HAS29) Land to the East of Houghton Regis • (HAS38) Land fronting Road, • (HAS49) Land East of Leighton Road, Toddington • (HAS50) Alma Farm, Toddington. • (HAS51) Land off Flitwick Road, • (HAS52) West View Farm, Westoning

Through the inclusion of these sites, we consider that the Council is still placing a large reliance on two very large sites to meet Luton’s housing need through the allocation of Houghton Regis and North Luton. The Council’s reliance on these sites to meet the majority of the need results in a severe risk of under delivery of housing for Luton early in the plan period. Our concerns and evidence regarding the delivery of these two sites is outlined in our representation in response to the Inspectors’ Matters, Issues and Questions for Examination in December 2020 and therefore will not be repeated as part of this representation, however this representation should be read in conjunction with th is previous representation for completeness.

The plan seeks to deliver housing need identified for the Luton HMA and some unmet need from Luton close to where it arises. However, many of the small and medium allocations are in fact located a significant distance away from Luton. In our December 2020 representations we produced a table (included at Appendix A for ease of reference) which includes all of the sites included in Exam41 and also those included in Table 2 of the Council’s submission. The table identifies the driving distances from the centre of Luton (identified as the train station for consistency) and travel times at peak and non-peak times. The results show that these allocations are not close to where the need arises within

2

Luton. There are significant distances ranging from 2.3 to 14 miles from Luton with car travel times of up to 29 minutes at off-peak times and 40 minutes at peak times.

Notwithstanding the above, it is important to clarify that these sites are not new sites which have been identified to meet Luton’s unmet need, but sites which were previously included in the figures to meet the housing needs of the Central Bedfordshire. Therefore, by “re-badging” and reallocating these sites to meet Luton’s need, it is unclear how the Council proposes to meet their own housing needs within Central Bedfordshire and specifically for Caddington.

In regards to Caddington, the plan refers (at MM15, MM43) to need being met at Caddington. This is clearly not the case and in need of rectification. The plan allocates one site (HAS07 Caddington Park) for development, but this is not a site which is actually in or indeed anywhere near the settlement of Caddington. It is actually 3km north of the village, on the edge of Luton. It just happens to be within the Parish of Caddington, but is only just within the boundary. For the council to suggest that this in any way meets the need for the residents of Caddington, as a settlement, is simply wrong. Caddington Park provides approximately 66 dwellings to meet the need arising from Luton, to which it is closer.

We therefore do not support Modification reference MM14 as the allocations to meet Luton’s need are not in locations close to where that need arises, and are in some examples located some distance away, leading to increased travel distances and journey times to Luton itself.

Furthermore, the sites allocated within Policy SP1 identified to meet Luton’s need mean that as a result, there are fewer allocated sites remaining to meet the need of Central Bedfordshire, resulting in a shortfall in provision for the residents of the district, specifically including present and future residents of the settlement of Caddington.

MM8 – Policy SP1a: Partial Review of the Local Plan

Policy SP1a of the Local Plan commits the Council to commencing a Partial Review of the Plan within six months of its adoption. However, they state (in para 5.5.4, as part of Modification reference MM7) that this will be ‘completed as soon as practicably possible, in line with government decisions around strategic infrastructure’. This creates ambiguity as there are no defined timescales within which the review must be completed, only that this must ‘commence’ within 6 months of adoption and be completed at some indeterminate point in the future. This means that MM8 does not set measurable timescales, or indeed define which triggers or decisions the Partial Plan Review relates to, thereby creating uncertainty and a lack of accountability.

The Cambridge-Milton Keynes-Oxford Arc (“The Arc” hereafter) is acknowledged as a strategic road and rail infrastructure project, within the plan (para 1.4.2). There are two major infrastructure projects which underpin The Arc, including the £3.5bn upgraded trunk road (“The Expressway” hereafter) linking Oxford and Cambridge, and the East-West rail link.

On 18th March, the Transport Secretary Grant Shapps, announced that his analysis showed that the Expressway cannot deliver sufficient connectivity links to provide value for money for the taxpayer and he therefore decided to cancel the project. In its place he has proposed a series of more targeted road

3

investigations are to be explored. As a result, a Milton Keynes connectivity study is being produced by Highways England and the transport body England’s Economic Heartland. Due to commence in March 2021 with no delivery date, this work will first identify the strategic questions relating to connectivity in each study area of The Arc, including Central Bedfordshire, in order to agree the outcomes required of the transport system and to then identify the investment required.

This represents a major shift in Government road building and calls into question the scale and timings for growth in the northern area of the district, and in particular on the intersection of the corridor with the key national north-south rail and road networks.

