For and on Behalf of Pigeon Investment Management
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For and on behalf of Pigeon Investment Management CENTRAL BEDFORDSHIRE DRAFT LOCAL PLAN (JULY 2017) Consultation Response DLP Ref: BE5265 Land East of Maulden Road, Flitwick Prepared by DLP Planning Ltd Bedford August 2017 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management Prepared by: Graeme Free BSc (Hons) MA MRTPI Senior Planner Approved by: Andrew Parry MA MRTPI Associate Director Date: August 2017 DLP Planning Ltd 4 Abbey Court Fraser Road Priory Business Park Bedford MK44 3WH Tel: 01234 832740 Fax: 01234 831266 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. 2 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management Contents Page 1.0 Introduction 4 2.0 General Comments 6 The Growth Strategy 6 Objective Assessment of Need 8 Duty to Cooperate 9 Evidence Base 10 3.0 The Site 12 4.0 Proposed Allocation 16 5.0 Overall Conclusions 23 3 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management 1.0 INTRODUCTION 1.1 These representations have been prepared by DLP Planning Ltd (DLP) on behalf of Pigeon Investment Management Ltd (Pigeon), in response to Central Bedfordshire Council’s consultation on the emerging Regulation 18 draft Local Plan and as relevant and available, its supporting evidence base. 1.2 DLP welcomes the Council’s decision to review the various elements of the extant development plan and provide for a comprehensive, up to date, single document Local Plan that will fulfil the requirements of the National Planning Policy Framework (the Framework) to provide for, a fully, up to date, objectively assessed development needs of the District and its residents in a balanced and sustainable manner. 1.3 DLP, on behalf of its client, wishes to make a number of comments on the emerging draft strategy as a whole as part of the background context to the representations we are submitting on the site itself. 1.4 Sections 3.0 and 4.0 discuss the suitability of our client’s site for development in detail and supplement our responses in Section 2.0. 1.5 The site was previously submitted to Central Bedfordshire Council’s ‘Call for Sites’ exercise under references ALP174, ALP177 and NLP321 as part of the emerging local plan process. 1.6 The Council’s assessment of the site, which we have concerns over on the basis of its objectivity and scoring, dismissed it primarily on the basis of the Site’s proximity to Flitwick Moor (SSSI), perceived impact on ecology and landscaping, impact on the setting of the listed Flitwick Mill, and the site being Grade 2/3 agricultural land. 1.7 As set out in Section 4.0 below, the site is being promoted for mixed use development that includes mixed use employment, a health and social care hub, residential units, formal and informal open space and ecological enhancements. An indicative master plan has been submitted with this representation. 1.8 Preliminary ecology and highway work has been undertaken to inform the proposed development on this site and which addresses the concerns raised by the Council’s assessment of this site. This is discussed further in Section 4.0 below. 4 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management 1.9 In respect of the impact on the setting of Flitwick Mill the built form would be set back substantially from Greenfield Road to the south and additional landscaping introduced which would offer opportunities to enhance the setting of Flitwick Mill, as well as provide for an attractive gateway to the town. The existing public rights of way across the site would be retained and additional footpaths would also be provided along with areas of public open space. This will improve the permeability through the site and make it accessible to local residents. 5 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management 2.0 GENERAL COMMENTS Positively Prepared 2.1 The Council’s vision and objectives are welcomed, in particular: “to deliver new high tech employment supported by sustainable new homes in a number of new village clusters and market town extensions which are well integrated into the existing high quality landscape.” 2.2 However, this intent must be followed up by a Local Plan that is positively prepared, justified by evidence, effective and consistent with national policy, as required by paragraph 182 of the Framework. The Growth Strategy 2.3 As a starting point in the preparation of the emerging Local Plan, CBC should seek to meet the full, unconstrained objectively assessed needs (OAN) for market and affordable housing in the housing market area, in accordance with the third Core Principle and paragraph 47 of the Framework. The express objective of this is to “boost significantly the supply of housing” and this also is set out clearly in the National Planning Practice Guidance. 2.4 DLP have significant reservations on the OAN advanced by the Council. This we believe both significantly underestimates the level of housing need and fails to reflect up to date government guidance on a range of matters, e.g. migration patterns and levels and as a result will both lead to a significant under supply of housing and worsen affordability. DLP believe there is a need to both substantially increase the level of housing beyond the very general scale that the Council have at this stage advanced, which in itself DLP believes is not in accord with Framework advice and both makes the strategy of the emerging Plan unclear and calls into question the basis of this. 2.5 Whilst DLP both recognise the need for and supports a strategy for growth, and also supports certain elements of the Council’s strategy, e.g. the intention to look to the establishment of ‘new settlements’ and allow for ‘urban extensions’, the approach adopted by the Council is in our considered view flawed and lacks proper, objective and thorough analysis and transparency. 6 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management 2.6 As published, the emerging Plan, whilst detailed in certain policy aspects, lacks a required level of detail in others, in particular in providing for a strategy for smaller and medium sized allocations. As currently proposed the Plan provides for a series of options that in themselves offer little detail or justification either as to their selection or what is proposed so far as the scale, form or phasing of development is concerned and this contrasts with the detail offered in the policies as referred to above and also undermines the credibility of the Plan at this stage. 2.7 Noticeably, also, the Council has restricted its engagement and discussion on these matters with promoters, in particular with respect to major proposed allocations (outside of its selected strategy sites), which in itself is both contrary to guidance and further undermines confidence in the emerging Plan. 2.8 So far as the overall strategy is concerned, regard should be given to the settlement hierarchy and the sustainability of this and the ability of settlements to accommodate development, or where development can provide new services and facilities. This appears to be absent and the emerging Plan provides only limited information and also makes only some general comments in respect to the levels of distribution in this regard. There appears to be an over reliance on large scale strategic growth locations, these again lacking any detail, and which if carried through will likely lead to significant delays in delivery over the Plan period. 2.9 We believe that the process followed so far is flawed and requires reconsideration both in approach and in strategy. It also lacks flexibility and we would strongly urge the Council to reconsider its strategic approach; redefine the allocations strategy and consider allocating a number of smaller and medium size sites within the Local Plan alongside any larger allocations to provide a short term flow of sites. Furthermore, the Plan needs to take into account the individual needs of each settlement which in the case of Flitwick includes supporting the regeneration of the town (including delivering new employment provision and a ‘health and social care hub’ with GP surgery), making optimum use of the proposed improvements to the railway station, facilitating access to the Country Park to the north of the town and increasing formal open space provision. 2.10 As set out in government guidance, all settlements have a role to play in meeting development needs and achieving sustainable development. It is however, accepted 7 BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management that the focus of development should be on settlements where there are existing services and facilities, or easy access to them, the potential to support/enhance such facilities, or where services and facilities may be introduced to the benefit of local residents. In this context, we support growth in Area A around Flitwick, which is defined as a Major Service Centre and a good range of services and facilities. 2.11 A number of opportunities for growth exist in and around some of the major service centres such as Flitwick, which has a good level of services and facilities providing for the needs of local residents.