BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd
For and on behalf of Pigeon Investment Management Ltd
CENTRAL BEDFORDSHIRE PRE SUBMISSION LOCAL PLAN (Regulation 19) Consultation Response
DLP Ref: BE5265
Land East of Maulden Road, Flitwick
Prepared by DLP Planning Ltd Bedford
February 2018
BE5265 – Land East of Maulden Road, Flitwick February 2018
On Behalf of Pigeon Investment Management Ltd
Prepared by: Emer Costello BA (Hons) MRTPI Associate Planner
Approved by: Andrew Parry MA MRTPI Associate Director
Date: February 2018
DLP Planning Ltd 4 Abbey Court Fraser Road Priory Business Park Bedford MK44 3WH
Tel: 01234 832740 Fax: 01234 831266
DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.
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CONTENTS Page
1.0 INTRODUCTION 4
2.0 PLAN REPRESENTATIONS 5
OBJECTION - Policy SP1: Growth Strategy 5
OBJECTION – Omission of a Robust Settlement Hierarchy 10
OBJECTION - Policy HA1: Small and Medium Allocations 11
OBJECTION - Policy SP7: Development within Settlement Envelopes 18
OBJECTION: Policy EE6 Tranquillity 18
3.0 THE SITE 19
4.0 PROPOSED ALLOCATION 21
5.0 OVERALL CONCLUSIONS 26
APPENDIX 1: Report on the Objection to the Housing Requirement in Policy SP1 in the Pre- Submission Local Plan based upon the Objectively Assessed Need for Housing in Central Bedfordshire Council
APPENDIX 2: Regulation 18 Draft Local Plan Representation, August 2017
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1.0 INTRODUCTION
1.1 These representations have been prepared by DLP Planning Ltd (DLP) on behalf of Pigeon Investment Management Ltd (Pigeon), in response to Central Bedfordshire Council’s Pre-Submission Local Plan. DLP, on behalf of our client, wish to make a number of comments on the proposed strategy. This site was previously submitted to Central Bedfordshire Council both in response to the Council’s ‘Call for Sites’ exercise which ran up to April 2016 and the Regulation 18 draft Local Plan, August 2017. We have concerns in relation to the Council’s evidence base which underpins their overall strategy for growth and their assessment of our site ‘Land East of Maulden Road, Flitwick’.
1.2 As set out in the National Planning Policy Framework (the Framework) in Paragraph 47 local planning authorities should aim to “boost significantly the supply of housing”. Local planning authorities are also required to meet their objectively assessed housing need (OAN). The Council’s Strategic Housing Market Assessment (2017) has been critiqued and a number of flaws have been identified which question the level of housing which is planned for in the Pre-Submission Local Plan. Our site was omitted as an alternative in the sustainability appraisal process. The Sustainability Appraisal, January 2018 (SAR) did not assess Land East of Maulden Road as an option to take forward housing growth within the town of Flitwick.
1.3 Our site is incorrectly dismissed in the Strategic Housing Land Availability Assessment (January 2018) (SHLAA). It was not deemed suitable primarily on the basis of the Site’s proximity to Flitwick Moor (SSSI), perceived impact on ecology and landscaping, impact on the setting of the listed Flitwick Mill, and the site being Grade 2/3 agricultural land. As we set out in our representation in August 2017 this is not a correct analysis and future residential development can be taken forward without adverse impacts on the natural or historic environment. Sections 3.0 and 4.0 discuss the suitability of our client’s site for development and supplement our responses in Sections 2.0. As set out in Section 3.0 below, the site is being promoted for mixed use development that includes mixed use employment, a health and social care hub, residential units, formal and informal open space and ecological enhancements. An indicative master plan was submitted with our representation of August 2017. This is also appended at Appendix 2 of this report.
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2.0 PLAN REPRESENTATIONS
OBJECTION - Policy SP1: Growth Strategy
2.1 The Pre-Submission Local Plan should be positively prepared, justified by evidence, effective and consistent with national policy, as required by Paragraph 182 of the Framework. In this regard, as a starting point in the preparation of the Pre-Submission Local Plan, CBC should seek to meet the full, unconstrained objectively assessed needs (OAN) for market and affordable housing in the housing market area, in accordance with the third Core Principle and Paragraph 47 of the Framework. The express objective of this is to “boost significantly the supply of housing” and this also is set out clearly in the National Planning Practice Guidance.
Planning White Paper Fixing our Broken Housing Market
2.2 The government’s Planning White Paper ‘Fixing our Broken Housing Market’ February 2017 (the White Paper) set out a number of proposals to reform the planning system to increase the supply of new homes and increase local authority capacity to manage growth. The White Paper outlined aims to reform the planning system to “Making more land available for homes in the right places, by maximising the contribution from brownfield and surplus public land, regenerating estates, releasing more small and medium-sized sites, allowing rural communities to grow and making it easier to build new settlements.”
