Gladman Developments Ltd

Representations on Central Bedfordshire Local Plan 2015-2035 Draft Plan – July 2017

August 2017

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

CONTENTS

1. EXECUTIVE SUMMARY ...... i 2. INTRODUCTION ...... 1 1.1 Context ...... 1 1.2 Previous Submissions ...... 2 3. NATIONAL PLANNING POLICY ...... 3 2.1 National Planning Policy Framework and Planning Practice Guidance ...... 3 2.2 Housing White Paper – Fixing our broken housing market ...... 4 4. DUTY TO COOPERATE ...... 8 4.2 Unmet Housing Needs ...... 8 5. SUSTAINABILITY APPRAISAL ...... 10 5.1 Overview ...... 10 6. OBJECTIVELY ASSESSED HOUSING NEED ...... 12 6.1 Background ...... 12 7. THE CENTRAL BEDFORDSHIRE DRAFT LOCAL PLAN, JULY 2017 ...... 17 7.2 The Spatial Strategy ...... 17 7.3 Policy SP1: Growth Strategy ...... 17 7.4 Policy SP2: National Planning Policy Framework – Presumption in Favour of Sustainable Development ...... 18 7.5 Implementation ...... 18 7.6 Policy SP4: Coalescence and Policy SP5: Important Countryside Gaps ...... 18 7.7 Settlement Envelopes & Hierarchy - Overview...... 19 7.8 The Proposed Position of Merpershall within the Settlement Hierarchy ...... 20 7.9 Policy SP6: Development within Settlement Envelopes and DC1: Development in the Countryside ..... 22 7.10 Policy H1: Housing Mix ...... 22 7.11 Policy H2: Housing Standards ...... 22 7.12 Policy H4: Affordable Housing / Viability ...... 22 7.13 Policy H6: Starter Homes...... 23 7.14 Policy H7: Self and Custom Build Housing ...... 23 7.15 Policy EE5 – Landscape Character and Value ...... 23 7.16 Policy CC1: Climate Change and Sustainability ...... 24 7.17 Policy HQ1: Health Impact Assessment ...... 24 7.18 Policy HQ2: Provision for Social and Community Infrastructure ...... 24 7.19 Policy HQ5: Broadband and Telecommunications Infrastructure ...... 24 7.20 Policy HQ8: Backland Development ...... 25 7.21 Policy HQ9: Larger Sites ...... 25 7.22 Policy HQ11: Modern Methods of Construction ...... 25 7.23 Policy HE3: Built Heritage ...... 25 7.24 Policy DC6: Agricultural Land ...... 26 8 SITE SUBMISSIONS ...... 27

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8.1 Overview ...... 27 9 CONCLUSIONS ...... 28 9.1 Overview ...... 28

APPENDICES

APPENDIX 1 - LAND OFF MILL ROAD, CRANFIELD

APPENDIX 2 - LAND AT WHARLEY END, CRANFIELD

APPENDIX 3 - LAND OFF LANGFORD ROAD, HENLOW

APPENDIX 4 - LAND AT SHEFFORD ROAD, MEPPERSHALL

APPENDIX 5 - LAND AT BIGGLESWADE ROAD, POTTON

APPENDIX 6 - LAND EAST OF HIGH STREET, SILSOE

APPENDIX 7 - LAND BETWEEN ASTWICK ROAD AND TAYLOR’S ROAD, STOTFOLD

APPENDIX 8 - LAND WEST OF ASTWICK ROAD, STOTFOLD

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

1. EXECUTIVE SUMMARY i This submission provides Gladman Development’s written representations on the Central Bedfordshire Local Plan 2015-2035, Draft Plan – July 2017. ii Gladman specialises in the promotion of strategic land for residential development, with associated community infrastructure, and has previously been involved in the preparation of the Local Plan and is actively promoting a number of sites for residential development within the District. iii These representations concern the following matters:

 National Planning Policy / Housing White Paper

 Duty to Cooperate

 Sustainability Appraisal

 Site Selection

 Housing Needs

 Settlement Hierarchy

 Draft Local Plan Policies

 Site Submissions iv At Section 5, Gladman raise specific concerns in relation to the site assessment process that has been undertaken to date. Whilst no sites have been identified for housing allocations at this stage, in preparing the pre-submission version of the Plan, it is essential that the sustainability appraisal considers all reasonable alternatives to the same level of details as the site options that are ultimately selected for allocation. v These submissions set out that the Local Plan that is published under Regulation 19 will need to provide a clear and justified position in terms of the minimum housing requirement that is being planned for. This must be based on a carefully considered evidence base and provide sufficient flexibility to ensure that the spatial strategy can deliver against this requirement. The Council will need to be mindful of the current national policy requirement in terms of calculating OAN, but also give careful consideration to the Government’s proposed move towards a standardised methodology which is expected to be published for consultation in September 2017. vi Gladman supports the concept of new settlements and town extensions which represent a potentially sustainable means of providing new homes, jobs and associated community infrastructure. It is, however, essential that the deliverability, scale, complexity and development requirements of all allocations that are ultimately proposed is thoroughly considered as part of the evidence base that underpins the pre-submission version of the Plan.

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

vii The Local Plan does not currently identify any potential allocations beyond a long list of sites that are being considered as town extensions or new settlements. Gladman consider that a wide portfolio of allocations will be required within and adjacent to sustainable settlements as part of the spatial strategy to ensure that the Local Plan can demonstrably meet the development needs of the area through its allocations and fulfil the national policy requirement to significantly boost the supply of housing. viii Gladman note the inclusion of a detailed Settlement Hierarchy and would expect this to be underpinned by up-to-date technical evidence and for this to support a wide range of sites to be proposed for allocation within the pre-submission version of the plan. ix Gladman also provide a number of comments on specific policies contained within the Plan at Section 7. It is likely that a number of draft policies will require further amendment if they are to meet the tests of soundness at examination. x At Section 8 and through associated appendices, Gladman provide site submissions for a number of sustainable locations within the District that require consideration as housing site allocations within the plan-making process. These sites are suitable, available and achievable; and are deliverable and developable within the plan period. As such, they represent significant opportunities for allocation through the Local Plan:

a. Land off Mill Road, Cranfield

b. Land at Wharley End, Cranfield

c. Land off Langford Road, Henlow

d. Land at Shefford Road, Meppershall

e. Land at Biggleswade Road, Potton

f. Land East of High Street, Silsoe

g. Land Between Astwick Road and Taylor’s Road, Stotfold

h. Land West of Astwick Road, Stotfold

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

2. INTRODUCTION

1.1 Context

1.1.1 Gladman Developments specialises in the promotion of strategic land for residential development with associated community infrastructure. This submission provides Gladman Development’s representations on the Central Bedfordshire Local Plan 2015-2035, Draft Plan – July 2017.

1.1.2 The pre-submission version of the Plan that is published in due course will need to ensure a sufficient supply of deliverable and developable sites to meet Central Bedfordshire’s objectively assessed housing needs in full, whilst fully taking into account any unmet need arising from neighbouring authorities. We submit that in addition to the strategic sites that have been identified for potential allocation, the Local Plan should be seeking to identify a wide number sites across the settlement hierarchy.

1.1.3 This response promotes the inclusion of the following sites for residential development within the Local Plan:

 Land off Mill Road, Cranfield

 Land at Wharley End, Cranfield

 Land off Langford Road, Henlow

 Land at Shefford Road, Meppershall

 Land at Biggleswade Road, Potton

 Land East of High Street, Silsoe

 Land Between Astwick Road and Taylor’s Road, Stotfold

 Land West of Astwick Road, Stotfold

1.1.4 An overview of the site submissions can be seen in Section 8, with further details provided in the form of ‘Development Briefs’ which have been appended to these representations.

1.1.5 The National Planning Policy Framework (NPPF) sets out four tests that must be met for Local Plans to be considered sound. In this regard we submit that in order to prepare a sound plan it is fundamental that it is:

 Positively Prepared – The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

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 Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.

 Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

 Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

1.2 Previous Submissions

1.2.1 Gladman have made submissions in response to the following consultations in relation to the preparation of the Central Bedfordshire Local Plan:

 Call for Sites, April 2016

 Sustainability Appraisal Scoping Report, September 2016

 SHLAA Viability, October 2016

 Shaping Central Bedfordshire Consultation Document, October 2016

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

3. NATIONAL PLANNING POLICY

2.1 National Planning Policy Framework and Planning Practice Guidance

2.1.1 The NPPF has been with us now for over five years and the development industry has experience with its application and the fundamental changes it has brought about in relation to the way the planning system functions. The NPPF sets out the Government’s goal to ‘significantly boost the supply of housing’ and how this should be reflected through the preparation of Local Plans. In this regard it sets out specific guidance that local planning authorities must take into account when identifying and meeting their objectively assessed housing needs:

“To boost significantly the supply of housing, local planning authorities should:

 Use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area

 Identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements…”

 Identify a supply of specific, developable sites or broad locations for growth, for years 6-10, and where possible for years 11-15” (Paragraph 47)” 2.1.2 The starting point of identifying objectively assessed housing needs is set out in paragraph 159 of the NPPF, which requires local planning authorities to prepare a Strategic Housing Market Assessment (SHMA), working with neighbouring authorities where housing market areas cross administrative boundaries. It is clear from the NPPF that the objective assessment of housing needs should take full account of up-to-date and relevant evidence about the economic and social characteristics and prospects of the area, with local planning authorities ensuring that their assessment of and strategies for housing and employment are integrated and take full account of relevant market and economic signals (paragraph 158).

2.1.3 Once a local authority has identified its objectively assessed needs for housing these needs should be met in full, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so (paragraph 14). Local planning authorities should seek to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Adverse impacts on any of these dimensions should be avoided. Where adverse impacts are unavoidable, mitigation or compensatory measures may be appropriate (paragraph 152).

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

2.1.4 As the Council will be aware the Government published its suite of Planning Practice Guidance (PPG) on the 6th March 2014, clarifying how specific elements of the NPPF should be interpreted when preparing their Local Plans and that this has since been the subject of periodic updates. The PPG on the Housing and Economic Development Needs in particular provides a clear indication of how the Government expects the NPPF to be taken into account when Councils are identifying their objectively assessed housing needs. Key points from this document include:  Household projections published by the Department for Communities and Local Government should provide the starting point estimate of overall housing need  Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic underperformance, infrastructure or environmental constraints.  Household projection based estimates of housing need may need adjusting to reflect factors affecting local demography and household formation rates which are not captured by past trends, for example historic suppression by under supply and worsening affordability of housing. The assessment will need to reflect the consequences of past under delivery and the extent to which household formation rates have been constrained by supply.  Plan makers need to consider increasing their housing numbers where the supply of working age population is less than projected job growth, to prevent unsustainable commuting patterns and reduced local business resilience.  Housing needs indicated by household projections should be adjusted to reflect appropriate market signals, as well as other market indicators of the balance between the demand for and supply of dwellings.

2.1.5 The more significant the affordability constraints (as reflected in rising prices and rents, and worsening affordability ratio) and the stronger other indicators of high demand (e.g. the differential between land prices), the larger the improvement in affordability needed, and the larger the additional supply response should be.

2.1.6 The total affordable housing need should be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the local plan should be considered where it could help to deliver the required number of affordable homes.

2.2 Housing White Paper – Fixing our broken housing market

2.2.1 The Government published the Housing White Paper in February 2017 for consultation. Whilst it is a White Paper, it nevertheless represents a very clear direction of travel and clear indication of the government’s intent. The Council will need to consider the emerging Plan against the points raised within the White Paper, and monitor the progress of the consultation as the proposals within it materialise as potential reforms to the planning system. Given that the intention of the document is

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to have some of its proposed changes come into force by November 2017, it is highly likely that a number of its measures will be relevant considerations prior to the submission and adoption of the plan.

2.2.2 The title of the White Paper makes apparent that the Government considers the housing market to be broken, it is also clear from the document’s foreword from the Prime Minister that the cost of housing is a key part of why the housing market is considered broken. In the foreword the Prime Minster states:-

“Today the average house costs almost eight times average earnings – an all-time record.”

“In total, more than 2.2 million working households with below-average incomes spend a third or more of their disposable income on housing.”

“We need to build many more houses, of the type people want to live in, in the places they want to live. To do so requires a comprehensive approach that tackles failure at every point in the system.” (Foreword from the Prime Minister)

2.2.3 The second foreword from the Secretary of State adds further to the Government’s thinking, particularly on the need to build new homes now, it states:-

“This country doesn’t have enough homes. That’s not a personal opinion or a political calculation. It’s a simple statement of fact”

“Soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation.”

“That has to change. We need radical, lasting reform that will get more homes built right now and for many years to come.”

2.2.4 The White Paper outlines further potential reforms to the plan making process, OAN methodology, and Green Belt consideration and housing delivery tests, amongst others. Gladman will refer to key aspects from the White Paper in relevant sections of this representation.

2.2.5 The Government White Paper (‘Fixing our Broken Housing Market’) issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy. The Government are in no doubt that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today.

2.2.6 The reason for this crisis is that the country is simply not building enough homes and has not done so for far too long. The consensus is that we need from 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.

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2.2.7 Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that “the housing shortage isn’t a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.”

2.2.8 Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever- widening gap between the property haves and have-nots.

2.2.9 The challenge of increasing supply cannot be met by Government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities.

2.2.10 The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.

2.2.11 Currently, over 40 per cent of local planning authorities do not have a plan that meets the projected growth in households in their area. All local authorities should therefore develop an up-to-date plan with their communities that meets their housing requirement based upon an honest assessment of the need for new homes.

2.2.12 Local planning authorities have a responsibility to do all that they can to meet their housing requirements, even though not every area may be able to do so in full. The identified housing requirement should be accommodated in the Local Plan, unless there are policies elsewhere in the Framework that provide strong reasons for restricting development, or the adverse impacts of meeting this requirement would significantly and demonstrably outweigh the benefits. Where an authority has demonstrated that it is unable to meet all of its housing requirement, it must be able to work constructively with neighbouring authorities to ensure the remainder is met.

2.2.13 Plans should be reviewed regularly, and are likely to require updating in whole or in part at least every five years. An authority will also need to update their plan if their existing housing target can no longer be justified against their objectively assessed housing requirement.

2.2.14 Policies in Local Plans should also 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 including opportunities for SME housebuilders to deliver much needed housing.

2.2.15 In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently find it hard to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a

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way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.

2.2.16 The Government has made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled people.

2.2.17 The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious about the provision of the right number of houses in the right places. The Central Bedfordshire Local Plan therefore needs to consider these policy intentions now in order to ensure that it fulfils the Government’s agenda and provides the homes that its local communities need.

2.2.18 Following the election, Sajid Javid re-iterated the Government’s intentions for boosting housing growth stating that he wants areas that have benefitted from soaring property prices to play their part in solving the housing crisis. Mr Javid pointed out that where property prices were particularly unaffordable, local leaders would need to take a long, hard and honest look to see if they are planning for the right number of homes. The Government also remains committed to introducing a standardised methodology for the calculation of housing need and it is anticipated that this will be the subject of consultation later this year and that the approach will apply to local plans that are submitted after March 2018.

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

4. DUTY TO COOPERATE

4.1.1 The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan preparation. As demonstrated through the outcome of the 2012 Coventry Core Strategy Examination and the 2013 Mid Sussex Core Strategy Examination, if a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.

4.1.2 Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration1, as set out in the PPG it is clear that it is intended to produce effective policies on cross- boundary strategic matters. In this regard Central Bedfordshire must be able to demonstrate that it has engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross boundary strategic issues, and the requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question of effective cooperation that is necessary to shape the preparation of a sound local plan.

4.1.3 Further, the PPG reflects on the bodies which are subject to the Duty to Cooperate. It contains a list of the prescribed bodies. The PPG then goes on to state that:

“These bodies play a key role in delivering local aspirations, and cooperation between them and local planning authorities is vital to make Local Plans as effective as possible on strategic cross boundary matters.”

4.1.4 It is noted that at present there is no Duty to Cooperate statement included on the Council website to support the submission of the plan. At this stage, and given the clear key issue around cooperation, we would expect to see a supporting statement from the Council clearly outlining its reasons for pursuing its chosen strategy.

4.2 Unmet Housing Needs

4.2.1 The Plan includes a suggestion that 7,400 new homes will be added to the minimum requirement in order to support the delivery of Luton’s unmet housing needs. It is however clear from the recent Inspector’s Report on the Examination of the Luton Local Plan 2011 to 2031 that a level of unmet need totalling 9,300 homes has arisen from Luton’s plan making (which is a figure that could grow over time). It is therefore essential that the Central Bedfordshire Local Plan sets out how this unmet need will be delivered. Furthermore, the Report highlights that there is little certainty regarding the scale or location of any contribution towards Luton’s unmet housing needs from Central Bedfordshire and Aylesbury Vale and it is important that the commitment towards meeting unmet needs across

1 PPG Reference ID. 9-011-2014036

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all relevant authorities is firmed up in order to ensure that housing needs can be met in full in the manner expected by the Framework.

4.2.2 It is also considered necessary for the Central Bedfordshire Local Plan to include a review mechanism within its policies to ensure its effectiveness in responding to issues of unmet need arising from neighbouring and nearby authorities. The SHMA indicates that Central Bedfordshire has links with the Milton Keynes, Bedford and Stevenage HMAs and it is therefore essential that Council works with these authorities on cross border matters such as economic development, housing and infrastructure delivery. Furthermore, the proposed Cambridge, Milton Keynes and Oxford Growth Corridor will impact on Central Bedfordshire and on-going co-operation will be essential to ensure the needs of this key economic growth area can be supported. The Plan will also need to be responsive to London’s unmet needs given the clear links to the Capital and the expectation that London will continue to under-deliver against its own needs.

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

5. SUSTAINABILITY APPRAISAL

5.1 Overview

5.1.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives.

5.1.2 Critically, the National Planning Policy Framework at Paragraph 165 sets out that:

“a sustainability appraisal which meets the requirements of the European Directive on strategic environmental assessment should be an integral part of the plan preparation process, and should consider all the likely significant effects on the environment, economic and social factors.”

Following this the Planning Practice Guidance (PPG) requires that different realistic and deliverable options for policies within the Plan are tested, setting out:

“they must be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made”2

The SA is required to set out why those reasonable alternatives were chosen. In terms of housing policies for the Plan this means the need to test:

i. Reasonable alternatives on the quantum of development (i.e. the housing requirement); and, ii. Reasonable alternatives on the distribution of development (i.e. the spatial strategy and combination of site allocations to be made).

5.1.3 The Central Bedfordshire Local Plan should be based on an SA process that clearly justifies its policy choices. In meeting the development needs of the area, it should be clear from the results of the assessment why some policy options have been progressed, and others have been rejected. Undertaking a comparative and equal assessment of each reasonable alternative, the Central Bedfordshire decision making and scoring should be robust, justified and transparent.

5.1.4 Gladman remind the Council that there have now been a number of instances where the failure to undertake a satisfactory SA has resulted in a local plan failing the test of legal compliance at Examination or being subjected to legal challenge.

