Lidlington Parish Council

Lizzie Barnicoat Clerk to the Council

To Whom It May Concern:

Response to Central Council Local Final Plan February 2018 Consultation

Overview Lidlington Parish Council disagrees with Council's inclusion of the parish of Lidlington as an area in which to build up to 4 new villages. Lidlington Parish Council strongly opposes the proposal in the consultation document for 5,000 houses and a new business park, and the proposal to take forward sites NLP103, NLP370 and NLP482. Lidlington Parish Council fundamentally feel the production of this document has been rushed, poorly researched and badly communicated to the electorate of Central Bedfordshire, and particular the residents of Lidlington. On this basis, set out below, fnd the national planning policy requirements which Lidlington Parish Council consider unsound. Clarity The Parish Council would like to go through a number of concerns which evidence the lack of due diligence which Ofcers at the local authority have taken though this entire Local Plan process, but in particular since 2017. There has been a complete disregard for the small, rural parish of Lidlington, which is proposed to have up to 5,000 new dwellings and a minimum of 40 hectares of employment land, thrust upon it. At no point in the main consultation document and/or any of the subsidiary documents, is there any reference to the actual name of the parish which is to receive all this proposed radical change. Lidlington, is disappointingly not mentioned. This obfuscation has led to a great deal of local confusion. Local residents have not realised that Policy SA2 new villages, is in fact nearly entirely “Lidlington Parish” new villages. The consultation was poorly publicised by the local authority in the immediate area to be affected. In addition, the absence of naming Lidlington in any of the accompanying literature many residents and locals took the understandable approach of thinking the proposals are for elsewhere in the Marston Vale. This is a severe oversight and shows complete disregard for true consultation Due Diligence The local authority have rushed the Local Plan process through committee stages, to release this fnal document. The total lack of detail was a thorough disappointment for the interested stakeholders, such as the Parish Council who expected to see a comprehensive document complete with supporting rationales, assessments and local studies which illustrate the reasons Central Bedfordshire Council have come to the conclusions they have. Instead, since the last consultation of the draft Plan in the summer of 2017, (which the Parish Council lambasted CBC for failing to provide sufcient information) there has been very little change to the document. Having such a broad expanse of land being proposed ‘allocated for signifcant development’ is simply lazy. It shows no careful consideration of the local impact, it shows no care for the number of tests that should have been applied by the local authority. Such as how can a site of hundreds of hectares in size be sustainable, when it has access to nothing? The local authority approach of having strategic land earmarked for development, would be plausible if there was detailed supporting evidence of this, which there is none. Naturally, any land owner seeking a massive uplift in the value of their land will say that it is suitable for development. The Parish Council are shocked that such little analysis of the light touch scoping information has been carried out. These are reasons for showing that the production of the Plan is not sound, along with the fact that there is insufcient examples of the local authority having been involved with and delivering such a high volume of houses in a single Parish. Having up to 5,000 dwellings is the equivalent of a new market town the size of . Central Bedfordshire Council have no experience, or track record in working with a large developer to deliver such high numbers of housing and truly sustainable high quality infrastructure in one focused area. This approach by the local authority is a great worry to the Parish Council, as doing this in one area would be a risk, delivering such a large proportion of the Plan with one developer in the lifetime of this Plan is even more risky. Other local authorities like and Borough () have experience of delivering new communities and have therefore been able to build on what they have learnt. The inexperience of Central Bedfordshire Council is portrayed in the poor quality of their policy SA2 which makes very sweeping gestures of what the new Marston Vale villages will look like. Taking such an overview is bad management, the policy wording should clearly stipulate and prescribe what MUST be delivered. The once only annihilation of the RURAL Parish of Lidlington must deliver real gains to the wider population of Central Bedfordshire, other than a sigh of relief from CBC’s remaining Parish Councils that houses are not being dumped in their area. Central Bedfordshire has a very sorry history of taking the grandiose promises of developers and failing to enforce the delivery of the gains which the public rightly expect for the irreversible destruction of valuable farmland and our countryside. Their policy gives no infrastructure guarantees, the lack of any “cascade phasing” is clear evidence that once again the developers will have their way and unfortunately we anticipate Central Bedfordshire Unitary Council will continue to assert that they could not have known that the developers would let them down. Document Inconsistencies The Local Plan Pre-Submission overview for homes, states - Triangle and are not included by CBC planners as they say :- “We believe these locations do have potential for growth but, as we said in the previous consultation, they are dependent on critical infrastructure (e.g. East- West Rail) to support them and you agreed with us in your feedback” Yet, NLP370 is predicated on this “critical infrastructure”

