CENTRAL LOCAL PLAN 2035 PRE-SUBMISSION CONSULTATION

REPRESENTATIONS ON BEHALF OF MR & MRS R KNOX AND MR & MRS M RICHARDS IN RESPECT OF PROPOSED ALLOCATION HAS26 – A5

1. INTRODUCTION

1.1 J & J Design have been engaged by the representors to challenge the draft allocation HAS26 at A5 Watling Street Hockliffe for residential development.

1.2 The proposed allocation is for approximately 41 dwellings on 1.74ha of greenfield land currently designated as Green Belt, on the north-west fringe of Hockliffe.

1.3 The representations raise issues including:

a. The soundness of the spatial strategy and the ongoing role of the Green Belt; b. Whether ‘exceptional circumstances’ have been demonstrated to justify alterations to Green Belt boundaries; c. Whether Hockliffe has the capacity for sustainable growth within the A5 transport corridor, and if so to what extent; d. Whether the proposed allocation site is appropriate having due regard to Green Belt, environmental and historical considerations; e. Whether there is justification for Hockliffe to be designated as a Large Village in the Settlement Hierarchy.

1.4 It is concluded that the draft allocation fails the soundness tests at paragraph 182 of the Framework, being unjustified and inconsistent with national policy. Accordingly, the proposed allocation should be deleted from the Local Plan.

1.5 Furthermore, it is concluded that there is inadequate justification for Hockliffe to be designated as a Large Village. Accordingly, Hockliffe should be re-designated as a Small Village.

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2. THE PROPOSED ALLOCATION

2.1 The proposed allocation site reference HAS26 is identified as part of draft Policy HA1 : Small and Medium Allocations, as follows:

Site Area Parish Approx Approx Site Additional Name density capacity Area Policy (ha) requirements (where applicable)

A5 South Hockliffe 30 41 1.74 Landscaping will Watling need to be Street sensitive to nearby listed buildings and the setting of the Scheduled Monument

2.2 The proposed allocation arises from Representation 6833 and the associated letter of Savills dated 29 August 2017, on behalf of Bedford Estates, promoting a larger landholding of 6.35 ha extending along the north- west frontage to Woburn Road (B5704).

2.3 The proposed allocation site is bounded by Hockliffe Lower School and Clipstone Brook to the south-east, A5 Watling Street and residential development to the south-west and open countryside to the north. There is no existing northern boundary.

2.4 The proposed allocation site is permanent grassland meadow normally utilised as open grazing.

2.5 The proposed allocation site has no previous planning history.

3. PLANNING POLICY HISTORY

3.1 Hockliffe lies in the former area of , where the extant adopted development plan is the Saved Policies of the South Bedfordshire Local Plan Review (2004).

3.2 In 2005, prior to local government reorganisation. Borough Council, South Bedfordshire District Council and Bedfordshire County Council promoted a Joint Luton and South Bedfordshire LDF to cover the whole of Luton and South Bedfordshire. The Joint Core Strategy (JCS) was submitted for examination in March 2011 but withdrawn in July.

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3.3 Subsequent upon the local government reorganisation in April 2009 when the former Mid Bedfordshire District Council merged with South Bedfordshire District Council to form the unitary authority , the Council promoted a draft Development Strategy for Central Bedfordshire 2014. Following initial hearing sessions in 2015, the Inspector concluded that the Council had failed to comply with the Duty to Co-operate. After litigation, the submitted Development Strategy was formally withdrawn in November 2015.

South Bedfordshire Green Belt

3.4 The history of the South Bedfordshire Green Belt is set out in Section 2 of the South Bedfordshire Local Plan Review (2004) at paragraphs 2.1-2.10. Salient points include:

 1960 – Bedfordshire CC submitted a sketch plan for the proposed Green Belt to the Minister of Housing and Local Government.

 1976 – Bedfordshire CC published the consultation draft County Structure Plan including Policy 12 – Green Belt.