2 Planning Practice Guidance Ref ID:11-018)

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5.1.5 As part of the site selection process, it considered vital that the Local Plan is underpinned by a process that includes a robust assessment of development opportunities across all scales of sites that exist in the area (not just strategic scale sites and those sites adjacent to Green Belt settlements as is currently the case in the Regulation 18 Sustainability Appraisal, July 2017). It is considered that small and medium sized sites across the district will form an essential element of a sustainable growth strategy for Central Bedfordshire and that an extensive number of alternatives will need to be thoroughly considered through the SA process. Due consideration must also be given to all development options outside of the Green Belt as part of any justification for the existence of ‘exceptional circumstances’ necessary for the adjustment of green belt boundaries. In addition, sites should not be discounted from consideration without being considered on a like-for-like basis with the option that is ultimately preferred within the Local Plan. Critically, the SA must positively reflect the Planning Practice Guidance which highlights that:

“The sustainability appraisal should identify any likely significant adverse effects and measures envisaged to prevent, reduce and, as fully as possible, offset them. The sustainability appraisal must consider all reasonable alternatives and assess them in the same level of detail as the option the plan- maker proposes to take forward in the Local Plan (the preferred approach).” (Our emphasis)3

5.1.6 At this stage, Gladman wish to raise a specific concern with the manner in which the Council’s ‘Site Assessment’ has sought to discount a number of sites from further consideration through the local plan process. In particular, the approach to selecting sites for consideration as land use allocations will need to take into account the potential for negative impacts to be mitigated through a comprehensive and comparable assessment of all reasonable alternatives at the same level of detail as the preferred option that is ultimately selected.

5.1.7 Gladman previously responded to the SA Scoping Report, which was published for consultation in September 2016. Clearly, the SA that accompanies this consultation is not at the stage where the comparative assessment of individual sites for residential allocation has been undertaken and we would therefore highlight the importance of the need for a comprehensive exercise to support the pre-submission version of the Local Plan. We look forward to reviewing the SA that accompanies the version of the Plan that is published under Regulation 19 in due course.

3 Planning Practice Guidance Reference ID: 11-018-20140306

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6. OBJECTIVELY ASSESSED HOUSING NEED

6.1 Background

6.1.1 The process of determining OAN is clearly set out in the NPPF principally in Paragraphs 14, 47, 152 and 159 and should be undertaken in a systematic and transparent way to ensure that the plan is based on a robust evidence base.

6.1.2 The starting point for this assessment requires local planning authorities to have a clear understanding of housing needs in their area. This involves the preparation of a SHMA working with neighbouring authorities where housing market areas cross administrative areas as detailed in Paragraph159 of the NPPF. The NPPF goes on to set out the factors that should be included in a SHMA including identifying

“the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:

 Meets household and population projections taking account of migration and demographic change;

 Addresses the need for all types of housing including affordable housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and

 Caters for housing demand and the scale of housing supply necessary to meet this demand.”

6.1.3 Key points that are worth noting from the above is that the objective assessment should identify the full need for housing before the Council consider undertaking any process of assessing the ability to deliver this figure. In addition, Paragraph159 specifically relates to catering for both housing need and housing demand within the authority area. It is worth pointing out that any assessment of housing need and demand within a SHMA must also consider the following factors; falling household formation rates, net inward migration, the need to address the under provision of housing from the previous local plan period, the results of the Census 2011, housing vacancy rates including the need to factor in a housing vacancy rate for churn in the housing market, economic factors to ensure that the economic forecasts for an area are supported by sufficient housing to deliver economic growth, off-setting a falling working age population by providing enough housing to ensure retiring workers can be replaced by incoming residents, addressing affordability and delivering the full need for affordable housing in an area.

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6.1.4 Of particular importance is the need to consider market signals. The consideration of market signals is one of the core planning principles considered in Paragraph17 of the NPPF, which states:

“..Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities.”

6.1.5 Of critical importance is what the NPPF goes onto say in Paragraph 158 in the section discussing Plan Making. It states here:

“Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.”

6.1.6 Market signals are therefore at the very core of what the NPPF is trying to achieve in promoting sustainable development and boosting the supply of housing land.

6.1.7 The formal publication of the Planning Practice Guidance (PPG) in March 2014 gives further explanation to what the NPPF means with regard to market signals, and sets out, in a range of paragraphs, the way in which local planning authorities should go about factoring in relevant market signals in arriving at their OAN. Paragraphs17, 19 and 20 of the PPG gives guidance on what market signals should be taken into account and how plan makers should respond to these market signals. The below extracts identify some particularly pertinent points.

“The housing need number suggested by household projections (the starting point) should be adjusted to reflect appropriate market signals, as well as other market indicators of the balance between the demand for and supply of dwellings. Prices of rents rising faster than the national/local average may well indicate particular market undersupply relative to demand.”

6.1.8 The paragraph goes on to indicate that these factors would include, but should not be limited to, land prices, house prices, rents, affordability, rates of development and overcrowding. However, given what the NPPF says at Paragraph17, quoted above, it seems clear that particular consideration should be given to affordability.

6.1.9 In order to consider how market signals should be taken forward, Paragraph 20 identifies some key concepts:

“Appropriate comparisons of indicators should be made. This includes comparison with longer term trends (both in absolute levels and rates of change) in the: housing market area; similar 13

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demographic and economic areas; and nationally. A worsening trend in any of these indicators will require upward adjustment to planned housing numbers compared to ones based solely on household projections.” (emphasis added)

6.1.10 It is clear therefore that where market signals are apparent (in any of the indicators assessed) there is an absolute and clear direction that an upward adjustment to housing numbers is required. It is also clear that both the absolute level of change and the rates of change are considerations, and that local planning authorities need to carefully bench mark themselves against other areas. This should not simply be a case of considering neighbouring authorities but should look at, as well as these, local authorities on a national basis, if the demographic and economic indicators are relevant. Gladman are firmly of the view that considering comparisons purely against neighbouring authorities is not sufficiently robust and does not address the underlying issues which both the NPPF and PPG are trying to tackle with regard to housing.

6.1.11 Also of importance when considering these issues is the period of time analysed when considering both relative and absolute change. It has become apparent, in our consideration of a number of plans that many local authorities choose to look at periods of time which are not fully representative of the depth of the housing crisis which we are currently experiencing.

6.1.12 The current housing shortage is highlighted in ‘Fixing the Foundations: Creating a More Prosperous Nation’ published by HM Treasury in July 2015. In paragraph 9.7 the report states:

“There remains more to do. As the London School of Economics (LSE) Growth Commission found, ‘under supply of housing, especially in high-growth areas of the country has pushed up house prices. The UK has been incapable of building enough homes to keep up with growing demand.”

6.1.13 Gladman is therefore of the view that local planning authorities must take a long term view when considering affordability and consider the relative and absolute change over a long term 15-20 year period, which coincides with the normal time span of a Local Plan. Authorities should assess, as a constituent part of their OAN, how they can improve affordability over the life time of a plan to a point where affordability is more in line with average earnings and affordable mortgage lending rates. They should assess a level of housing over the 15-20 year plan period which would enable this step change and consider its deliverability in the plan. Only through planning for significant housing growth can local authorities realistically tackle market signals in the way advocated by the PPG and tackle the affordability and housing crisis.

6.1.14 The need to identify the full OAN before considering any issues with the ability of a Local Planning Authority to accommodate that level of development has been confirmed in the High Court. Most notably in Solihull Metropolitan Borough Council v (1) Gallagher Homes Limited (2) Lioncourt Homes

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Limited where it was considered that arriving at a housing requirement was a two stage process and that first the unconstrained OAN must be arrived at. In the judgement it was stated:

“The NPPF indeed effected a radical change. It consisted in the two-step approach which paragraph 47 enjoined. The previous policy’s methodology was essentially the striking of a balance. By contrast paragraph 47 required the OAN [objectively assessed need] to be made first, and to be given effect in the Local Plan save only to the extent that that would be inconsistent with other NPPF policies. […] The two-step approach is by no means barren or technical. It means that housing need is clearly and cleanly ascertained. And as the judge said at paragraph 94, “[h]ere, numbers matter; because the larger the need, the more pressure will or might be applied to [impinge] on other inconsistent policies”.

6.1.15 Therefore, following the exercise to identify the full OAN for housing in an area,

“Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where adverse impacts are unavoidable, measures to mitigate the impact should be considered. Where adequate mitigation measures are not possible, compensatory measures may be appropriate.” (NPPF para 152)

6.1.16 This statement clearly sets out that local planning authorities should seek to deliver the full OAN and that this should be tested through the evidence base. Only where the evidence shows that this is not reduced or eliminated by pursuing these options. If this is not possible then they should test if the significant adverse impacts could be mitigated and where this is not possible, where compensatory measures may be appropriate.

6.1.17 The final stage of the process is outlined in Paragraph14 of the NPPF and involves a planning judgement as to whether, following all of the stages of the process outlined above,

“Local Plans should meet OAN, with sufficient flexibility to adapt to rapid change, unless:

 any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this framework taken as a whole; or

 specific policies in this Framework indicate development should be restricted.”

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6.1.18 It is also worth noting that the final part of this sentence refers to footnote 9 of the NPPF which sets out the types of policies that the Government consider to be restrictive. These include:

“sites protected under the Birds and Habitat Directive (see paragraph 119) and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion”.

6.1.19 Although this list is not exhaustive it is clear that local landscape designations, intrinsic value of the countryside, the character of areas, green gaps etc. are not specifically mentioned as constraints by the NPPF.

6.1.20 The PPG contains guidance to support local authorities in objectively assessing and evidencing development needs for housing (both market and affordable) and economic development. This document supports and provides further guidance on the process of undertaking such assessments, in addition to what is set out in the NPPF.

6.1.21 Obviously, the Government intends to standardise the calculation of housing need as set out in the White Paper on housing. As yet, we are unaware of what the new methodology will involve, but the Council will need to the evidence base of the Local Plan under review to ensure that it reflects the latest guidance as the White Paper is implemented. It is anticipated that the proposed consultation on the standardised housing needs calculation will take place in the autumn and that the new approach will apply to local plans submitted for examination after 31 March 2018.

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7. THE CENTRAL BEDFORDSHIRE DRAFT LOCAL PLAN, JULY 2017

7.2 The Spatial Strategy

7.2.1 At this stage, the Local Plan remains unfixed in terms of the level of need that must be planned for. Paragraph 7.1.4 of the Plan highlights that land for a minimum of 20,000 new homes is to be allocated over the plan period, whilst table 7.2 sets out a range that suggest that the Council may actually need to Plan to accommodate a minimum of 31,822 new homes on newly allocated sites from 2015 to 2035. Further to Section 6 above, it is essential that a robust approach is taken in determining the level of growth that is required before identifying an appropriate spatial strategy that will underpin how this growth can be accommodated in a sustainable manner across a wide range of sites.

7.2.2 The Local Plan does not currently provide any information on the extent to which small and medium sized sites will contribute towards meeting the development needs of the area. Paragraph 7.8.2 confirms that this remains undecided in the context of the number of strategic sites that are carried forward into the next version of the Plan as draft allocations. This is discussed further below in Section 7.3 on the ‘Growth Strategy’ and in Section 10 on the ‘Settlement Hierarchy’.

7.3 Policy SP1: Growth Strategy

7.3.1 Gladman’s experience is that the best way in which to ensure the delivery of housing targets is to maintain a good spread of sites and site typologies across a district. When considering housing needs of the scale that is likely to be required in Central Bedfordshire (and with one eye to the next plan period and any further unmet need from neighbouring authorities) it is reasonable for the Council to consider new settlements and town extensions. The level of infrastructure required to deliver such sites can however be substantial and costly. As a result, it can be difficult to accurately forecast the length of time that will be required to implement such schemes. It is therefore our view that the spatial strategy must specifically recognise the need for a wide range of smaller allocations for new housing of between 50 and 300 dwellings across a wide range of settlements. These sites will be deliverable in the short to medium term, provide greater certainty and make a significant contribution towards soundly meeting the plan’s housing targets.

7.3.2 It is essential that the pre-submission version of the Local Plan sets out a minimum housing target that has been robustly determined and the spatial strategy will need to be refined to enable a housing trajectory that can demonstrably deliver against that local plan target over the plan period. The trajectory must also provide a detailed breakdown of any committed sites and the proposed site allocations to set out how they are expected to contribute towards meeting the housing requirement.

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7.4 Policy SP2: National Planning Policy Framework – Presumption in Favour of Sustainable Development

7.4.1 Gladman are fully supportive of the emphasis of Policy SP2, the final version of which should affirm the Local Planning Authority’s commitment to making local planning decisions based on a presumption in favour of sustainable development. This should provide assurance of a local approach to planning that will proactively seek to improve the social, environmental and economic well-being of area by ensuring that development demonstrably contributes to the specific strategic and local vision and objectives of the Local Plan. The ethos of sustainable development is key to assessing planning proposals, it is the golden thread running through the NPPF.

7.5 Implementation

7.5.1 Paragraph 8.3.2 indicates that the Council is looking at options that might assist in preventing the presumption in favour of sustainable development. It should however be recognised that this is a direction that is central to the Government’s planning policies contained within the Framework and as such it is not possible for a local plan to over-ride such a presumption. It is however possible for a local plan to take a positive and flexible approach to the identification of land for housing that will enable it to minimise the risk of its policies for the supply of housing being deemed out-of-date in the context of paragraph 49 of the Framework. To achieve this, it is essential that the Local Plan identifies a sufficient number of sites across a broad range of settlements, with sufficient contingency provided to ensure that any changes in circumstance can be quickly addressed. This is likely to be achieved by planning for at least 20% above the minimum housing target and the inclusion of a Local Plan review mechanism that can be triggered through a robust and pro-active approach to monitoring.

7.5.2 With the above in mind, we welcome the local planning authority’s commitment to monitoring that is provided at paragraph 8.4 and suggest that there is a need to include an associated local plan review mechanism within the policies contained in the pre-submission version of the Plan.

7.6 Policy SP4: Coalescence and Policy SP5: Important Countryside Gaps

7.6.1 The identification of local environmental designations through planning policies, including countryside gaps and buffers relating to the separation of settlements, must be predicated on a robust and comprehensive evidence base that can be used in the planning balance advocated by the Framework, allowing the Council to assess whether the adverse impacts of the loss of such areas significantly and demonstrably outweigh the benefits of delivering the full need for housing.

7.6.2 Green Buffer / Gap policies have been questioned by Inspectors in recent appeal decisions as to whether they are compliant with the Framework and the Presumption in Favour of Sustainable Development. It is unlikely that any policy of this nature will meet the tests of soundness set out in the Framework. Policies of this nature put at risk the ability of the Council to grant planning permissions for development in sustainable locations to meet its full objectively assessed need. The Council should not therefore continue to promote the policy designations in the manner that is prescribed through polices SP4: Coalescence and Policy SP5: Important Countryside Gaps.

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7.6.3 Gladman are opposed to the use of green buffers of this nature if the policies associated with them would only serve to act as an arbitrary tool to prevent sustainable development. In this regard we submit that new development can often be located in such areas, without leading to the physical or visual merging of settlements, eroding the sense of separation between them or resulting in the loss of openness and character.

7.6.4 Gladman are also concerned that the Council is promoting an approach to the allocation of housing that may inadvertently preclude sustainable development options from being considered to the same level of detail as the site options that that ultimately selected for allocation. A number of sites have been unduly discounted from consideration for allocation on a high level assumption that they may result in coalescence without any consideration being given to whether this is actually the case or if any perceived harm could be successfully mitigated.

7.7 Settlement Envelopes & Hierarchy - Overview

7.7.1 The Draft Plan includes a proposed Settlement Hierarchy (page 123). No supporting text has been provided with regard to this hierarchy or how it has been established. It is considered necessary for this to be formulated upon an up-to-date evidence base that provides an accurate comparison of the sustainability of the settlements. This is required to provide a robust hierarchy, as well as a baseline from which to monitor the sustainability of settlements over time. Furthermore, the proposed hierarchy does not appear to form part of a local plan policy at this stage and therefore it is unclear as to the role that it is intended to take in future decision making, both in terms of the further development of the local plan and in decisions on individual planning applications.

7.7.2 The settlement hierarchy and associated policies (including the wider spatial strategy) should be formulated on a strategy that seeks to fully support the future housing needs of each settlement and the needs of those communities in terms of the of availability of local services and facilities in both quality and quantity. Careful consideration will also need to be given to the role that each of the settlements can play in supporting the delivery of the housing needs of the local plan area as a whole. Clear evidence will be required to support the proposed settlement hierarchy and to explain the way in which the local plan has been shaped to respond to the future sustainability of the settlements within it.

7.7.3 Whilst it is supported that the strategic scale town extensions and new settlements can play a key role in the accommodation of future development within the district, this should not be at the expense of ensuring that the housing and employment needs of other settlements are met. Gladman would draw attention to paragraph 55 of the Framework which states that “housing should be located where it will enhance or maintain the vitality of rural communities.” This highlights the need for a strategy to promote sustainable development in rural areas and locate housing where it will enhance and maintain the vitality of rural communities.

7.7.4 The Local Plan must avoid the creation of a sustainability trap whereby rural communities are considered as unsustainable in principle. The Plan must contain mechanisms by which a settlement that is assumed to function at a lower level within the hierarchy can migrate up the sustainability

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ladder and in doing so improve the ability of the population to easily access quality facilities, retail and housing.

7.8 The Proposed Position of Meppershall within the Settlement Hierarchy

7.8.1 A more specific concern with the Settlement Hierarchy that has been published on page 123 of the Draft Plan relates to the village of Meppershall. Gladman were surprised and concerned to note that Meppershall had been downgraded from a Large Village to a Small Village in the Draft Local Plan (2015-2035). Meppershall is currently recognised as a Large Village under Policy CS1 of the adopted Core Strategy (November 2009) and has been seen as a sustainable location for growth (i.e. through the allocation for 68 dwellings within the Site Allocations Plan, 2011).

7.8.2 As set out in the overview at section 7.7 above, the settlement hierarchy must be underpinned by a robust evidence base. In respect of Central Bedfordshire, the Council’s “Settlement Hierarchy Technical Paper” (June 2014) identifies Meppershall as a Large Village as is its position in the adopted Local Plan. Having reviewed the Technical Paper, it is noted that the approach to the assessment does not provide credit for the full range and diversity of services and facilities within the settlement. Indeed, the Council’s Technical Paper does not recognise the existing play area within Meppershall, nor does it acknowledge that the ‘Village Store’ sells groceries, as well as providing Post Office services. In addition, the Village Hall development (CB/16/01769/FULL) includes the provision of a new Village Hall with associated Sport Pitches, which further enhance Meppershall’s sustainability credentials.

7.8.3 Several other settlements with similar credentials are classified as ‘Large Villages’ in the Draft Local Plan, and it is difficult to distinguish why these differences occur. In addition, there are nine Large Villages which are located within the Green Belt, limiting the contribution that they can make towards meeting the full, objectively assessed, market and affordable housing needs of Central Bedfordshire. Settlements such as Meppershall are sustainable locations that have capacity for growth and should be recognised by the Council as such in the Local Plan.