The Government’s decision to cancel the Expressway has also returned infrastructure planning in The Arc back to its’ initial investigations stage with consequential delays to the progress of a decision on East-West Rail infrastructure as well. As such, based upon its proposed triggers, it is very unlikely that Council will take any decision for a Partial Plan Review in the reasonably near future.

Furthermore, there are questions as to whether the proposed targeted road investigations and “Connectivity” studies would constitute a ‘government decision around significant infrastructure’ sufficient to trigger a Partial Review as set out within the plan. Therefore, we question whether the triggers for the Partial Review have a realistic prospect of ever actually being met.

In addition, such a Partial Review would mean that any updated plan would still be based on the old strategy and housing numbers of this current plan. The NPPF 2012 (under which the current plan is being assessed as part of the transitional arrangements), at para 158, states that ‘each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area’. This version of the NPPF has now itself been updated but the case remains the same, namely, that any plan should be based on up to date evidence. The emerging plan was issued as a draft in August 2017, based on evidence prepared before that time and was submitted to the Secretary of State for examination on Monday 30 April 2018.

Since then, not only has the NPPF changed, but so too has the way in which housing need is calculated, such that even the emerging plan is out of date and any Partial Review thereof will be even more so.

In parallel with this, the Government has announced a series of Planning Reforms which were outlined within the Planning for the Future White Paper in August 2020. Whilst it is recognised that these proposals are not yet enacted in law, part of the proposals on which the government consulted, was the introduction of a statutory timescale within which Councils are to have new Local Plans in place under the new planning framework, identifying land for Growth zones, Renewal and Protection. It is expected that these new Local Plans could be in place by the end of the current Parliament.

In summary, given the uncertainties surrounding the timings of road infrastructure, the out of date evidence base and the prospects for a significantly revised planning regime likely to be enacted later this year, it is clear that a partial review of this long delayed local plan is no longer appropriate and we therefore do not support Modification MM8. Instead, we suggest the Council is to be encouraged to commence a Full Review of this plan, based on up to date evidence and in line with the Government’s new planning system at the earliest opportunity.

4

Yours sincerely,

Chris Dadds Director - Planning and Development

Appendix A – Travel distances table

5

Appendix A - Travel distances table

The table below shows the sites, the number of dwellings proposed, respective driving distances from the centre of Luton (as measured to the train station) and travel times, at both peak and non-peak times. Those sites which were in Exam 41 are shown crossed through, whilst those that have been added more recently are shown in red. The reason for including the deleted sites is for consistency with our representations as submitted in December 2020.

Site Site Name Capacity Exam 41 % of Distance Drive Drive Ref to 2031 deleted total to central time time peak (Table 2) sites Luton off-peak (mins) (miles) (min)

HRN1 Houghton Regis 2,601 32.27% North Site 1

HRN2 Houghton Regis 1,328 16.48% North Site 2

SA1 North of Luton 1,980 24.57% 4.7 18 29

HAS04 Land at Luton Road, 168 7 20 - Barton le Clay

HAS05 Land East of Barton le Clay 498 6.18% 7 20 29

HAS07 Caddington Park, 66 0.82% 2.3 6 16 Caddington

HAS09 Chapel Farm, Chalton 54 9 20 -

HAS14 Land off Eaton Park 49 0.61% 12 25 45

HAS17 Land South West of 216 2.68% 13 25 40 Steppingley Road, Flitwick

HAS18 Site adj. to Flitwick Garden 35 0.43% 14 29 40 Allotments off Steppingley Road

HAS19 Land at Upper 39 0.48% 13 25 38 Gravenhurst/The Pyghtle

HAS20 Land West of the Midland 429 5.32% 10 20 29 Mainline Railway, Harlington

HAS21 Land West of Sundon 154 1.91% 10 20 30 Road, Harlington

6

Site Site Name Capacity Exam 41 % of Distance Drive Drive Ref to 2031 deleted total to central time time peak (Table 2) sites Luton off-peak (mins) (miles) (min)

HAS24 Land to the South West of 77 10 25 - the A5,Hockliffe

HAS25 Land at Leighton Road, 23 10 25 - Hockliffe

HAS26 A5 Watling Street, 41 10 25 - Hockliffe

HAS28 Bidwell Gospel Hall (Dell 25 0.31% 6 19 31 Mount)

HAS29 Land to the East of 350 4.34% 6 18 30 Houghton Regis

HAS38 Land fronting Silsoe Road, 39 0.48% 14 26 40 Maulden

HAS49 Land East of Leighton 92 1.14% 9.5 17 25 Road, Toddington

HAS50 Alma Farm, Toddington. 159 1.97% 9.5 26 32

HAS51 Land off Flitwick Road, 135 1.67% 12 22 35 Westoning

HAS52 West View Farm, 85 1.05% 11 21 35 Westoning

Caddington Brickfields 3.5 11 20

7