For and on Behalf of Pigeon Investment Management

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.

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

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.

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.

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

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. These opportunities should not be overlooked, and where necessary the Council should consider reviewing the current policy of restrictive settlement envelopes and consider suitable sites on the edge of settlements on their merits, in accordance with the Framework’s presumption in favour of sustainable development. Indeed we hold some reservations about the concept of defined settlement envelopes and, as the recent appeal decision in Stotfold (Ref: APP/P0240/W/16/3166033) has shown, there is some doubt as to whether this approach is consistent with the Framework.

2.12 In the context of the strategy advanced at this stage, we generally support Major Service Centres, such as Flitwick, being identified for new development. However, we feel that the Plan should also take into account the individual needs of each settlement. In this regard we consider Flitwick is clearly capable of accommodating new growth which will meet the needs of this town and reference is made within Sections 3.0 and 4.0 of this report to site specific justification for this.

2.13 As will be discussed in detail in Sections 3.0 and 4.0 below, our client’s site on land to the east of Maulden Road, Flitwick represents a suitable and sustainable site for new development that is well related to the main built form of the town.

Objective Assessment of Need

2.14 DLP do not consider the Draft SHMA 2017 approach to be in accordance with the Framework or the current guidance and it is clear that if adopted across the wider Housing Market Area the approach would result in a substantial undersupply of housing compared to the official projections and would worsen the affordability of the housing market.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

2.15 The OAN should take into account the unmet need from Luton whilst also making an allowance for market indicators. Based on this, DLP believe that the Local Plan needs to make provision for a significantly larger number of dwellings than currently provided for in the draft Local Plan.

Duty to Cooperate

2.16 In light of the Inspector’s conclusions on the Development Strategy in his letter to the Council dated 16th February 2015, specifically the Council’s failure to meet the requirements of Section 33A of the Planning and Compulsory Purchase Act 2004 (as amended by Section 110(1) of the Localism Act 2011) and satisfy the Duty to Cooperate, this must be a fundamental consideration for the Council going forward in the preparation of the new local plan.

2.17 The Duty is enshrined in paragraphs 178 and 179 of the Framework. Paragraph 156 also sets out a series of key planning matters of ‘strategic priority’, which includes “the homes and jobs needed in the area”; “the provision of infrastructure…” We note in particular that S33(A)(2a) requires a local planning authority to, “engage constructively, actively and on an ongoing basis in any process…”

2.18 The National Planning Practice Guidance (Paragraph: 001 Reference ID: 9-001- 20140306) acknowledges that:

“The duty to cooperate is not a duty to agree. But local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination.”

However, “…As part of their consideration, local planning authorities will need to bear in mind that the cooperation should produce effective and deliverable policies on strategic cross boundary matters.”

2.19 Paragraph: 011 Reference ID: 9-011-20140306 goes on to say:

“Cooperation should produce effective policies on cross boundary strategic matters. This is what local planning authorities and other public bodies should focus on when they are considering how to meet the duty. Local planning authorities should bear in mind that effective cooperation is likely to require sustained joint working with concrete

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

actions and outcomes. It is unlikely to be met by an exchange of correspondence, conversations or consultations between authorities alone.”

2.20 The most pressing strategic cross boundary matter for Central Bedfordshire is how to address the significant existing shortfall and projected future needs for housing generated by Luton.

2.21 The new Local Plan should seek to meet a proportion of Luton’s need in addition to fully meeting the needs generated within Central Bedfordshire. At the Luton Local Plan examination hearings there were considerable objections made to the OAN for the Luton and Central Bedfordshire housing market area (HMA) in relation to the methodology used. Some 9,300 dwellings have been identified as not being able to be accommodated within Luton. The Local Plan Inspector has said that the distribution of this should be informed by the ‘Growth Options Study’. This has not yet been published and so there is no agreement as to how or where this will be met by neighbouring authorities.

2.22 The draft Local Plan states that some 7,400 dwellings maybe accommodated to assist in meeting the shortfall in Luton. Taking account of the unmet need from Luton at 7,400 dwellings the correct approach to considering the demographic need while making no allowance for response to market indicators would require a local plan requirement of 47,446 dwellings. A response to market indicators as recommended by LPEG would increase the Local Plan requirement for CBC to 55,940 dwellings.

