For and on Behalf of Pigeon Investment Management Ltd
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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. 2 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd 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 3 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd 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. 4 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd 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.” 5 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd 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 6 BE5265 – Land East of Maulden Road, Flitwick February 2018 On Behalf of Pigeon Investment Management Ltd 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.