 1987 – Beds CC amended the Structure Plan policy to exclude five villages of Barton, Toddington, , and from the Green Belt. was subsequently excluded from the Green Belt on the adoption of the Leighton- and Heath and Reach Local Plan 1987.

3.5 A Green Belt boundary was proposed around Hockliffe for the first time in the extant Local Plan Review (2004). The Green Belt boundary was drawn tightly around the urban form and terminated at the Clipstone Brook on the north-west of the settlement. Two previously developed sites were allocated for housing development within the excluded area. Both have been implemented.

3.6 The adopted South Bedfordshire Local Plan Review (2004) did not include a formal settlement hierarchy but Policy GB3 set out a village categorisation in terms of the Green Belt.

Hockliffe Neighbourhood Plan

3.7 The Hockliffe Neighbourhood Plan 2017-2035 Consultation Draft (NP) was published in September 2017 for a six week consultation period. Hockliffe Parish Council are currently considering the consultation responses, prior to formal submission to Central Bedfordshire Council.

3.8 The draft NP recognises that Hockliffe is an appropriate location for some new housing, subject to investment in essential community infrastructure. In the absence of the local referendum, it is unclear whether this is supported by a majority of local village residents. The representors suggest that the local residents may not concur with the NP in this respect.

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3.9 The NP accepts that the scale of new development, the allocation of housing sites and the related consideration of Green Belt boundaries will be undertaken through the emerging Local Plan. Subject to these criteria the NP concludes that Hockliffe can accommodate up to 170 homes.

3.10 The NP identifies five preferred locations for future new housing development for a total of 170 new dwellings.1 These sites do not include the proposed allocation HAS26.

Central Bedfordshire Local Transport Plan (LTP)

3.11 The LTP for Central Bedfordshire covers the period April 2011 to March 2026. The overall LTP is broken down into 10 Local Area Transport Plans (LATP) which set out the key transport issues and concerns of local people.

3.12 The LATP for Heath and Reach, Toddington and Barton-le-Clay includes Hockliffe. The plan is based on three Areas of Delivery. The relevant Area of Delivery is Heath and Reach, Hockliffe and Stanbridge, which include the parishes of Egginton and .

3.13 The LATP describes Hockliffe as a linear village dominated by the A5 trunk road running through its heart. Whilst the village does have its own Lower School on Woburn Road (B5704), residents rely on nearby Service Centres such as and for all main services.

3.14 The A5 Watling Street is the major transport link in Hockliffe, and is a strategic link of national importance, providing direct links to Milton Keynes and Dunstable. These links are supplemented by A4012/B5704 which provide a north-east to west link to places such as Woburn, M1 junction 13 and Leighton Buzzard.

3.15 Within the LATP area, travel-to-work modes are dominated by the private car (85%). Levels of out-commuting are also high with 51% of journeys to work outside the local area. Commuting destinations include Leighton Buzzard, Hertfordshire, London and Milton Keynes.

3.16 The LATP confirms that Hockliffe is completely dominated by vehicular traffic, resulting in an environment which is hostile towards pedestrians. The A5 is a heavily-trafficked route with a local 40mph speed limit. Whilst pelican crossings are provided and footways are of adequate width, traffic volumes, speed and congestion discourage pedestrian use. The A4012 also brings similar issues, particularly accessing Hockliffe Lower School. Whilst Woburn Road (now B5704) has a lower speed limit (30mph), traffic volumes, congestion and narrow pavements combine to provide a hostile pedestrian environment.

3.17 Despite its location on a strategic transport corridor, public transport services in Hockliffe are poor. Centrebus X31 provided a two hourly service between Central Milton Keynes and Dunstable but the service was withdrawn in December 2017.2 Service 169 Leighton Buzzard – Toddington – provides two services daily each way on College days only. Service 74 provides five services daily between Hockliffe and

1 Hockliffe Neighbourhood Plan – Policy DP2 2 CBC website – Public Transport – bus timetable changes January 2018

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Dunstable. Service 47 provides two services on Monday, Wednesday and Fridays on the route Woburn to Leighton Buzzard via Tilsworth and Egginton. Marshalls Coaches provide two outbound morning and three return evening journeys between Leighton Buzzard – Hockliffe – Dunstable – – London. The nearest railway station is at Leighton Buzzard, some 8km to the west, which offers four trains per hour on the Euston – Watford – Milton Keynes route, with reduced service onwards to Northampton and Birmingham. Plusbus rail-bus integration is available from Leighton Buzzard but does not extend to Hockliffe.

