Central Bedfordshire Pre‐Submission Local Plan 2035 Consultation Land east of Leighton Road, Toddington
February 2018
Contents
1. Introduction 3
2. Response to Local Plan ‐ Strategy and Housing Numbers 4
3. Response to Local Plan – Site Specific 12
4. Response to Local Plan – Development Management Policies 29
5. Conclusion 40
Appendix 1: Site Location Plan 42
Appendix 2: Landscape & Visual Appraisal 43
David Wetherill
Client Taylor Wimpey UK Ltd Our reference TAYR3035
February 2018
1. Introduction
1.1 These representations have been prepared by Turley on behalf of Taylor Wimpey UK Ltd in respect of the Central Bedfordshire Pre‐Submission Local Plan 2015‐2035 consultation (January 2018).
1.2 Our client has important land interests in the Local Plan area, in particular at Toddington. As such this response focuses on issues particularly affecting Toddington.
1.3 Each of our responses relates to a particular policy or paragraph and this report is structured accordingly.
1.4 We can confirm we wish to appear at the Examination in Public in due course and look forward to continuing to engage with the Local Plan process.
2. Response to Local Plan ‐ Strategy and Housing Numbers
Chapter 2: Key Themes
Objectively Assessed Need 2.1 The Local Plan has been informed by the Luton and Central Bedfordshire SHMA (December 2017) which calculates the full Objectively Assessed need (OAN) for housing in Central Bedfordshire to be 31,778 dwellings over the period 2015 to 2035 (1,589dpa). For Luton the OAN is calculated to be 18,810 dwellings over the Plan period (940dpa).
2.2 The Government published a draft new standardised methodology for calculating housing need in September 2017. Applying this methodology would result in a significant increase of 60% in the number of homes that would be required to be delivered (1,589dpa – 2,553dpa) to meet just Central Bedfordshire’s own housing need. The consultation documents made clear that Plans submitted before the end of March 2018, or prior to the publication of the NPPF (whichever is the later) could continue to be prepared on the basis of previous OAN assessments. Plans submitted after this time would need to be prepared in accordance with standardised methodology in its final form.
2.3 The Council’s Local Development Scheme (December 2017) confirms the Council’s intention to submit the Plan in March 2018 and in this scenario the calculation of housing need will fall under the old methodology (1,589dpa). Whilst the timetable for the publication of the NPPF has been delayed, with this now scheduled for summer 2018 with the ‘cut off’ point for submission of Plan’s under the old OAN methodology delayed accordingly, it is understood that the Council intend to continue with its current stated programme.
2.4 In light of the above, the Council have proceeded with the preparation of the Local Plan on the basis of the OAN proposed in the SHMA of 31,778 dwellings over the plan period to 2035. The overall housing target proposed by the Local Plan is 39,350 dwellings, including 23,528 homes that are already planned for or built and a proportion of ‘unmet housing need’ from Luton.
2.5 In respect of the new standardised methodology, the Local Plan at paragraph 1.4.1 states that:
“The Council consider that while the OAN is likely to rise over time further work is needed on factors specific to Central Bedfordshire before a new approach can be supported and is looking to commission additional studies for the relevant Housing Market Area, together with neighbouring authorities.”
2.6 There is an apparent reliance on an early review by Central Bedfordshire as part of the Local Plan preparation to account for a number of changing circumstances that are already anticipated towards the start of the plan period.
2.7 The background to these ‘changing circumstances’ relates to planned infrastructure improvements, including East West Rail/Expressway. Paragraph 5.5.4 of the Local Plan states:
“The Partial Review is proposed to start within six months of adoption of this Plan and complete as soon as decisions on routeing and financial commitment to strategic infrastructure are in place.”
2.8 Whilst we have no objection to the principle of a commitment to an early review of the Local Plan, an approach which has now been accepted in a number of Local Plans, it is important that where decisions can be reached under the current Local Plan process they are not artificially pushed‐back to a future review. We recognise the challenges, and significant opportunities, represented by the Cambridge‐Milton Keynes‐Oxford Arc and support the recognition that the Council needs to respond positively to this. In considering the Arc it is important that Central Bedfordshire also considers the opportunities and challenges faced by both neighbouring authorities and those located in the wider Arc. At this time it is unclear what form any strategic governance arrangement for the Arc would take, although it is noted that the Oxfordshire authorities have secured a growth deal and will be preparing a Joint Spatial Plan which will inform the separate Local Plans for each authority. It is important that the Council therefore consider the wider relationships.
2.9 As a justification for ‘changing circumstances’, whilst the Council refer to planned infrastructure improvements in paragraph 5.5.4, no reference is made to the further implications of the new standardised methodology. Assuming the methodology as originally consulted upon is implemented, the new methodology would lead to a 60% increase in the number of homes that would be required to be delivered per annum for Central Bedfordshire ‐ in addition to any unmet housing needs from the neighbouring authorities such as Luton (set to increase from 890 to 1,417dpa) which it agreed to accommodate. This is a significant increase for both authorities over the plan period, and one which both authorities should be alive to as part of this Local Plan preparation process.
