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Legal & General Property Legal & General Property Representations on soundness Economy, Airport, Green Belt and landscape policies of the Draft Luton Local Plan for Public Consultation (2011-2031) Savills August 2014 August 2014 Representations on Behalf of Legal & General Property Economic, Airport, Green Belt and Landscape Policies of the Draft Luton Local Plan (2011 – 2031) Soundness 1. Introduction 1.1. This Statement of Representation is submitted by Savills UK Limited on behalf of Legal & General Property (LGP) in relation to Policy LP 4 (Green Belt), Policy LP 29 (Landscape and Geological Conservation); Policy LP 6 (London Luton Airport), Policy LP 31 (Sustainable Transport Strategy), the Key Diagram and Policies Map, and Policy LP 13 (Economic Strategy) of the Draft Luton Local Plan for Public Consultation (2011 – 2031) (June 2014) (DLLP). The representation justifies why it is considered that the DLLP is not sound in relation to these policies. 1.2. LGP owns approximately 23 ha of land at Someries Farm occupying a strategic location south of London Luton Airport with direct frontage to the Airport operational boundary. Appendix 1 contains a Site Location Plan and a copy of the DLLP Key Diagram showing a proposed amendment. 1.3. The Statement is arranged in the following sections: • Section 2 sets out the case on soundness – this addresses economic, Airport, Green Belt, landscape, and site specific considerations. • Section 3 provides conclusions. Legal & General Property Representations on the Draft Luton Local Plan (June 2014) Page 1 August 2014 2. Soundness – Economic Policies, Green Belt and Airport Economic policies 2.1. The economic strategy seeks to provide land that can deliver about 18,000 B class jobs over the plan period to 2021. This is below the target identified to achieve Luton’s economic growth potential (20,000 jobs), so a constrained target was adopted to reflect the ‘limited supply of employment land’. It identifies several sites for this purpose at Butterfield Green Technology Park, Napier Park, Stockwood Park and Century Park east of London Luton Airport (Policy LP 13). 2.2. The Luton Employment Land Review (ELR) confirms the available employment land in Luton, including a new site associated with the relocation of Luton Town FC to Stockwood Park near M1 Junction 10A, as being 69.2 ha: these produce a total of 275,370 sq m of floorspace. Table 7.2 of the ELR provides a quantitative assessment of the demand and supply of employment floorspace, finding a shortfall of floorspace/land up to 2031 under two of the growth scenarios. It also states that a large proportion of the available land supply is at Napier Park (40,000+ sq m); Century Park (150,000 sq m) and Butterfield Park (55,700 sq m) and concludes (para 7.8) by stating that ‘if some of these large sites did not deliver over the plan period... this could mean a sizable deficit under all scenarios.’ Para 7.12 specifically refers to Century Park stating it ‘requires costly infrastructure before development can take place, including provision of a new access road which could involve a new surface road or a tunnel beneath Luton Airport...the prospects of this new road being developed in the medium term appear uncertain...there appears some risk of this site not coming forward in the next 20 years or not delivering all its potential floorspace in that period’. Legal & General Property Representations on the Draft Luton Local Plan (June 2014) Page 2 August 2014 2.3. A key reference figure that can be derived from the Luton ELR is that the deficit of B class employment space arising under the different growth scenarios ranges from 47,230 - 83,430 sq m (Table 7.2). Using the plot ratio indication set out at para 7.4 of the ELR (1 ha produces approx 4,363 sq m) an unmet employment land requirement of between 10 and 19 ha would be produced. 2.4. There are significant concerns over the deliverability of Century Park east of London Luton Airport: this relates to the need to fund a tunnel under the airport to gain access to the land. The 42 ha would need to generate funds of £1,190,000/ha to fund £50,000,000 of abnormal infrastructure costs (tunnel) without other costs being taken into account. This makes the site undeliverable without additional development land as a source of extra funding: such land has been proposed in North Hertfordshire’s area east of the airport, but has not been progressed by that Council. 