3.18 In 2008, the Highways Agency (now Highways ) estimated that the A5 in Hockliffe was operating at between 110% and 130% of capacity, leading to delays when entering Dunstable and in Hockliffe at peak periods. By 2026, it is estimated that the A5 will be operating at 150% of capacity as a result of increasing travel demands. This includes the impact of the A5 to M1 (Junction 11a) link road.

3.19 The LATP has identified the following priorities for action in Hockliffe:

- Congestion at A5/A4012 junction creates air quality issues and poor pedestrian crossings - Narrow pavements and on-street parking in Woburn Road creates poor pedestrian environment - Volume/speed of traffic resulting in poor pedestrian and cycling environment - Poor pedestrian permeability across A5 to the south of the village - Poor sightlines at junction between Road [ Road] and A5 resulting in road safety hazard

4. BACKGROUND EVIDENCE

4.1 The following background documents have informed this representation:

a. South Bedfordshire Local Plan Review (2004); b. Partnering for Prosperity : A new deal for the Cambridge-Milton Keynes-Oxford Arc : NIC : 2017; c. Central Bedfordshire and Luton Green Belt Study – July 2017; d. Central Bedfordshire Local Plan – Stage 3 Green Belt Study – January 2018; e. Luton HMA Growth Options Study – July 2017; f. Central Bedfordshire Local Plan – Settlement Envelope Review – January 2018; g. Central Bedfordshire Proposed Submission Policies Map; h. Central Bedfordshire Local Plan (2015-2035) Transport Modelling Stages 1B, 1C & 1D and 2A (January 2018).

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5. PLANNING ISSUES

5.1 The following key planning issues have been identified:

a. The soundness of the spatial strategy and the ongoing role of the Green Belt; b. Whether ‘exceptional circumstances’ have been demonstrated to justify alterations to Green Belt boundaries; c. Whether Hockliffe has the capacity for sustainable growth within the A5 transport corridor, and if so to what extent; d. Whether the proposed allocation site is appropriate having due regard to Green Belt, environmental and historical consideration; e. Whether there is justification for Hockliffe to be designated as a Large Village in the Settlement Hierarchy.

5.2 Each of these issues will be considered in turn.

6. PLANNING CONSIDERATIONS

6.1 The soundness of the spatial strategy and the ongoing role of the Green Belt

6.1.1 The Spatial Strategy proposed by the Council is set out at Chapter 5 of the Pre-Submission Local Plan. This includes the Key Spatial Objectives and a Balanced Strategy.

6.1.2 The respondents note and accept the influence of the surrounding major centres; including London, Milton Keynes, Luton and the emerging strategic corridor of the Cambridge-Milton Keynes-Oxford Arc.

6.1.3 The respondents are also aware of the major housing needs arising from both the Dunstable and Houghton Regis conurbation and Luton’s unmet needs. They support the need for sustainable urban extensions to the primary urban areas, to develop additional growth opportunities around transport hubs and other strategic growth opportunities.

6.1.4 However, it is considered that the Spatial Strategy approach fails to reflect national policies which seek to attach great importance to Green Belts, including their essential characteristics of openness and permanence. Rather, the ‘Balanced Strategy’ appears to merely regard Green Belt as a ‘constraint’.

6.1.5 It is considered that the Spatial Strategy Approach should be amended to include a specific reference to the importance of Green Belt and its ongoing role as identified in the 1980 Structure Plan and restated in the adopted Structure Plan 2011. This should be restated as a benchmark against which current proposals and future growth can be considered, in order to ensure the ongoing role of the Green Belt and its effectiveness in moulding the local and regional growth strategies.