2.3 The White Paper in Paragraph 1.22 outlines that authorities “should have a clear strategy to maximise the use of suitable land in their area, so it is clear how much development can be accommodated.” The White Paper sets out, inter alia, to make “sure every part of the country has an up-to-date, sufficiently ambitious plan, so the local communities decide where development should go; and ensure that plans start from an honest assessment of the need for new homes and that local authorities work with their neighbours so that difficult decisions are not ducked.”
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Planning for the Right Homes in the Right Places: Consultation Proposals
2.4 Further to the White Paper, the government consulted on “Planning for the right homes in the right places: consultation proposals.” Paragraph 1.29 of this document sets out that “policies in plans should allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector. Small sites create particular opportunities for custom builders and smaller developers. They can also help to meet rural housing needs in ways that are sensitive to their setting while allowing villages to thrive”.
2.5 This also includes a new proposed approach to calculating local housing need. This contains the below recommendations:
• Step 1: setting the baseline should be a demographic baseline using the most recent official projections.
• Step 2: an adjustment to take account of market signals. Government consider that household growth is insufficient on its own, as household formation can be constrained by housing supply and households may wish to move close to work, this may mean moving housing market areas. The important point that that the current consideration of market signals focuses on affordability of new homes and that where income is high, affordability may not be an issue. This could be a particular issue when moving across HMAs. Therefore, the workplace-based median house price to median earnings ratio should be used. The formula proposed to be used is set out in paragraph 21.
• Step 3: capping the level of any increase. Here government recognises that the market adjustment may result in significant increases and therefore should be capped at a 40% increase of that in existing plans.
2.6 This consultation report is the third document prepared or instigated by Government that which set out the changes they considered necessary the calculation of OAN. The first
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document was the Local Plans Expert Group1 (LPEG) report which set out the changes they considered necessary the calculation of OAN. This was then followed by the housing White Paper, which applied conclusion from the LPEG report and set out that a simplification to the plan making process was required, to deliver the key Government objective of addressing the housing crisis. From all three consultation documents it is clear that:
• The official projections; DCLG based household growth, MYE and census are considered by the government to be robust. • A standard approach for calculating the response to market signals has been inconsistent across the country and that a standard approach is necessary.
2.7 The consultation was supported by a housing need consultation table. The proposed figures would result in a significant increase in Central Bedford Council’s (CBC) objectively assessed housing need (OAN).
Objective Assessment of Need
2.8 DLP do not consider the SHMA, 2017 approach to be in accordance with the Framework or the current guidance and it is clear that if adopted across the wider Housing Market Area the approach would result in a substantial undersupply of housing compared to the official projections and would worsen the affordability of the housing market.
2.9 The Council’s SHMA, 2017 identifies that there is a dwelling requirement of 31,778 dwellings for the plan period (2015-2035) which is 1589 dpa.
2.10 Against the government’s consultation on the methodology for assessing local housing need the indicative figures would result in the current level of housing need of 1, 600 (rounded) increasing to 2, 553 per annum (2016 – 2026).
2.11 Under the Government’s proposals, unless the Pre-Submission Local Plan has been published and submitted for examination by a prescribed deadline, the new standard method for calculating OAN should be used.
2.12 In this context, it is noted that the trend of CBC’s five-year land supply is decreasing
1 An independent expert group to recommend measures to help ensure efficient and effective production of Local Plans. 7
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rather than increasing. Their Five-Year Land Supply Statement, January 2018 shows that the Council’s five-years housing supply has reduced from 5.94 years’ supply (1st Oct 2017) to 5.87 years’ supply (1st Jan 2018). It is noted a lot of the current supply is based on the previous situation whereby the Council did not have a five-year supply and a number of permissions were granted. It is likely in the current context this will not be the case.
Central Bedfordshire Council’s Objectively Assessed Housing Need Analysis
2.13 The Strategic Planning Research Unit (SPRU) have undertaken an independent analysis of CBC’s OAN in February 2018 (included as Appendix 1). SPRU is a dedicated team of economic specialists, statisticians and planners providing independent advice as well as supporting the work of DLP Planning. SPRU’s report challenges the robustness of CBC’s approach in arriving to their OAN of 1600 dpa. The report differs from the SHMA, 2017 in the following key ways:
• It incorporates both the underlying population projections and the household formation rates from the most recent household projections (published in 2016) by the Department of Communities and Local Government2 - these are referred to as the DCLG 2014 household projections.
• It takes into account the more recent evidence on migration from the 2015 Mid-Year Estimate (MYE) of population published by the Office for National Statistics (ONS).
• It analyses market indicators including affordability ratios and concludes that a 20% uplift should be applied to the demographic forecast.
• The report also considered the implications of other demographic projections, these being:
I. The application of improved household formation rates for under 44’s.
II. Long term migration trend (most recent 10 years including the 2015 Mid-Year Estimates). As these levels of migration are lower than the MHCLG projection, they therefore have not been modelled as in accordance as we consider the higher of the two projections should be preferred.