2.23 In order to be pass the Duty to Cooperate, the Council must engage constructively, actively and on an ongoing basis with the necessary authorities from the outset of the plan preparation i.e. now at the scoping and evidence gathering stage.

Evidence Base

2.24 Paragraph 158 requires LPA’s to ensure that local plans are based on “adequate, up- to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.” It is therefore essential that the Council does not simply carry forward the evidence that was prepared to support the previous Development Strategy, simply to expedite the process. Where necessary the evidence should be reviewed to reflect the most up to date information available.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

As mentioned previously, there has been limited technical information published to support the strategic allocations being considered and 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). The justification for the proposed allocation of these sites is therefore unclear and as such, their deliverability and suitability for development is questioned as the technical work required to identify any constraints associated with these sites has either not been undertaken or published.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

3.0 THE SITE

Site Location & Context

3.1 The site lies on the eastern side of Maulden Road. It is contained by existing residential development on Maulden Road and Moor Lane to the west, Greenfield Road to the south, Flitwick Moor to the east and Folly Farm to the north.

3.2 The major service centre of Flitwick is concentrated around Steppingley Road and the High Street. Facilities within Flitwick include, but are not limited to, a supermarket, Community Centre, 5+ pre-schools/nurseries, 3 lower schools, a middle school, health care services including GP surgery, 3 chemists, 3 dentists, pubs, leisure centre, professional services, take-away and convenience stores.

3.3 The town is also served by bus route Nos. 34 (Milton Keynes), 42/44 (Bedford), 5 (Silsoe), 200 (Silsoe/Biggleswade), which also serve some of the surrounding villages and settlements. The closest bus stop to the site is on Maulden Road and is served by bus route Nos. 42 and 5.

3.4 Flitwick Railway Station is located approximately 0.6 miles to the west of the site, and is on the Govia Thameslink line that provides fast and frequent services to Brighton and London St Pancras in the south, and Bedford in the north.

3.5 In this context, Flitwick can be clearly considered a sustainable location for new development.

The Allocation Site

3.6 The site is 20.5ha in size and is located within the Green Belt on the eastern edge of Flitwick and currently comprises an agricultural field.

3.7 The topography of the site is relatively flat and there is an existing agricultural access from Maulden Road adjacent to the existing residential properties adjoining the site. It is proposed to access the site from Maulden Road via a new roundabout junction with Maulden Industrial Estate. If required a secondary vehicle access could be provided off Greenfield Road to the south of the site.

3.8 The site is screened along the eastern boundary with Flitwick Moor but the western

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

boundary with Maulden Road is open. There is some moderate existing natural screening to the northern and southern boundaries.

3.9 The majority of the site is within Flood Zone 1 with a small corner in the south-east being within Flood Zone 2 and 3. It is only proposed to develop that part of the site within Flood Zone 1.

3.10 The extent of the report site is shown in figure 1 below.

Figure 1: Location Plan of Report Site

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

The Major Service Centre of Flitwick – A Sustainable Location for Growth

3.11 As a major service centre, Flitwick has a good range of facilities. These include the following:

 Supermarket & Convenience Stores  Professional Services  Health Care Facilities, including GP surgery  Leisure Centre  Pubs  Open Space  Community Centre

 Pre-schools/Nurseries

 Lower schools

 Middle school

3.12 There is also a railway station providing good access into London and good bus services providing access to surrounding towns and villages.

3.13 In the context of the sites location on the edge of Flitwick and the services and facilities provided, Flitwick is a sustainable location for further growth.

Central Bedfordshire & Luton Green Belt Study (November 2016)

3.14 Central Bedfordshire jointly with Luton Borough Council commissioned LUC to undertake an assessment of the Green Belt within Central Bedfordshire and Luton.

3.15 The aim of the study was to assess the extent to which the Green Belt land within the study area contributes to the purposes of a Green Belt as set out in the Framework.