The local authority contradicts itself through the document in terms of Lidlington and the local area. On Page 105 there is reference to Lidlington being classifed as a ‘small village’, yet Pages 60 - 61 have an allocation of an additional 5,000 houses, an increase of 1000% The consultation document talks about the Marston Vale being a special area, it is nationally recognised, it is unique in character, yet it is suitable for 5,000 houses and a large amount of business buildings. Surely, in terms of preservation and protection, the Marston Vale, as it has clearly been regarded numerous times in the past, should be protected from such urbanisation. Omissions from the Document The Parish Council note there is no introduction or reference to Health Impact Assessment documents to be produced as part of the consideration process, which are becoming the norm in other local authorities. Also having no visual ideas on such a vast housing development seems a considerable oversight, we feel this has been a deliberate strategy to obfuscate. When people have little or no REAL information, how can people REALLY engage? The document only briefy outlines monitoring and how this will be achieved by the local authority in terms of projected deliverability to ensure the 5 year land supply target is being met. This has been a well know issue for the local authority in recent years, and has resulted in a number of piecemeal and inappropriate developments coming to Lidlington. This also means developers build their houses with little regard to the local infrastructure needs. The infrastructure issues in this area seem to have been swept aside. The lengthy queues at the A507 junction trying to exit the village, the excessive speeds seen along the C94 and numerous fatalities. The grid lock at Junction 13 with no credible plans in the foreseeable future to change the access to this area. The deeply worrying queues at the local doctors surgery, which are already well oversubscribed and the facilities not ft for purpose to meet the current needs. The local schools which are full to capacity, meaning children in catchment often have to taken their admission case to appeal to gain access to their local school. It would be reasonable to expect with 5,000 new houses you will need some new schools, will these be aligned to the unusual three tier system delivered in the local authority. That seems a high cost to add to all the other items that are going to have to appear by the developer, which would question the realistic viability of the site that is being proposed. Yet, in light of all the above, Central Bedfordshire Council feel no need for a robust and strongly worded policy when managing the deliverability of 5000 homes in this Parish. The Ofcers also seem to have overlooked a number of subsidiary planning policies that would be expected with a Local Plan fnal document. This is another concern of the Parish Council’s which shows the lack of soundness of this document. There are no guidelines to which planning policies the local authority are following, which ones have been reviewed, or deleted. This is an extensive piece of work which seems to have been overlooked by the local authority, and/or completely omitted from the public consultation process. Where is the cumulative modelling of the Marston Vale new villages and whole plan sites presented and taken into account by Central Bedfordshire Council Ofcers? A number of key items seems to have been dealt with by a brief paragraph in the consultation document, for example, not the usual detailed study that is needed to confdently ascertain the local area needs around employment and economy.