7.8.4 Some recognition of Meppershall’s more sustainable status amongst the Large Villages is indicated by the Council’s assessment of settlements within Area D. Meppershall is assessed as having a medium capacity for growth, and the Council conclude:

Overall, development of a sufficient scale could support improved service and facility provisions, and deliver a range of housing for the local community, however it is likely to result in the loss of best and most versatile agricultural land. Small scale development may increase reliance on the private vehicle.

7.8.5 In direct contrast, the village of Blunham is designated as a Large Village, yet has a population of 950 people and 450 dwellings, in comparison with Meppershall, which has a population of 1,750 people and 700 dwellings. It is clear from the scoring assessment within the Council’s “Settlement Hierarchy Technical Paper” (June 2014) that Meppershall is incorrectly scored, and had the Council revisited this

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assessment for the production of the Local Plan evidence base, it would have been clear that Meppershall would score significantly better than it had previoulsy.

7.8.6 The recognised lack of significant constraints and its demonstrably more sustainable status both point to the fact that Meppershall should be higher up the settlement hierarchy. It ought to be classified as a Large Village, with a higher level of growth attributed accordingly.

7.8.7 Gladman consider the site it is promoting for residential use on land off Shefford Road, Meppershall should be included as a residential allocation. Further details of the Site are provided at Appendix 4. The site is clearly suitable and does not suffer from any of the strategic constraints that would preclude its development, as confirmed by the Council in their Site Assessment. The Council reached the following conclusion in their Site Assessment:

The site is to be considered further for assessment:

 The site forms an extension to the north west of the settlement.

 There are no physical or primary constraints to development on the site.

 Although Meppershall does not provide a wide range of services, the adjoining settlements provide these.

 In terms of environmental constraints, those identified can be mitigated, such as landscape and boundary with Nunswood. The hedgerow frontage needs to be conserved with strong mitigation to the north and west of the site.

 Mitigation may be required for the adjoining use

7.8.8 The Council have access to all of the application documents submitted alongside planning application CB/17/01041/OUT (Gladman’s outline planning application for the demolition of 59 Shefford Road and associated buildings and the erection of up to 150 dwellings). Gladman can confirm that the site is available now, is achievable and can be delivered in full within the five-year period.

7.8.9 The Officer’s Delegated Report for application CB/17/01041/OUT also recognised the sustainability of Meppershall, stating within section 1 (“Principle”), that:

Meppershall is categorised as a Large Village under Policy CS1 of the Core Strategy. There are various facilities in the village including a shop, a pub, lower school, Church, community facilities. There is also a bus service through the village and therefore Meppershall is, on balance, considered to be a sustainable location in planning terms.

7.8.10 It is clear that Meppershall benefits from a good range of services, including public transport links to larger settlements, and is a recognised sustainable location for growth within Central Bedfordshire. 21

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Gladman consider that Meppershall should continue to be acknowledged as a Large Village within the Draft Local Plan (2015-2035) and Gladman’s site at Shefford Road, Meppershall (see CB/17/01041/OUT) represents a suitable and sustainable option for allocation within the Draft Local Plan, which could deliver a significant number of dwellings (up to 150) within the five year period.

7.9 Policy SP6: Development within Settlement Envelopes and DC1: Development in the Countryside

7.9.1 In the absence from the draft plan of the site allocations for the land that is needed to meet development needs in full over the plan period, it is not currently possible to consider the extent to which any draft development management policies of this nature meet the tests of soundness contained in paragraph 182 to the Framework.

7.9.2 A similar issue applies to Policy DC1: Development in Countryside which promotes a highly restrictive approach to development outside settlement envelopes. The Plan should look to apply a more permissive approach in its recognition of the intrinsic character and beauty of the countryside and not mirror a mechanism that was used to apply out-of-date national policies that sought to safeguard the countryside for its own sake.

7.10 Policy H1: Housing Mix

7.10.1 Gladman note the intention in policy H1 to shape the housing mix of individual sites in line with the most up to date SHMA. It is essential that this Policy remains sufficiently flexible to enable individual sites to respond to prevailing market requirements in their locality.

7.11 Policy H2: Housing Standards

7.11.1 Gladman raise an initial concern with regard to the intention to introduce enhanced technical standards for market and affordable homes. Any such requirements should be fully evidenced. The NPPG (ID: 56-020) sets out that:

“where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies”

7.11.2 If the Council wishes to adopt these standards they must be fully justified by meeting the criteria set out in the NPPG including need, viability and impact on affordability. Care should be taken to ensure that generic arguments are avoided in the justification for the adoption of the higher optional standards for adaptable / accessible dwellings and / or the nationally described space standard. It is incumbent on the Council to provide a local assessment evidencing the specific case for Central Bedfordshire which justifies these policy requirements.

7.12 Policy H4: Affordable Housing / Viability

7.12.1 The Local Plan includes a wide range of development and design related requirements, such as: standards for accessibility (Policy H2), requirements for bungalows and low density flatted

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developments (Policy H1), requirements for serviced plots for self/custom build (Policy H7), significant tree features (Policy EE4), modern methods of construction (Policy HQ11), broadband (Policy HQ5), vehicle charging points (Policy T7), indoor sport facilities (Policy HQ3), social and community infrastructure (Policy HQ2), Public Art (HQ7) and enhanced energy related requirements (Policy CC1). Clearly, these intended policy requirements will need to be fully justified through the Council’s evidence base in terms of their consistency with the tests of soundness and impact on viability through the accompanying viability study. This does not necessarily appear to be the case at this stage of the plan-making process. It is essential that all relevant costs are considered as part of the exercise of calculating an appropriate percentage of affordable housing from all qualifying sites. In setting the affordable housing target from individual sites, sufficient flexibility will be required in terms of the overall percentage requirement and the tenure split to ensure that the policy can operate effectively and respond to the individual circumstances of sites on a case-by-case basis.

7.13 Policy H6: Starter Homes

7.13.1 It is noted that the Council has drafted a Starter Homes policy in addition to its wider policy on affordable housing. Clearly, the delivery of Starter Homes is high on the Government’s agenda and it will therefore be necessary to ensure that a policy approach is developed that integrates this product within the wider approach to securing affordable housing on a case by case basis.

7.14 Policy H7: Self and Custom Build Housing

7.14.1 The proposed introduction of a percentage requirement for custom / self-build plots should be fully justified through an assessment of housing needs, so that it appropriately reflects local circumstances in relation to the need and demand for self-build and custom build housing. In addition, any such requirements should be fully reflected in the Council’s housing trajectory in terms of the impact that any delayed delivery of such plots may have on overall supply. Gladman are concerned that the policy wording in relation to custom / self-build is not sufficiently responsive to circumstances that will arise on a site by site basis and request that this is addressed through modifications to ensure that housing delivery is not delayed in circumstances where there is no demonstrable demand for these products in a particular locality. In addition, we request that the policy and supporting text makes it clear that the Council is ‘seeking to encourage’ the inclusion of self-build and custom build on large housing sites rather than ‘requiring it’.

7.15 Policy EE5 – Landscape Character and Value

7.15.1 Policy EE5 relates to landscape character and value. It is noted that this could be read as the introduction of a policy that requires all development proposals to enhance the landscape. Care must be taken in the drafting of the pre-submission version of this policy to ensure that it correctly reflects the emphasis that is provided by paragraph 109 of the Framework, which looks to protect and enhance ‘valued landscapes’. Furthermore, a balanced criteria based policy will be required to set out how development proposals will be judged in response to the requirements set out in paragraph

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113 of the Framework. Any criteria based policy should be proportionate and clearly linked to the Council’s evidence base.

7.16 Policy CC1: Climate Change and Sustainability

7.16.1 Policy CC1 seeks to introduce a range of requirements to be addressed through Sustainability Statements that will be required to accompany all major development proposals. A range of policy requirements are then set out in a bulleted list. In setting these policy requirements, we would recommend that the Council reflects the more flexible wording of the Planning Practice Guidance (PPG Ref ID: 26-013-20140306), which seeks to promote the efficient use of natural resources rather than setting fixed standards. In this context, the Council should be ‘encouraging’ the use of these measures rather than requiring them.

7.17 Policy HQ1: Health Impact Assessment

7.17.1 Gladman accept the importance of the need to improve the health and well-being of those living and working in Central Bedfordshire and that this is a consideration for the local plan making process. However, this alone does not justify the introduction of a policy requirement to submit a Health Impact Assessment (HIA) alongside all planning applications. The proposed approach appears to be at odds with national policy which only goes as far as saying that HIA’s may be a useful tool to use where there is expected to be significant impacts and this is unlikely to be the case in the majority of development proposals.

7.18 Policy HQ2: Provision for Social and Community Infrastructure

7.18.1 Policy HQ2 forms part of the Council’s proposed approach to ensuring the delivery of ‘High Quality Places’ through its Local Plan. It is essential that the local plan ensures that the vitality of communities can be maintained and enhanced over the plan period and as such, the growth strategy must respond positively to delivering opportunities to provide social and community infrastructure.

7.19 Policy HQ5: Broadband and Telecommunications Infrastructure

7.19.1 It is noted that Policy HQ5 sets out the Council’s future planning policy expectations with regard to the provision of superfast next generation broadband infrastructure. It is vital that the policy wording is suitably clear in terms of the expectations that are being placed on the development industry in this regard. The Council will need to be mindful that the wider availability of this infrastructure is outside of the control of individual developers and that this should not become a mechanism that would prevent otherwise sustainable proposals for development from coming forward.

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7.20 Policy HQ8: Back-land Development

7.20.1 It is noted from the supporting text at paragraph 18.7.2 of the Plan that the Council does not object to all back-land development. As a result, it is important that any such policy recognises that such sites can form appropriate extensions to existing settlements and that they have the ability to support their wider sustainability as locations for growth. It is therefore considered important for any such policy to be positively framed in order to recognise that proposals of this nature can be successfully integrated into settlements. A criteria based policy should therefore be produced to clearly set out the circumstances where planning permission would be granted for development of this nature.

7.21 Policy HQ9: Larger Sites

7.21.1 Policy HQ9 includes a requirement for the approval of a development brief prior to the submission of a Full or Outline planning application and that design codes will also be required in specific circumstances. The Council will need to take into account the additional timescales involved in this process when determining its housing trajectory and also give consideration as to whether it would be more appropriate to consider these matters within the context of a planning application rather than as an additional policy hurdle.

7.22 Policy HQ11: Modern Methods of Construction

7.22.1 Policy HQ11 sets an aspiration for the use of modern methods of construction which would see 20% of all new development brought forward in this way over the plan period. In setting this aspiration, it is essential that the Council provides sufficient evidence that this is an appropriate target.

7.23 Policy HE3: Built Heritage

7.23.1 Gladman note the inclusion of Policy HE3 relating to built heritage. The approach to protecting the historic built environment must fully reflect the guidance set out in the Framework paragraphs 126- 141. With reference to designated heritage assets, the Council should refer specifically to paragraphs 133 and 134 of the Framework, which set out the need to assess the significance of a designated heritage assets and where there is less than substantial harm, this should be weighed against the public benefits of the proposal. Where there is deemed to be substantial harm, then the proposal would need to achieve substantial public benefits to outweigh that harm.

7.23.2 For non-designated assets, the policy must reflect the guidance set out within paragraph 135 of the Framework. This states that the policy test that should be applied in these cases is that a balanced judgement should be reached having regard to the scale of any harm and the significance of the heritage asset.

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7.24 Policy DC6: Agricultural Land

7.24.1 The Judgment in BT&W Vs. SSCLG and Gladman Developments Ltd. [2016] EWHC4 concludes that Paragraph 112 of the Framework, regarding best and most versatile agricultural land (BMV), cannot be characterised as a policy which indicates that ‘development should be restricted’ within the context of Paragraph 14 of the Framework (and the associated footnote 9).

7.24.2 Gladman consider that the implications of the judgment apply equally to the decision-making process and the plan making process. It confirms that there is not a prohibition on the development of BMV agricultural land, nor a restriction on its development in principle. The location of a site on BMV agricultural land should not therefore automatically result in its removal from consideration as an option for allocation within the local plan making process. Any such sites should be judged within the sustainability appraisal alongside all other reasonable alternatives. This must clearly identify the significant positive and negative effects of each reasonable alternative to the same level of detail as the option that the plan-maker ultimately proposes to take forward in the Local Plan.

4 Borough of Telford and Wrekin [2016] EWHC 3073 (Admin), Lang J

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8 SITE SUBMISSIONS

8.1 Overview

8.1.1 Gladman consider that the Central Bedfordshire Local Plan must avoid an over reliance on the delivery of housing from large scale new settlements and town extensions if it is to demonstrate a robust housing land supply. It is important that the Plan does not contain a strategy that risks a shortfall of housing provision during the early years of the plan and over the plan period as a whole.

8.1.2 The version of the Local Plan that is published under Regulation 19 will need to identify a minimum housing requirement and a suite of deliverable and developable housing allocations that will enable this. There is also a need for the Local Plan for Central Bedfordshire to be flexible to allow for changes in circumstances which include sites not coming forward as anticipated or delivering fewer units than expected. Typically, Inspectors are seeking an additional 20% above the housing requirement to ensure that the Local Plan meets or hopefully surpasses the housing requirement over the Plan period.

8.1.3 Therefore, in order to account for all of the above factors, it is considered that the site selection process must consider a wide range of sites through the Sustainability Appraisal process and result in the allocation of sites for new housing in the range of 50 to 300 dwellings across the settlement hierarchy that will deliver housing in the short term and over the remainder of the plan period to meet development needs in full and support the delivery of the vision and objectives of the Plan. This approach will contribute to securing the Council’s 5-year housing land supply and allow a wider range of housebuilders (including those that are Small and Medium Sized) the opportunity to deliver sites in Central Bedfordshire thereby increasing the range of products available and speeding up delivery in the district. It will also ensure a Plan that positively responds to the imperative to plan for thriving rural communities.

8.1.4 Gladman are promoting a number of sites across the district which are located in sustainable settlements and are available, achievable and deliverable. Details of each of the sites are provided in the form of development frameworks which have been appended to these representations.

Appendix 1 - Land off Mill Road, Cranfield

Appendix 2 - Land at Wharley End, Cranfield

Appendix 3 - Land off Langford Road, Henlow

Appendix 4 - Land at Shefford Road, Meppershall

Appendix 5 - Land at Biggleswade Road, Potton

Appendix 6 - Land East of High Street, Silsoe

Appendix 7 - Land Between Astwick Road and Taylor’s Road, Stotfold

Appendix 8 - Land West of Astwick Road, Stotfold

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9 CONCLUSIONS

9.1 Overview

9.1.1 Having considered the Central Bedfordshire Draft Local Plan, Gladman have raised a range of matters that will need to be addressed in the pre-submission version of the Plan. This includes housing and employment needs; delivery of the new settlements and town extensions; spatial distribution; the wider allocation of land for housing; and, several of the detailed development management policies.

9.1.2 The plan must be positively prepared, effective, justified and consistent with national policy to be found sound at examination. In the first instance, the Council must start with clearly defining an NPPF and PPG compliant OAN by developing an unconstrained requirement which properly follows the guidelines set out at the national level. The Council should then develop a robust housing requirement using this OAN as a starting point. Notwithstanding this, the Council will also need to be mindful of the Government’s forthcoming proposals on a new standardised methodology for the calculation of housing needs and its intention to apply this to local plans that are submitted to the Secretary of State after 31 March 2018.

9.1.3 Careful consideration needs to be given to the spatial strategy that forms the basis of the spatial distribution of growth across the district. All sustainable settlements should be allowed to play their part in meeting their own housing and employment needs as well as contributing to the wider district’s requirements and improving their sustainability over time. A flexible approach to delivering the development needs of the district will ensure the plan’s ultimate deliverability and success.

9.1.4 Whilst it is supported that new settlements and town extensions will play a key role in the accommodation of future development within the district, this should not be at the expense of ensuring that the housing and employment needs of other settlements are met. Paragraph 55 of the Framework seeks to promote sustainable development in rural areas to maintain and enhance rural vitality and viability.

9.1.5 This is particularly the case given that with the complexities of delivering the strategic sites, it is considered that in order to avoid significant shortfalls in housing provision, a significant number of smaller scale housing allocations will be required.

9.1.6 Gladman are therefore commending the following sites for inclusion within the Central Bedfordshire Local Plan as residential allocations and details of each in the form of ‘Development Briefs’ have been appended to these representations:

 Appendix 1 - Land off Mill Road, Cranfield

 Appendix 2 - Land at Wharley End, Cranfield

 Appendix 3 - Land off Langford Road, Henlow

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

 Appendix 4 - Land at Shefford Road, Meppershall

 Appendix 5 - Land at Biggleswade Road, Potton

 Appendix 6 - Land East of High Street, Silsoe

 Appendix 7 - Land Between Astwick Road and Taylor’s Road, Stotfold

 Appendix 8 - Land West of Astwick Road, Stotfold

Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 1

LAND OFF MILL ROAD, CRANFIELD

DEVELOPMENT BRIEF

Land of Mill Road, Cranfield Central Bedfordshire Council Introduction

Gladman Developments wish to promote land at Mill Road, Cranfield for development. The 6.59-hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location.

A new residential development on this site would incorporate both new market and affordable housing of a variety of types and tenures, to help meet the current and future housing needs of Cranfield and the District.

Development of this site would respond to and complement its surroundings to achieve seamless integration. Gladman would welcome the opportunity to discuss the potential delivery of this site with you in more detail so it can be considered fully in the preparation of your emerging Local Plan.