3.16 The report site was assessed as follows in relation to the purposes of a Green Belt under reference (FW2/FW2a) as follows.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

Green Belt Criteria Purpose FW2 / FW2a Assessment

Purpose 1 to check the unrestricted sprawl weak/no contribution of large built up areas

Purpose 2 to prevent neighbouring towns weak/no contribution merging into one another

Purpose 3 to assist in safeguarding the relatively strong countryside from encroachment – contribution

Purpose 4 to preserve the setting and relatively weak contribution special character of historic towns

3.17 Overall, the promotion site was assessed as having a relatively weak contribution to the purposes of a Green Belt. Therefore, in the context of the Council’s own Green Belt review, the allocation of the report site for development would not have a detrimental impact on the purposes of including land within a Green Belt.

3.18 Furthermore, irrespective of the development potential of the site, given the weak contribution this land makes to the purposes of a Green Belt, it can safely be removed from the Green Belt without harm.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

4.0 PROPOSED ALLOCATION

4.1 As shown on the submitted indicative master plan, the vision for this site is to provide an employment-led mixed use development incorporating the following uses:

 2.13ha of mixed use employment with structured planting/landscaping along the northern boundary;

 1.67ha for health and social care hub including new GP surgery;

 6.8ha of residential development (around 150 dwellings at 25dha) including bungalows and a mix of house sizes;

 Formal open space (1ha); and

 Informal open space/Ecological enhancements including 2.5km of footpaths.

4.2 The primary access to the site would be taken from Maulden Road via a new roundabout junction with Maulden Industrial Estate, which would provide a safe means of access to both the site and industrial estate as well as reducing vehicle speeds along Maulden Road in the locality of existing residential properties. The road would run east into the site before curving and running south towards Greenfield Road. Additionally, a new cycle/footpath would be provided to the western side of Maulden Road towards the new Country Park providing a safe and convenient means of access to the park for both new and current residents. The south eastern part of the site that is within the flood zone would be left undeveloped. Just over 2 ha of employment land is proposed to the north western corner of the site adjacent to the existing industrial estate, with a strategic landscape belt to extend along the northern boundary. The Strategic Employment Site Assessment Technical Document: Appendix D advises that the employment allocation for Flitwick (site NLP351) fails the stage 2 assessment due to the impact on archaeological assets. Therefore, our client’s site will assist with the provision of employment infrastructure for the area which will contribute to the ongoing regeneration of the town and assist in reducing out commuting of existing residents.

4.3 To the south of the employment land a ‘Health and Social Care Hub’ is proposed which is to include a new replacement GP surgery which will cater for the immediate needs of the locality as well as future needs arising in the area.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

4.4 South of the ‘Health and Social Care Hub’ bungalows are proposed to the rear of existing development on Maulden Road. This would ensure no concerns of overlooking/shadowing arise as well as offer an expanded choice in accommodation to existing residents to enable them to downsize whilst remaining in the town. Furthermore, the bungalows are located to the west of the site with the shortest walking distance of the town centre.

4.5 Housing is proposed to the east of the spine road at a density of circa 25 dha (in keeping with the density of housing to the west of Maulden Road) with this to include a mix of house sizes (1, 2, 3 and 4 bed units). The built form is to be separated from the adjacent woodland (Flitwick Moor SSSI) and Greenfield Road by a substantial buffer, including areas of formal open space (which will address the existing shortfall in the town) as well as informal open space. The informal open space includes 2.5km of footpaths and ecological improvements. These measures (along with the delivery of a new cycle/footpath to the Country Park) offer the opportunity to both enhance the existing ecological value of the site and reduce recreation pressure on the SSSI through providing easily accessible and high quality (all weather surface, seats and benches, litter and dog waste bins) circuit of footpaths. Additionally this buffer will provide an attractive gateway to the south eastern entrance to the town and improve the setting of Flitwick Mill.

Technical Work

4.6 A range of technical work has been undertaken in relation to ecology and transport. This work has confirmed that these elements do not represent a constraint to development on this site and more importantly offers the opportunities to make enhancements.

4.7 Ecology

An initial ecology appraisal and strategic assessment has been carried out for the site and adjacent Flitwick Moor SSSI and has been submitted with this representation. This review concludes the site is of low ecological value and is not considered functional habitat for the SSSI. Furthermore there is little overlap between species on the site and the SSSI.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

4.8 Site - The informal open space proposed (to replace low value arable fields) will include new habitat creation that could include new woodland and wetland, and will offer an enhancement in available habitat for many species.