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6.2 Whether ‘exceptional circumstances’ have been demonstrated to justify alterations to Green Belt boundaries

6.2.1 This key issue will require consideration of Chapter 6 : The Proposed Locations for Growth and Chapter 8 : Green Belt, Coalescence and Settlements.

6.2.2 Section 6.2 : South Area records the pressures for additional growth to accommodate ‘unmet need’ from Luton, with a commitment to contribute 7350 homes within Central Bedfordshire and within the Luton HMA.

6.2.3 The respondents accept that local pressures including Luton ‘unmet needs’ may be considered to be ‘exceptional circumstances’ in terms of Framework paragraph 83. However, it is considered that the assumption that there is potential for medium scale growth along the A5 transport corridor will need to be tested in the local plan examination.

6.2.4 In the case of Hockliffe, which is the sole settlement in Central Bedfordshire north of Dunstable on the A5 transport corridor, the Green Belt boundaries were first set as recently as 2004. Previous decisions on Green Belt boundary revisions have established that ‘permanence in the long term … enduring beyond the plan period’ would indicate that changes would be unlikely to be justified within 30 years. Helpful guidance is available in recent caselaw.3

6.2.5 It is considered that ‘exceptional circumstances’ to justify alterations to Green Belt boundaries has not been demonstrated in respect of Hockliffe.

6.3 Whether Hockliffe has the capacity for sustainable growth within the A5 transport corridor, and if so to what extent

6.3.1 It is accepted that the Consultation Draft Hockliffe NP proposes new housing development for a total of 170 new dwellings in five preferred locations. However, it is submitted that limited weight should be afforded to the emerging NP and that it is incumbent upon Central Bedfordshire Council and the Inspector to consider the consequences of growth in this location, prior to the independent examination of the NP.

6.3.2 It is submitted that it is noteworthy that the following judicial guidance has been provided:

“The second sentence of paragraph 84 is not altogether clear. On the face of things, it might well be argued that it appears to reinforce the need to protect the Green Belt, but in my view it is capable of being interpreted slightly more broadly. The consequences for sustainable development may require revision of the Green Belt. Nonetheless, I do not readily agree with Miss Ellis that paragraph 84 throws any light on the meaning of ‘exceptional circumstances’ within paragraph 83, or should be taken as somehow diluting this aspect. Sustainable development embraces environmental factors, and such factors are likely to be negatively in play where release of

3 See: Gallagher Homes Ltd v Solihull BC [2014] EWHC 1283 (Admin) IM Properties Development Ltd v Lichfield DC [2014] EWHC 2440 (Admin) Calverton Parish Council v Nottingham City Council, Broxtowe BC and Gedling BC [2015] EWHC 1078 (Admin)

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Green Belt is being considered. The second sentence of paragraph 83 supplies a fetter or brake on development which would, were it not for the Green Belt, otherwise be sustainable; but in deciding whether exceptional circumstances pertain regard must be had to the whole picture, including as I have said the consequences.”4

Further relevant advice includes:

Paragraph 84 “is clear evidence to decision-makers to take into account the consequences for sustainable development of any review of Green Belt boundaries. As part of that patterns of development and additional travel are clearly relevant.”5

6.3.3 The Central Bedfordshire Local Transport Plan provides evidence that travel to work modes within the LATP area of Heath and Reach, Hockliffe and Stanbridge, including Egginton and Tilsworth are characterised by high levels of out commuting and dominant use of the private car, together with a poor public transport service and remote location from the rail network.

6.3.4 Furthermore, the LTP clearly indicates that the A5 is already operating above capacity particularly at peak periods and within the Local Plan period is expected to reach 150% of capacity, leading to sharply increased congestion and delay without further intervention. No such interventions are proposed within the emerging Local Plan. Further growth within or adjoining Hockliffe will exacerbate the congestion and delays to the trunk road traffic.