Justification for non-inclusion in the plan Lidlington P.C.’s view of what CBC should have said about NLP370 – ( Cf. NLP463 ) The site consists of arable farmland predominately within the Marston Clay Vale and is contained by the distinctive landscape of the Greensand Ridge to the south. Development within this site would not form a logical extension to Lidlington however it is considered that the size of the site is capable of providing standalone developments. Strategic scale development within this site would need to mitigate impacts upon these distinctive landscapes and appropriate landscape buffers that would limit negative impacts on existing settlements. Any new settlement would be required to provide appropriate physical and visual separation between the development and neighbouring villages. It is considered that development within this site should not proceed until a route has been identified and safeguarded for the proposed Oxford to Cambridge Expressway to provide key transport infrastructure to enable commuting within the Oxford to Cambridge arc in the plan period. Strategic scale development of this site would require a comprehensive scheme for transport improvements including improved public transport connections to both Milton Keynes and Train Station (East-West Rail). The site is adjacent to and directly accessible from the A421 where there are a number of concerns in regard to trafc and queuing implications that could arise from development at this location. Further trafc implications may be felt within the surrounding settlements and minor road networks, particularly at the level crossing within Lidlington, alongside creating new sources of air and noise pollution in addition to those currently being experienced from the A421 and the M1 motorway. There are a number of listed buildings within nearby Lidlington and therefore impacts on the setting on these will need to be considered, particularly in the area of the Marston Vale Basin with the Ringwork Scheduled Monument and the Medieval village and moated sites at Thrupp End. However, when considering the separation between the site and these heritage assets it is considered that the likely impact of development upon the signifcance of these heritage assets would be less than substantial and the benefts of development would likely outweigh such harm. The site also contains the most significant and costly section of the planned route for the Bedford and Milton Keynes Waterway Park and Waterway. Without end to end security for the irrevocable delivery of land for this critical piece of infrastructure the overwhelming impact on this single parish would lead to an unjustifiable dumping of yet more commuter estates and lead to greater “out- commuting”. For the Local Plan to deliver signifcant public benefts and provide opportunities for habitat creation and leisure facilities, a high quality environment must be guaranteed. Given the location, the connection to the nearby planned Heat Network associated with the Combined Heat and Power Facility that is to be constructed at Rookery Pit South must be mandated. In light of the comments mentioned above, the harm to the area is outweighed by the obvious public benefits that the site could provide. Therefore the site is worthy of further consideration for development only when a coherent plan outcome can be properly secured. Given the huge uncertainly of so many major infrastructure planning considerations. development of the site would be highly speculative. BACKGROUND INFORMATION RELATIVE TO LIDLINGTON Unique Character of Lidlington and Historical Context Lidlington is a small rural village currently comprising less than 600 houses. In recent years it has seen a decrease in local facilities, but a signifcant increase in development which has seen the village grow in the past decade by over 20%. The character of the village is rural, set in the rolling countryside of the historic Marston Vale, allowing properties to look out to green felds. The village is also particularly unique, given it has a railway line which runs through the centre of the village, effectively dissecting it into two. This is a very important factor to bear in mind. However, there have been some important recent changes:  The construction of the bypass and completion of the A421 between the A1 and the M1 created a destination that attracted vehicles of all classes to the local area, and unfortunately to use the immediate minor, country road network surrounding Lidlington as a short-cut, or diverting through the village itself, creating congestion.  Centre Parcs, and an increase in other employment facilities in the local areas whilst creating employment opportunities has negatively impacted on the local road network particularly the A507, which is a key exit route out of the village and has in recent years become a very dangerous junction. As a designated small rural village, the proposed extension of 5,000 dwellings within the parish combined with a new business park will swamp it. Central Beds own Settlement Hierarchy states this and confrms (page 124 of the consultation document) Lidlington is a small village. The Parish Council feels that taking this proposal forwards will in effect destroy Lidlington's unique character and is in direct contradiction of all the caveats in the consultation document. Bringing 5,000 houses and a business park to the village will not keep it small. This is a ten-fold increase – which is clearly over development. Growth Development in the Local Area The recent growth in Central Bedfordshire has all followed similar patterns. In general they have been developments which have looked to enhance a specifc area, bringing regeneration to the local community, such as in and . This style of development has not seen the creation of large new settlements which coalesce with or expand over an existing village setting. The proposed changes in Lidlington Parish therefore appear to be contra to the Council’s previous position on such development. Landscape and Visual Impact on Wider Community No one is entitled to a countryside view, but this land is part of the established Marston Vale area. The consultation document refers to maintaining a visual gap and talks about coalescence. However, it seems supremely optimistic to believe that this can be maintained between the 4 newly built developments in close proximity to one another and an historic small rural parish. The site assessment clearly states that these homes will be within 800 metres of Lidlington Station. Yet there appears to be no qualms that this will not coalesce and wash over Lidlington. Lidlington is predominantly low-density development. History suggests that any schemes brought forward will be high density. This is totally against planning policy guidelines. Such development would be out of keeping with nearby housing and it is impossible to foresee how such high density housing would blend into the rural landscape. The Parish Council believes this would have a detrimental visual impact and 5,000 high density housing is out of keeping with the character of this small village based in the Marston Vale.