2.10 At present the Council are adopting a cautionary approach to need. It is important that there is flexibility for the towns and villages to accommodate additional development where needed and appropriate, in order to ensure the “continuous delivery of homes in the short to medium term and enable the Council to maintain a rolling 5 year housing land supply” (paragraph 5.3.1). Whilst the Council considers that it is proposing to allocate sufficient sites in the Local Plan to meet the OAN as identified in the SHMA, given the inevitability that the Council’s housing requirement will increase, where sites are shown to be suitable and deliverable, there is no justification as to why these sites should not be allocated through the current Local Plan process. Indeed, given the scale of some of the proposed allocations, with their associated longer lead‐in times, it is important that a range of sites are proposed to ensure delivery across the Plan period.
2.11 Whilst we support the Council’s commitment to undertaking a Green Belt review as part of its new Local Plan, it is important to recognise the requirements of paragraph 85 of the NPPF. As such, in reviewing the Green Belt boundaries the Council must
consider not only the current proposed Local Plan requirements but also the need to meet longer‐term development needs stretching well beyond the plan period.
2.12 On the basis of the current draft Local Plan, concern is raised that adequate assessment has not taken place to assess the potential of sites to meet longer term needs. As such it is anticipated that further Green Belt release will be required under the Local Plan partial review and the boundaries subject to further review and amendment, contrary to the requirements of the NPPF. Where sites are shown to be appropriate for Green Belt release, suitable and achievable, the Local Plan should be looking to allocate these sites at this stage either as full allocations for development or safeguarded sites to meet future needs.
2.13 Clearly, the implications of the new standardised methodology will be significant. For example a 60% increase in the number of homes that would be required to be delivered per annum for Central Bedfordshire ‐ in addition to any unmet housing needs from the neighbouring authorities such as Luton (set to increase from 890 to 1,417dpa). The draft Local Plan rightly focuses the “delivery...of some unmet need from Luton close to where it arises”. No provision has been made as to how future needs could be met, particularly in the “South Area” closest to Luton, which is contrary to the requirements of the Framework.
Duty to Cooperate and Unmet Needs 2.14 There is an acknowledgement of the relationship the authority has with the wider area and the need to both meet the requirements of the Duty to Cooperate, and to fully address the challenges and opportunities which the area faces, particularly in light of its strategic position at the heart of the Cambridge‐Milton Keynes‐Oxford Arc as discussed above.
2.15 Whilst the SHMA itself covers the authority areas of Luton and Central Bedfordshire, it is important to note that Central Bedfordshire is in fact split across four functional Housing Market Areas (HMA). The largest number of Central Bedfordshire residents live in the Luton functional HMA. Almost 99% of the resident population currently living in the Luton housing market area were identified to live in either Luton Borough or Central Bedfordshire.
2.16 The SHMA (December 2017) apportions the joint OAN across the four HMAs as identified on the diagram below.
2.17 Clearly Central Bedfordshire has a strong functional relationship with Luton Borough in particular. It is noted that Central Bedfordshire Council withdrew its draft Development Strategy in 2015, due to the failure to comply with the duty to co‐operate in respect of Luton Borough Council and the proposed allocations to meet its needs. North Hertfordshire has agreed to provide 2,100 dwellings to help meet Luton's housing need by 2031. Other neighbouring authorities such as St Albans and Stevenage are severely constrained in terms of capacity, and therefore their ability to assist in meeting Luton’s unmet needs is limited. The Plan identifies that through Duty to Co‐operate discussions, Central Bedfordshire Council has agreed to provide for 7,350 homes within Central Bedfordshire within the Luton HMA. We support the proposals to help meet Luton Borough Council’s unmet needs.
2.18 Central Bedfordshire is one of the most accessible areas in the East of England and the wider region given its rail and road links. Central Bedfordshire is well placed to contribute towards meeting this unmet need, given its close relationship with Luton.
2.19 Whilst we support the commitment to assist in meeting the unmet needs of Luton Borough, it is important that discussions continue with other neighbouring authorities in accordance with the duty to cooperate. The majority of the neighbouring authorities to Central Bedfordshire are also in the process of preparing new Local Plans, with these at various stages of completion. Discussions should continue with theses authorities on whether any unmet needs will arise from these authorities. This will be of particular importance in the Local Plan review assuming the standardised OAN methodology when brought in continues to identify a significant increase in the housing requirement for the authority.
Spatial Strategy 2.20 We welcome the acknowledgement that there is a need to provide for a range of forms and scales of new development to meet the identified needs including growth at existing settlements and provision for large scale new communities.