6.3.5 Central Bedfordshire Council has commissioned Transport Modelling which has been published as part of the Technical Evidence in support of the Pre- Submission Local Plan. Stage 1b modelling identified the following ‘hot- spots’ on the A5 north of Dunstable:

12 A5/Woburn Road [Sheep Lane roundabout] 12A A5/A4012 [Hockliffe Crossroads] 12B A5/A505 [Dunstable northern bypass/A5]

6.3.6 Stage 1C and 1D Transport Modelling provided further details of the ‘hot- spots’ with reference to 2025 Local Plan and 2035 Local Plan scenarios, with congestion/at capacity at hot spot 12. At 12A modelling predicts congestion and/or saturation on both A4012 approaches for both AM and PM peak periods. At 12B there is limited congestion at 2025, increasing to congestion on A5 southbound approach in AM peak, and at capacity on the A505 approach northbound in the PM peak.

6.3.7 Transport Modelling Stage 2A considers mitigation at the various ‘hot- spots’. The following is proposed:

H-12 A5/Woburn Road – Widening of roundabout exits to allow a two lane straight ahead movement for A5 traffic. Implementation is indicated for 2035.

4 Calverton Parish Council v Nottingham City Council, Broxtowe BC and Gedling BC [2015] EWHC 1078 (Admin)

5 IM Properties Development Ltd v Lichfield DC [2014] EWHC 2440 (Admin)

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H-12A A5/A4012 (Hockliffe) – Do Nothing. It is noted that for the 2035 Local Plan scenario, the signalised staggered junction is over capacity. However, due to physical constraints on all sides with frontage access and at-grade pedestrian crossings, carriageway widening is not feasible.

H-12B A5/A505 – Dunstable Northern Bypass – Road widening and lane reallocation. It is noted that all approaches to this junction will operate at capacity for the 2035 Local Plan scenario. The indicative delivery timescale for improvements is 2035.

6.3.8 It is demonstrated by the Traffic Modelling that the A5 north of Dunstable is under stress, which will increase to congestion/at capacity/saturation by 2035. Mitigation in Hockliffe itself is considered to be not feasible. This adds further weight to the concerns of the representors and strongly suggests that Hockliffe has no capacity for sustainable growth.

6.3.9 The Growth Study considered and rejected a new settlement/large village extension at Hockliffe (location ID:L15). The assessment provided negative responses on sustainability criteria with the exception of publicly accessible open spaces, access to lower, middle or primary schools and bus stops. The settlement failed on proximity to major employment areas, town centres and major out-of-centre retail parks, secondary or upper schools and higher education establishments, local/neighbourhood centres, together with NHS primary healthcare and hospitals. It is submitted that these assessments apply to even limited growth, indicating strongly that growth at Hockliffe will not be sustainable.

6.4 Whether the proposed allocation site is appropriate having due regard to Green Belt, environmental and historical considerations

6.4.1 As noted at Section 2 above, the proposed allocation arises from Representation 6833 submitted in August 2017 in response to the Regulation 18 consultation. Accordingly, the allocation was not included in the earlier Call for Sites and Preliminary Site Assessments. Furthermore, the respondents have had no previous opportunity to comment on the proposal.

6.4.2 However, the Green Belt Study has assessed the wider area enclosing Church End, Hockliffe Grange and Grange Farm, together with the ribbon development alongside the A5 Watling Street and the promoters site. This is land parcel HL1 with a total area of 97.6ha.

6.4.3 The parcel description includes:

“A small number of properties including a caravan park extend beyond the inset edge of Hockliffe along the A5. Field boundaries are well defined by hedgerows and hedgerow trees and vegetation surround the buildings within the parcel.

Urbanising influences are generally well-screened within the parcel and intervening vegetation limits the relationship that it has with the settlement of Hockliffe. There is a strong landform distinction between the inset linear settlement on fairly level ground along the A5 and the dispersed rural

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settlement on the steeper hillsides to the west. Also, Clipstone Brook forms a strong edge.

The parcel is some distance from Leighton Buzzard but provides the openness to the Toddington and Hockliffe Clay hills which form part of the town’s historic setting.”