2.14 A review of the SHMA, 2017 Update that provides the background evidence to the Local Plan for Central Bedfordshire has revealed a number of shortcomings. Key examples
2 Now referred to as the Department for Housing, Communities and Local Government. 8
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are summarised provided below.
2.15 The methodology for calculating the migration flows is weak and in conflict with the advice from Office for National Statistics (ONS) regarding the nature of Unaccountable Population Change (UPC) for the period 2001 to 2011.
2.16 The approach towards assessing migration flows is considered to be out of line with the methodology followed in surrounding areas (which were also modelled by the same consultant). The findings are a significant change in the level of migration and unmet need. The negative impact on household formation that has arisen as a result of the housing crisis is not factored in.
2.17 SPRU’s analysis identifies that the SHMA’s response to the very acute market indicators of just 10% is inadequate and that the comparators used are unsuitable two being outside the influence of London and the third (Luton) being clearly unaffordable in its own terms. Comparing one unaffordable location with another as a methodology, is not going to result in decisions which will address the affordability in locations such as Central Bedfordshire.
2.18 A considerable oversite in the SHMA, 2017 is the lack of any reference to the recommendations made to the government regarding the standardised approach to the OAN made by LPEG. This resulted in SPRU’s view, in an inappropriately low suggested OAN which does not respond to either the up-to-date demographic information or market indicators.
2.19 The housing requirement, before accounting for Luton’s unmet need is of 2,157 dwellings year is derived from the demographic projection plus a 20% uplift, which is higher than the OAN suggested by the Council’s evidence base. Adding in the need arising from Luton, which the plan takes into consideration, this equates to 2,525 dwellings per annum.
2.20 SPRU’s independent analysis demonstrates that if the plans were to proceed using the 2017 SHMA’s OAN as a basis this would result in a significant undersupply of housing over the plan period.
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2.22 In conclusion, Policy SP1 Growth Strategy as submitted does not sufficiently plan to meet its OAN. The current growth strategy does not seek to meet its full objectively assessed need over the plan period. It is therefore not sound as it is not positively prepared, justified nor consistent with national policy.
OBJECTION – Omission of a Robust Settlement Hierarchy
2.23 The principle of the settlement hierarchy is supported as indeed is the identification of Flitwick as a Major Service Centre and a focus for employment, shopping and community facilities for the local community and surrounding rural communities alongside Ampthill, Biggleswade, Dunstable, Houghton Regis, Leighton Linslade, Sandy and Wixams. The policy itself should however list the settlement hierarchy, as the locations which are best placed to absorb and accommodate additional development owing to their existing infrastructure. Future development should as a rule be prioritised in those locations.
2.24 This hierarchy should take a more central role in informing the overall strategy of the Pre-Submission Plan. At present the relationship between the growth strategy and the settlement hierarchy is not clear. For example, Flitwick, although it is a Major Service Centre, does not feature high in the apportionment of growth. Flitwick as a settlement could make a real and valuable contribution to the Council’s growth. By way of example, some of the seven Major Service Centres are accommodating significant growth such as Biggleswade (1, 500 dwellings) Wixams Southern Extension (650 dwellings) and Houghton Regis (355 dwellings). Others for example Sandy, and Flitwick are not subject to growth and it is not clear why.
2.25 As a ‘Major Service Centre’, Flitwick has a good range of facilities. These include the following: Supermarket & Convenience Stores, Professional Services, Health Care Facilities, including GP surgery, Leisure Centre, Pubs, Open Space, Community Centre, Pre-schools/Nurseries, Lower schools and Middle school. There is also a railway station providing good access into London and good bus services providing access to surrounding towns and villages. In the context of the sites location on the edge of Flitwick and the services and facilities provided, Flitwick is a sustainable location for further growth.
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2.26 As a result of the above, we object to the council’s settlement hierarchy. We are of the view that this is not based on a robust up to date evidence base including the SAR (which includes an assessment of reasonable alternatives such as Flitwick town) and the Green Belt Study.
OBJECTION - Policy HA1: Small and Medium Allocations
2.27 The Pre-Submission Local Plan omits the Land East of Maulden from its site allocations. This is as a result of errors in the evidence base. These are set out in more detail below.
Central Bedfordshire and Luton Green Belt Study
2.28 Central Bedfordshire jointly with Luton Borough Council commissioned LUC to undertake an assessment of the Green Belt within Central Bedfordshire and Luton. The aim of the Central Bedfordshire & Luton Green Belt Study (November 2016) (the Green Belt Study) was to assess the extent to which the Green Belt land within the study area contributes to the purposes of a Green Belt as set out in the Framework.
2.29 The report site was assessed as follows in relation to the purposes of a Green Belt under reference (FW2/FW2a). This is set out in Table 1 below.