2.21 The Spatial Strategy is outlined in Chapter 5 of the Local Plan. Of the five growth scenarios that have been tested through the Sustainability Appraisal, the Spatial Strategy appears to broadly follow scenario 1 in terms of distribution (growth spread across all of Central Bedfordshire). However as discussed above, we consider that there are additional opportunities available which could be secured in order to meet the anticipated future growth and ensure that the plan is ‘positively prepared’.
2.22 The background to the Spatial Strategy is outlined in Section 5.3 (A Balanced Strategy), which states:
“This strategy aims to balance wider delivery and sustainability considerations within this overall approach:
The delivery of small and medium scale growth alongside the strategic locations will ensure the continuous delivery of homes in the short to medium term and enable the Council to maintain a rolling 5 year housing land supply
A balance between more moderate development around existing towns and villages and large new settlements, recognising that an entirely new community takes longer to deliver and needs entirely new services
Green Belt continues to be a constraint in the south of the area but there is a strong case for alterations to green belt boundaries immediately adjoining Luton so that a good proportion of unmet housing need from Luton and Dunstable can be met close to where it arises;
A balance between growth in the north and south of the area supported by evidence in the Sustainability Appraisal (SA). In addition to alleviating the cumulative impact of development on the north by distributing the growth more evenly, the SA also supports growth in the south by virtue of the clear positive effects on social sustainability as a result of regenerating areas with higher levels of social deprivation.”
2.23 In terms of growth distribution, we support the proposed spatial strategy which reflects the importance of the delivery of small and medium scale growth alongside the strategic locations, and the importance of considering Green Belt land close to Luton where the unmet need arises. We consider the merits of the proposed allocation of our client’s site in full in Section Three of this Statement.
2.24 Regarding the approach to distribution of Luton’s unmet need, the Spatial Strategy Approach is outlined in Section 5.4. The final bullet point is of particular note, which reads:
“This Plan seeks to….deliver housing need identified for the Luton HMA and some unmet need from Luton close to where it arises where there is capacity to do so sustainably. This will be through a strategic extension close to Luton’s urban edge and moderate extensions to existing villages and towns with good connectivity and access to services. This will mean releasing some Green Belt land where exceptional circumstances can be demonstrated.”
2.25 We support the approach of considering Green Belt land close to Luton or with good connectivity to it where the unmet need arises.
2.26 Given the likely scale of future growth in the authority, and the lack of any sites proposed to be safeguarded to meet this future growth, concern is raised that the proposed Green Belt boundaries will not meet the requirement to ‘be capable of enduring beyond the plan period’ (NPPF paragraph 85). Whilst it is recognised that some growth will be able to be accommodated in parts of the authority area not subject to Green Belt designation, given the sustainability of settlements in the southern area and its close functional relationship with Luton, it is considered that further releases will be required through the Local Plan Review if this does not take place through the current Local Plan.
2.27 The Plan period for Central Bedfordshire runs to 2035, however that for Luton (on which the scale of unmet need is based) only runs until 2031. The scale of Luton’s unmet need post‐2031 will therefore need to be determined through a review of Luton’s Local Plan. If further unmet need is identified, a subsequent review of Central Bedfordshire’s Local Plan will be likely (in addition to the partial review that the Council have committed to commence within 6 months of adoption). This would represent a piecemeal approach to potential future review of Green Belt boundaries.
2.28 The Local Plan proposes to commit the Council to commencing a partial review of the Local Plan within six months of adoption of this Plan. In terms of timescales for completion for the review, paragraph 5.5.4 of the Plan confirms the intention to “complete as soon as decisions on routeing and financial commitment to strategic infrastructure are in place” (Turley emphasis). Paragraph 5.5.3 states that the Review “will consider whether there is delivery potential for years 15‐20 (2030‐2035) for the current Plan period or whether this would fall in the next Plan period (Turley emphasis), given long lead times for these large sites.” Due to the uncertainties regarding the timing of the Partial Plan Review, which are outside of Central Bedfordshire’s control, sufficient flexibility should be built in to allow the Plan to respond to changing circumstances in order to make the Plan sound.
2.29 We consider the potential for our client’s site at land east of Leighton Road to assist in meeting these needs and providing further flexibility in Section Three of this Statement.
Chapter 6: The Proposed Locations for Growth
2.30 The draft Local Plan subdivides the authority into four sub‐areas. The Sustainability Appraisal (SA) which informs the draft Local Plan supports growth in Areas A, B and C as having ‘positive effects’ on housing delivery and employment. Whilst the SA identifies that development within Area A will require the release of Green Belt, it also
highlights that “such constraints have also restricted the opportunities for communities that can be associated with new development including new housing and supporting infrastructure.” As such whilst growth in Area A1 has an important role in meeting the needs of Luton Borough, it is also important in supporting the existing settlements within the sub‐area. This is reflected in the text contained within paragraph 5.3.1 (‘A Balanced Strategy’).
2.31 Whilst other sub‐areas in the authority, which are not subject to Green Belt designation, have received growth recently through speculative developments, this has not been the case in the South Area. As such the importance of allocating development within the South Area is enhanced to ensure growth is allowed to support the existing communities and meet their needs, and we welcome the approach to sharing the distribution of growth.