Noise Pollution Since the sites predominantly wrap around the housing area of the parish, during the construction phase Lidlington would be subjected to unacceptable noise and disturbance, not to mention disruption to local roads and services, for a prolonged period. This is not acceptable. Highways and Transport The proposal for 4 large villages (over 1,000 houses each) with no clear route of access other than onto roads which have evolved on the ancient historical routes and were not originally designed or engineered to modern highway requirements, is short-sighted. These village roads are wholly unsuitable to sustain the large volumes of trafc that will result at the peak times. It is clear the village road network and infrastructure of Lidlington would not be able to accommodate any required access points. As a result of the recent development mentioned in above, the increase in volumes and speeds of trafc, not only in the village but on local subsidiary roads, is very noticeable at peak fows. Having such a signifcantly large housing development which relies on direct highways access onto the local road network and which potentially includes direct access onto a 'C' unclassifed road is not acceptable. It is usual for large housing developments to be serviced by direct access onto urban roads which are part of the main highway route. The associated trafc from 5,000 houses will have a signifcant detrimental impact on the road network within the parish, which as previously detailed is not designed to cope with this. The National Planning Policy Framework (paragraphs 29-41) states that planning policies should ‘actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling and focus signifcant development in locations which are or can be made sustainable’. It further states that planning policies should aim to achieve places which promote accessible environments containing clear and legible pedestrian routes, and that developments should be designed to give priority to pedestrians and cyclists. The NPPF, highway design standards (DRMB) and local policy require high quality pedestrian and cycle links. The Parish Council believes there is simply not sufcient room with the narrowness of the local village network to accommodate additional foot- ways or indeed a cycleway. Such changes would require signifcant engineering with a potential heavy impact on current residents, such as the removal of front gardens, if the village is to be accessible to the proposed 5,000 houses. Sustainability The proposed development area is not close to existing services and facilities, other than those few currently found in Lidlington. These cannot meet the demands of 5,000 additional houses. This in turn will increase issues around parking at the local village shop which is situated on a narrow road and already has parking issues. There are no car parking facilities at Lidlington station but it would be prudent to assume many of the new residents in the 5,000 homes will want to take advantage of the improved East West rail link. This will bring chaos to the already stressed roads of Lidlington. If a 'new' village is to be grown from scratch successfully then this is a tall order. It takes a lot of time to 'grow' a community, to ensure it matures and has the right access to services. To achieve this four-fold appears very optimistic especially given the nearest example where this has been tried and yet is still rife with problems. The “Wixams village” development was billed to bring a new community together, however it has several missing facilities promised to those people who bought their home and bought the 'vision' of Wixams; schools are oversubscribed, there is no healthcare facility, there is no train station, the local shops cannot sustain their business and close down, in addition to a number of unfulflled developer obligations such as a community woodland area, all of which have not materialised. The Parish Council believes this idea of having four villages ‘growing’ is little short of fanciful. Healthcare Whilst the Parish Council understands healthcare is not a local authority responsibility it is a signifcant area of importance for all current or future residents. The nearest surgery, which is at Marston, is at capacity with a rapidly growing population. People expect and need local healthcare facilities. The example of Wixams is again relevant here. There must be no further housing development in or around Lidlington until after healthcare facilities are signifcantly expanded and other facilities can be guaranteed not simply speculatively laid out in plans. Insufcient Infrastructure The supplementary document states that the necessary supporting infrastructure can be provided. How much improvement of existing roads will be required if the village is to accommodate the trafc related to 5,000 additional dwellings and a business park? What detrimental impact will there be on being able to maintain Lidlington as a small rural community? These questions must be answered fully. The Parish Council cannot see any evidence, precedent or statutory statements that will prevent the landowners from saying they need more than 5,000 dwellings to meet the cost of infrastructure provision, leading to even further unjustifed development in the future. Based on recent history, there is no evidence of robust planning enforcement if developers do not meet the agreed delivery of infrastructure. The lack of proper Unitary Council legal powers to enforce the promises of developers leaves us sceptical that the Waterways plan is just a fanciful pipe-dream. This is of great concern and has the potential to propagate the current belief that planning is all pain and no gain. Impact on Village School and Education Provision The popularity of Thomas Johnson Lower School attracts pupils from a wide area. It is located in Hurst Grove which is a no through route. Many travel to the school on foot but also by car and on regular occasions there is heavy congestion at peak times. In view of the proposed Network Rail changes