Should you wish to further discuss our proposals, please contact: Planner: Chris Still Email: [email protected] Telephone: 01260 288932 Site & Planning Context

Site & Surroundings From Bedford station, trains run to London St Pancreas International, Nottingham and Brighton providing opportunities for linked sustainable The site is located to the west of Cranfield, west of Mill Road trips by train to more regional and national destinations. and is approximately 6.59 hectares in area. Adjacent to the site lies the previous phase of development (CB/14/05007/OUT). It is currently Cranfield is an active and successful community and provides residents envisaged that built development would only be situated in the with direct access to community facilities including: south-eastern part of the site in order to retain existing landscape • Cranfield University Leisure Centre • Cranfield University features, providing a significant amount of open space. With this in • Cranfield Church of England Library mind, the proposed developable area is 2.59 hectares, which could Academy • Holywell Middle accommodate up to 78 dwellings. • Cranfield Church of England School A Vibrant Community Academy (St Paul Site) Pre-School • Convenience Stores • Post Office Cranfield is a vibrant settlement. The civil parish of Cranfield Principle of Development hosts a population in the region of 5,816 people according to a UK national statistics population 2015 estimate. The site is sustainably The principle of development in Cranfield is well established through located with good access to the centre of Cranfield, surrounding existing and emerging planning policies. community amenities and public transport network. Cranfield is identified as a ‘Minor Service Centre’ under the adopted and The site has good access links to public transport with bus stops emerging Local Plan. less than 800m from the site, providing links locally to Cranfield University and further afield to the two major local towns of Milton The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will Keynes and Bedford which offer employment, leisure and retail seek to deliver between 20,000 and 30,000 additional new homes which will opportunities. be delivered and a minimum of 24,000 new jobs between 2015 and 2035. The Council will also continue to support the delivery of the existing committed The nearest bus stops are located just to the north of the sites. The draft plan also states that Central Bedfordshire will deliver housing vehicular and pedestrian accesses on Mill Road. The buses that run need identified for the Luton HMA and some unmet need from Luton close to on these stops are the 53 and the services C1 / C10 / C11 which where it arises where there is capacity to do so sustainably. travels between Milton Keynes and Bedford via Cranfield and other towns and villages. The 52 runs once a weekday and the R2 service The growth of villages and changes to settlement boundaries is an inevitable operates once a day on the 2nd and 4th Tuesday of each month. consequence of meeting additional housing needs. There is nothing within planning policy or law that makes it wrong in principle to breach settlement Millbrook (Bedfordshire) railway Station is the nearest railway station boundaries to accommodate sustainable development. As referenced in the to the site. The station is on the London Midland line with services ministerial foreword to the Framework; “The purpose of planning is to help running to Bedford, Ridgmont, Bow Brickhill and Bletchley. achieve sustainable development ... Development means growth.” Site Development Potential

This site offers a unique opportunity for Central Bedfordshire Council to plan, and more importantly deliver, a new development where people will genuinely want to live, whilst embracing the distinctive character of the surrounding area. This will be achieved by:

Housing Delivery Going forward

• The site is capable of delivering up to 78 dwellings of varying • Cranfield is identified within the emerging Local Plan as a minor sizes, types and tenures (including affordable housing; 27 service centre with a good level of services, including a school, dwellings to be (35%) delivered in accordance with planning doctor’s surgery, a basic retail offer and frequent public transport policy). The site can also provide land for a much needed doctor’s links. surgery. • Emerging Local Plan policy SP6: Within the Settlement Envelopes • Gladman consider that housing on this site is capable of being of both Major and Minor Service Centres, the Council will support brought forward within the next 5 years. in principle housing, employment and other settlement related development proportionate to the scale of the settlement, taking account of its role as a minor service centre. Site Development Potential

Landscape Character The site is located adjacent to the main settlement of Cranfield and is set within a landscape character with a medium landscape value and low- medium susceptibility to change. As such, it has been assessed as being The LVA has assessed landscape character and visual amenity, and the able to accommodate a well-designed and considered development as resulting landscape visual effects of the proposed development on the set out by the Development Framework plan. receiving landscape and visual receptors. The landscape and visual effects have been considered in relation to the proposed land uses and the The proposal seeks to provide facilities for the existing community as parameters that are defined on the application’s Development Framework well as the new residents. The scheme provides an area of land for a Plan. doctors surgery as well as a variety of outdoor recreation provision and proposes new connections to the PRoW network outside of the site. The Development Framework plan has been sensitively designed with consideration given to the baseline information and findings of the LVA. The site is considered to be visually well-contained within the context of The layout has been designed to ensure that the development is set within the wider landscape. The existing local topography and features within a substantial Green Infrastructure network which incorporates existing the landscape combine to provide limited views to a small number of boundary vegetation. A substantial area of open space will be created residential receptors and users of PRoW FP22. Whilst there will be within and to the north of the site to buffer the surrounding landscape from inevitable adverse impacts on the landscape and visual receptors during development and to connect the scheme to its landscape setting. The construction and after completion, the overall visual effects are connection to the Phase 1 scheme will provide site wide access via a considered to be minor to negligible in the longer term. Impacts are network of green corridors. therefore considered to be acceptable within the landscape context and would not result in any overall landscape and visual harm. New footpath links will be created to allow access to the wider footpath network in particular providing opportunities to achieve the local The proposals form a logical extension to the Phase 1 scheme and within community aspirations outlined within the Cranfield Green Infrastructure Cranfield itself. The site well contained by existing mature vegetation Plan. These proposals will combine to help lessen the impact of the adjacent to the site and set within the wider landscape. Consequentially, proposed built development upon the existing landscape. through a considered approach to the Development Framework a second phase would not be significantly visible in the wider The site itself is not covered by any landscape designations and contains surroundings of the area and would blend into the landscape context. few features of landscape merit. These are limited to occasional trees and hedgerows along the site boundary. The proposals will retain these features where possible. The site will be enriched by new tree planting and the creation of new wildlife habitats including a balancing pond.

SCHOOL

the new residents. The scheme provides an area of land for a doctors surgery as well as a variety of outdoor recreation provision and proposes new connections to the PRoW network outside of the site. Site Development Potential

Biodiversity, Green Infrastructure & Local Wildlife Heritage

5IFQSPQPTBMJODMVEFTIBPGGPSNBMBOEJOGPSNBMPQFOTQBDF PWFS In accordance with central government planning policy, a desk-based PG UIF HSPTT TJUF PVUMJOF BQQMJDBUJPO BSFB 5IF QSPQPTBM BMTP PVUMJOFT BO assessment has been undertaken to clarify the archaeological potential JNQSPWFE DPOOFDUJWJUZ UP UIF FYJTUJOH 1VCMJD 3JHIU PG 8BZ BOE QVCMJD of the study site. BDDFTT UP MBOE QSFWJPVTMZ OPU BWBJMBCMF BOE OFX BDDFTT BSSBOHFNFOUT JODMVEJOH BO JOGPSNBM GPPUQBUIDZDMF MJOL BOE IJHIXBZ JNQSPWFNFOUT UP There are no Scheduled Monuments or other designated assets on the $SBOGJFME site. Similarly, there are no non-designated archaeological assets on the site. 5IFQSPQPTFEEFWFMPQNFOUXJMMBJNUPFOIBODFUIFFOWJSPONFOUUISPVHI UIF QSPWJTJPO PG HSFFO JOGSBTUSVDUVSF DPNQSJTJOH OFX QVCMJDMZ BDDFTTJCMF The site is considered to have a low to moderate potential for Iron Age HSFFOTQBDF FRVJQQFE QMBZ BSFBT BOE SFDSFBUJPOBM QBUIT JODSFBTJOH UIF settlement activity. Across the site evidence of Medieval and Post- QFEFTUSJBOMJOLBHFTUPTVSSPVOEJOHBSFBTPGJOUFSFTUBOEGBDJMJUJFT Medieval agricultural activity can be anticipated.

0VSJOJUJBMFDPMPHZXPSLIBTGPVOEUIBUUIFSFJTPOF4JUFPG4QFDJBM4DJFOUJGJD The nature of any archaeological evidence on the site and its ploughed *OUFSFTU BOE UXP $PVOUZ 8JMEMJGF 4JUFT MPDBUFE XJUIJO UIF LN BOE LN condition is likely to render it of local archaeological interest. TFBSDI BSFBT PG UIF TJUF IPXFWFS UIF EFWFMPQNFOU XPVME OPU JNQBDU OFHBUJWFMZPOUIFTFEFTJHOBUFETJUFT Given the limited archaeological interest of the study site, it is suggested that this interest can be secured by an appropriately worded *U JT DPOTJEFSFE UIBU UIF NBKPSJUZ PG UIF TJUF DPNQSJTFT MPX WBMVF BSBCMF planning condition. However, in the first instance a programme of IBCJUBU XJUI GJFME NBSHJOT OPU PG TJHOJGJDBOU JOUSJOTJD WBMVF )FEHFSPXT geophysical survey will be undertaken to determine the archaeological XPVME CF SFUBJOFE XIFSF QPTTJCMF BOE JG HBQ DSFBUJPO PS SFNPWBM JT baseline conditions of the site to allow for an informed planning SFRVJSFE UP GBDJMJUBUF EFWFMPQNFOU SFQMBDFNFOU OBUJWF IFEHFSPXT XPVME decision. CF DSFBUFE )FEHFSPX DSFBUJPO BOE SFUFOUJPO XJMM IFMQ UP NBJOUBJO BOE JNQSPWFDPOOFDUJWJUZGPSXJMEMJGFUISPVHIUIFTJUF

5IFTJUFJTVOMJLFMZUPQSPWJEFIBCJUBUGPSHSFBUDSFTUFEOFXU BOENJUJHBUJPO BOE FOIBODFNFOU NFBTVSFT IBWF CFFO SFDPNNFOEFE UIBU XJMM QSFWFOU TJHOJGJDBOUBEWFSTFJNQBDUTPOQSPUFDUFETQFDJFTUIBUIBWFCFFOSFDPSEFE JOUIFXJEFSBSFB"GVMMFDPMPHJDBMBQQSBJTBMIBTCFFODBSSJFEPVUXIJDIXBT TVCNJUUFEXJUIUIFQMBOOJOHBQQMJDBUJPO $#065 SCHOOL Site Development Potential

Arboriculture Hydrology

The site was situated to the north of Cranfield comprised of a single The Environment Agency flood map shows that the entirety of the arable field parcel bounded by a series of managed hedgerows. The Site is located within Flood Zone 1; which is land considered to be assessment area is to form a phase two application to an approved at low risk of flooding from rivers and sea i.e. land assessed as development to the east. No species present were particularly having a less than 1 in 1,000 annual probability of flooding. dominant with native species such as hawthorn, blackthorn, ash and elder. A sustainable drainage solution to manage surface water run-off will be provided as part of the proposals. To provide the required road links to the proposed development two small sections of H3 and H8 will need to be removed. The removal of The FRA demonstrates that the proposed development would these short sections should not constrain the development, from an be operated with minimal risk from flooding, and would not increase arboricultural perspective, as this material was generally considered to flood risk elsewhere. The development should therefore not be be of low quality. The material can be replaced with new tree planting precluded on the grounds of flood risk or drainage. as part of the supporting landscaping scheme for the development and this would be considered suitable to mitigate for the required losses. Design

In conclusion, the proposed development will retain the majority of The proposed development will follow a design-led existing boundary tree cover seeing them incorporated in to the approach, informed by consultation with the Council, key landscape buffers. The proposed development should also be stakeholders and the local community, responding sensitively to considered an ideal opportunity in terms of arboriculture to improve, the site’s setting and respecting the grain of the surrounding enhance and increase overall tree cover in the local area through new landscape, both built and undeveloped. The development will planting without the loss of any currently arboriculturally significant be a positive addition to Cranfield, complementing the trees. character of the surrounding area in terms of scale, density, character and quality. Site Development Potential

Topography Socio-economic

Cranfield is located on the edge of a large, elevated plateaux of land Our preliminary research shows that the proposed development could extending northwards and westwards from the village, lead to a significant boost in local spending and there is an indication that incorporating Cranfield Airfield and Cranfield Business Park. To the the gross spending power of the new residents could be in excess of £3.1 southeast, the landscape drops into a small valley towards the A421. million each year, a proportion of which will be spent in the locality. Cranfield Airfield creates a strong sense of enclosure to the west, whilst the extended urban edge of Cranfield Village forms a strong Central Bedfordshire’s population has grown by 16.3% since 1991 and is boundary to the east. anticipated to grow a further 38% by 2039. This population is likely to be accommodated across the district and their significant contribution to the The proposed site has a relatively flat gradient located on a gently economy can be captured locally by allowing smaller, sustainable north west facing slope. The low point to the northwest lies at settlements such as Cranfield to grow. approximately 108.5m AOD. The slope continues southeast reaching a high point of approximately 111m AOD. Central Bedfordshire is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.6 is significantly above the national average and demonstrates this fact, but equally shows that this location is Accessibility a particularly unaffordable place to live. The proposal to build 78 homes will go some way to improving both these situations – the development Development in this location will provide quality pedestrian, will provide new market and affordable homes which will open the cycle and public transport connections with the existing built settlement up to local people, key workers and others previously unable form of Cranfield and nearby communities. An access solution to purchase a house in Cranfield. with suitable visibility splays can be achieved without the need for third party land. NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has been endorsed by a number of Inspectors reporting on recent appeals (as discussed in the Report) In this regard, the economic benefits derived from this scheme will be substantial and will impact positively on the local area and are a significant material consideration in the determination of this application. Indicative Framework Plan

This drawing is the property of FPCR Environment and Design Ltd andThis is issueddrawing on is the the condition property itof is FPCR not repro Environment- and duced, retainedDesign or disclosed Ltd and to is any issued unauthorised on the condition person, it is not repro- either wholly orduced, in part retained without or written disclosed consent to any of unauthorised FPCR person, either wholly or in part without written consent of FPCR PotentialPotential Access Access for for Environment and Design Ltd. Pumping Station and Environment and Design Ltd. Pumping Station and Dedham Road Aerial imagery © 2015 Microsoft Corporation Farm Land Dedham Road Aerial imagery © 2015 Microsoft Corporation Farm Land Ordnance Survey material - Crown Copyright. All rights Ordnance Survey material - Crown Copyright. All rights reserved. Licence Number: 100019980 (Centremapslive. reserved. Licence Number: 100019980 (Centremapslive. com) com)

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Indicative MainIndicative Access Main Route Access Route Site with Consent for Residential SiteDevelopment with Consent of for16 dwellingsResidential Indicative LocationIndicative of Location proposed of proposed Development(Ref: 15/01218/DETAIL) of 16 dwellings (Ref: 15/01218/DETAIL) Pumping StationPumping (0.01Ha) Station (0.01Ha)

Potential Retained Green InfrastructureGreen Infrastructure (3.36Ha) includes: (3.36Ha) includes: PotentialFarm Retained Access Farm Access Ingram’s Piece Ingram’s Piece Existing PublicExisting Rights Public of Way Rights of Way

St. Mary’s Church St. Mary’sof England Church Existing VegetationExisting Vegetation to be Retained to be Retained of EnglandPrimary School Primary School Proposed TreeProposed Planting Tree Planting

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Indicative AttenuationIndicative Attenuation Area Area Aveline Road Wick Lane A137 Colchester Road (0.25Ha) (0.25Ha) Wick Lane A137 Colchester Road Aveline Road Proposed LEAPProposed Play LEAP Area Play Area (0.07Ha) (0.07Ha)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

Station Road Proposed AllotmentsProposed Allotments A137 Colchester Road (0.07Ha) Station Road (0.27Ha) A137 Colchester Road Potential Land to be Gifted to St. Mary’s Church of England School (0.20Ha)

N N

500 100 150 200 300 400 500m 500 100 150 200 300 400 500m 500 100 150 200 300 400 500m 0 50 100 150m 0 50 100 150m J:\7000\7017\LANDS\Plans\7017-L-03 Framework Plan rev G.indd 0 50 100 150m J:\7000\7017\LANDS\Plans\7017-L-03 Framework Plan rev H.indd

J:\7000\7017\LANDS\Plans\7017-L-03 Framework Plan rev H.indd masterplanning environmental assessment masterplanning 1:2500@A3 landscape design FPCR Environment and Design Ltd Gladman Developments Ltd. environmental assessment urban design Lockington Hall 1:2500@A3 landscape design FPCRmasterplanning Environment and Design Ltd Gladman Developments Ltd. ecology Lockington 14 April 2016 KAD / KMN urban designenvironmentalLockington assessment Hall Derby DE74 2RH 1:2500@A3 architecture Wick Lane Framework plan ecology Lockingtonlandscape design FPCR Environment and Design Ltd Gladman Developments Ltd. arboriculture 15 March 2017 KAD / KMN Derby DE74 2RH Wick Lane Framework plan architecture urban design Lockingtont: 01509 Hall 672772 arboriculture ecology Lockingtonf: 01509 674565 rev fpcr t: 01509 672772 Ardleigh 15 7017-l-03March 2017 KAD / KMNG architecture Derbye: [email protected] DE74 2RH Wick Lane Framework plan f: 01509 674565 w: www.fpcr.co.uk rev fpcr arboriculture Ardleigh 7017-l-03 H e: [email protected] t: 01509 672772 w: www.fpcr.co.uk f: 01509 674565 Ardleigh 7017-l-03 rev H fpcr e: [email protected] w: www.fpcr.co.uk Conclusion

Design

We consider the potential development at Mill Road, Cranfield represents a viable, realistic option for growth to help Central Bedfordshire Council to meet their Objectively Assessed Needs and the unmet needs of Luton.

The development is both deliverable and achievable with the site able to be delivered in its entirety within the 5 year period to make a significant contribution to the Council’s five year housing land supply.

. Gladman Land Gladman House, Alexandria Way, Congleton, CW12 1LB

If you have any questions, contact your Project Manager: Rob Black 01260 288 822 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 2

LAND AT WHARLEY END, CRANFIELD

DEVELOPMENT BRIEF

Land at Wharley End, Cranfield Central Bedfordshire Councill Introduction

Gladman Developments wish to promote land at Wharley End, Cranfield for development. The 20.23 hectare site presents an ideal opportunity to create a sustainable, high quality residential development with provision for a primary school and local service centre, situated in a sought-after location. A new residential development on this site would incorporate both new market and affordable housing of a variety of types and tenures, to help meet the current and future housing needs of Cranfield and the District. Development of this site would respond to and complement its surroundings to achieve seamless integration. Gladman would welcome the opportunity to discuss the potential delivery of this site with you in more detail so it can be considered fully in the preparation of your emerging Local Plan.

Should you wish to discuss our proposals further, please contact: Planner: Chris Still [email protected] 01260 288932 Site & Planning Context

Site & Surroundings The buses that run on these stops are the 53 and the services C1 / C10 / CHR which travels between Milton Keynes and Bedford via Cranfield and other towns and villages. The 52 runs once a weekday and the R2 service operates once a day The site is located to the West of Cranfield University and is split by Boundary on the 2nd and 4th Tuesday of each month. Road. The site is therefore separated into a Northern and Southern Field. The total site area is approximately 20.23 hectares. The northern field is adjacent to Millbrook (Bedfordshire) railway Station is the nearest railway station to the site. existing residential accommodation. Taking this into account, residential The station is on the London Midland line with services running to Bedford, development is proposed to be sited to the North of Boundary Road. The Ridgmont, Bow Brickhill and Bletchley. From Bedford station, trains run to proposed developable area is approximately 8.78 hectares and will London St Pancreas International, Nottingham and Brighton providing accommodate up to 300 dwellings. Existing landscape features are to be opportunities for linked sustainable trips by train to more regional and national retained and enhanced and a NEAP is proposed to accommodate outdoor play. destinations

The Southern Field is envisaged to accommodate a primary school to serve Cranfield is an active and successful community and provides residents with pupils that would be generated from the development. In addition, land is direct access to community facilities including: proposed for a local service centre. Existing landscape features would be retained and enhanced whilst allotments would be provided with approximately 40% public open space. • Cranfield University Leisure Centre • Cranfield University Library A Vibrant Community • Cranfield Church of England Academy • Holywell Middle School Cranfield is a vibrant settlement. The civil parish of Cranfield hosts a population in the region of 5,816 people according to a UK national statistics population 2015 • Cranfield Church of England Academy (St Paul Site) Pre-School estimate. The site is sustainably located with good access to the centre of • Convenience Stores Cranfield, surrounding community amenities and public transport network. • Post Office The site has good access links to public transport with a number of bus routes pass through the University campus and are thus within easy walking distance of the site. The nearest bus stops are actually located adjacent to Prince Philip Avenue with further stops on University Way less than 110m East of the site, providing links locally to Cranfield University and further afield to the two major local towns of Milton Keynes and Bedford which offer employment, leisure and retail opportunities. Site & Planning Context

Principle of Development Going Forward

The principle of development in Cranfield is well established through existing and emerging planning policies. Cranfield is identified within the emerging Local Plan as a minor service centre Cranfield is identified as a ‘Minor Service Centre’ under the adopted and with a good level of services, including a school, doctor’s surgery, a basic retail emerging Local Plan. offer and frequent public transport links.