2.30 There were five land parcels [FW1 (north), FW2/2a (north -east), FW3/3a (south-west), FW4 (west) & FW5 (north-west)] assessed at Stage 1 of the study which surrounded the town of Flitwick. The parcels of land that were the worst performing locations (i.e. weakest contribution to the 4 purposes of the Green Belt) against the purposes of the Green Belt were FW2/2a and FW3a. This was followed by FW5. FW1 and FW4 performed the best (i.e. strongest contribution) against this analysis.
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Parcel Purpose 1 Purpose 2 Purpose 3 Purpose 4
Table 1. Green Belt Study, p. 28, 2016
2.31 The stage 2 assessment analysed the most ‘weak’ performing areas in more detail. The conclusions of the study set out in Figure 5.2 identified that FW3a was moderately weak and that FW2a was relatively weak (the lowest score of all of the land parcels) for the town.
2.32 Stage 4 of the Green Belt Assessment identified the site NLP039 Steppingley Road. This is located in the FW4 parcel of land which was the best scoring location along with FW1. Appendix 1 sets out the scoring in more detail this identifies that “the majority of the parcel relates strongly to the wider countryside, has a sense of separation from the settlement and lacks urbanising development. Development would represent encroachment into the countryside”. Irrespective of this, NLP039 Steppingley Road (Flitwick west) is the only site carried forward to stage 3 of the Green Belt process. This is a critical flaw in the Green Belt study. This does not constitute a fair or transparent process. The findings of the stage 3 analysis for this site are “harm to Green Belt resulting from release of site”, despite the fact the site apparently has a weaker contribution to the purposes of the Green Belt than the proposed allocation site. (See Figure 1 below.
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Figure 1 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd
2.33 The area of land, to which our proposal site relates FW2a made the weakest contribution towards the purposes of a Green Belt. It can safely be removed from the Green Belt without causing harm or undermining the purposes of the Green. The reasons why this has not been taken forward are not given. In stage 3 NLP039 is taken forward. Why this site has been selected is not justified.
Sustainability Appraisal
2.34 The Sustainability Appraisal, January 2018 (SAR) is a core part of the evidence base which informs the Pre-Submission Local Plan’s Strategy and Policies. At a strategic level, the assessment of Growth Locations Options (Appendix 5 of the SAR) discounts Flitwick town/major service centre as a potential growth location. This is a significant omission, given Flitwick’s prominent location in the settlement hierarchy. The potential for Flitwick to become a town which absorbs a larger scale of growth should have been analysed further and assessed as a reasonable alternative in the Sustainability Appraisal process.
2.35 Flitwick West is discounted in Table 5.7 of the SAR for the following reasons: Green Belt designation; concern over coalescence between Flitwick and Ampthill; potential detrimental impact on the landscape, ecology and heritage in the east of Flitwick; concentrating growth along key transport corridors (A507, M1 and Midland Main Line Rail); promoting sustainable development in areas that have seen little growth due to Green Belt restrictions. Flitwick West the only option for development in the town. The omission of other locations around the, especially those which were not deemed to meet the five purposes of the Green Belt in the stage 1 and 2 assessments should have been considered here. Furthermore, it contained FW2/2a which performed as ‘weak’ in the Green Belt study.
2.36 The Non-Strategic Site Options (Appendix 7 of the SAR) only assess two options. These are NLP039 Steppingley Road for 420 residential units and NLP492 Site Next to Flitwick Allotments for 24 residential units. This site ‘Land East of Maulden Road’ is omitted from consideration, this being despite it scoring better in respect to impacts upon the Green Belt were it to be released. Table 2 below provides a commentary id our site had been BE5265 – Land East of Maulden Road, Flitwick February 2018
On Behalf of Pigeon Investment Management Ltd
assessed in the SAR. Our site, Land East of Maulden Road fairs better against the selected site NLP039. Our site preforms particularly well against the employment and health objectives.
Table 2. Sustainable Appraisal Commentary Sustainability Appraisal Site Options Objectives Steppingley Site next to Land East of Land East of Maulden Road Flitwick Maulden Road Road (NLP039) Allotments (NLP321) (NLP321) (NLP492) Justification
1 Housing + + + The site would provide up to 216 residential units. 2 Community & -- 0 0 0 -? The site makes a relatively Green Belt weak contribution towards Identity the Green Belt. 3 Services & + + + The site connects to the Facilities eastern boundary of Flitwick. It has excellent access to services and facilities 4 Employment 0 0 + The site proposes to provide 2.13ha of employment land. 5 Health & + -? + The site would provide Equality 1.67ha for health and social care hub including new GP surgery. 6 Highways & Air -? -? -? Transportation Technical Quality Note has been prepared. Access be taken via a new four arm roundabout that includes the existing Maulden Road industrial estate, which will not only provide for a safe means of access 7 Sustainable + + + The process connects to Transport existing transport network. The report includes 2.5km of new and enhanced footpaths. 8 Energy & 0 0 0 The development will Climate follow the principles of Change energy efficient design. 1ha of formal open space and 2.5ha of new and enhanced footpaths are examples of sustainable design measures. 9 Water 0? 0? 0? The configuration and Resources & design of the scheme Quality would be sensitive to development impacts in terms of water levels and quality.