6.4.4 The parcel assessment found as follows:

Purpose 1 – Check the unrestricted sprawl of large built-up areas Rating : Weak/No contribution Notes: The parcel is not adjacent to a large built-up area and development here would be associated with Hockliffe.

Purpose 2 – To prevent neighbouring towns merging into one another Rating : Weak/No contribution Notes: The parcel does not make a significant contribution to the extent of any countryside gaps between towns.

Purpose 3 – To assist in the safeguarding of the countryside from encroachment Rating : Relatively strong contribution Notes: There is a strong separation between most of the parcel and the inset settlement, as well as a degree of separation from the surrounding countryside. There is less distinction at the eastern end alongside the A5, where there are shallower slopes and existing urbanising influences in the parcel, but Clipstone Brook still provides separation from the inset settlement. There is a greater sense of containment and relationship with the settlement edge in the south-eastern corner, behind Augustus Road, where a dwelling is located within the Green Belt.

Purpose 4 – To preserve the setting and special character of historic towns Rating : Moderate contribution Notes: The parcel’s openness contributes to the relationship between the settlement and characteristics identified as contributing to special character or historic setting, but development would have only a moderate impact on historic character.

Purpose 5 – To assist in urban regeneration by encouraging the recycling of derelict and other urban land

All parcels make an equally significant contribution to this purpose.

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6.4.5 The Central Bedfordshire Stage 3 Green Belt Study Appendix – Hockliffe includes an assessment of the promotion site NLP538 with a total site size of 6.35ha. In regard of Green Belt Purpose 3 : Safeguarding of the countryside from encroachment the assessment concludes:

“The site is undeveloped and has a significant sense of openness relating strongly to the countryside. There is some relationship with the settlement, namely with the school site which has breached the Green Belt Edge formed by the brook to the south. However, this does not exert a significant urbanising influence. Furthermore, A5 and Hockliffe Brook [Clipstone Brook] provide some distinction between the site and the settlement. Open boundaries to the north, east and west of the site reinforce a relationship with the wider countryside. Therefore, development of this site would represent significant encroachment into the countryside.”

6.4.6 Under the consideration of potential alternative Green Belt boundaries, the assessment concludes:

A new Green Belt boundary along the north and west of the site would constitute a weaker boundary than the existing boundary along Clapton Brook [Clipstone Brook!]. Hockliffe Road [Woburn Road] is considered a strong eastern boundary. There are no alternative Green Belt boundaries within this site.

6.4.7 It is concluded that release of NLP538 in isolation would result in moderate high harm to Green Belt with the comment:

This site makes a significant contribution to preventing encroachment into the countryside but does not contribute significantly to other Green Belt purposes. The weak boundaries along the west and north of the site comprised of stock fencing and low hedgerow would result in the weakened contribution Green Belt land to the north-west, which would be bordered by inset development with no separating features.

6.4.8 The respondents strongly concur with the above assessment and conclude that the proposed allocation on the southern section of the promotion site would equally result in moderate-high harm to the Green Belt, particularly given that the Clipstone Brook forms a defensible boundary at the northern end of the linear village.

6.4.9 Furthermore, it is considered that it is significant that the additional policy requirements identified under Policy HA1 at HAS26 advise:

Landscaping will need to be sensitive to nearby listed buildings and the setting of the Scheduled Monument.

This refers to the proximity of the proposed allocation site to the following listed buildings:

Brook House and Brookside Watling Street Turpin Cottage Watling Street Kings Arms Farmhouse Watling Street

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These three listed buildings are all Grade II which were first listed in September 1980. These are all located on the south-west side of Watling Street within the existing ribbon development.

6.4.10 The Scheduled Monument is Church Farm Moated Site and associated settlement and cultivation earthworks List Entry No. 1012915 at grid reference SP96611 26828.