The Central Bedfordshire Draft Local Plan (July 2017) states that the plan Within the Emerging Local Plan, policy SP6 states that within the will seek to deliver between 20,000 and 30,000 additional new homes Settlement Envelopes of Minor Service Centres, the Council will support in which will be delivered and a minimum of 24,000 new jobs between principle housing, employment and other settlement related development 2015 and 2035. The Council will also continue to support the delivery of proportionate to the scale of the settlement, taking account of its role as a minor the existing committed sites. The draft plan also states that Central service centre. Bedfordshire will deliver housing need identified for the Luton HMA and some unmet need from Luton close to where it arises where there is capacity to do so sustainably. The growth of villages and changes to settlement boundaries is an inevitable consequence of meeting additional housing needs. There is nothing within planning policy or law that makes it wrong in principle to breach settlement boundaries to accommodate sustainable development. As referenced in the ministerial foreword to the Framework; “The purpose of planning is to help achieve sustainable development ... Development means growth.” Site Development Potential

Housing Delivery Adjoining properties located off Royce Road and West road adjacent to the northern field parcel to the east would experience moderate adverse residual The site is capable of delivering up to 300 dwellings of varying sizes, types and effects as the current views would be replaced by that of proposed Green tenures (including affordable housing delivered in accordance with emerging Infrastructure (GI) and new housing. The potential impact on these properties planning policy H4, requiring 30% affordable housing on sites of 11 or more will be from the front ground and first storey windows, while views will be seen units). beyond the existing wide treed verge and boundary hedgerow. Effects will be Gladman consider that housing on this site is capable of being brought forward minimised by the reinforcing of the existing GI with new tree planting along the within the next 5 years. boundary of the Site. Effects will be minimised with careful attention at the detailed design stage to issues of proximity, privacy and overshadowing.

Landscape Character The Site itself is not covered by any landscape designations and contains few features of landscape merit. There are hedgerows and hedgerow trees The Landscape and Visual Appraisal concludes the effect of the proposed surrounding the Site, with a number of gappy hedgerows demarcating the development upon the character of the landscape at a Site wide scale would be southern field parcel. The proposals will retain, enhance and reinforce these localised in its extent. The primary change would arise as a direct result of the features where possible along with new tree planting and the creation of new replacement of arable farmland with residential development and associated wildlife habitats including attenuation basins. infrastructure. However, the Site is isolated from the wider Landscape Character Types (LCT) ‘Clay Farmland’ and the sub Landscape Character Area (LCA) The appraisal demonstrates that the proposals respond well to the local ‘Cranfield to Stagsden Clay Farmland’, thus the assessed residual effect is landscape character of the Site, recognising and responding to opportunities by considered to be minor adverse, given the adjoining urban characteristics of responding to the Site topography. The proposals will also retain and enhance Cranfield University. existing landscape features such as the PROW and the creation of dedicated public open space. Site Development Potential

The development will include provision of new public open space and an Heritage enhanced footpath route through the Site providing dedicated safe routes for pedestrians. Footpath connections will create enhanced access around the Site Archaeological resource along with enhanced connections to the Milton Keynes Boundary Walk (MKBW) and PRoW out in the wider landscape to the west. Two groups of cropmarks are recorded within the study area; one of which is likely to relate to former field boundaries and enclosures associated with an Therefore it is considered that the proposed development within the Site will adjacent now-demolished farm, below ground remains of which appear to result in an overall residual minor adverse effect upon completion. Overall it is survive within the study area, and these have also been recorded during a considered the development proposals demonstrate a well-considered approach recent magnetometry geophysical survey. These remains are not considered to to the landscape and context of the Site and appropriate development of the Site be of archaeological significance. has the potential to successfully integrate into the local surroundings without any unacceptable landscape or visual effects. Another group of cropmarks in the south-eastern area of the study area may potentially relate to earlier activity, conceivably of prehistoric, Roman or early Biodiversity, Green Infrastructure & Local Wildlife medieval date. This has not been proven by archaeological investigation but the presence of below-ground features in this area is suggested by the results The proposed development will seek to enhance the environment through the of the recent geophysical survey. Again, below ground archaeological remains provision of green infrastructure, comprising new publicly accessible indicated by these are likely to be a nondesignated heritage asset. These greenspaces, equipped play areas and recreational paths increasing pedestrian appear to comprise a ditched enclosure with an internal structure as well as linkages to surrounding areas of interest and facilities. linear anomalies, forming a possible trackway, which terminate in a potential rectangular enclosure. Our initial ecology work, carried out by specialist consultants has found that there are no statutory designated sites in proximity to the proposal site. A single non- The land within the study area most likely formed part of the agricultural statutory site is present 0.8km to the west. Amongst the records of notable and hinterland to Cranfield from at least the medieval period. Cropmarks protected species within 1km of the site are bats and GCNs. A full ecological immediately adjacent to the north of the study area are likely to relate to former appraisal will be carried out which will be submitted with the planning proposal. field boundaries. Evidence of medieval activity has also been recorded in the Work will also be carried out to assess impact on nearby ecological designations. wider study area, with a large number of moated sites recorded in the Cranfield Area. The development proposals will provide adequate mitigation and enhancement, wherever possible to ensure notable species are protected. Anomalies in the remainder of the study area appear to represent features of agricultural origin, including postenclosure field boundaries and modern ridge and furrow agriculture. These are not considered, on current evidence, to be heritage assets. Site Development Potential

No designated heritage assets are recorded within the study area or within a 500m Topography radius of the study area. The nearest designated heritage asset is the Grade II Listed Ringtail Farmhouse located c. 1.1km north of the study area. The topography immediately to the north of the Site is broadly flat. From the Development within the study area is not considered to have the potential to northern extent of the university accommodation located off Royce Road, there is adversely affect the significance of this Grade II Listed building, or other Listed a tributary that runs northwards towards Ringtail Farm and Lodge Farm at buildings located in the centre of Cranfield. approximately 95m AOD. Cranfield University and Cranfield Airport are located on an elevated plateau located at approximately 105m AOD, while further to the east Hydrology the centre of Cranfield is located at approximately 110m AOD. Beyond the centre of Cranfield the topography falls away along a broad ridgeline to approximately 50m AOD. The Environment Agency flood maps shows that the entirety of the Site is located within Flood Zone 1; at low risk of flooding from rivers and sea. The To the south west the topography gradually falls away from the Site, opening out proposed residential development is classified as ‘more vulnerable’, which is towards the low lying land of Lower Wood and Broughton Grounds Nature considered acceptable in terms of flood risk in Flood Zone 1. Reserve. The land immediately to the west of the Site is located on a level plateau The Flood Risk Assessment (FRA) commissioned by Gladman has considered the of 105m AOD, before falling away beyond Moulsoe Old Wood. The highest point potential impact of the development on surface water runoff rates, given the of the Site itself is located at approximately 107m AOD south of Wharley End Road increase in developable areas post-development, these rates have been in the north of the southern field parcel. The north of the Site falls to calculated, and it has been demonstrated that surface water can be managed, approximately 104m AOD, while the south of the Site falls to approximately 96m such that flood risk to and from the Site following development will not increase. AOD. This will be achieved through restricted discharge rates and two appropriately sized attenuation ponds, with outfall to the bounding drainage ditches. Accessability The FRA demonstrates that the proposed development would be operated with minimal risk from flooding, and would not increase flood risk elsewhere. The Given the size and shape of the development, clearly multiple access points are development should therefore not be precluded on the grounds of flood risk or appropriate, with two for the northern element and one for the south. The drainage. northern site has two access points onto Wharley End Road and the southern site has one also onto Wharley End Road. In each case the junction is a simple priority Design junction. For each case the access road is a 5.5 metre road with pedestrian footways around The proposed development will follow a design-led approach, informed by the radii. For the access points on Wharley End Road, 2.4 by 90 metre visibility consultation with the Council, key stakeholders and the local community, splays are shown on the basis that most of the length is subject to a 30 miles per responding sensitively to the site’s setting and respecting the grain of the hour speed limit and the section that is outside the limit is so close to the ninety surrounding landscape, both built and undeveloped. The development will be a degree bend that vehicle speeds will be low in any case. This is consistent with positive addition to Meppershall, complementing the character of the the requirements of DMRB and the splays are clearly available but if Manual for surrounding area in terms of scale, density, character and quality. Streets standards were applied these could be reduced. Site Development Potential

Development in this location will therefore provide quality pedestrian, cycle and public transport connections with the existing built form of Cranfield and nearby communities. The site fronts directly onto Highways land and an access solution with suitable visibility splays can be achieved without the need for third party land. Overall, therefore, it is concluded that there are no material transport issues associated with the proposal.

Socio-economic

Central Bedfordshire’s population has grown by 16.3% since 1991 and is anticipated to grow a further 38% by 2039. This population is likely to be accommodated across the district and their significant contribution to the economy can be captured locally by allowing smaller, sustainable settlements such as Cranfield to grow.

Central Bedfordshire authority area is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.6 is significantly above the national average and demonstrates this fact, but equally shows that this location is a particularly unaffordable place to live. The proposal to build 300 homes will go some way to improving both these situations – the development will provide new market and affordable homes which will open the settlement up to local people, key workers and others previously unable to purchase a house in Cranfield.

NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has been endorsed by a number of Inspectors reporting on recent appeals (as discussed in the Statement). In this regard, the economic benefits derived from this scheme will be substantial and will impact positively on the local area and are a significant material consideration in the determination of this proposal. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

If you have any questions, contact your Project Manager: Rachael Evans 01260 285 641 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 3

LAND OFF LANGFORD ROAD, HENLOW

DEVELOPMENT BRIEF

Land West of Langford Road, Henlow Central Bedfordshire Councill Introduction

Gladman Developments wish to promote land at Langford Road, Henlow for development. The 6.29-hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location. A new residential development on this site would incorporate both new market and affordable housing of a variety of types and tenures, to help meet the current and future housing needs of Henlow and the District. Development of this site would respond and complement its surroundings to achieve seamless integration. Gladman would welcome the opportunity to discuss the potential delivery of this site with you in more detail so it can be considered fully in the preparation of your emerging Local Plan.

Should you wish to discuss our proposals further, please contact: Planner: Chris Still [email protected] 01260 288932 Site & Planning Context

Site & Surroundings Principle of Development

The site is located to the west of Henlow, west of Langford Road and is The principle of development in Henlow is well approximately 6.29 hectares in area. Although it is currently envisaged that built established through existing and emerging planning policies. development would only be situated in the eastern parts of the site in order to retain existing landscape features. With this in mind, the proposed developable )FOMPX JT JEFOUJGJFE BT B A-BSHF 7JMMBHF VOEFS UIF BEPQUFE -PDBM 1MBO CVU area is 4.48 hectares, up to 135 dwellings. IBTCFFOSFWJTFEVQXBSETUPBA.JOPS4FSWJDF$FOUSFXJUIJOUIFFNFSHJOH-PDBM 1MBO SFDPHOJTJOH)FOMPXTTVJUBCJMJUZBTBTVTUBJOBCMFMPDBUJPOGPSHSPXUI 5IF A Vibrant Community $FOUSBM#FEGPSETIJSF%SBGU-PDBM1MBO +VMZ TUBUFTUIBUUIFQMBOXJMMTFFLUP EFMJWFS " NJOJNVN PG BEEJUJPOBM OFX IPNFT XJMM CF EFMJWFSFE BOE B NJOJNVN PG OFX KPCT CFUXFFO BOE 5IF $PVODJM XJMM Henlow is a vibrant settlement. The civil parish of Henlow hosts a population in BMTPDPOUJOVF UP TVQQPSU UIF EFMJWFSZ PG UIF FYJTUJOH DPNNJUUFE TJUFT 5IF the region of 2,338 people according to a UK national statistics population ESBGU QMBOBMTP TUBUFT UIBU $FOUSBM #FEGPSETIJSF XJMM EFMJWFS IPVTJOH OFFE 2015 estimate. JEFOUJGJFE GPS UIF-VUPO )." BOE TPNF VONFU OFFE GSPN -VUPO DMPTF UP Henlow has good public transport links to larger employment centres, XIFSF JU BSJTFT XIFSFUIFSFJTDBQBDJUZUPEPTPTVTUBJOBCMZ in particular Hitchin, Luton and Bedford. The nearest bus stops to the site can 5IF HSPXUI PG WJMMBHFT BOE DIBOHFT UP TFUUMFNFOU CPVOEBSJFT JT BO be found immediately adjacent to the eastern boundary of the site on JOFWJUBCMFDPOTFRVFODF PG NFFUJOH BEEJUJPOBM IPVTJOH OFFET 5IFSF JT Langford Road, which represents an approx. 260m walk from the centre of the OPUIJOH XJUIJOQMBOOJOH QPMJDZ PS MBX UIBU NBLFT JU XSPOH JO QSJODJQMF site. The 71 service operated by Stagecoach is the main service in Henlow and UP CSFBDI TFUUMFNFOUCPVOEBSJFT UP BDDPNNPEBUF TVTUBJOBCMF links the village to Hitchin-Bedford running from 7:10-22:40. The service is hourly EFWFMPQNFOU "T SFGFSFODFE JO UIFNJOJTUFSJBM GPSFXPSE UP UIF throughout the day in each direction, and there is a reduced service running on 'SBNFXPSL i5IF QVSQPTF PG QMBOOJOH JT UP IFMQBDIJFWFTVTUBJOBCMF Sundays. EFWFMPQNFOU%FWFMPQNFOUNFBOTHSPXUIw Henlow is an active and successful community and provides residents with direct access to community facilities including: Going Forward

• Raynsford VC Lower School Henlow is identified within the emerging Local Plan as a minor service centre with a good level of services, including a school, doctor’s surgery, a basic retail offer and • Henlow Church of England Middle School frequent public transport links. • Post Office Emerging Local Plan policy SP6: Within the Settlement Envelopes of both Major • Public Houses and Minor Service Centres, the Council will support in principle housing, Residents in Henlow can easily access facilities in Arlesey, which offers employment and other settlement related development proportionate to the scale employment, leisure and retail opportunities. of the settlement, taking account of its role as a minor service centre. Site Development Potential

Housing Delivery The Community Park will link to a central corridor of open space as well as other landscape features throughout the site. New footpath links will be created to The site is capable of delivering up to 135 dwellings of varying sizes, types and allow access to the wider footpath network in particular providing opportunities tenures (including affordable housing delivered in accordance with planning to achieve the local community aspirations outlined within the Henlow and policy). Langford GI Plans. These Proposals will combine to help lessen the impact of the proposed built development upon the existing landscape. Gladman consider that housing on this site is capable of being delivered in full within the next 5 years. The site is located adjacent to the main settlement of Henlow and is set within a landscape character with a medium landscape value and medium susceptibility to Landscape Character change. As such, it has been assessed as being able to accommodate a well- deigned and considered development as set out by the Development Framework The Development Framework Plan has been sensitively designed with Plan. consideration given to the baseline information and findings of the LVA. The The site is considered to be visually well-contained within the context of the layout has been designed to ensure that the development is set within a wider landscape. The existing local topography and features within the landscape substantial Green Infrastructure network which incorporates existing boundary combine to provide limited views to a small number of residential receptors, users vegetation. A substantial area of open space will be retained within and to the west of the application area to form a new Community Park. of PRoW and promoted walk routes and only a very small number of less sensitive vehicular routes. Whilst there will be inevitable adverse impacts on the landscape and visual receptors during construction and after completion, the overall visual effects are considered to be minor in the longer term. Impacts are there considered to be acceptable within the landscape context and would not result in any overall landscape and visual harm. Site Development Potential

Biodiversity, Green Infrastructure & Local Wildlife Arboriculture

The proposed development will aim to enhance the environment through the Tree cover is confined to the site boundaries and includes a number of provision of green infrastructure, comprising new publically accessible specimens within the verge adjacent to Langford Road and furthermore mature greenspace, equipped play areas and recreational paths increasing permeability specimens adjacent to the water course and the site’s western boundary. to surrounding areas of interest and facilities. The proposals will see all of the existing individual trees and tree groups retained Our initial ecology work, carried out by specialist consultants found that no within a landscape strip adjacent to Langford Road and incorporated into an breeding habitat suitable for great crested newts was present within the site area of public open space and a new community park within the west of the site boundary, no buildings or trees suitable to support a bat roost were present which would extend along the length of the site’s western boundary. within the site boundary. There are also no records of water vole within the 1km of the site, with the closest record being 2.5km to the south east. Only two, approximately 20m sections of hedgerow, would need to be removed to facilitate two proposed new vehicular access points from Langford Road. The A single designated site of local importance was situated 790m north-east of the removal of these two 20m sections of hedgerow should no however raise an site. Henlow Common and Langford Meadow Local Nature Reserve (LNR) is objection from an arboricultural perspective and their loss would be mitigated publicly accessible via a network of footpaths and as the proposed development for through new tree and hedgerow planting which has been illustrated both is residential, the development is likely to lead to a small increase in the number within the frontage landscape strip and open space provision of the proposed of people utilising the LNR for walking and recreation. development. Where necessary, the development proposals will provide adequate mitigation In conclusion, the proposed development will see nearly all of the existing tree and enhancement, wherever possible to ensure species are protected. cover retained within green space and the extensive new tree planting illustrated within the open space provision will more than adequately mitigate for the hedgerow loss required to facilitate the access points. The new planting Heritage as part of the supporting landscaping proposals for the development is set to significantly increase the tree cover on the site in the future, which along with retention of existing tree cover is positive from an arboricultural perspective. There are no Scheduled Monuments or other designated assets on the application site.

A highly speculative route of a Roman road is recorded on the Historic Environment Record (HER) traversing the site in a south-west to north-east alignment; however, no evidence of the road or associated activity was identified during the recent geophysical survey.