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10 Flood Risk + + + It is only proposed to develop that part of the site within Flood Zone 1. 11 Soil -- -- -/? There are no records of land contamination on this site. 12 Biodiversity & + + -/? An initial ecology appraisal Geodiversity and strategic assessment was also carried out for the site and adjacent Flitwick Moor SSSI and this was submitted with the August 2017 representation. This review concludes the site is of low ecological value and is not considered functional habitat for the SSSI. Furthermore, there is little overlap between species on the site and the SSSI. 13 Landscape + + + The proposed development would be sensitively designed. Will include structured planting and landscaping. 14 Historic -? + -/? In regard to the impact on Environment the setting of Flitwick Mill the built form would be set back substantially from Greenfield Road to the south and additional landscaping introduced which would offer opportunities to enhance the setting of Flitwick Mill, as well as provide for an attractive gateway to the town
The Strategic Land Availability Assessment 2.37 The Strategic Housing Land Availability Assessment (January 2018) (SHLAA) determines the suitability, achievability and availability of potential housing and employment sites. The sites NLP039 Steppingley Road (Green belt) & NLP492 Site adjacent to Flitwick Garden Allotments (Not Green belt) are identified as suitable, available and achievable.
2.38 Land adjacent to Maulden Road (Ref ALP 174 – NLP321) is assessed at 10.94. This site is assessed as unsuitable. It is identified that “…the site’s proximity to Flitwick Moor makes it unsuitable for development, it is inappropriate for development in terms of landscape, ecology and green infrastructure. The proximity of the site to Flitwick Moor SSSI makes it unsuitable. The site, if taken forward would be able to protect and
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enhance the landscape which provides the foreground to Flitwick Moor SSSI and is an important visual feature giving identity to Flit Valley. Opportunities for the creation of high quality new habitats are welcomed such as Suitable Alternative Natural Greenspace (SANG) to further enhance the setting of the SSSI.
2.39 In respect of the impact on the setting of Flitwick Mill the built form would be set back substantially from Greenfield Road to the south and additional landscaping introduced which would offer opportunities to enhance the setting of Flitwick Mill, as well as provide for an attractive gateway to the town. The existing public rights of way across the site would be retained and additional footpaths would also be provided along with areas of public open space. This will improve the permeability through the site and make it accessible to local residents.
2.40 Evidence was provided at the earlier stages of this Local Plan’s preparation including the Call for Sites and Regulation 18 Draft Local Plan consultations to clarify and correct some of the above assumptions in relation to ‘Land adjacent to Maulden Road’. More information is set out on this in section 4 below. The findings should have been adjusted to take the submitted evidence into account. However, it does not appear that their Pre- Submission Local Plan, SHMA, 2017 or Green Belt evidence has been informed by this.
2.41 Further to the analysis above, the Pre-Submission Policy HA1: Small and Medium Allocations is not sound as it is not justified and based on robust evidence to identify the most suitable locations for housing. This is a fundamental flaw in the Pre-Submission Local Plan. The Green Belt Study discounts sites irrespective of the fact that it was the best scoring location against the purposes of the Green Belt. This site should have been carried across to stage 3 of the Green Belt study. The site was also incorrectly excluded from the SAR as a potential alternative both in the strategic and individual site analysis. The SHLAA, 2017 discounts this our clients site on grounds which are not substantiated. This proposal if taken forward for a high quality mixed use development would offer an opportunity to enhance the setting of the SPA contributing to the habitats and species there. The site would only bring forward development on Flood Zone 1. The proposed development at this site would respect the historic context of the area. The proposed strategy would recede any build development away from any area sensitives to the west to connect to the existing settlement boundary. A draft masterplan (Appendix 2) illustrates how this could be achieved. This was submitted to
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the Council in July 2017. We regret to note that this has not been fully taken into account.
OBJECTION - Policy SP7: Development within Settlement Envelopes 2.42 Policy SP7 seeks to identify defined settlement envelopes and provide guidance as to how applications within and outside this boundary would be assessed. Whilst we welcome the recognition within the policy that the intrinsic character beauty of the countryside should be recognised (as per Paragraph 17 of the Framework), the policy then goes on to imply that only certain types of development i.e. rural exception housing or housing for those working in agricultural/forestry. This is overly restrictive and goes over and above the requirements of the Framework.
2.43 There is no recognition in Policy SP7 that sites on the edge of settlement are often sustainably located close to facilities and services and can provide a material contribution to meeting the District’s identified housing needs. A greater distinction should be made between edge of settlement locations and the truly open countryside. The policy should therefore be amended to provide additional flexibility and opportunity for sites adjacent to settlement envelopes to be considered favourably, where they are sustainably located and meet the other policy requirements. As drafted Policy SP7 is therefore not sound as it is not consistent with national policy.
