James Stirling Clerk to the Council Parish Council c/o 31 Plum Tree Road SG16 6NE tel: 01462 887521 email: [email protected]

Stuart Robinson, Principal Planning Officer Central Council Priory House, Monks Walk , Shefford SG17 5TQ 19 August 2020 Dear Stuart,

Application number: CB/20/02334/OUT Location: Land South of Lower Stondon West of Road Lower Stondon Proposal: Outline Application: for up to 115 dwellings with means of access only for consideration (all other matters reserved for subsequent approval) at land south of Lower Stondon served by a proposed access point from Bedford Road.

I am writing this letter to register Stondon Parish Council’s (SPC) objection relating to this outline planning application. The objection was resolved at a meeting of Stondon Parish Council of the 29 July 2020.

In accordance with section 38(6) of the Planning and Compulsory Purchase Act 2004, and section 70(2) of the Town and Country Planning Act 1990, applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise.

The outline application is contrary to the provisions of the development plan and there are no material considerations which would outweigh policies.

This objection raises the following issues:  Principle of Development  Local Plan  Five Year Housing Land Supply  Cumulative impact of developments on highways  Cumulative impact of developments - Character And Appearance Of Area  Harm to Character & Appearance of the Landscape  Access To Services And Facilities  Flooding  BMV - loss of good quality agricultural land.  Site is not sustainable on economic grounds.

Page 1 of 10 Principle of Development

This site is in direct opposition to the Authorities development plan, which includes the Core Strategy and Development Management Policies adopted in 2009, Site Allocations adopted 2011, and the saved policies from the Mid Beds Local Plan 2005. Policy CS1 sets out the spatial strategy, directing development to sustainable locations and settlements, and DM4 which covers development within and beyond settlement envelopes.

Weight may be applied to emerging policies, such as ’s draft Local plan, in accordance with paragraph 48 of the National Planning Policy Framework (NPPF). Again, this application is in direct opposition to the proposed Local plan. The new Local Plan submitted in early 2018 and hearings held up to July 2019. Additional information has been submitted by the Central Bedfordshire Council in response to the Inspectors’ questions, and is currently available for public consultation (June – August 2020). SP1 provides the Growth Strategy and SP7 deals with development within settlement envelopes.

Lower Stondon is developing a Neighbourhood Plan as described in the Localism Act. The Neighbourhood Plan will enable local residents to decide, amongst other things and against the background of housing targets set by CBC’s draft Local Plan 2035, which land should be developed and what type and design of dwellings and other development they would like to see in their area. Lower Stondon should therefore be allowed to complete their Neighbourhood Plan without the threat of further applications for major development outside of the Local Plan, being granted on a regular basis.

Para 29 of the NPPF 2018 states - Neighbourhood planning gives communities the power to develop a shared vision for their area. Neighbourhood plans can shape, direct and help to deliver sustainable development, by influencing local planning decisions as part of the statutory development plan.

The site lies outside the settlement boundary, according to both adopted and emerging planning policy, and the principle of the proposal is therefore contrary to policy.

Local Plan This site, proposed during the ‘Call for Sites’ process of the Local Plan as site NLP291, failed the site assessment at Stage A of the site assessment process with the conclusion that: “The proposed site is separated from Lower Stondon by agricultural land and would detract from the parkland and wetland wooded landscape along the southern boundary to Stondon. Accordingly, it is considered that the site would not form a logical extension to Lower Stondon”.

At para 14 of the DCLG Procedural Practice in the Examination of Local Plans it states - It must be remembered that the examination process starts on submission of the plan. The CBC Pre-submission Local Plan was submitted for Inspection on 30th April 2018 and did not include this site. The examination of the Local Plan is now in progress. Allocations approved outside of the Local Plan at this stage would undermine the process of site assessment and the Local Plan itself.

Central Bedfordshire has already seen extensive development granted for sites outside of settlement envelopes and not included in the Local Plan, resulting in a projected level of growth beyond that proposed within it.

This accumulative growth is already undermining the plan-making process by predetermining decisions about the scale, location and phasing of new development: a recent FOI request, made by a nearby village Action Group, revealed that at least 1,276 homes have been granted planning permission since the submission of the CBC Local Plan to the Inspector, despite the robust 5 year land supply. We understand that

Page 2 of 10 these allocations do not include all additional permissions granted, such as those awaiting confirmation in respect of conditions.

