Local Plan Central Bedfordshire Council Priory House Monks Walk Chicksands Shefford SG17 5TQ
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Local Plan Central Bedfordshire Council Priory House Monks Walk Chicksands Shefford SG17 5TQ 21st February 2018 By Hand and Email Dear Sirs Draft Local Plan Consultation I write in order to make representations on the Draft Local Plan currently in consultation. In particular, as a resident of Harlington village, I find the proposed large scale housing development wholly unacceptable; not only would this effectively turn our historic village into a town but there are a number of areas where I do not believe your Draft Plan has been properly prepared. I find it very difficult to follow your Draft Plan with its various references and appendices and the system for comment itself is also very cumbersome – I feel this may be deliberate in order to discourage comments from people living in your area. Nonetheless I have chosen to respond in letter form in order to ensure I have my say and I would like the opportunity to appear at any enquiry that is held. Before identifying the various issues can I first point out that your very own website says the following: From the consultations and community engagement events, we know that local communities want us to: make sure our roads and other transport networks can cope limit the impact on the countryside keep the character of Central Bedfordshire plan for homes for the older generation and affordable homes to help people get on the housing ladder plan for local jobs and services use brownfield sites This being the case, why have you only addressed the ‘plan for homes’ bullet point for Harlington village but completely disregarded every other item that you identify as community requirements? The draft plan identifies 2 large sites in the village of Harlington (I believe these are identified as HAS20 and HAS21), both within the current greenbelt. In total these areas, even at the notional densities stated, would add 589 houses to the village – thereby increasing the village population by significantly in excess of 1200 people, an increase of 60% or so on the current size. Whilst there is no doubt that the village has a part to play in the overall need for more housing this seems to be completely out of proportion. It is impossible to argue that an increase of this size would not completely change the character of the village and have a negative impact on villager’s quality of life which would be against the National Planning Policy Framework. In addition, the rationale for such a dramatic increase in the size of the village seems to be based on a poorly researched / inaccurate evidence base – indeed it’s hard to believe you have even visited the village. The village capacity study suggests that there are 3 pubs (there are only 2), a restaurant (there are none just a daytime café) and 2 stores (there is only 1). Local schools are already at full capacity, indeed not all age groups have provision in the village, and there is only a part time medical facility. Conversely, much is made of the larger site (HAS20) being able to provide a much needed open recreational space when in fact the village already has a very large space with children’s play areas, football pitches, cricket ground, etc. There is a lack of proper study into sewerage and drainage (a cynic might say deliberately so) as this is a well-known existing problem within the village. I can likewise find no study on flood risk for the sites but the village has clay soil and drains very poorly. The larger site comprises 18.15 hectares of arable fields on which crops are produced every year so loss of this space would seem to be again contrary to Central Government policy. Perhaps most surprising is the inconsistent assessment of sites – a number of sites in the wider plan area were deemed unsuitable as they were across a road which currently defines the village/town boundaries – in the case of the larger site (HAS20) the site is completely separated from the village by a railway line a very clear village boundary. The access to this site is via a very narrow bridge (often with traffic taking turns to move due to parked cars) and a single pedestrian path that requires crossing the main road at least 3 times to get to the village centre. The natural barrier formed by the railway line and the poor interconnection of this site with the rest of the village would create two very separate and distinct communities. This problem already exists in Flitwick with the railway line and also in other areas such as Tempsford (here the issue is caused by the A1). Furthermore specific site proposals were considered unsuitable within Harlington itself and I have underlined in the extracts below the elements that would be at least as relevant to either one or both of the proposed sites (HAS20/21) but which were seemingly ignored in this case: ALP123/ NLP303 Land off Goswell End Road Harlington Harlington Green Belt 12.89 NLP303 No Site would not be a logical option for extension of Harlington as it would extend the settlement northwards towards Westoning, narrowing what is currently a relatively small gap. It would also extend the settlement away from the core services and railway station. There are flood risks that require further investigation on this site, and mitigation would also be required to address the noise from the railway. Further, development of this site would raise landscape concerns as the site is on open and rising ground and development here would extend Harlington into the open countryside. ALP355/ NLP379 Land north of Goswell End Road Harlington Harlington Green Belt 2.46 No Despite the sites proximity to the upper school, it would not be the most logical option for extension of Harlington as it would extend the settlement northwards and further away from the railway, crossing the road which currently separates the residential edge of the settlement. It would also extend the settlement away from the core services and railway station. The site is in close proximity to a Grade II listed building and therefore caution would be required in relation to any development of this site. Further, development of this site would need to avoid rising ground and extension of development beyond the existing built edge. Structural landscape mitigation may also be required to the northern and eastern boundaries alongside ecological mitigation. The larger site (HAS20) would, presumably be accessed directly from the very busy road between the village and the M1 on which there are a number of accidents each year and the road has very poor visibility around a number of bends. No attempt appears to have been made to assess the suitability of access points into the land leading one to wonder how the site was considered suitable from a highways / access point of view. The plan proposes a significant release of Green Belt, very much contrary to the national policy framework. It does not seem that almost 25 hectares of green belt release can in anyway be justified as “limited release”, nor does the plan set out the “exceptional circumstances” that it claims exist. The larger site (HAS20) was considered to have a “moderate high” harm rating if released whereas a number of other sites in the village that are not to be released from green belt were considered only “moderate” impact – again this seems like a very inconsistent approach. It should also be noted that HAS21 is close to the AONB so it seems illogical that this site would have only a moderate impact. As I understand it, the Council have failed to find enough brownfield sites but is cooperating with Luton Council to help with their housing needs. It seems likely that Luton could identify more brownfield sites – or indeed reconsider some of their Green Belt areas for their own requirements. Clearly it is much easier for councils to ignore the wishes of the community to use brown field sites and allocate large green field and indeed green belt sites to hit targets. On a personal note the larger site HAS20 is on a hill side and currently drains into a lake on our property which in turn feeds the River Flit. Development on this site would surely mean significantly more hard areas increasing the drainage issues which, if allowed to run into the lake, taking with it petrol, oil, pesticides and other daily pollutants from 400 or more houses would have a serious detrimental issue on the ecology of the area. The lake is home to many species of fish, shellfish, amphibians, birds, small & large mammals, bats, insects and plants. Again no assessment of the ecological impact appears to have been taken in order to inform the decision to pass site HAS20. Whilst I understand the need to provide additional housing in the Central Bedfordshire, and Harlington must play a part along with all other areas, it seems to me that there are numerous flaws and missing data that would be necessary to fully inform the council in reaching the conclusions that it has and the plan is clearly in conflict with National Policy in many areas. I therefore find it necessary to raise my objections to the large scale additional housing allocations and loss of Green belt around our historic village of Harlington. As I stated before I would welcome the opportunity to speak at enquiry should the proposals remain in the draft local plan. Yours faithfully Gary Felce .