Based on the available evidence including the results of the recent geophysical survey the site is considered to have low archaeological potential. Site Development Potential

Hydrology Topography

The development proposal falls entirely within the Environment The local landform is relatively flat with the villages of Henlow, Clifton and Agency Flood Risk Zone 1 i.e. land assessed as having a less than 1 in Langford being located on land between 35 and 40m AOD. 1,000 annual probability of flooding. The landform relates to the local watercourses of the River Ivel and the A sustainable drainage solution to manage surface water run-off River Ivel Navigation. The landform starts to rise at several points will be provided as part of the proposals. approximately 2km from the site east of Langford and south west of Clifton. The site lies on a gentle west facing slope falling to Henlow Brook, a watercourse that skirts the western edge of Henlow and flows north to meet the River Ivel at Langford. The highpoint of the site lies at Design approximately 39m above ordnance datum (AOD) at the southern end of the site’s eastern boundary along Langford Road. The site’s western The proposed development will follow a design-led approach, boundary broadly follows the contour height of approximately 35m AOD. informed by consultation with the Council, key stakeholders and There is also a low point located at the southern tip of the site which forms the local community, responding sensitively to the site’s setting and a localised ‘bowl’ with a low point of approximately 36m AOD. respecting the grain of the surrounding landscape, both built and undeveloped. The development will be a positive addition to Henlow, complementing the character of the surrounding area in terms of scale, density, character and quality. Accessability

Development in this location will provide quality pedestrian, cycle and public transport connections with the existing built form of Henlow and nearby communities. The site fronts directly onto Highways land. An access solution with suitable visibility splays can be achieved without the need for third party land. Site Development Potential

Socio-economic

Central Bedfordshire is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.6 is significantly above the national average and demonstrates this fact, but equally shows that this location is a particularly unaffordable place to live. The proposal to build 135 homes will go some way to improving both these situations – the development will provide new market and affordable homes which will open the settlement up to local people, key workers and others previously unable to purchase a house in Henlow.

NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has been endorsed by a number of Inspectors reporting on recent appeals (as discussed in the Report) In this regard, the economic benefits derived from this scheme will be substantial and will impact positively on the local area and are a significant material consideration in the determination of this application. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

If you have any questions, contact your Project Manager: Rob Black 01260 288 822 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 4

LAND AT SHEFFORD ROAD, MEPPERSHALL

DEVELOPMENT BRIEF

Land at Shefford Road | Meppershall Central Bedfordshire Councill Introduction

Gladman Developments wish to promote land at Shefford Road, Meppershall for development. The 8.23 hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location. A new residential development on this site would incorporate both new market and affordable housing of a variety of types and tenures, to help meet the current and future housing needs of Meppershall and the District.

Should you wish to discuss our proposals further, please contact: Planner: Liam Ryder [email protected] 01260 288912 Site & Planning Context

Site & Surroundings Meppershall is an active and successful community and provides residents with direct access to community facilities including: The site is located to the north west of Meppershall and is approximately 8.23 hectares in area. It is currently envisaged that informal recreational space will be • Meppershall Church of England Academy in the north and west of the site in order to retain existing landscape • Meppershall Village Hall features. With this in mind, the proposed developable area is 5.28 hectares, • Post Office which could accommodate up to 150 dwellings. • Convenience Stores A Vibrant Community • Public House Principle of Development Meppershall is a vibrant settlement. The civil parish of Meppershall hosts a population in the region of 1,727 people according to a UK national statistics The principle of development in Meppershall is well established population 2015 estimate. The site is sustainably located with good access to the through existing and emerging planning policies. centre of Meppershall, surrounding community amenities and public transport network. Meppershall has good public transport links to larger Meppershall is identified as a ‘Small Village’ under the emerging Local Plan. employment centres, such as Shefford which offer employment, leisure and Gladman have addressed Central Bedfordshire’s decision to downgrade retail opportunities, utilising sustainable modes of transport. Meppershall to a small village within their main representations.

The closest bus stop to the development site lies to the south approximately The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will 776m from the centre of the site, on High Street. The number 79 service seek to deliver between 20,000 and 30,000 additional new homes which will travels along the edge of the site on its route from Meppershall to Luton. The first be delivered and a minimum of 24,000 new jobs between 2015 and 2035. The bus arrives at 7:30 in the morning, whilst the final bus arrives at 18:25 in the Council will also continue to support the delivery of the existing committed evening. In total there are 4 services per day from these stops. The bus service sites. The draft plan also states that Central Bedfordshire will deliver provides existing and future residents with a genuine choice about how they housing need identified for the Luton HMA and some unmet need from travel to work in larger employment centres, in accordance with §29 of the Luton close to where it arises where there is capacity to do so sustainably. NPPF. Gladman would consider a contribution towards the improvement of the existing service, providing further services at peak AM and PM times. The growth of villages and changes to settlement boundaries is an inevitable consequence of meeting additional housing needs. There is The nearest railway station is at Arlesey. This is on the edge of the cycle nothing within planning policy or law that makes it wrong in principle to catchment and cycle parking is available at the station. Alternatively, it is only a breach settlement boundaries to accommodate sustainable development. As short drive with again car parking available. It can be accessed by bus referenced in the ministerial foreword to the Framework; “The purpose of directly from Shefford. The station is on the East Coast Mainline. It offers half- planning is to help achieve sustainable development ... Development means hourly services to Kings Cross (and stations in between including Hitchin, growth.” Stevenage and Welwyn Garden City) to the south and Peterborough (and stations in between) to the north. Emerging Local Plan policy SP6: Within Settlement Envelopes of Small Villages, development will be limited to infill development, small-scale employment uses, and community facilities. Site Development Potential

Housing Delivery Neither the Site nor the immediate landscape is covered by any statutory or non- statutory designations for landscape quality. The Site is well contained by the The site is capable of delivering up to 150 dwellings of varying sizes, types and existing village and its existing boundary vegetation, which separates it from the tenures (including affordable housing (53 units) to be delivered in accordance wider landscape. This is further assisted by Nunswood which lies adjacent to the with planning policy). northern edge of the Site. Site access is proposed through the plot of no. 59 Shefford Road, with the limited loss of hedging and a few garden trees. The Site is Gladman consider that housing on this site is capable of being delivered in full assessed as being of medium landscape quality, value and sensitivity. within the next 5 years. The visual assessment found that the Site is well contained by the existing Landscape Character residential development of the village to the southwest and by Nunswood to the northwest. There are, however views of the Site from public vantage points and The LVA has assessed landscape character and visual amenity, and the resulting some residential properties to the north, northwest and southeast, due to the landscape visual effects of the proposed development on the receiving general undulation of the area and the Site’s location on higher land to the landscape and visual receptors. The Site comprises a residential property, two northwest of the settlement. From these vantage points, setting the housing back paddocks and an arable field on the north-western side of Meppershall, to the from the northern boundary and the north-western corner, with new planting southwest of Bedford. The Site is predominantly set back off Shefford Road proposed along these boundaries, would link the Site to Nunswood, further to the behind existing properties and a small area of unmanaged grassland with a north and the north western treed ridgeline of the village. Furthermore, the small part fronting onto the road. development would be seen in the context of the existing settlement generally, the existing properties on the north-western ridgeline and the proposed properties of the allocated site (now consented). Site Development Potential

The Development Framework Plan shows how an appropriate development can Heritage be accommodated at the Site which respects the Site’s existing landscape features, containing the Site within them and providing a sensitive edge to the There are no Scheduled Monuments or other designated assets on the adjoining undulating countryside. The retention and enhancement of the application site. However, a non-designated archaeological asset has been existing mature landscape framework, and the planting of the tree belts on the recorded on the study site in the Central Bedfordshire Historic Environment northern boundary and the north-western corner of the development will enable Record. the development to be integrated into the fabric of the village and into the wider landscape in due course. The proposed development has a potential to impact on known and any as yet to be discovered non-designated assets of probable local archaeological For the reasons set out in this assessment, it is considered that development in interest. The study site is considered to have a high potential for Medieval accordance with the Development Framework Plan and the principles set out in evidence and a low theoretical potential for all other evidence. Section 5, can be accommodated without giving rise to material landscape / townscape or visual effects Based on current information, there appears to be no archaeological constraint which would preclude development of the study site. Biodiversity, Green Infrastructure & Local Wildlife Arboriculture The proposal includes 2.74 ha of formal and informal open space (over 33% of the gross site outline application area); the proposed development also aims to By design, the proposals accommodate the parcel of ancient woodland, and the enhance the environment through the provision of green infrastructure, majority of the moderate quality trees considered to be important to the future comprising new publically accessible greenspace, equipped play areas and amenity of the site and in facilitating the proposal’s integration within the wider recreational paths increasing permeability to surrounding areas of interest and setting. facilities. The removal of a single of moderate quality tree, has been unavoidable to The Site is not covered by any designations for nature conservation or value. The provide a vehicular access, and as a semi mature ornamental specimen, can be nearest site with an ecological designation is the Nunswood County Wildlife Site mitigated for within a scheme of soft landscaping. which forms part of the Site’s northern boundary. An appropriate buffer is The level of tree retention expected is considered deliverable subject to future proposed to offset development from Nunswood. detailed design reflecting the need for temporary tree protection, and The Site generally offers limited opportunities for protected species; however, mitigation for permanent development in close proximity to retained trees bats, reptiles and nesting birds were recorded on Site during the surveys. Long- during construction. term opportunities for these protected species will be maintained and enhanced It is our professional opinion that confidence in the long-term viability of through retention of hedgerows, new landscape planting and provision of bat and bird boxes. retained and appropriate tree cover, and would not result in harm to the wider treescape including Ancient Woodland. The principle of the proposed Where necessary, the development proposals will provide adequate mitigation development is therefore considered supportable from the arboricultural and enhancement, wherever possible to ensure species are protected. perspective and in terms of the NPPF and Local Policy where it relates to trees. This opinion is strongly subject to appropriate mitigation planting proposals, and the adoption of future safeguards for protecting trees during construction. Site Development Potential

Hydrology Topography

The development proposal falls entirely within the Environment Agency Flood The Site is relatively flat, lying at approximately 70m Above Ordnance Risk Zone 1 i.e. land assessed as having a less than 1 in 1,000 annual probability Datum (AOD), and along with the rest of Meppershall, lies on a small of flooding. There are no water bodies which present a source of risk to the localised plateau. The north-western corner and much of the hedgerow development. along the northern boundary mark the highest part of the Site and the It is proposed to connect surface water drainage to the ditch system to the south ridgeline to the north west of the village at approximately 73m AOD, with flows limited to greenfield run off rates thus mimicking existing run off in beyond which the land falls away from the plateau to the north, north accordance with the NPPF. west and north east.

It is therefore concluded that this FRA has demonstrated in accordance with the The landscape around Meppershall consists of rounded, undulating NPPF that the development is not at risk of flooding from external sources, will landform, rising to localised high points and falling to streams and rivers, not increase flood risk associated with the development and its environment including the Rivers Flit and Hiz, and the River Ivel ‘Navigation’. Villages and is therefore appropriate. situated on the edges or tops of the higher points are typically at between 70m and 80m AOD, while others are at approximately 40m AOD where the land falls to the water courses. Higher land at Deacon Hill and Design the Barton Hills Nature Reserve rises to between 150m and 175m AOD respectively, over 6km from the Site to the south and south west. The proposed development will follow a design-led approach, informed by consultation with the Council, key stakeholders and the local community, responding sensitively to the site’s setting and respecting the grain of the surrounding landscape, both built and undeveloped. The development will be a Accessability positive addition to Meppershall, complementing the character of the Development in this location will provide quality pedestrian, cycle and public surrounding area in terms of scale, density, character and quality. transport connections with the existing built form of Meppershall and nearby communities. The site fronts directly onto Highways land. An access solution with suitable visibility splays can be achieved without the need for third party land. Pedestrian access is proposed between the site and Shefford Road at the western end of the development. Site Development Potential

Socio-economic

Central Bedfordshire authority area is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.6 is significantly above the national average and demonstrates this fact, but equally shows that this location is a particularly unaffordable place to live. The proposal to build 145 homes will go some way to improving both these situations – the development will provide new market and affordable homes which will open the settlement up to local people, key workers and others previously unable to purchase a house in Meppershall.

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

If you have any questions, contact your Project Manager: Rob Black 01260 288 822 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 5

LAND AT BIGGLESWADE ROAD, POTTON

DEVELOPMENT BRIEF

Land at Biggleswade Road | Potton Central Bedfordshire Council Introduction

Gladman Developments wish to promote land West of Biggleswade Road, Potton for development. The 5.10 hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location.

Development of this site would respond and complement its surroundings to achieve seamless integration. Gladman would welcome the opportunity to discuss the potential delivery of this site with you in more detail so it can be considered fully in the preparation of your emerging Local Plan.

Should you wish to further discuss our proposals, please contact:

Planner: Chris Still Email: [email protected] Telephone: 01260 288932 Site & Planning Context

Furthermore, Potton is 4.5 miles from Biggleswade and Sandy, which constitute Major Service Centres which have access to a range of facilities and services Site & Surroundings which would provide local employment, leisure and retail opportunities. There are also good bus routes to wider services and facilities in neighbouring The site is located towards the southern edge of the settlement of Potton east of towns including Sandy and larger cities including Cambridge, 30km east of Sandy and the A1. The overall vision for the site is to provide a distinctive and Potton. The nearest bus stop is situated approximately 400m to the north of the high quality place, which complements the qualities and character of Potton. site on Ridgeway. The development covers 5.10 ha and compromises a residential area (2.82ha) The stops on Station Road at Oak Crescent and Market Square, which are all creating up to 85 dwellings with a range of housing to meet the needs of the within a 10-minute walk of the centre of the site, provide connection to a area, whilst respecting and enhancing the site’s environmental assets. Housing greater number of services (2, 127, 188 & 190). The stops at The Ridgeway will be set within a robust network of green infrastructure and public open and Oak Crescent have flags with the latter also having timetable information space (2.21ha), which will help to integrate development within the landscape while the stop at Market Square has a shelter and seating as well as timetable and create a distinctive sense of place. The design will be inspired by the information. The nearest railway station is located in Sandy, 5km west of character and detail found within Potton and the surrounding villages. A Potton with direct connections to Peterborough and London. Development Framework Plan sets the parameters of the proposed development. The precise design and layout of the proposed development Principle of Development would be provided at the reserved matters stage. The principle of development in Potton is well established through existing A Vibrant Community and emerging planning policies. Potton is a vibrant settlement. The civil parish of Potton hosts a The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will seek population in the region of 5,066 people according to a UK national to deliver between 20,000 and 30,000 additional new homes which will be delivered statistics population 2015 estimate. and a minimum of 24,000 new jobs between 2015 and 2035. The Council will also continue to support the delivery of the existing committed sites. The draft plan Potton is an active and successful community and provides residents with also states that Central Bedfordshire will deliver housing need identified for the direct access to community facilities including: Luton HMA and some unmet need from Luton close to where it arises where there is capacity to do so sustainably. • Lower school • Pharmacy The growth of villages and changes to settlement boundaries is an • Middle school • Town centre shops and facilities inevitable consequence of meeting additional housing needs. There is nothing • Pre-school • Sports facilities within planning policy or law that makes it wrong in principle to breach • Medical Centre • Churches settlement boundaries to accommodate sustainable development. As referenced in • Supermarket • Pubs the ministerial foreword to the Framework; “The purpose of planning is to help • Post office achieve sustainable development ... Development means growth.” Site Development Potential

Housing Delivery Going forward

• The site is capable of delivering up to 85 dwellings (including affordable • Potton is identified within the emerging Local Plan as a minor service housing delivered in accordance with the council’s requirements). centre with a good level of services, including a school, doctor’s surgery, a basic retail offer and frequent public transport links. • The site is owned by one landowner and is capable of coming forward • Within the emerging Local Plan, policy SP6 states that within the within the next 5 years. Settlement Envelopes of both Major and Minor Service Centres, the • Gladman has demonstrated that the site is capable of delivering up to Council will support in principle housing, employment and other 85dwellings of varying sizes, types and tenures (including affordable settlement related development proportionate to the scale of the housing delivered in accordance with planning policy). settlement, taking account of its role as a minor service centre. Site Development Potential

Landscape Character

• A Landscape and Visual Appraisal prepared for Gladman has assessed • The site is located adjacent to the main settlement of Potton and is set landscape character and visual amenity, and the resulting landscape visual within a landscape character with a medium landscape value and effects of the Proposed Development on the receiving landscape and medium susceptibility to change. As such, it has been assessed as visual receptors. The landscape and visual effects have been considered in being able to accommodate a well-designed and considered relation to the proposed land uses and the parameters that are defined on development as set out by the Development Framework plan and the proposal’s Development Framework Plan. Design and Access Statement.

• The Development Framework plan has been sensitively designed with • The site is considered to be visually well-contained within the context consideration given to the baseline information and findings of the LVA. of the wider landscape. The existing local topography and features The layout has been designed to ensure that the development is set within the landscape combine to provide limited views to a small within a substantial Green Infrastructure network which incorporates number of residential receptors, users of PRoW and promoted walk existing boundary vegetation. A generous portion of the site is proposed routes and only a very small number of less sensitive users of vehicular as green infrastructure. The southern parcel of land will provide a buffer routes. Whilst there will be inevitable adverse impacts on the between the proposed built development and the woodland to the landscape and visual receptors during construction and after south. A corridor is also provided to the west of the site to allow for a completion, the overall visual effects are considered to be minor in the woodland buffer along this edge. These proposals will combine to create a longer term. Impacts are therefore considered to be acceptable within softened edge to the development help lessen its impact upon the the landscape context and would not result in any overall landscape existing landscape whilst also improving the integration of the edge of and visual harm. Potton with its landscape setting. In doing so the proposals will adhere to the landscape character Guidelines for New Development.

SCHOOL Site Development Potential

Biodiversity, Green Infrastructure & Local Wildlife Heritage

• A total of 2.21 hectares will comprise green infrastructure and will include • There are no Scheduled Monuments or other designated heritage recreational space, footpaths, an attenuation basin and structural planting. assets on or particularly near to the site and no non-designated assets are recorded on the site. • The layout has been designed to ensure that the development is set within a substantial Green Infrastructure network which incorporates • The site is considered to have a modest potential for prehistoric existing boundary vegetation. A generous portion of the site is proposed evidence. Sub-surface evidence of Medieval and Post-Medieval as green infrastructure. The southern parcel of land will be reserved for agricultural activity can be anticipated across the site. The nature of and maintained as acid grassland, a priority habitat in the area. It also any archaeological evidence on the site along with the effect of any provides a buffer between the proposed built development and the historic ploughing is likely to render any evidence of local woodland to the south. A corridor is also provided to the west of the site archaeological interest. This archaeological interest could be secured to allow for a woodland buffer along this edge. These proposals will by an appropriately worded planning condition. combine to create a softened edge to the development help lessen its impact upon the existing landscape whilst also improving the integration Hydrology of the edge of Potton with its landscape setting. In doing so the proposals will adhere to the landscape character Guidelines for New Development. • The site is shown on published mapping to be located within the Environment Agency’s Flood Zone 1. Comparison of topographical data with the EA modelled flood level data indicates that the whole site is in Flood Zone 1 - low risk of flooding. SCHOOL • A low risk of flooding from pluvial flooding is possible to the existing housing but this should be mitigated by a positive drainage system constructed as part of the development. • The low risk from surface water is from an external source to the north where the flow would enter the site along the northern boundary. The overland flow would be captured by the positive drainage to the access road thus limiting the risk to residents. • Similarly, a foul sewer follows the route of the low surface water risk and any overland flow would be captured by the access road drainage.