Proposed Allocations
2.32 The following Allocations are proposed within the ‘South Area’ for housing:
• Strategic Allocations: North of Luton – around 4,000 homes
• Small and Medium Allocations: Extensions to Barton le Clay, Chalton, Eaton Bray, Flitwick, Harlington, Hockliffe, Houghton Regis, Leighton Linslade, Luton (Caddington parish), Toddington and Westoning.
2.33 Given the longer lead‐in times associated with the delivery of strategic allocations, we support the recognition of the need to plan for extensions to larger towns and villages within the Green Belt. As recognised in paragraph 5.3.1 this will “ensure the continuous delivery of homes in the short to medium term and enable the Council to maintain a rolling 5 year housing land supply”. We support the proposed allocation of Land East of Leighton Road (HAS49) Toddington. We consider the merits of our client’s site as a potential extension to the existing proposed allocation in Section Three of this Statement.
Proposed Identified Locations for Future Growth
2.34 Whilst the Council has identified a series of Locations for Future Growth as part of the Partial Plan Review, relating to future infrastructure provision (CB PLP, paragraph 5.5.3) these relate to large strategic sites only. Given the anticipated scale of future needs it is anticipated that further allocations at all scales will be necessary.
2.35 Within the ‘South Area’ the only proposed location for future growth identified is Land West of Luton for around 2,000 homes.
2.36 We support the focus on the “South Area”, to “alleviate the cumulative impact of development on the north by distributing the growth more evenly” (paragraph 5.3.1).
2.37 Whilst we have not reviewed the proposals for Land West of Luton, it is important that these are seen in the context of the “London Luton Airport Vision for Sustainable
1 Referred to as the ‘South Area’ in the draft Local Plan
Growth 2020‐2050”. This document considers increasing existing runway capacity, to in the region of 240,000 aircraft movements per year.
2.38 The increase in existing runway capacity could have as yet unquantified amenity implications for Land West of Luton, and we understand that uncertainty over the nature of potential impacts led the Council to only identify the site as a ‘Location for Future Growth’ rather than as an ‘Allocation’.
2.39 In the context of such uncertainty, and in order for the Council to “alleviate the cumulative impact of development on the north by distributing the growth more evenly” it is important that the Council also consider other opportunities for growth. As discussed above, the exact quantum of development which the Plan will be required to plan for is at this stage unknown so it is important that there is flexibility for the towns and villages to accommodate additional development where needed and appropriate. We consider the suitability of our client’s site to meet these needs in Section Three of this Statement.
Chapter 9: Green Belt, Coalescence and Settlements
2.40 The Central Bedfordshire Green Belt extends across approximately 40% of the Plan area. Importantly the area covered is that which most closely relates to Luton which the Plan area has a close functional relationship with. We support the Council’s recognition of the need to release Green Belt. These releases are required both to meet the unmet needs of Luton Borough which the authority has committed to meeting, but also to meet its own needs and support its existing communities. As highlighted above, it is important that in considering revisions to the Green Belt boundaries the Council looks beyond the current Plan period. We consider the suitability of our client’s site at Toddington for release from the Green Belt as an extension to the existing proposed allocation at Land east of Leighton Road (HAS49) at Section Three of this Statement.
3. Response to Local Plan – Site Specific
3.1 Our client’s landholding at ‘Land east of Leighton Road, Toddington’ comprises 4.4 hectares of land. The site is comprised of two pastoral fields with a landscape framework of field boundary hedgerows and tree belts.
3.2 The site adjoins the proposed allocation of site HAS49, Land East of Leighton Road, which would extend the settlement boundary of Toddington to immediately adjoin our client’s site to the north. The Site lies north of Dunstable and northeast of Leighton Buzzard, approximately 6.5km and 8.7km respectively. The site is located in Flood Zone 1, which is the lowest category of flood risk. The site currently lies wholly within the Green Belt.
3.3 To the north west, the site is bound by Leighton Road, which joins Harlington Road within Toddington, leading to junction 12 of the M1 to the northeast. To the south, Leighton Road becomes Toddington Road joining Watling Street (A5) to the southwest of Toddington.
3.4 To the southwest, the site is bound by a pair of agricultural fields, with a tree belt on their south western boundary, and further agricultural fields beyond.
3.5 To the southeast, the site is bound by a wedge‐shaped tree belt, the eastern side of which follows the edge of a small watercourse, with an irregularly shaped arable field, and a recent housing development at Randall Close and some allotments further to the east.
3.6 The site is visually well contained by the network of boundary hedgerows and tree belts. The majority of existing landscape features on the site including the hedgerows, tree belt and individual trees have the potential to be retained in development proposals. Enhancement planting to the southern site boundary will help to provide a strong defensible boundary to the Green Belt in this location.