6.4.11 The citation includes the following:

The monument at Church End includes a well preserved example of a medieval moated site, the significance of which is emphasised by its commanding position situated on a platform overlooking a valley to the west of Watling Street. The size of the central island is also significant as it suggests an element of fortification which is not usually associated with this form of monument. The island and the outer enclosure will retain the buried remains of structures and other features relating to the occupation of the site, whereas the ground beneath may retain evidence of earlier occupation and land use. The silts within the ditches maintain conditions suitable for the preservation of both artefactual and environmental evidence which will provide evidence for the character of occupation on the site and for the landscape in which it was set. The importance of the monument is enhanced by the direct association between the moated site and a range of well-preserved earthworks which comprise the remains of part of a contemporary settlement and a sample of its associated agricultural system. The relationship between the moated site and the adjacent settlement earthworks provides important evidence for the study of the social and economic development of the overall site, illustrating contrasts in lifestyles amongst its various inhabitants.

6.4.12 The Central Bedfordshire Initial Settlements Capacity Study includes the following information:

Landscape and Land Quality:

Landscape Character Type (LCT): The settlement is located within the Toddington-Hockliffe clay hills. This LCT is defined by a series of connected hills. The area is dominated by arable crop production but interspersed with pockets of pasture (sheep and some cattle grazing). Within this LCT there is a strong landscape pattern of fields defined by hedgerows punctuated by mature trees and set back from the roads by wide grass verges and drainage channels.

Best and Most Versatile Agricultural Land: To the south-east of the settlement there is a patch of Grade 2 agricultural land. The settlement itself and the rest of the surrounding land is in Grade 3 agricultural land, however, it is unknown whether this is sub-grade 3A or 3B.

6.4.13 The proposed allocation site would conflict with the existing strong landscape pattern of fields defined by hedgerows, introducing a new boundary which is currently undefined. The proposed allocation site appears to be within Grade 3 agricultural land and is set to permanent pasture.

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6.4.14 The Council has published a Settlement Envelope Review. However, this does not propose any review of settlement envelopes at Hockliffe. The result of this is that HAS26 allocation will represent a significant extension of the built environment into the Green Belt. Although there is existing ribbon development on either side of the A5 north of Clipstone Brook, this is currently washed over by Green Belt and does not form part of the village. For this reason, HAS26 allocation will weaken the Green Belt designation of the adjoining ribbon development and will represent an inappropriate extension of the settlement inset within the Green Belt to the north.

6.4.15 For all these reasons, it is submitted that the proposed allocation site is inappropriate having due regard to limited sustainable transport connections, a lack of services and facilities that can support sustainable growth, together with Green Belt, environmental and historical considerations.

6.5 Whether there is justification for Hockliffe to be designated as a Large Village in the Settlement Hierarchy

6.5.1 The settlement hierarchy is set out at Chapter 9 of the LP and takes account of local sustainability credentials. Four tiers are included – major service centres, minor service centres, large villages and small villages.

6.5.2 The broad approach to the settlement hierarchy has been adopted by Central Bedfordshire in the extant Core Strategy at Policy CS1 : Development Strategy. The adopted South Bedfordshire Local Plan Review (2004) did not include a formal settlement hierarchy but Policy GB3 set out a village categorisation in terms of the Green Belt. Policy GB3 set out three categories of villages within the Green Belt. Category 1 where the Green Belt washes over the settlement. In Category 2, limited infilling was permitted at Chalton, and Stanbridge. In Category 3, the villages of Barton, Caddington, Eaton Bray, Heath & Reach, Hockliffe, Slip End and Toddington were excluded from the Green Belt where new development and redevelopment was permitted within the Inset boundaries.

6.5.3 Whilst the Framework does not require the identification of a settlement hierarchy, it can enable the LP to take account of the different roles and character of different areas, promoting the vitality of main urban areas and supporting thriving rural communities. It can also assist in ensuring that development is appropriate in scale and character to the features of individual settlements. Given the diversity of settlements in Central Bedfordshire, it is considered that the principle of a hierarchy is justified, particularly as this broad approach has served well in the past.

6.5.4 That said, it is unclear how CBC has designated the various Green Belt villages within the Settlement Hierarchy. Based on local knowledge, it is submitted that Hockliffe is more comparable with the Small Villages and it is considered that Hockliffe should be reclassified as such.

J R Shephard February 2018

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