OBJECTION: Policy EE6 Tranquillity
2.44 The Pre-Submission Local Plan already contains policies on green infrastructure, enhancing biodiversity, nature conservation, trees, woodlands and hedgerows, landscape character and value, the Chilterns Area of Outstanding Natural Beauty. Whilst the Framework, in Paragraph 109, positively supports the protecting and enhancing the natural environment does not advocate additional policies on non-designated land which are overly restrictive. The evidence to underpin what land is considered to be ‘tranquil’ and its location in spatial terms is not apparent. Paragraph 158 sets out that “each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence.” On this is basis the Pre-Submission Policy EE6 Tranquillity is not sound or consistent with national policy.
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3.0 THE SITE
Site Location & Context
3.1 The site lies on the eastern side of Maulden Road. It is contained by existing residential development on Maulden Road and Moor Lane to the west, Greenfield Road to the south, Flitwick Moor to the east and Folly Farm to the north
3.2 The major service centre of Flitwick is concentrated around Steppingley Road and the High Street. Facilities within Flitwick include, but are not limited to, a supermarket, Community Centre, 5+ pre-schools/nurseries, 3 lower schools, a middle school, health care services including GP surgery, 3 chemists, 3 dentists, pubs, leisure centre, professional services, take-away and convenience stores. The town is also served by bus route Nos. 34 (Milton Keynes), 42/44 (Bedford), 5 (Silsoe), 200 (Silsoe/Biggleswade), which also serve some of the surrounding villages and settlements. The closest bus stop to the site is on Maulden Road and is served by bus route Nos. 42 and 5.
3.3 Flitwick Railway Station is located approximately 0.6 miles to the west of the site, and sits on the Govia Thameslink line that provides fast and frequent services to Brighton and London St Pancras in the south, and Bedford in the north. In this context, Flitwick can be clearly considered a sustainable location for new development.
The Proposed Allocation Site
3.4 The site is 20.5ha in size and is located within the Green Belt on the eastern edge of Flitwick and currently comprises an agricultural field.
3.5 The topography of the site is relatively flat and there is an existing agricultural access from Maulden Road adjacent to the existing residential properties adjoining the site. It is proposed to access the site from Maulden Road via a new roundabout junction with Maulden Industrial Estate. If required a secondary vehicle access could be provided off Greenfield Road to the south of the site.
3.6 The site is screened along the eastern boundary with Flitwick Moor but the western boundary with Maulden Road is open. There is some moderate existing natural screening to the northern and southern boundaries.
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3.7 The majority of the site is within Flood Zone 1 with a small corner in the south-east being within Flood Zone 2 and 3. It is only proposed to develop that part of the site within Flood Zone 1. The site therefore demonstrates minimal risk of flooding. The extent of the report site is shown in figure 1 below.
Figure 2: Location Plan Land East of Maulden Road
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4.0 PROPOSED ALLOCATION
4.1 An indicative masterplan was submitted to the Council in August 2017 (See Appendix 2). The vision for this site is to provide an employment-led mixed use development incorporating the following uses:
• 2.13 ha of mixed use employment with structured planting/landscaping along the northern boundary;
• 1.67 ha for health and social care hub including new GP surgery;
• 6.8 ha of residential development (around 150 dwellings at 25 dha) including bungalows and a mix of house sizes;
• Formal open space (1 ha); and
• Informal open space/Ecological enhancements including 2.5km of new and enhanced footpaths.
4.2 The primary access to the site would be taken from Maulden Road via a new roundabout junction with Maulden Industrial Estate, which would provide a safe means of access to both the site and industrial estate as well as reducing vehicle speeds along Maulden Road in the locality of existing residential properties. The road would run east into the site before curving and running south towards Greenfield Road. Additionally, a new cycle/footpath would be provided to the western side of Maulden Road towards the new Country Park providing a safe and convenient means of access to the park for both new and current residents. The south eastern part of the site that is within the flood zone would be left undeveloped. Just over 2 ha of employment land is proposed to the north western corner of the site adjacent to the existing industrial estate, with a strategic landscape belt to extend along the northern boundary. Our client’s site will assist with the provision of employment infrastructure for the area which will contribute to the ongoing regeneration of the town and assist in reducing out commuting of existing residents.
4.3 To the south of the employment land a ‘Health and Social Care Hub’ is proposed which is to include a new replacement GP surgery which will cater for the immediate needs of
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the locality as well as future needs arising in the area. Discussions with the existing GP surgery are currently ongoing.
4.4 South of the ‘Health and Social Care Hub’ bungalows are proposed to the rear of existing development on Maulden Road. This would ensure no concerns of overlooking/shadowing arise as well as offer an expanded choice in accommodation to existing residents to enable them to downsize whilst remaining in the town. Furthermore, the bungalows are located to the west of the site with the shortest walking distance of the town centre.