3.7 We support the proposed allocation of Land East of Leighton Road (HAS49) for approximately 92 dwellings. It is considered the allocation recognises the sustainability of Toddington as a whole as a location to support growth and meet the identified needs for residential development, and more specifically recognises the suitability of land south of Toddington to accommodate this growth. It is considered that our client’s landholding should be included as part of an extended allocation at HAS49. The Council have recognised that the need for housing in the area will continue to increase and have committed to an early review of the Local Plan to address this. Should the Council conclude the site is not required to meet current identified needs, it should in any event be removed from the Green Belt and safeguarded to meet future needs.
3.8 We consider the Council’s assessment of the site through its evidence base below. In summary no constraints to the principle of development of the site are identified. The site is now under the under control of our client Taylor Wimpey who are committed to bringing forward the site to meet housing needs.
Chapter 10: Settlement Envelopes and Settlement Hierarchy –Toddington
3.9 Toddington is identified as a Minor Service Centre in the Council’s settlement hierarchy, inset from the Green Belt. Minor Service Centres are the second tier of settlements. They are recognised in Draft Local Plan Policy SP7, alongside Major Service Centres, as being locations where “the Council will support housing, employment and other settlement related development proportionate to the scale of the settlement, taking account of its role as a local service centre.”
3.10 It is understood that the settlement hierarchy has been informed by the Initial Settlements Capacity Study (May 2017) which was prepared in support of the previous round of consultation on the Local Plan. The Study has undertaken an assessment of the overall sustainability of settlements within Central Bedfordshire. The study concluded that Toddington has medium capacity for accommodating additional development.
3.11 The location was one of the 34 settlements that were considered in the study. The majority of settlements were considered to have a low capacity, with only 9 settlements with medium or high capacity (assuming Green Belt release). Toddington was one of the few settlements found to have medium capacity.
3.12 Following this the study then considered 5 locations with the highest capacity for growth in Area A, when considering Green Belt settlements with railway connections. As Toddington is only 3km to a mainline rail connection (at Harlington), it was selected as one of the 5 settlements with the highest capacity for growth.
3.13 The supporting text to the policy advises that the hierarchy “helps to provide a framework for considering the levels of new development to be directed through the Development Management process.” Whilst we support the recognition that the higher tiers of settlements are capable of accommodating a commensurately higher proportion of development, we would highlight that this approach should be applied both to the plan making process as well as the Development Management process.
3.14 We agree that Toddington is a sustainable location, and that there are no significant constraints to the capacity of the settlement to accommodate additional development. Accordingly the settlement should be a focus of sustainable growth. We are supportive of the recognition that Toddington comprises one of the more sustainable settlements in the authority area. Whilst this has been partially recognised through the allocations of sites HAS49 and HAS50, it is not considered that this has been fully reflected in the approach to the potential for allocation of sites for development at the settlement, given that only the north‐eastern part of the site is proposed for allocation. It is considered that the proposals for development of the wider site to the east of Leighton Road represent an important opportunity to support the existing community and its facilities.
Green Belt
3.15 We support the Council’s recognition of the need for Green Belt release. The Council has clearly demonstrated the exceptional circumstances which it considers justify the release of some Green Belt land. Paragraph 8.3.2 of the Local Plan advises that:
“These villages are well‐placed to make a contribution to meeting wider housing need and, in many cases; development could help to improve the sustainability of the villages. Green Belt release has been guided by the principle of creating ‘sustainable patterns of development’ as per NPPF paragraph 84. This means that we have sought to identify the most sustainable locations for development, having regard to the overall integrity and performance of the wider Green Belt.”
3.16 As discussed above, Toddington is identified by the Council as a Minor Service Centre, the second tier of settlements, with Toddington found to be one of the few settlements found to have medium capacity in the Initial Settlements Capacity Study (May 2017). The Council should therefore give careful consideration to the potential for growth to be accommodated at Toddington.
3.17 Furthermore paragraph 83 of the NPPF makes clear that:
“Local planning authorities with Green Belts in their areas should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”
3.18 The Council recognises that the OAN is likely to rise over time from the currently proposed Plan target of 39,350 homes, particularly in light of the Government’s proposed standardised OAN methodology. Furthermore the Council have committed to undertake a Partial Plan Review which is due to commence within six months of the adoption of the Local Plan. The Review will consider the implications and opportunities presented by the Cambridge‐Milton Keynes‐Oxford Arc. It is clear therefore that further growth will need to be accommodated within the authority area, and that this is likely to be within the current Local Plan period as a result of increased needs as well as beyond the Plan period. It is therefore important that the Council considers future growth requirements when considering the release of Green Belt. In this regard Paragraph 85 of the NPPF makes clear that potential locations for land to be safeguarded for future development should be considered.
3.19 We consider the process through which the Council has assessed the potential for the release of our client’s site at Toddington from the Green Belt below.