4.9 Flitwick Moor SSSI – A number of Public Rights of Way extend from Flitwick through the SSSI with users of these footpaths giving rise to recreational pressure on the woodland. The provision of a cycle/footpath along Maulden Road, facilitated by development on this site, to the new Country Park will provide convenient access for both new and existing residents to access this open space thus reducing recreational pressure on the SSSI. Moreover, the provision of a substantial area of public formal and informal open space including 2.5km of all-weather footpaths (served by litter and dog waste bins and seats and benches) will provide attractive alternatives to users of the woodland thus substantially further reducing recreational pressure.

4.10 Development on this site therefore offers the opportunity to improve the existing ecological value of the site and reduce recreational pressure on the adjoining SSSI and the Council’s previous concerns in relation to the impact on ecology and the SSSI can be safely mitigated against and do not represent a constraint to development on this site.

4.11 Transport

A Transportation Technical Note has been carried out which provides an outline of the potential impact of the development on the local highway network and demonstrates the site lies in a sustainable location in terms of accessibility to public transport and day-to-day services and facilities.

4.12 It is proposed the access be taken via a new four arm roundabout that includes the existing Maulden Road industrial estate, which will not only provide for a safe means of access to this site but also assist in circulation of vehicles accessing/egressing from the industrial estate, and act as a traffic calming measure along Maulden Road where a number of residential properties are located.

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4.13 Furthermore, it is proposed as part of the development that a new cycle/footpath be provided towards the Country Park on the western side of Maulden Road thus representing a significant improvement to the local highway network.

4.14 In terms of access to public transport the site is within 1km walking distance to Flitwick Railway Station and is well connected to both the railway station and town centre by a network of well-lit footpaths. Additionally the site is well located for journeys to school either on foot or bicycle, with Kingsmoor Lower School, Flitwick Lower School, Templefield Lower School and Woodland Middle School all lying within the recommended 2km walking distance

4.15 The highway appraisal also concludes that the proposed development on the site would not have a significant impact on existing traffic flows within the town centre or the wider area.

Development Opportunities

4.16 Following an assessment of the site’s constraints and opportunities, a concept master plan has been prepared to demonstrate how the site could potentially accommodate a range of different uses. This has been submitted with this representation.

4.17 The master plan shows that new employment provision provided opposite the existing industrial estate with a new roundabout introduced on Maulden Road which would improve vehicle movements and act as a traffic calming measure. The delivery of new employment to the town will contribute significantly to the ongoing regeneration of Flitwick and assist in reducing out commuting. A landscape belt is proposed to extend along the north of the site thus providing a suitable landscape buffer. Further highway improvements include the provision of a cycle/footpath along Maulden Road providing safe means of access for existing and new residents of Flitwick to the Country Park.

4.18 To the south of the employment land a Health and Social Care Hub including GP surgery is to replace the existing constrained surgery and provide for an integrated medical hub to serve the local community. The provision of bungalows will expand the range of housing stock in the town thus offering opportunities for existing residents to remain ‘local’ and free up larger houses for families. Moreover by locating the

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

bungalows adjacent existing houses will ensure the amenity of Maulden Road residents are protected.

4.19 On the eastern part of the site, houses are proposed at a similar (25dha) density to the built form on the western side of Maulden Road, with significant informal and formal public open space along with a network (2.5km) of public footpaths. This space would enhance the ecological value of site, reduce recreational pressure on the SSSI, improve the setting of the listed Flitwick Mill and provide an attractive gatweway to the town.

4.20 The site is well related to the edge of the built up area of Flitwick and as discussed above, does not perform any particular Green Belt function. Therefore, its allocation for development in the local plan would not harm any of the purposes of a Green Belt.

4.21 In the context of the above, the site represents a sustainable location for medium scale growth with no overriding constraints to the development and the concept master plan has been designed so that development on the site relates well to the existing pattern of development and settlement edge of Flitwick.

Comments on Specific Development Plan Policies

4.22 The Development Plan includes a range of draft planning policies. Our client, Pigeon, wish to comment specifically on the following policies:-

4.23 Policy H7 Self and Custom Build – relevant to sites of 10 dwellings or more

Pigeon support the principle of self and custom build housing and have successfully delivered this provision on other sites. However Policy H7 should provide greater clarity on the mechanism and terms for offering plots to those on the self-build register.