2.5. The land south of the Airport could address the unmet need for employment land; provide land specifically to meet the growing needs of the Airport for landside facilities and aviation / airport-related uses, and in part to compensate for the undeliverable land at Century Park. The Airport is currently the subject of proposals to expand its operation to 18 million passenger per annum (mppa): with this will come demand for land to accommodate primary, secondary and catalytic employment related to the Airport’s growth. The site could be accessed via a new road from the airport access road network (Airport Way) and the Airport (landside access) to serve 23 ha of employment development on land well related to the Airport. Policy LP 13 should be amended to include this site for aviation / airport related employment uses. Legal & General Property Representations on the Draft Luton Local Plan (June 2014) Page 3 August 2014 Green Belt 2.6. The site forms part of the Green Belt south of Luton known as Someries identified in Policy LP 4 (Green Belt). The land forms part of a flat plateau area south of the Airport; land to the south east and south falling away towards Lower Harpenden Road and Chiltern Green. The site therefore forms a relatively discrete area more closely related to the Airport than the surrounding landscape to the south east and south. The principle of releasing land from the Green Belt around Luton has been established through the release of significant areas of land to accommodate the SUEs north of Luton and Houghton Regis, and east of Leighton Linslade in the Development Strategy for Central Bedfordshire. In this context, it is considered that the site could be released from the Green Belt without prejudicing the purpose of the Green Belt in this area as noted at paragraph 80 of the NPPF. Area of Local Landscape Value (ALLV) 2.7. The site is identified as one of several Areas of Local Landscape Value (ALLV) under Policy LP 29. The site is located adjacent to and at the same level as the Airport; it has very limited landscape qualities; is not a tranquil area; is isolated from the town by the Airport, and is topographically distinct from the wider landscape to the south. Based on these characteristics, it is considered that its identification as a candidate ALLV through the Luton Landscape Character Assessments (2013) was not justified. Furthermore, the land to the south within Central Bedfordshire Council is no longer proposed as an Area of Great Landscape Value (AGLV) in the emerging Development Strategy for Central Bedfordshire (DSCB): is instead identified as a Green Infrastructure Priority Area within which the intention is to secure contributions from acceptable development to provide expanded / enhanced green infrastructure. Legal & General Property Representations on the Draft Luton Local Plan (June 2014) Page 4 August 2014 On this basis, the site should be removed from the ALLV list in Policy LP 29 (‘(viii)... Land south of the Airport’). London Luton Airport 2.8. Policy LP 31 (Sustainable Transport Strategy) supports the continued economic success of the Airport with reference to safeguarding related highway capacity and surface access potential. The Policy goes on to identify Safeguarded Land for strategic infrastructure schemes, including the tunnel to serve the Century Park site. If the land south of the Airport is identified for employment use related to the Airport, then Policy LP 31 would need to be amended to include this as a strategic infrastructure scheme. Policy LP 6 (London Luton Airport) identifies Century Park for airport and aviation related uses. Given the uncertainty surrounding the deliverability of this site, the policy should be amended to identify the land south of the Airport for airport or aviation related uses consistent with the need for more employment land noted in this Statement. Soundness 2.9. Given the quantitative and qualitative deficiencies in the employment provision in the DLLP, it is considered that it is not sound as it has not addressed the objectively assessed need for employment land. Further, with Century Park being undeliverable, the DLLP has not addressed the employment land requirements related to the Airport. Legal & General Property Representations on the Draft Luton Local Plan (June 2014) Page 5 August 2014 3. Conclusion 3.1. For the reasons stated in this Statement, the DLLP is not considered to be sound. It was not therefore positively prepared taking account of the quantitative and qualitative need for employment land; has not been prepared on a credible evidence base; does not contain the most appropriate economic strategy; is not effective insofar as some provisions are undeliverable; does not incorporate a flexible approach to employment land provision to accommodate changes in circumstances, and is inconsistent with the guidance in the NPPF on building a strong and competitive economy. 3.2. The site south of London Luton Airport is well placed to address the employment land deficiencies of the DLLP: it can provide a high quality site to serve the needs to the Airport; it can provide a more flexible employment land strategy; it can compensate for the Century Park site, and it can support the growth of the Airport up to and beyond 18 mppa.
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