Lower Stondon was allocated 189 homes within the Pre-submission Local Plan (HAS46 & HAS47) which was submitted for Inspection. Additional ‘Windfall’ applications have been granted for 274 homes since submission of the Local Plan of which 113 are in the process of being built out or completed in the village.

The Local Plan is at an advanced stage with CBC having received the Inspectors’ feedback from the Hearings and responded in May of this year. Therefore, consideration of this outline proposal is premature. Para 14 PPG and 49 of the NPPF 2018 – reasons for refusing an application on the ground of prematurity include: - a) the development proposed is so substantial, or its cumulative effect would be so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging plan; and b) the emerging plan is at an advanced stage but is not yet formally part of the development plan for the area.

Five Year Housing Land Supply

According to the latest updated position on 5-year land supply in Central Beds (Housing Technical Paper May 2020), the Council can demonstrate a housing supply of 6.19 years. This application is therefore surplus to requirements.

With a housing supply of 6.19 years policies that deal with housing land provision are not out of date, and paragraph 11(d) of the NPPF is not engaged. This statement is supported by five Appeal decisions since the beginning of the year. These include two Planning Inquiries:  Appeal Ref: APP/P0240/W/19/3236423 Land west of Langford Road, Langford Road, Langford, SG18 9QU, and  Appeal Ref: APP/P0240/W/16/3164961 Land to the west of Langford Road, , Bedfordshire SG16 6AF. In each case the tilted planning balance was not engaged following forensic examination of the 5-year land supply and the Inspectors’ endorsement of the use of the SHMA produced for the Local Plan, to correctly assess housing need to 2035. The proposed sites under appeal were found to constitute unsustainable development; therefore the appeals were dismissed.

Page 3 of 10 Cumulative impact of developments on highways

Owing to the 115 dwellings proposed and likely traffic generated in excess of 600 car trips a day, the access on to the A600 would be heavily used. Traffic surveys from other developments indicate a volume in excess of 10,000 vehicles per day for this section of road.

The section approaching the entrance has a proposal to slow the traffic from 60mph to 30mph but this is only metres from the entrance. The section of road needs to have 40mp to 30mph buffer zone at least 500m away based on previous permissions.

Traffic turning right into the development will result in stationary traffic queuing and holding up the traffic flow. Similarly, buses stopping in the area would restrict the free flow of traffic and could result in hazardous traffic movements where cars seek to overtake stopped buses, pulling into fast-moving, on-coming traffic.

The photo above shows the entrance would be on a fast stretch of road entering the village where there have been a number of fatalities in the past.

The cumulative impacts on the highway network of other residential developments already given approval need to be taken into account: • CB/16/05229 - land west of Bedford Road for 85 units Approved March 2018 • 19/01758 border of North Herts and adjacent to the site for 144 units, Approved October 2019 • CB/19/01681/OUT - Bedford Road 85 Units – Approved 6 November 2019 • CB/18/00181/FULL 149 units Approved December 2018 The above does not include all the applications that will almost double the size of the community by adding some 613 new and approved dwellings since 2016.

The applicant has provided no detail on how the proposed site will interconnect with sites to the north and there is a danger that this site will be isolated and inaccessible by any other means other than by car thereby increasing impact on highways and creating an isolated area with no connection to the wider village community.

The location of the site to the West will bring with it issues on access and the proposal does not show how the site might interconnect and the impact of another bespoke access on to the A600. No detail or consideration has been made on how pedestrians will access the only available footway on the opposite side of the road without trying to cross the very busy A600. This will present highways safety issues especially for children walking to and from school by bus.

Overall there seems to be a lack of interest both on the applicant/developer and CBC on the lack of holistic planning for all four sites listed above.

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In context the site is adjacent to two developments, both of which are having an impact and likely to cause more problems in relation to traffic and incidents.

Cumulative impact of developments - Character And Appearance Of Area The site is on agricultural land with some trees and partial hedging to boundaries. It is rural in character, in contrast to the suburban character of the existing dwellings in Lower Stondon and those being provided under recent planning permissions.

View from public open space towards A600

Owing to the largely open nature of the land to the south, east and west, gently undulating topography and lack of significant trees or hedges, the proposal would be prominent in the wider landscape setting and harmful to the rural character of the area.

Page 5 of 10 View from new access road to Mulberry development (this will be a public access).

The landscape and natural features militate against achieving integration of the site into the existing village. The water course and flood plain along the northern boundary of the site provide a clear physical and visual break between the existing development including the Mulberry site of 85 dwellings, and new housing at the application site.