Toddington Green Belt Review 3.20 The site was assessed in the Central Bedfordshire and Luton Stage 1 and 2 Green Belt Study (November 2016) as part of a wider land parcel (T4) as shown on the plan below.
3.21 In assessing parcel T4, the assessment reached the following conclusions:
Council’s Turley Comment Turley Assessment Assessment Purpose 1 – Weak / No We agree with the Council’s conclusion in Weak / No Check the contribution respect of this purpose. Contribution unrestricted sprawl of large built‐ up areas Purpose 2 – Weak / No We agree with the Council’s conclusion in Weak / No Prevent contribution respect of this purpose. Contribution neighbouring towns merging into one another Purpose 3 – Moderate As highlighted by the Council in table 4.3, Weak / No Assist in contribution almost all parcels contribute to this Contribution safeguarding purpose to a greater or lesser extent. the Contrary to the Council’s assessment, it is countryside considered that the site has a close from relationship with the existing settlement encroachme of Toddington. It should be noted that the nt assessment considered a much larger site, and so issues of encroachment will be less with the proposed site.
We would also contend that southern encroachment has already occurred along the Dunstable Road and we would not be proposing to extend settlement limits beyond this. To assist, existing boundaries of the site will be reinforced to provide a
defensible boundary to the proposed development. Purpose 4 – Weak / no We agree with the Council’s conclusion in Weak / No Preserve the contribution respect of this purpose. Contribution setting and special character of historic towns
3.22 Given the above, we disagree with the Study’s conclusion that the site assists in safeguarding the countryside from encroachment, and we consider the site to be the most appropriate location for growth around the settlement.
3.23 The site was taken forward for assessment in the Central Bedfordshire Stage 3 Green Belt Study (January 2018). The conclusions of the assessment of the potential sites around Toddington are shown below.
3.24 The sites have been assessed as both individual parcels and in various combinations to inform the site selection process. We note that both the Alma Farm site (HAS50 – NLP411) and parts of Land east of Leighton Road (HAS49 – ALP086, ALP184, NLP153, NLP152) are identified as having moderate harm to the Green Belt. This conclusion is also applicable to the Council’s assessment of our client’s site as part of site reference NLP378c as shown on the plan below.
3.25 We consider the conclusions of the Council’s assessment in respect of site NLP378c below:
Purpose Council Assessment Turley Assessment 1: Checking the Any development in this area We agree with the Council’s unrestricted would be associated with conclusion on this purpose. The sprawl of large, Toddington, and not the large suitability of land to the south of built up areas built up area of Dunstable / Toddington to accommodate Luton / Houghton Regis to the development has been accepted south. by the Council and we consider the additional land parcels under our client’s control would form a logical extension to this. The inclusion of the additional field parcels controlled by our client would create a more robust and defensible boundary to the Green Belt than would be achieved through the current allocation. 2: Preventing The parcel makes no significant We agree with the Council’s the merger of contribution to settlement gaps. conclusion. neighbouring towns 3: Safeguarding A woodland block forms the The Council have acknowledged the countryside northern part of the parcel, the need for Green Belt release from creating strong separation and recognised Toddington as a between the western half of the suitable location to
encroachment parcel and the urban area accommodate some of its together with parcel NLP378. development needs. The However, the parcel is part of an necessity of development area of pastoral farmland that is encroaching into the Green Belt also fairly contained within its has therefore been accepted and wider context, with Leighton acknowledged by the Council. Road to the west, a woodland belt to the south and the settlement edge of Toddington along the A5120 Dunstable Road to the east. Any new development within this parcel would constitute a moderate degree of encroachment on the countryside. 4: Preserving The parcel does not form a We support the Council’s the setting and significant part of the setting of conclusion. special any historic towns. character of historic towns 5: Assisting All parcels make an equally We agree with the Council’s urban significant contribution to this conclusion. regeneration by purpose. encouraging the recycling of derelict and other urban land
3.26 Overall the Council’s Assessment concludes:
“This parcel is free of urban development and is in part separated from the urban edge by woodland. However its size and its location within an area that has relatively strong separation from the wider countryside limits the Green Belt harm that would result from its release, even though that release would weaken the contribution of adjacent fields. Were the parcel to be released, there would be little justification for retaining the Green Belt status of land between it and the settlement edge (NLP378a and NLP378b).”
3.27 We support the proposed allocation of Land east of Leighton Road, Toddington and consider it to be a suitable location for Green Belt release as outlined above. Given the conclusions of the Green Belt Assessment are also applicable to the additional field parcels to the south of the proposed allocation, which also formed part of area LP378c, there is no apparent justification for these parcels to not also be released from the Green Belt.
3.28 Whilst the Council considers that it is proposing the allocation of sufficient sites under the Local Plan to meet its current proposed housing target, it is notable that the
Council recognise that the housing requirement will increase and that it is imperative in order for the Plan to be consistent with national policy, and therefore to be found sound, that the Green Belt boundaries also consider the needs for beyond the Plan period. The Council has itself recognised the suitability of land south of Toddington for Green Belt release for development through the existing proposed allocation to the east of Leighton Road. In light of the above conclusions in respect of the sustainability of Toddington and the conclusions of the Green Belt Assessment, we consider that further consideration should be given to the release of the whole site for development, including the additional field parcels under the control of our client.