Site Development Potential Accessibility

Design Development in this location will provide quality pedestrian, cycle and public transport connections with the existing built form of Potton and nearby The design of the site is inspired by the character and detail of existing communities. An access solution with suitable visibility splays can be achieved properties within Potton. The proposed development will follow a design-led without the need for third party land. The access arrangement also allows for speed approach, informed by consultation with the Council, key stakeholders and the reduction measures on the approach to Potton. The site will also contribute towards local community, responding sensitively to the site’s setting and respecting the enhancement of PROWs and Bridleways in the local area. grain of the surrounding landscape, both built and undeveloped. The development will be a positive addition to Potton, complementing the character Socio-economic of the surrounding area in terms of scale, density, character and quality. Our preliminary research shows that the proposed development could lead to a significant boost in local spending and there is an indication that the gross spending power of the new residents could be in excess of £2 million each year, a proportion of which will be spent in the locality.

Topography Central Bedfordshire’s population has grown by 16.3% since 1991 and is anticipated to grow a further 30.9% by 2037. This population is likely to be accommodated Potton lies on a south east facing slope (between approximately 50m and 35m across the district and their significant contribution to the economy can be captured AOD) that forms the south eastern dip slope of the Green Sand Ridge. This locally by allowing smaller, sustainable settlements such as Potton to grow. slope reaches a low point of approximately 35m AOD at Potton Brook before the land rises again to the east reaching a highpoint of approximately 81m Bedfordshire is clearly a sought-after location to live. The ratio of house prices to AOD at Potton Wood. average earnings at 10.7 is significantly above the national average, at 8.1 and demonstrates this fact, but equally shows that this location is a particularly The site lies on an east facing slope falling to Biggleswade Road and beyond unaffordable place to live. The proposal to build 85 homes will go some way to to Potton Brook. The highpoints of the site lie at approximately 45m and 46m improving both these situations – the development will provide new market and AOD at two points along the western site boundary to the north and south affordable homes which will open the settlement up to local people, key workers respectively. The highpoint within the south west of the site forms part of a and others previously unable to purchase a house in Potton. small ridge within the site. The site’s eastern boundary provides the lower extents of the site lying at approximately 36m AOD. NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has been endorsed by a number of Inspectors reporting on recent appeals (as discussed in the Report) In this regard, the economic benefits derived from this scheme will be substantial and will impact positively on the local area and are a significant material consideration in the determination of this proposal. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

Design

We consider the potential development at Biggleswade Road, Potton represents a viable, realistic option for growth to help Central Bedfordshire Council to meet their Objectively Assessed Needs and the unmet needs of Luton.

If you have any questions, contact your Project Manager: Rob Black 01260 288 822 [email protected]

www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 6

LAND EAST OF HIGH STREET, SILSOE

DEVELOPMENT BRIEF

Land East of High Street, Silsoe Central Bedfordshire Council Introduction

Gladman Developments wish to promote land east of High Street, Silsoe for development. The 5.9 hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location.

Should you wish to further discuss our proposals, please contact: Planner: Chris Still Email: [email protected] Telephone: 01260 288932 Site & Planning Context

Site & Surroundings Silsoe is an active and successful community and provides residents with direct access to community facilities including: The site is located to the north east of Silsoe, east of High Street and is • Silsoe Lower School • Sports centre approximately 5.9 hectares in area. Although it is currently envisaged that built • Cranfield University • Village Hall development would only be situated in the western part of the site, retaining • Pre-school/ nursery • Pubs existing landscape features, providing a significant amount of open space. With • Convenience store • Churches this in mind, the proposed developable area is 3.04 hectares, which could • Post Office accommodate up to 105 dwellings. A Vibrant Community Furthermore Silsoe is nearby to Shefford and Flitwick which constitute Service Centres which have access to a range of facilities and services which would Silsoe is a vibrant settlement. The civil parish of Silsoe hosts a population in the provide local employment, leisure and retail opportunities. region of 2,635 people according to a UK national statistics population 2015 estimate. The site is sustainably located with good access to the centre of Silsoe, Principle of Development surrounding community amenities and public transport network. Silsoe is identified in the adopted and emerging versions of the Plan as a suitable Silsoe has good public transport links to larger centres, in particular Luton and location to accommodate additional homes and this is evidenced by the built-out Bedford which have access to a range of facilities and services which would allocation in the settlement. provide local employment, leisure and retail opportunities. The nearest bus The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will seek to stops to the site can be found immediately adjacent to the northern boundary of deliver between 20,000 and 30,000 additional new homes which will be delivered and a the site, which represents a circa 180m walk from the centre of the site. The 81 minimum of 24,000 new jobs between 2015 and 2035. The Council will also continue to service operated by Stagecoach is the main service in Silsoe and links the village support the delivery of the existing committed sites. The draft plan also states that to Luton, Bedford and Bedford bus station. Bedford- Luton, running from Central Bedfordshire will deliver housing need identified for the Luton HMA and some 05:05-20:00, and Luton- Bedford running from 08:00-23:34. The service is hourly unmet need from Luton close to where it arises where there is capacity to do so throughout day in each direction, and there is a reduced service running on sustainably. Sundays. The growth of villages and changes to settlement boundaries is an inevitable There are also good bus connections to schools in the local area with consequence of meeting additional housing needs. There is nothing within planning connections to the upper school within the catchment area as well as others in policy or law that makes it wrong in principle to breach settlement boundaries to Shefford and in Bedford. accommodate sustainable development. As referenced in the ministerial foreword to the Framework; “The purpose of planning is to help achieve sustainable development ... The nearest railway station is Flitwick station, which is approximately 6.3km from Development means growth.” the site. Trains from here operate directly to London St Pancras and London Blackfriars around 4 times an hour. The journey takes about an hour, depending Silsoe is identified as a ‘Large Village’ under the adopted and emerging Local Plan, a upon which train you take. There are also regular services to Bedford. recognition by Central Bedfordshire Council as to the sustainability of the settlement. Site Development Potential

Housing Delivery Going forward

• The site is capable of delivering up to 105 dwellings (including affordable • The settlement boundaries are being reviewed, and Gladman housing delivered in accordance with the council’s requirements). consider that this site should be allocated. •The site is owned by one landowner and is capable of coming forward • Emerging Local Plan policy SP6: Within Settlement Envelopes of within the next 5 years. Large Villages, small-scale housing and employment uses, together • Gladman has demonstrated that the site is capable of delivering up to with new retail, service, and community facilities to serve the village 105 dwellings of varying sizes, types and tenures (including affordable and its catchment will be supported in principle. housing delivered in accordance with planning policy). Site Development Potential

• In conclusion, it is assessed that the landscape character of the site has the ability in which to absorb change through the introduction of high Landscape Character quality development as presented by the Development Framework and the Design and Access Statement. The proposed development of up to 105 houses and associated green infrastructure would be appropriate • The LVA has assessed landscape character and visual amenity and the within this landscape context and it is judged that the effects, as a result resulting landscape and visual effects of the proposed development on the of the proposed development, would not give rise to any unacceptable receiving landscape and visual resource. landscape and visual harm. • • Whilst there would inevitably be some adverse landscape and visual effects at the outset (Year 1 of completion), it is judged that the effects of the Arboriculture proposed development and the consequential effects would, however, be localised and limited in their extent. The existing boundary hedgerows and • No significant tree loss will be required with only the removal of a trees are largely to be conserved as part of the proposals and would be number of low quality trees and a young hedgerow required. The strengthened by new infill hedgerow planting and appropriate proposed built element of the development is to be positioned management, together with additional tree planting. An internal hedgerow centrally to the northern field parcel. The existing trees, recorded by the and small number of trees along High Street are proposed for removal but survey on site, are to be retained. Additional new tree planting has also would be replaced by significantly greater areas of new native planting that been proposed within the landscape buffer strips and areas of public form part of the Green Infrastructure (GI) proposals. open space which will enhance and increase the amount and quality of both existing and future tree cover on the site. • Distant views towards the site from Wrest House and the part of Wrest Park north of the house are possible, however, areas of intervening vegetation • The proposed development retains a large proportion of existing tree between the site and the estate include vegetation associated with the A6 cover creating a maturity to the residential areas. Generous buffer strips and stands of woodland planted in the estate itself filter and limit views. along with areas of open space provide sufficient standoffs from The site slopes away from this direction towards the northwest, and views existing trees including those with historical importance. The would likely be restricted initially to the upper floors and roof tops at the development can be achieved without the loss of any arboricultural southern built development edge beyond the existing stone boundary significant trees and new tree planting will insure future tree cover wall. The development would result in little perceptible change to the within the area along with improving the current tree stock. nature of the view. As the proposed tree planting along the southern boundary matures views will be screened or softened from this receptor. The assessed effects are at worst Minor Adverse at the outset reducing to Negligible as planting matures. SCHOOL

• Site Development Potential Heritage Biodiversity, Green Infrastructure & Local Wildlife • There are no Scheduled Monuments or other designated assets on the • The development proposals provide 2.4 hectares of new public open site. In addition, no non-designated assets have been recorded on the space and a high quality landscape setting, along with functional green site. infrastructure that will provide new public open space, with a circular recreational footpath route, an attenuation basin, SuDS, grassland and new • The proposed development has a potential to impact on any as yet to native tree planting to provide a soft green edge to the settlement. The be discovered non-designated assets although the likelihood of these proposals create a housing site with pedestrian links, retaining public occurring on the site is considered low. The condition and character of footpaths and creating new pedestrian links through the site, linking it to any evidence (in the context of the Secretary of State’s non-statutory Silsoe’s centre and the surrounding area. criteria for Scheduled Monuments (DCMs 2013) and the Regional Research Framework) suggests that, if present, they would be of local • Habitats present within the site are limited both in their range with arable significance. • land predominating and floristic diversity. The arable habitat, including the Hydrology ruderal field margins are considered to be of negligible nature conservation value. The loss of this habitat is not considered to be • The Environment Agency flood map shows that the Site is located significant. entirely within Flood Zone 1; which is land considered to be at low risk of fluvial flooding. • No protected species constraints to development of the site were identified. The site is likely to be of low value for foraging/commuting bats • The FRA has considered the potential impact of the development on given the lack of habitat diversity and prevalence of arable land which is of surface water runoff rates, given the increase in impermeable areas negligible value. Further Bat surveys are to be undertaken, should any post-development. These rates have been calculated, and it has been constraints be found, the green infrastructure proposals for the site demonstrated that surface water can be managed, such that flood risk incorporate inbuilt mitigation and a bat sensitive lighting scheme will be to and from the Site following development will not increase. This will designed at the reserved matters stage. be achieved through restricted discharge rates and an appropriately sized attenuation pond, with an outfall to the watercourse located to the north of the Site.

• The FRA demonstrates that the proposed development would be SCHOOL operated with minimal risk from flooding, and would not increase flood risk elsewhere. The development should therefore not be precluded on the grounds of flood risk. . Site Development Potential

Design Accessibility

The proposed development follows a design-led approach, informed by Development in this location will provide quality pedestrian, cycle and public consultation with the Council, key stakeholders and the local community, transport connections with the existing built form of Silsoe and nearby responding sensitively to the site’s setting and respecting the grain of the communities. An access solution with suitable visibility splays can be achieved surrounding landscape, both built and undeveloped. The development will be a without the need for third party land. positive addition to Silsoe, complementing the character of the surrounding area in terms of scale, density, character and quality. Socio-economic

Our preliminary research shows that the proposed development could lead to a significant boost in local spending and there is an indication that the gross spending power of the new residents could be in excess of £2 million each year, a proportion of which will be spent in the locality. Topography Central Bedfordshire’s population has grown by 17.2% since 1991 and is anticipated to grow a further 30.9% by 2037. This population is likely to be accommodated The site lies on a gentle north west facing slope with a minor tributary of the across the district and their significant contribution to the economy can be captured River Flit located approximately 60m to the north which flows roughly west to locally by allowing smaller, sustainable settlements such as Silsoe to grow. east. The site itself falls gently northwest from a highpoint of 65 metres at the south-eastern boundary to around 58 metres at the northwest corner. Central Bedfordshire County is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.6 is significantly above the national average To the south of the site, Silsoe rises slightly from east to west from above 60 and demonstrates this fact, but equally shows that this location is a particularly metres to around 70 metres at its highest point. Land continues to rise to a unaffordable place to live. The proposal to build 70 homes will go some way to highpoint of 93 metres at Thrift Wood. To the east of Silsoe Wrest Park falls improving both these situations – the development will provide new market and within a wide, flat vale, with slightly elevated undulating land to the east. affordable homes which will open the settlement up to local people, key workers There is a local highpoint of 81 metres at Cain Hill just to the south east of and others previously unable to purchase a house in Silsoe. Wrest House. NPPF Paragraph 19 states that significant weight should be placed on the need to In the wider context, the base of the river valley to the north is around 50-55 support economic growth through the planning system. This has been endorsed by metres AOD. The valley is separated from the site by an intervening low ridge a number of Inspectors reporting on recent appeals (as discussed in the Report) In of land that rises to a highpoint of 76 metres. North of the Flit Valley land rises this regard, the economic benefits derived from this scheme will be substantial and significantly to the Greensand Ridge, this reaches 120 metres AOD around will impact positively on the local area and are a significant material consideration in 3km northwest of the site. the determination of this application. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

Design

We consider the potential development at High Street, Silsoe represents a viable, realistic option for growth to help Central Bedfordshire Council to meet their Objectively Assessed Needs and the unmet needs of Luton.

The development is both deliverable and achievable with the site able to be delivered in its entirety within the 5-year period to make a significant contribution to the Council’s five-year housing land supply. . Gladman Land Gladman House, Alexandria Way, Congleton, CW12 1LB

If you have any questions, contact your Project Manager: Rachael Evans 01260 285 641 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 7

LAND BETWEEN ASTWICK ROAD AND TAYLOR’S ROAD,

STOTFOLD

DEVELOPMENT BRIEF

Land between Astwick Road and Taylor's Road, Stotfold

Central Bedfordshire Council Introduction

Gladman Developments wish to promote land between Astwick Road and Taylor’s Road, Stotfold for development. The 3.35 hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location.

Should you wish to further discuss our proposals, please contact: Planner: Chris Still Email: [email protected] Telephone: 01260 288932 Site & Planning Context

The site is located to the north of Stotfold, between Astwick Road and • Etonbury Middle School • Post Office Taylors Road and comprises one agricultural field approximately 3.35 • St Mary's Church of England • Sports Centre hectares in area. The eastern edge of the site is bound by Taylors Academy Primary School • Larksfield Surgery Road, and beyond the recent development of 118 dwellings by Taylor • Roecroft Lower School • Pharmacy Wimpey. The boundary is marked by a hedgerow interspersed with • Nurseries/ Pre-Schools • Town Hall several mature trees. The Southern boundary lies adjacent to Astwick • Convenience Stores Road and land with permission for residential development of 26 Residents in Stotfold can easily access facilities in Letchworth Garden dwellings. The northern and western boundary adjoin open City, Baldock and Arlesey, which offer employment, leisure and retail agricultural fields. With this in mind, the proposed developable area opportunities, and can travel to these higher level settlements via can accommodate up to 78 dwellings with associated open space sustainable modes of transport. and landscaping. A Vibrant Community Principle of Development The principle of development in Stotfold is well established through Stotfold is a vibrant settlement. The civil parish of Stotfold hosts a existing and emerging planning policies. population in the region of 8,156 people according to a UK national statistics population 2015 estimate. Stotfold is identified as a ‘Minor Service Centre’ in the adopted and emerging Stotfold has good public transport links to larger employment Plan. centres, such as Letchworth Garden City and the train station close by in Arlesey provides a direct service to London, Kings Cross. The The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will nearest bus stops to the site can be found at The Green which is seek to deliver between 20,000 and 30,000 additional new homes which will approximately 400m south of the site. The main service, route 97, be delivered and a minimum of 24,000 new jobs between 2015 and 2035. The provides a regular service from Arlesey to Hitchin via Letchworth. The Council will also continue to support the delivery of the existing committed service provides one to two buses an hour from early morning sites. The draft plan also states that Central Bedfordshire will deliver housing (05.40am leaving Stotfold) until early evening (20.05pm leaving need identified for the Luton HMA and some unmet need from Luton close to Hitchin) Monday to Saturday and therefore, provides a perfectly where it arises where there is capacity to do so sustainably. reasonable option for work, shopping, personal business and leisure The growth of villages and changes to settlement boundaries is an inevitable trips to the main nearby centres. Overall, therefore, the site is well consequence of meeting additional housing needs. There is nothing within located to allow for travel by the more sustainable modes of transport planning policy or law that makes it wrong in principle to breach settlement to a full range of facilities and destinations. boundaries to accommodate sustainable development. As referenced in the Stotfold is an active and successful community and provides residents ministerial foreword to the Framework; “The purpose of planning is to help with direct access to community facilities including: achieve sustainable development ... Development means growth.” Site Development Potential

Housing Delivery Going Forward

• The site is capable of delivering up to 78 dwellings of varying sizes, • Stotfold is identified within the emerging Local Plan as a minor types and tenures (including affordable housing delivered in service centre with a good level of services, including a school, accordance with planning policy). doctor’s surgery, a basic retail offer and frequent public transport links. • Gladman consider that housing on this site is capable of being brought forward within the next 5 years. • Emerging Local Plan policy SP6: Within the Settlement Envelopes of both Major and Minor Service Centres, the Council will support in principle housing, employment and other settlement related development proportionate to the scale of the settlement, taking account of its role as a minor service centre. Site Development Potential

Landscape Character Long term landscape effects are assessed as being Minor Adverse for the site and the immediate context due to the retention of existing features and overall enhancement. Some individual features will result in The site is located on the northern edge of Stotfold and is set within a beneficial effects as a result in the increase of planting and the creation landscape character which consists of an open flat landform with field ofthe swale. boundary hedgerows and some woodland blocks with numerous small settlements. The landscape has been identified as having an ‘enhance and Long term visual effects are assessed as being Minor Adverse or create’ landscape strategy within the Central Bedfordshire Landscape Negligible due to the associated substantial GI which will help to soften Character Assessment and is assessed as being of ‘medium/low’ landscape and screen views of the development and help it assimilates into the value. existing edge of settlement context. The creation of the new northern boundaries will also help to improve views towards Stotfold from the The site is not covered by any landscape designations for landscape quality north. at a national or local scale. Astwick Conservation Area lies approximately 240m to the north of the site boundary and is visually enclosed by numerous It is therefore concluded that the sites landscape character has the ability mature trees. to absorb change through the introduction of high quality development as illustrated by the masterplan. The proposed development of up to 78 The visual envelope for the site has been identified as being limited due to new dwellings with associated perimeter planting, public open space and the flat landform and overlapping field boundaries and existing swale creation is appropriate within this landscape context and the development within the area. Visual receptors are therefore restricted to effects as a result of the proposed development would not give rise to those in the vicinity of the site and include residents on Taylor’s Road and any unacceptable landscape and visual harm. Astwick Road, public footpath users and local road users.