4.24 Policy R1 ‘Ensuring Town Centre Vitality’

Pigeon has no specific comments on this policy but would reiterate that new homes are required at Flitwick to support the regeneration of Flitwick Town Centre.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

4.25 Policy T2 Mitigation of Transport Impacts on the Network

Pigeon has no objection to the principle of this policy and the requirement for Transport Assessments, Travel Plans and promoting sustainable methods of transport. However, paragraph 5 which references proximity to bus and rail services is not clear and should be refined. If this is a requirement of new development, the ability for new homes to enhance existing provision and the viability and frequency of services should be recognised when assessing proposals.

4.26 Policy T6 Strategic Transport Improvements

Pigeon recognises the aspirations within the Local Plan for delivery of the Strategic Transport Infrastructure referenced in this policy. Again we would reiterate that strategic growth options in Central Beds are overly reliant on this infrastructure to deliver the housing required with no certainty that this will come forward.

4.27 This is highlighted in the final paragraph of Policy T6, which references contributions being sought towards the strategically important infrastructure. However, the policy is not clear which projects would contribute, or the mechanism for doing so as CBC does not currently have CIL in place and contributions via S106 would be limited under the ‘pooling’ criteria, and the tests of a S106 contribution being applicable to the development. Accordingly, further information is required as to how this will operate.

4.28 This policy also raises a ‘chicken and egg’ scenario in that the Development Plan is clear that for strategic sites such as Tempsford (page 86 onwards), the infrastructure is essential for their delivery. Therefore, the infrastructure will need to be in place ahead of development. This raises questions as to whether the sites that will benefit most from the infrastructure will contribute towards it in terms of the timings and phasing of development.

4.29 Policy HQ1 Health Impact Assessments

It is difficult to comment on this policy without understanding the thresholds and requirements of the forthcoming Health Impact Assessment SPD. Pigeon therefore reserves the right to comment further once the SPD is published.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

4.30 Policy HQ9 ‘Larger Sites’

Pigeon notes the potential requirement for Development Briefs and Design Codes. However, the Council should ensure that these requirements do not lead to any additional complication or delay to the delivery of sites.

BE5265 – Land East of Maulden Road, Flitwick August 2017 Pigeon Investment Management

5.0 OVERALL CONCLUSIONS

5.1 The emerging Plan should be prepared within the context of the Government’s policy advice as set out in the Framework and related documents and guidance, to objectively identify and then fully meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Specifically, the emerging Plan should seek to “boost significantly the supply of housing” in accordance with paragraph 47 of the Framework.

5.2 Furthermore, the emerging Plan needs to ensure that the significant housing needs arising from Luton are met in order to satisfy the requirements of the Duty to Cooperate. This is a fundamental issue that will need to be addressed in the new Local Plan in order for it to be found sound.

5.3 The Development Strategy, which as presently presented is in our view flawed and insufficiently explained, and appears as overly reliant on large scale strategic growth sites. We would strongly urge the Council to reconsider both its approach and also strategy and adopt a more pragmatic and deliverable approach and one that reasonable responds to the needs of its community. In this regard we would urge allocating a number of smaller and medium size sites, such as our client’s land, within the Local Plan alongside any larger allocations to provide a short term flow of sites.

5.4 Our client’s site on the east side of Flitwick offers an opportunity to provide a well- planned employment-led mixed use development, including much needed new housing, in a timely manner that could be delivered early in the plan period. Flitwick is a sustainable location for growth and provides a good range of services.

5.5 The Green Belt Review study concluded that our client’s site provides a relatively weak contribution to the purposes of a Green Belt as set out in the Framework. Therefore, removal of this site from the Green Belt would be appropriate.

5.6 Our client’s site is in a sustainable location for development, the landowner is committed to developing the site so it is available, and there are no constraints to developing the site. In this respect the site is truly deliverable.

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5.7 In the context of the above, we submit this site as a sustainable proposition to be allocated for new development in the next iteration of the Development Plan for Central Bedfordshire.

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