Strategic Housing Land Availability Assessment (January 2018) 3.29 As shown on the plan below, the assessment of the site in the SHLAA (2018) has been split across a number of separate sub‐parcels.
3.30 The field parcels controlled by Taylor Wimpey were assessed in the SHLAA under site reference NLP378. Parcel NLP378 is concluded to have failed the assessment. The SHLAA note that parcel ‘NLP378’ failed the assessment as the “landowner is not intent to develop”. Clearly given the involvement of our client Taylor Wimpey, this conclusion is no longer accurate. The reason to fail ‘NLP378’ is therefore no longer relevant.
3.31 It is notable that no overarching assessment has been made in the SHLAA of the potential for the parcels to form a comprehensive development. As such it is not considered that the SHLAA has given appropriate consideration to the development
potential of our client’s site as part of a wider development site, given the piecemeal nature of the assessment.
3.32 We therefore encourage the Council to allocate the whole of ‘Land east of Leighton Road’ for residential development in the Local Plan 2035.
Luton HMA Growth Options Study 3.33 The Council’s Luton HMA Growth Options Study (July 2017) has assessed a series of growth locations within the Luton HMA, including the part that falls within the administrative area of Central Bedfordshire. The site was one of the 32 locations that were considered in the study, albeit considered as a part of a larger site (L13) as shown on the plan below. The wider was assessed for the potential to deliver a new settlement / large village extension.
3.34 We note that our client’s site was identified as a “missing site”, e.g. a site which has not been promoted. Given the involvement of Taylor Wimpey in respect of the site now, we can confirm the deliverability of the site.
3.35 The identification of the 32 sites followed a sieving exercise to remove sites that were situated within areas of primary constraint or could not be grouped to form larger strategic options. The assessment concluded that the overall site had an overall
deliverability of medium and was subject to only 8 secondary constraints (of a total of 17). The secondary constraints identified are as follows:
• Listed Building
• Conservation Area
• Priority Habitat Inventory
• Locally Designated Wildlife Site
• Locally Identified Sensitive Landscape
• Grade 1, 2 or 3 agricultural land
• Surface water flooding (1:100)
• Publically accessible open space
3.36 We consider each of these constraints in turn below. In summary it is considered that the matters identified do not represent in principle constraints to development of our client’s site and that, where the constraints are applicable to our client’s site, the matters raised can be satisfactorily addressed through the design of the proposals.
Figure 3.1: centralbedfordshire.gov.uk
3.37 With reference to Conservation Areas, Toddington Conservation Area is located in the centre of the settlement (as outlined in brown in fig 3.1). The majority of Listed Buildings are located within this Conservation Area, with one located to the north‐west of the site (fig 3.2). We therefore do not consider that the location of Conservation Areas or Listed Buildings represent a constraint to the development of the site. Indeed it is notable that the proposed allocation at Alma Farm is located in closer proximity to the listed building to the north west of our site.
Figure 3.2: magic.gov.uk
3.38 With reference to Priority Habitat Inventory and Locally Designated Wildlife Sites, it is noted that Dropshort Marsh is located to the south of the site. According to the Council’s website, this is designated as an SSSI, County Wildlife Site and Trust Nature Reserve. As more detailed proposals for the site are developed, these will be accompanied by a more detailed ecology strategy for the site. These designations are not considered to represent a constraint to development of the site.
3.39 The Growth Options Study identifies the site as a Locally Identified Sensitive Landscape. No such designation is shown on the Council’s draft Local Plan proposals maps.
Figure 3.3: Central Bedfordshire Proposed Submission Policies Map
3.40 The Council have undertaken a Landscape Character Assessment which divides the authority into 38 landscape character areas. The site falls within Hichcliffe Clay Hills (Category 8A). The Assessment does not define areas which are formed of especially
sensitive landscapes and is an evidence base document to form policy and not policy in itself. It is unclear therefore on what basis the Council has asserted that the site is a Locally Identified Sensitive Landscape, and we understand that this may be reference to policy in the previous South Bedfordshire Local Plan as the draft plan does not include specific landscape designations. These conclusions are equally applicable to the land proposed to be allocated under site HAS49.
3.41 In any event it is considered that the development of the site would not have a detrimental impact on landscape. A Landscape & Visual Appraisal which considers both the current proposed allocation site (HAS49) and our client’s landholdings is enclosed at Appendix 2, produced by CSA Environmental. This appraisal concluded that the wider site is visually well contained by the network of boundary hedgerows and tree belts, and the majority of existing landscaping features on the site including the hedgerows, tree belt and individual trees have the potential to be retained. The south western boundary of the site will be reinforced and enhanced to provide a defensible boundary to the proposed development, as recommended by the findings of the Landscape & Visual Appraisal.