Whilst the proposal is in outline, the indicative layout shows the type of development envisaged. The topography means that integration into the existing settlement in terms of building orientation and opportunities for cycle and pedestrian access can not be achieved by the proposal.

A generic housing estate layout with standard house types, as indicated on the layout, would not reflect local distinctiveness and does not respond to the specific topography of the site and neighbouring developments.

Harm to Character & Appearance of the Landscape

The proposed development is outside the Lower Stondon settlement envelope, adjacent to open countryside , unsustainable and would be contrary to the adopted Core Strategy and Development Management Policies (2009), which will apply until an adopted Local Plan is in place and the proposed Local Plan.  DM4 - Development within and beyond Settlement Envelopes;  CS16 - Landscape and Woodland;  DM14 - Landscape and Woodland;  CS14 - High Quality Development  DM3 - High Quality development  SP7 of the emerging Local Plan

This site, proposed during the ‘Call for Sites’ process of the Local Plan as site NLP291, failed the site assessment at Stage A of the site assessment process with the conclusion that:

“The proposed site is separated from Lower Stondon by agricultural land and would detract from the parkland and wetland wooded landscape along the southern boundary to Stondon. Accordingly, it is considered that the site would not form a logical extension to Lower Stondon”.

Page 6 of 10 A recent Planning Application for 103 homes on a nearby site, CB/19/02039/OUT - Land at the rear of 40 Shefford Road, , was REFUSED on the following grounds;-

"The proposed development will result in the permanent irreversible loss of open countryside, with an over- intensive, urbanising development which will harm the open countryside character in the area, and harm the adjacent settlement character of Meppershall, contrary to CB CS policies CS14, CS15, CS16, DM3, DM4, DM14 and the NPPF."

We believe that this decision would equally apply to this application, particularly in respect of the over- intensive urbanising development and effect on the settlement character.

We draw your attention to the Inspector’s findings in relation to the Langford Inquiry decision of 24th February 2020 - Appeal Ref: APP/P0240/W/19/3236423 Land west of Langford Road, Langford Road, Langford, SG18 9QU – Application Ref CB/18/04783/OUT

The Inspector agreed that the Council had both planned to provide a sufficient number of homes over the Local Plan period to 2035 and had a robust five year land supply. He also found that the few benefits offered by the development of the site, were far outweighed by the need to protect the landscape and setting of the village.

Access To Services And Facilities

The doctor’s surgery and lower school in Lower Stondon are not within walking distance of the application site, being approximately 1 mile and 1.5miles away, respectively. The secondary school is not within walking distance. There are no major employment areas within walking distance. There are no supermarkets, banks, restaurants, or retail chains. The facilities of the village, such as they are, which in any case are not within easy walking distance, comprise a couple of small convenience shops, takeaways, a public house, a small hairdresser, a veterinary surgery and funeral parlour. The local Post Office is accommodated within a small pharmacy, with two parking spaces outside.

These facilities are insufficient to serve a further development of 115 dwellings, particularly when taken in conjunction with three other recently approved developments and in addition to the pre-existing dwellings at Lower Stondon.

Transport facilities also cannot be regarded as offering a sustainable alternative to car usage. The nearest train station is 5.2km away. There are no details on cycle paths and an infrequent hourly bus service. Therefore car usage will be essential in this location. This would be in direct conflict with the NPPF and National Planning Policy Guidance (February 2019) objectives for sustainable transport.

Flooding

The site adjoins the watercourse to the north, and part of it is within flood zones 2 and 3. Even if the development itself could be made acceptable, the proposal is likely to increase the risk of flooding elsewhere by replacing existing open, farmland with hard surfacing thus increasing run-off. We note the concerns raised by the Bedfordshire and River Ivel Internal Drainage Board, both points making the current proposal unacceptable:

On the northern boundary of the development, the plan includes an area within 9 metres of the river bank top; this is contrary to the Board’s byelaws. The expected surface water drainage to the watercourse is expected to be at an unacceptable level.

Page 7 of 10 BMV - loss of good quality agricultural land. According to the application, the site is agricultural land grade 3a. This falls within the definition of ‘best and most versatile agricultural land’ and according to national planning policy.

National planning policy seeks to preserve and protect the ‘best and most versatile agricultural land’, defined as grades 1, 2 and 3a. In the section on Conserving and Enhancing the Natural Environment, the NPPF states that the economic and other benefits of the best and most versatile agricultural land should be taken into account and where significant development of agricultural land is demonstrated to be necessary, poorer quality land should be sought in preference to that of higher quality.