4.5 Housing is proposed to the east of the spine road at a density of circa 25 dha (in keeping with the density of housing to the west of Maulden Road) with this to include a mix of house sizes (1, 2, 3 and 4 bed units). The built form is to be separated from the adjacent woodland (Flitwick Moor SSSI) and Greenfield Road by a substantial buffer, including areas of formal open space (which will address the existing shortfall in the town) as well as informal open space. The informal open space includes 2.5km of footpaths and ecological improvements. These measures (along with the delivery of a new cycle/footpath to the Country Park) offer the opportunity to both enhance the existing ecological value of the site and reduce recreation pressure on the SSSI through providing easily accessible and high quality (all weather surface, seats and benches, litter and dog waste bins) circuit of footpaths. Additionally, this buffer will provide an attractive gateway to the south eastern entrance to the town and improve the setting of Flitwick Mill.
Technical Work
4.6 Detailed technical work in relation to ecology and transport was submitted to the Council as part of the representation in August, 2017. (See Appendix 2). This work has confirmed that these elements do not represent a constraint to development on this site and more importantly offers the opportunity to make substantial enhancements.
Ecology
4.7 An initial ecology appraisal and strategic assessment was also carried out for the site and adjacent Flitwick Moor SSSI and this was submitted with the August 2017 representation. This review concludes the site is of low ecological value and is not
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considered functional habitat for the SSSI. Furthermore, there is little overlap between species on the site and the SSSI.
4.8 Site - The informal open space proposed (to replace low value arable fields) will include new habitat creation that could include new woodland and wetland, and will offer an enhancement in available habitat for many species.
4.9 Flitwick Moor SSSI – A number of Public Rights of Way extend from Flitwick through the SSSI with users of these footpaths giving rise to recreational pressure on the woodland. The provision of a cycle/footpath along Maulden Road, facilitated by development on this site, to the new Country Park will provide convenient access for both new and existing residents to access this open space thus reducing recreational pressure on the SSSI. Moreover, the provision of a substantial area of public formal and informal open space including 2.5km of all-weather footpaths (served by litter and dog waste bins and seats and benches) will provide attractive alternative recreation space for users of the woodland thus substantially further reducing recreational pressure.
4.10 Development on this site therefore offers the opportunity to improve the existing ecological value of the site and reduce recreational pressure on the adjoining SSSI and the Council’s previous concerns in relation to the impact on ecology and the SSSI can be safely mitigated against and do not represent a constraint to development on this site.
Transport
4.11 A Transportation Technical Note was submitted alongside the August 2017 representation. (See Appendix 2). This provided an outline of the potential impact of the development on the local highway network and demonstrates the site lies in a sustainable location in terms of accessibility to public transport and day-to-day services and facilities.
4.12 It is proposed the access be taken via a new four arm roundabout that includes the existing Maulden Road industrial estate, which will not only provide for a safe means of access to this site but also assist in circulation of vehicles accessing/egressing from the industrial estate, and act as a traffic calming measure along Maulden Road where a number of residential properties are located.
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4.13 Furthermore, it is proposed as part of the development that a new cycle/footpath be provided towards the Country Park on the western side of Maulden Road thus representing a significant improvement to the local highway network.
4.14 In terms of access to public transport the site is within 1km walking distance to Flitwick Railway Station and is well connected to both the railway station and town centre by a network of well-lit footpaths. Additionally, the site is well located for journeys to school either on foot or bicycle, with Kingsmoor Lower School, Flitwick Lower School, Templefield Lower School and Woodland Middle School all lying within the recommended 2km walking distance
4.15 The highway appraisal also concludes that the proposed development on the site would not have a significant impact on existing traffic flows within the town centre or the wider area.
4.16 Following an assessment of the site’s constraints and opportunities, a concept master plan has been prepared to demonstrate how the site could potentially accommodate a range of different uses. This has been submitted with this representation.
4.17 The master plan shows that new employment provision provided opposite the existing industrial estate with a new roundabout introduced on Maulden Road which would improve vehicle movements and act as a traffic calming measure. The delivery of new employment to the town will contribute significantly to the ongoing regeneration of Flitwick and assist in reducing out commuting. A landscape belt is proposed to extend along the north of the site thus providing a suitable landscape buffer. Further highway improvements include the provision of a cycle/footpath along Maulden Road providing safe means of access for existing and new residents of Flitwick to the Country Park.
4.18 To the south of the employment land a Health and Social Care Hub including GP surgery is to replace the existing constrained surgery and provide for an integrated medical hub to serve the local community. The provision of bungalows will expand the range of housing stock in the town thus offering opportunities for existing residents to remain ‘local’ and free up larger houses for families. Moreover by locating the bungalows adjacent existing houses will ensure the amenity of Maulden Road residents are protected.