The development proposals would result in the loss of an open arable field however existing landscape features such as the flat landform and boundary hedgerows where present, will be retained and incorporated into the GI proposals for the development.

The development proposals include the creation of substantial boundaries to the north east and north west with hedgerow and tree planting as well as a perimeter footpath, swale and an area of public open space to the west of the site. The GI will soften views of the development and will create additional habitats to improve biodiversity of the site. SCHOOL

Biodiversity, Green Infrastructure & Local Wildlife Arboriculture

A total of 0.85 hectares will comprise green infrastructure and will include There are no tree preservation orders or Conservation Area designations recreational space, footpaths, an attenuation basin and structural planting. that would apply to any trees present on, or in close proximity to the assessment site and therefore no statutory constraints would apply to Development of the site is not expected to negatively impact on any the development in respect of trees. statutory or non-statutory designated sites located in proximity to the site. Hedgerows are recommended for retention as well as measures to avoid The position of the site in relation to the surrounding fields and roads adverse effect from development such as buffering and green corridor meant that only one boundary was fully formed by a road and as such creation. Precautionary measures have been recommended that would contained tree cover assessed as group G2. The remaining boundaries prevent harm to breeding birds, should they be present. Biodiversity were devoid of tree cover as they were formed by further field parcels enhancements are recommended including provision of deadwood habitat piles and bat and bird boxes. with no obvious demarcation of the boundary. Where the western and southern boundaries connected a small section of Astwick Road there Heritage was further tree cover along the road, formed by group G1.

No major archaeological constraints to development have been The majority of tree cover will be retained with only small sections of identified. It is possible that some further archaeological investigations both groups required for removal to facilitate the main vehicle entrance such as desk-based assessment, geophysical survey or trial trenching and a footpath, respectively. The majority of each group will be retained would be required prior to the determination of an application for the along the roadsides and there will be plenty of new planting along the development of the site. boundaries currently devoid of tree cover, which would more than The settings of designated heritage assets in the vicinity of the site are mitigate for the loss of this cover. not considered to be a major constraint to development. Some further assessment of the setting of Bowman’s Mill and Listed buildings at In conclusion, the proposed development would be considered as Astwick may be required to accompany an application but I would not arboriculturally sound allowing for the retention of the vast majority of anticipate anything above minor levels of harm resulting from residential the existing trees on site and the additional proposed new tree planting development within the site, at worst. set to greatly increase the tree cover on site and within the local area to that which currently exists.

SCHOOL Site Development Potential

Hydrology It is therefore concluded that this FRA has demonstrated in accordance with the NPPF that the development can be delivered so as not to be at EA mapping identifies the site as being located in a Zone 1 area of flood risk of flooding from external sources or from within the development, risk. The requirement for some raising of levels along the north and so as not to increase flood risk to the surrounding area. boundary of the site will reinforce this status. The Sequential and Exception Tests do not therefore apply. Design Desk study work has identified that ground conditions have potential for the introduction of infiltration based drainage. This aspect will be The design is inspired by the character and detail of existing properties further assessed at detailed design stage. within Stotfold. Identifying the distinctive components that define local character has been a fundamental starting point for the design of On this basis is proposed to limit flows to existing run off rates. Surface the site. water attenuation will be provided within a linear basin located along the north boundary of the site. Local character comprises of a variety of design elements, from the way in which streets interconnect, development blocks and buildings are Overall the basin will receive flows from the development piped arranged, the use of common building materials, visual containment drainage system which will be designed to accommodate flows up to and boundary treatments etc. the 1 in 30 year event. The piped system will be put forward for adoption under a Section 104 Agreement by Anglian Water who will The site does not specifically seek to recreate, or generate what has therefore become responsible for the long term maintenance of the gone before, but instead looks forward to contemporary sustainable system. design solutions which effectively integrate into the existing fabric of Stotfold by way of referencing common building materials, layout and The management company for the development will become street hierarchy. responsible for the long term maintenance of the basin. The proposed development will follow a design-led approach, Overall the basin and piped system supplemented by appropriate informed by consultation with the Council, key stakeholders and the setting of levels will contain flows on the site up to the 1 in 100 year local community, responding sensitively to the site’s setting and event plus climate change. respecting the grain of the surrounding landscape, both built and undeveloped. The development will be a positive addition to Stotfold, Private drainage (i.e. not adoptable) serving houses within the complementing the character of the surrounding area in terms of scale, development will be designed to current building standards and will density, character and quality. become the responsibility of the individual householders. Site Development Potential

Topography Accessibility

The site lies on a very gentle north east facing slope with the River Development in this location will provide quality pedestrian, cycle Ivel located approximately 300m to the east which flows roughly and public transport connections with the existing built form of south to north. The site itself, comprising currently of an arable Stotfold and nearby communities. An access solution with suitable field, falls gently north from a high point of 42.8m metres at the visibility splays can be achieved without the need for third party land. southern boundary to around 41.5m metres at the northwest corner. Two vehicle access points are proposed, one comprising of a simple priority T junction off Taylor’s Road and another emergency access To the south of the site, Stotfold rises slightly from north to south point off Astwick Road. To provide the visibility splay for the access from around 45 metres to around 50 metres at its highest point. will require the removal or cut back of a section of hedgerow with Land continues to rise to a high point of 80 metres at the northern Category C trees. Elsewhere the existing tree belt will be retained and settlement edge of Letchworth Garden City. supplemented with new native hedgerow, and tree planting will be undertaken within the green space behind the visibility splay to Immediately to the west, north and east of the site the land remains offset any loss and form part of a comprehensive green infrastructure consistently level, with a valley formation in landform following the proposal for the development. course of the River Ivel, transitioning into low ridges north, east and south. Gladman have prepared the access proposals in accordance with the provisions of the NPPF and saved Local Plan Policies, having regard to Although the landform around Stotfold is predominantly flat, there safe access for everyone and providing a pedestrian friendly are several high points in the area forming low mounds, all of which environment. This is delivered through the provision of a safe appear beyond 2km from the site. There is a local high point of 95 junction to access the site and a provision of a permeable layout metres at Bygrave and 84 metres at Ashwell. The other high point in which restricts traffic speeds and provides priority for pedestrians. the immediate context is north of the site at Bleak Hall Farm of 77 metres. Site Development Potential

Socio-economic

Central Bedfordshire’s population has grown by 16.3% since 1991 and is anticipated to grow a further 30.9% by 2037. This population is likely to be accommodated across the district and their significant contribution to the economy can be captured locally by allowing smaller, sustainable settlements such as Stotfold to grow.

Central Bedfordshire is clearly a sought-after location to live. The ratio of house prices to average earnings at 11.7 is significantly above the national average and demonstrates this fact, but equally shows that this location is a particularly unaffordable place to live. The proposal to build 78 homes will go some way to improving both these situations – the development will provide new market and affordable homes which will open the settlement up to local people, key workers and others previously unable to purchase a house in Stotfold.

NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has been endorsed by a number of Inspectors reporting on recent appeals.. In this regard, the economic benefits derived from this scheme will be substantial and will impact positively on the local area and are a significant material consideration in the determination of this application. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

Design

We consider the potential development at land between Astwick Road and Taylor’s Road, Stotfold represents a viable, realistic option for growth to help Central Bedfordshire Council to meet their Objectively Assessed Needs and the unmet needs of Luton.

. Gladman Land Gladman House, Alexandria Way, Congleton, CW12 1LB

If you have any questions, contact your Project Manager: Pet Twigg 01260 288 853 [email protected] www.gladmanland.co.uk Gladman Developments Ltd Central Bedfordshire Draft Plan, July 2017

APPENDIX 8 –

LAND WEST OF ASTWICK ROAD, STOTFOLD

DEVELOPMENT BRIEF

Land West of Astwick Road, Stotfold Central Bedfordshire Council Introduction

Gladman Developments wish to promote land at Astwick Road, Stotfold for development. The 5.34 hectare site presents an ideal opportunity to create a sustainable, high quality residential development situated in a sought-after location.

Should you wish to further discuss our proposals, please contact: Planner: Chris Still Email: [email protected] Telephone: 01260 288932 Site & Planning Context Site & Surroundings • Etonbury Middle School • Convenience Stores • St Mary's Church of • Post Office England Academy The 5.34ha site is located on the northern edge of Stotfold and is • Sports Centre Primary School • Larksfield Surgery currently used as arable/ grazing land. The site adjoins an existing • Roecroft Lower School • Pharmacy industrial estate and the residential edge of Stotfold lies to the east. To • Nurseries/ Pre-Schools • Town Hall the north lies Astwick Road, from which the site access is proposed. Agricultural fields lie beyond the western and southern boundaries of Residents in Stotfold can easily access facilities in Letchworth Garden the site. The developable area is 3.45 hectares, providing up to 100 City, Baldock and Arlesey, which offer employment, leisure and retail dwellings. opportunities, and can travel to these higher level settlements via sustainable modes of transport. A Vibrant Community

Stotfold is a vibrant settlement. The civil parish of Stotfold hosts a Principle of Development population in the region of 8,156 people according to a UK national The principle of development in Stotfold is well established through statistics population 2015 estimate. existing and emerging planning policies.

Stotfold has good public transport links to larger employment centres, Stotfold is identified as a ‘Minor Service Centre’ in the adopted and emerging such as Letchworth Garden City and the train station close by in Arlesey Plan, which reflects the settlement’s ability to accommodate growth over the provides a direct service to London, Kings Cross. The nearest bus stops plan period. Stotfold is a sustainable location for new housing. to the site can be found at The Green which is approximately 600m south of the site. The main service, route 97, provides a regular service The Central Bedfordshire Draft Local Plan (July 2017) states that the plan will from Arlesey to Hitchin via Letchworth. The service provides one to two seek to deliver A minimum of 20,000 additional new homes will be delivered buses an hour from early morning (05.40am leaving Stotfold) until early and a minimum of 24,000 new jobs between 2015 and 2035. The Council will evening (20.05pm leaving Hitchin) Monday to Saturday and therefore, also continue to support the delivery of the existing committed sites. The provides a perfectly reasonable option for work, shopping, personal draft plan also states that Central Bedfordshire will deliver housing need business and leisure trips to the main nearby centres. Overall, identified for the Luton HMA and some unmet need from Luton close to therefore, the site is well located to allow for travel by the more where it arises where there is capacity to do so sustainably. sustainable modes of transport to a full range of facilities and destinations The growth of villages and changes to settlement boundaries is an inevitable consequence of meeting additional housing needs. There is nothing within planning policy or law that makes it wrong in principle to breach settlement Stotfold is an active and successful community and provides residents boundaries to accommodate sustainable development. As referenced in the with direct access to community facilities including: ministerial foreword to the Framework; “The purpose of planning is to help achieve sustainable development ... Development means growth.” Site Development Potential

Housing Delivery Going forward

• The site is capable of delivering up to 100 dwellings of varying sizes, • Stotfold is identified within the emerging Local Plan as a Minor types and tenures (including affordable housing delivered in Service Centre with a good level of services, including a school, accordance with planning policy). doctor’s surgery, a basic retail offer and frequent public transport • Gladman consider that the site will be able to deliver the full 100 links. dwellings in their entirety within the five year period, making a • Emerging Local Plan policy SP6: Within the Settlement Envelopes significant contribution to the Council’s five year housing land of both Major and Minor Service Centres, the Council will support supply. in principle housing, employment and other settlement related development proportionate to the scale of the settlement, taking account of its role as a Minor Service Centre. • Site Development Potential Landscape Character An area of public open space is also proposed to the north with play features and a footpath through areas of open grassland and planting. The site is located on the northern edge of Stotfold and is set within a Internal planting will also be provided along the existing hedgerow and landscape character which consists of an open flat landform with field ditch field boundary to internally break up the development. Tree boundary hedgerows and some woodland blocks and scattered settlement. planting will also be used to soften the frontage along Astwick Road. The The landscape has been identified as having an ‘enhance and create’ Green Infrastructure (GI) will soften views of the development and will landscape strategy within the Central Bedfordshire Landscape Character create additional habitats to improve biodiversity of the site. Assessment and is assessed as being of ‘medium/low’ landscape value. Long term landscape effects are assessed as being Moderate/Minor The site is not covered by any landscape designations for landscape quality Adverse for the site and the immediate context as open fields will be lost at a national or local scale. Astwick Conservation Area lies approximately to development but existing features will be retained with some overall 350m to the north of the site boundary and is visually enclosed by numerous enhancement. Some individual features will result in beneficial effects as mature trees. a result in the increase of planting and the treatment of water features. The additional planting should ultimately improve the existing edge The visual envelope for the site has been identified as being limited due to treatment of Stotfold, improving the setting of the settlement within the the flat landform and overlapping field boundaries and existing local landscape context. development within the area. Visual receptors are therefore, restricted to those in the vicinity of the site and include adjacent residents on Astwick Long term visual effects are generally assessed as being Minor Adverse or Negligible due to the associated substantial GI which will help to Road to the north and Dane Close and Common Road to the south, public soften and screen views of the development and help it assimilate into bridleway users and local road users. the existing edge of settlement context. The creation of new boundaries along the bridleway BW18 route and the public open space area to the The development proposals would result in the loss of open arable fields, north will also help to improve views towards Stotfold from the north. however existing landscape features such as the flat landform and boundary hedgerows where present, will be retained and incorporated into the GI It is therefore concluded that the sites landscape character has the ability proposals for the development. to absorb change through the introduction of high quality development as illustrated by the masterplan. The proposed development of up to 100 The development proposals include the creation of substantial planted new dwellings with associated perimeter planting, public open space boundaries to the south east adjacent to the existing industrial estate, and and enhanced water features is appropriate within this landscape to the south west along the route of bridleway. context and the effects as a result of the proposed development would not give rise to any unacceptable landscape and visual harm.

• SCHOOL Site Development Potential

Biodiversity, Green Infrastructure & Local Wildlife Arboticultural Assessment

A total of 1.89 hectares will comprise green infrastructure and will include There are no tree preservation orders or Conservation Area designations recreational space, footpaths, an attenuation basin and structural planting. that would apply to any trees present on, or in close proximity to the This green infrastructure could significantly improve biodiversity on the assessment site and therefore no statutory constraints would apply to site. There is a proposed Local Area for Play (LAP) for younger children and the development in respect of trees. a seating provision proposed for this site, which will serve both the residents of the development and the local community. The site contained tree cover mainly around the boundaries with only a small number within the northern field parcel close to the boundaries. Two waterbodies are proposed and the open space has been designed to The central areas of both fields were devoid of trees. maximise biodiversity incorporating native tree and shrub planting and species rich grassland. Currently the site provides limited opportunities for The majority of tree cover will be retained with only small sections of wildlife however the proposals create a mosaic of habitats and a corridor of two hedgerows required for removal to facilitate the main vehicle movement through the site which will provide biodiversity gain. entrance off Astwick Road and for the internal access through the development. The majority of each hedgerow will be retained and as mitigation for the loss of the two sections there will be plenty of new planting along the boundaries of the southern field parcel which is Heritage currently devoid of tree cover as well as in the open space provision.

In conclusion the proposed development would be considered as There are no Scheduled Monuments or other designated heritage assets arboriculturally sound allowing for the retention of the vast majority of on the site nor are there any non-designated archaeological assets on the existing trees on site and the additional proposed new tree planting the site set to greatly increase the tree cover on site and within the local area. No major archaeological constraints to development have been identified. It is possible that some further archaeological investigation such as desk-based assessment, geophysical survey or trial trenching would be required prior to any application being determined. .

SCHOOL Site Development Potential Accessibility Hydrology Development in this location will provide quality pedestrian, cycle and public transport connections with the existing built form of Stotfold and The development proposal falls entirely within the Environment Agency nearby communities. An access solution with suitable visibility splays can Flood Risk Zone 1 i.e. land assessed as having a less than 1 in 1,000 be achieved without the need for third party land. annual probability of flooding. Socio-economic A sustainable drainage solution to manage surface water run-off will be provided as part of the proposals. In accordance with the NPPF the Our preliminary research shows that the proposed development could development can be delivered so as not to be at risk of flooding from lead to a significant boost in local spending and there is an indication that external sources or from within the development, and so as not to the gross spending power of the new residents could be in excess of £ 4 increase flood risk to the surrounding area. million each year, a proportion of which will be spent in the locality.

Central Bedfordshire’s population has grown by 16.3% since 1991 and is anticipated to grow a further 38% by 2039. This population is likely to be Design accommodated across the district and their significant contribution to the economy can be captured locally by allowing smaller, sustainable The proposed development will follow a design-led approach, informed settlements such as Stotfold to grow. by consultation with the Council, key stakeholders and the local community, responding sensitively to the site’s setting and respecting Central Bedfordshire is clearly a sought-after location to live. The ratio of the grain of the surrounding landscape, both built and undeveloped. house prices to average earnings at 11.6 is significantly above the national The development will be a positive addition to Stotfold, average and demonstrates this fact, but equally shows that this location is complementing the character of the surrounding area in terms of scale, a particularly unaffordable place to live. The proposal to build 100 homes density, character and quality. will go some way to improving both these situations – the development will provide new market and affordable homes which will open the settlement up to local people, key workers and others previously unable to purchase a house in Stotfold.

Topography NPPF Paragraph 19 states that significant weight should be placed on the need to support economic growth through the planning system. This has The site lies on a very gentle north facing slope currently comprising been endorsed by a number of Inspectors reporting on recent appeals (as two arable/grazing fields, falling gently north west from a highpoint discussed in the Report) In this regard, the economic benefits derived from of 42.9m metres at the southernmost corner to around 41.5m metres this scheme will be substantial and will impact positively on the local area at the northernmost corner. and are a significant material consideration in the determination of this application. Indicative Framework Plan

KEY: KEY:

Site BoundarySite (7.58ha)Boundary (7.58ha)

Proposed ResidentialProposed Residential Development Development (4.21Ha) (4.21Ha) Up to 118 dwellingsUp to 118 @dwellings 28dph @ 28dph

Potential VehicularPotential AccessVehicular Access

Proposed ReplacementProposed Replacement Hedgerow Hedgerow Planting (alongPlanting Wick (along Lane) Wick Lane)

Proposed FootpathsProposed Footpaths/ / CyclewaysCycleways Gernon Road Gernon Road Proposed PublicProposed Open Public Space Open Space (2.77Ha) (2.77Ha)

N N

Design

We consider the potential development at West of Astwick Road, Stotfold represents a viable, realistic option for growth to help Central Bedfordshire Council to meet their Objectively Assessed Needs and the unmet needs of Luton.

. Gladman Land Gladman House, Alexandria Way, Congleton, CW12 1LB

If you have any questions, contact your Project Manager: Pet Twigg 01260 288 853 [email protected] www.gladmanland.co.uk