and consequent eradication of a safe pedestrian crossing direct to the school, combined with the proposal to increase housing signifcantly in the local area, this compounds and creates a number of issues. It will bring danger to the entrance route which in turn is a safety concern for both parents and local residents. There appears to have been no joined up thinking of how the school site could increase in capacity if more children are coming to the local area. There also seems to be a major gap around future educational provision in terms of how this will be managed during the proposed signifcant growth. There is no clear vision or structure for how school place provision in the growth period has been calculated or what number of children needing a school place has been set at. This means such uncertainty of how this will be delivered and if schools are built frst, last or whenever the developer may or may not feel like it, is not thought out properly Looking at Bedford Borough Council's calculations on Page 15 the Background Evidence Table of their recent Local Plan consultation document (June 2017) it shows from the samples taken 500 houses requires a one-form entry school to be created. This would mean each 1 of the new 4 villages being proposed would need a two-form entry school each. Who pays for the building of this, who ensures it is delivered at the right time, and that children from out of catchment do not fll it up so those moving into the area then have no local school to send their children to? This does not sound sustainable. Site Assessments (NLP 103, NLP370 and NLP482) The Parish Council’s objections to the plan necessarily focus on NLP 370 and the 5,000 homes because of the devastating impact this would have on Lidlington. However, the council is also very surprised and disappointed to see that sites NLP 103 and 482 put forward to the next stage. Planning permission has already been refused previously for these sites so following further consideration the council can again see no justifcation for taking them forward. Access to this site down a narrow lane bordering land owned by Network Rail and potentially earmarked for EWR upgrade is not feasible and again lacks any joined-up thinking. The proposal for 65 dwellings for the 2 sites is completely unworkable. Not only are there access problems but the infrastructure in terms of roads, healthcare, and public transport is simply inadequate. The assessment of these sites in section 21 is disingenuous to say the least. Since April 2016 a further 50+ dwellings are either underway or planned making the real current growth >10%. We also cannot agree with the NLP370 site assessment that “The majority of the site is classifed as non-agricultural and is former clay working for the brick industry.” this claim is a fabrication, along with the assertion that Lidlington has a frequent bus service. Site NLP370 is far too large for Central Bedfordshire, and the Public to make reasoned judgements, it MUST be withdrawn from the plan in the current form Risks and Opportunities Central Bedfordshire has failed to take a balanced risk and opportunities approach to the plan. In particular the omission of Tempsford to settle it’s duty to the environment by including a signifcant BROWNFIELD site in plan. Tempsford excellent CURRENT connectivity with it’s mainline railway and major road network into London have been ignored, focusing instead on the common issue of lack of “Ox-Bridge arc” infrastructure. In order to future proof the plan, Electric Vehicles must be a key consideration. Current battery technology only provides 50-90 miles round trip range with certainty. Thus sites NLP370 and NLP463 would only be of use to Milton Keynes commuters. The delivery of an Expressway will not make Cambridge or Oxford signifcantly closer. New residents are always keen to commute via a MAINLINE TRAIN STATION. Capacity constraints on the BRANCHLINE between Bletchley and Bedford must therefore dismiss this as a realistic major transport option from the plan. Given the acknowledged difculties at the M1 Junction 13, this points to an obvious preference for the Aspley Guise Triangle (site NLP463) as a commute to Milton Keynes from that side of the M1 does not need to battle through this troublesome junction. The inclusion of NLP463 in addition to well cascaded development of NLP370 is the only realistic method of securing end to end DELIVERY of the Grand Union to Bedford canal. Furthermore there is less risk of a Carillion style failure, by using three sites instead of one. Developers will very quickly backtrack on their commitments during the next economic downturn. The use of proper project phasing where the developers only unlock their next tranche of profts ”cascade” by meeting previous obligations to the public. There must not be a continual repetition of the Wixhams MAINLINE station fasco. Conclusion The Local Plan Pre-Submission overview for homes, states - Aspley Guise Triangle and Tempsford are not included by CBC planners as they say :- “We believe these locations do have potential for growth but, as we said in the previous consultation, they are dependent on critical infrastructure (e.g. East- West Rail) to support them and you agreed with us in your feedback” They justify NLP370 - the annihilation of Lidlington as a rural parish, simply by ignoring their own observations.

In summary the Parish Council have set out signifcant reasons to demonstrate why the Plan is not sound and why the parish of Lidlington is not suitable for 5,000+ houses, whether termed a “set of villages” or indeed more appropriately collectively a “small town”. This evidence clearly shows that Lidlington’s classifcation as a small village will be violated as part of the local authority strategy.

The Parish Council further believes that it has demonstrated that such an overwhelming development so closely situated to Lidlington is against the Council's own current, recently reviewed, planning policy statements.

Yours sincerely

E. Barnicoat Lidlington Parish Clerk