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4.19 On the eastern part of the site, houses are proposed at a similar (25dha) density to the built form on the western side of Maulden Road, with significant informal and formal public open space along with a network (2.5km) of public footpaths. This space would enhance the ecological value of site, reduce recreational pressure on the SSSI, improve the setting of the listed Flitwick Mill and provide an attractive gateway to the town.
4.20 The site is well related to the edge of the built-up area of Flitwick and as discussed above, does not perform any particular Green Belt function. Therefore, its allocation for development in the local plan would not harm any of the purposes of a Green Belt.
4.21 In the context of the above, the site represents a sustainable location for medium scale growth with no overriding constraints to the development and the concept master plan has been designed so that development on the site relates well to the existing pattern of development and settlement edge of Flitwick.
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5.0 OVERALL CONCLUSIONS
5.1 The Pre-Submission Plan should be prepared within the context of the government’s policy advice as set out in the Framework and related documents and guidance, to objectively identify and then fully meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Specifically, the Pre-Submission Plan should seek to “boost significantly the supply of housing” in accordance with paragraph 47 of the Framework.
5.2 DLP have significant reservations on the OAN advanced by the Council. This we believe both significantly underestimates the level of housing need and fails to reflect up to date government guidance on a range of matters, e.g. migration patterns and levels and as a result will both lead to a significant under supply of housing and worsen affordability. DLP believe there is a need to both substantially increase the level of housing beyond the very general scale that the Council have at this stage advanced, which in itself DLP believes is not in accord with Framework advice and both makes the strategy of the Pre- Submission Local Plan unclear and calls into question the basis of this.
5.3 CBC’s housing need figure for the plan is circa OAN of 1600 dpa. SPRU’s individual analysis identifies an OAN of 2,525 dpa. The government’s indicative OAN under its consultation on the methodology for assessing housing need is 2, 553 per annum (2016 – 2026).
5.4 On this basis we object to the Policy SP1: Growth Strategy. This policy should include a more flexible approach to be able to absorb changing circumstances.
5.5 Whilst DLP both recognise the need for and supports a strategy for growth, and also supports certain elements of the Council’s strategy, e.g. the intention to look to the establishment of ‘new settlements’ and allow for ‘urban extensions’, the approach adopted by the Council is in our considered view flawed and lacks proper, objective and thorough analysis and transparency.
5.6 In the context of the strategy advanced at this stage, we generally support Major Service Centres, such as Flitwick, being identified for new development. However, we feel that
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the Pre0Submission Local Plan should also take into account the individual needs of each settlement. In this regard we consider Flitwick is clearly capable of accommodating new growth.
5.7 Flitwick West the only option assessed in the SAR for development in the town. The omission of the analysis of any other strategic alternatives to bring forward growth in the town is a flaw in this process. Our site, in the East of Flitwick is a strong contender to bring forward growth.
5.8 The Green Belt in the stage 1 and 2 assessments identified the parcels of land FW2/2a as the most ‘weak’ in their conclusions in Figure 5.2. Therefore, it is an error of this analysis to account this land from the next stage of the Green Belt Assessment.
5.9 As such we object to the Council’s current apportionment of growth. We are of the view that the Council have not got a robust settlement hierarchy which is backed up by an up to date evidence base including the Green Belt Study and the SAR.
5.10 In addition, our site ‘Land East of Maulden Road’, should be included as an allocation in the Pre-Submission Policy HA1: Small and Medium Allocations. This site has been incorrectly omitted from the SAR. The selected site allocation ‘NLP039 Steppingley Road’ for 420 residential units is being put forward. This formed part of the land parcel FW4 in the Green Belt study which represented one of the best scoring locations against the purposes of the Green Belt.
5.11 The SHLAA discounts this site as being suitable, available and achievable for future housing growth, however it does not take into account the configuration, design and approach that can be taken to avoid any designated land constraints and align the proposed development along the existing settlement boundary. The ‘Land to the East of Maulden Road’ represents a suitable and sustainable site for new development that is well related to the main built form of the town. Our client’s site on the east side of Flitwick offers an opportunity to provide a well-planned employment-led mixed use development, including much needed new housing, in a timely manner that could be delivered early in the plan period. Flitwick is a sustainable location for growth and provides a good range of services. Our client’s site is in a sustainable location for development, the landowner is committed to developing the site so it is available, and there are no constraints to
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developing the site. In this respect the site is truly deliverable. As a result of the above, we object to the Council’s Policy HA1: Small and Medium Allocations.
5.12 Policy SP7: Development within Settlement Envelopes ignores the development potential of sites adjoining the settlement boundary. On this basis we object to Policy SP7: Development within Settlement Envelopes as it is not considered consistent with the Framework Paragraph 17. The Policy: EE6 Tranquillity is considered to be overly restrictive and not based on sufficient evidence. We object to Policy: EE6 Tranquillity this policy as it is not consistent with the Framework Paragraph 109.
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