The CBC Sustainability Appraisal for the Local Plan includes the following Key Issue - The retention and protection of best and most versatile agricultural land, which is a National issue.

Development of this BMV Grade 3a site is clearly not necessary or sustainable and so this land should be retained for future agricultural use. The Government’s 25 year Environment Plan proposals, also add weight to the clauses in the NPPF in terms of conserving this land.

Site is not sustainable on economic grounds.

With no Community Infrastructure Levy in place there will be no contribution being paid directly to the area to mitigate the effects of the development. Currently for economic reasons, it is the stated policy of CBC to use the New Homes Bonus to support the provision of frontline services across Central Bedfordshire and not directly in support of areas affected by development. The economic benefits should not take into consideration those of Council Tax and New Homes Bonus accruing from this site, as these benefits would apply to those homes to be built on sites identified within the Local Plan. There could only be very limited economic benefit during construction and there is a lack of support for local businesses such as pubs and shops.

The application speaks of the economic benefits of this development to Lower Stondon however, in a recent appeal conclusion, when denying Appeal Ref: APP/PO240/W16/3164961, Planning Application CB/16/02721/OUT Site at Land between 103 and 27 Langford Rd, Henlow, SG16 6AG. The Inspector stated in para 160: “Economic benefits would include construction spend and employment during the building programme. Input into the economy from residents of the scheme would apply over the long term. Whilst not seeking to minimise the value to the local economy, in the overall picture these benefits are not out of the ordinary and in this instance carry limited weight. Planning Practice Guidance advises that it would not be appropriate to make a decision based on the potential for the development to raise money for a local authority. Therefore, a New Homes Bonus is not a consideration that has any weight. This conclusion is similar to that of my colleague in the Clifton decision. (APP/PO240/W/18/3211229 re: CB/18/01099/OUT, Land off Broad Street Clifton).”

Impact on local business.

MDBA – We understand this site has a licence for works with a limit on it of 10,000 vehicles a day for the adjoining A600 and currently it is indicated the volume is about 13,000. This does not include the extra traffic coming from Bovis, Mulberry, Barrett and Bloor. This could have an impact on the loss of employment in the area.

Community gain Stondon Parish Council has had limited engagement with the proposer of this application and has had some broad discussions on the development and community gains, but to date the proposer has failed to provide any proposals that the Council can have any surety will be delivered.

Page 8 of 10

The Parish Council are constantly reviewing our objectives for community gain in relation to any applications.

We require the Local Planning Authority to involve the Parish Council in discussions with any developer proposing applications that will have an impact on the community, such as this one. This would extend to any discussions on delivering community gains.

Page 9 of 10 Conclusions  The proposed development is outside settlement boundaries and does not represent a sustainable form of development. It is therefore unacceptable in principle.  The Council has more than the required five year housing land supply. Policies relating to the supply of housing land are up-to-date and relevant.  The proposed vehicular access on to the A600 would give rise to hazardous highway conditions, particularly when the cumulative impact of nearby large housing developments is considered.  Owing to the topography and natural vegetation, the proposal would be unduly prominent in the wider landscape setting and harmful to the rural character of the area. Sensitive integration into the existing settlement can not be achieved owing to the watercourse and natural topography which means that new development, of necessity, must be located further south and more remote from the existing settlement. The proposal would therefore be harmful to the rural character and appearance of the area.  It could be at risk of flooding and increase the risk of flooding elsewhere.  The services and facilities available in the village are very limited and residents of the proposed housing would need to travel by car to access education, employment, and all but very basic shopping.  The land falls within the definition of ‘best and most versatile agricultural land’ and according to national planning policy.  The proposal is contrary to national and local planning policies in several fundamental respects and it is therefore requested that planning permission be refused.  Lack of engagement and detail on community gains, if the Planning Authority go against all the above reasoned arguments.

It is therefore respectfully requested that Central Bedfordshire refuse this planning application.

Finally, please note that in our submissions in respect of the proposed development, while we have taken every effort to present accurate information for your consideration, as we are not a decision maker, we cannot accept any responsibility for unintentional errors or omissions and you should satisfy yourselves on any facts before reaching your decision.

Yours sincerely, James Stirling James Stirling Clerk and Responsible Financial Officer Stondon Parish Council

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