3.42 In terms of publically accessible open space, it is noted from the Council’s website that “small amenity space”, “large recreation space” and “allotments” are located to the east of the site. Given they fall outside of the site, the proposals do not result in the loss of this open space. Furthermore the development has the potential to supplement this provision. Therefore this is not considered to be a constraint to development.
3.43 The Natural England Agricultural Land Classification Maps identify the site as being comprised of Grade 3 agricultural land, which is ”good to moderate”. This is comparable with much of the agricultural land in the authority area. The Council has recognised that as a result of its OAN, it will need to release some greenfield land for development and this will inevitably lead to the loss of some Grade 3 agricultural land given the nature of the authority area. Indeed it is notable that this conclusion is equally applicable to the land proposed to be allocated under site HAS49.
Figure 3.4: naturalengland.org.uk
3.44 There is a watercourse running along the south‐eastern boundary. However the site is entirely located in flood zone 1 and is therefore subject to the lowest probability of
flooding. Whilst, as identified by the Council, there are areas at risk of surface water flooding within the site, these are only on parts of the site as shown on figure 3.5 below, following the route of the watercourse. As more detailed proposals for the site are developed, these will be accompanied by a more detailed drainage strategy for the site. In any event, it is considered that the surface water flooding areas do not represent a constraint to development of the site and can be addressed through an appropriate drainage strategy in due course. Indeed it is notable that this conclusion is equally applicable to the land proposed to be allocated under site HAS49.
Figure 3.5: https://flood‐warning‐information.service.gov.uk/long‐term‐ flood‐risk/map
3.45 As is clear from the above, none of the constraints identified by the Council in respect of the wider assessment site of L13 represent in principle constraints to the development of our client’s site. Indeed it is noted that all of the conclusions reached are equally applicable to the proposed allocation site of HAS49 as our client’s site. The Council have themselves confirmed that these do not represent in principle constraints to development through the decision to propose the allocation of site HAS49. It is apparent that seemingly the only difference between the proposed allocation site and the additional land parcels promoted by our client, is that these were not promoted at the time of the earlier assessment and were noted as a “missing site.” The site is now under the control of Taylor Wimpey who are committed to bringing forward the site as an extension to the current proposed allocation.
Sustainability Appraisal 3.46 Land East of Leighton Road is included within Appendix VIIc: Non‐Strategic Site Options SA of the Council’s assessment of sites against the SA Framework. The proposed allocation is assessed under references NLP152, NLP153 and NLP184/ALP086. Our client’s landholdings are assessed under site reference NLP405/NLP378.
3.47 The conclusions of the Sustainability Appraisal in respect of the above four field parcels are set out below, together with our commentary.
SA Objectives NLP152 NLP153 NLP184/ NLP405/ Turley Comment ALP086 NLP378 1 Housing + + + + We agree with the Council’s conclusions. It is important that consideration is also given to the cumulative benefits associated with the increased quantum of development achievable as a result of the recommended increased allocation site. 2 Communities ‐ ‐ ‐ ‐ We have no comments on the Council’s conclusions. 0 0 0 0 3 Services & Facilities + + + + We have no comments on the Council’s conclusions. 4 Employment 0 0 0 0 We have no comments on the Council’s conclusions. 5 Health & Equality + + + + We have no comments on the Council’s conclusions. 6 Highways & Air Quality ‐? ‐? ‐? ‐? We have no comments on the Council’s conclusions. 7 Sustainable Transport ‐? ‐? ‐ ‐ It is noted that the site scores a comparable level of impact, although with a greater degree of certainty. It is not however considered that the parcel is significantly further from the nearest bus stop than the other parcels assessed and allocated. In addition, the SA concludes in the “Key positive effects” section that “all of the sites are well located in terms of accessibility to the settlement and its services, and could be accommodated without having major adverse effects on its character (given Toddington’s ‘Medium’ capacity to accommodate growth). Therefore the evidence presented in this regard is contradictory and does not justify the failure to allocate our client’s site. 8 Energy & Climate Change 0 0 0 0 We have no comments on the Council’s conclusions. 9 Water Resources & 0? 0? 0? 0? We have no comments on the Council’s conclusions. Quality
10 Flood Risk + + + +? It is unclear why the Council have identified greater uncertainty in respect of our client’s site than the other land parcels. The site is in flood zone 1 and development proposals for the site would be accompanied by a Flood Risk Assessment. The Council’s assessment of the site should be updated to reflect this and the scoring updated accordingly. 11 Soil ‐‐? ‐‐? ‐‐? ‐‐? We have no comments on the Council’s conclusions. 12 Biodiversity & ‐? ‐? ‐? ‐? We have no comments on the Council’s conclusions. Geodiversity 13 Landscape 0 0 0 0 We have no comments on the Council’s conclusions. 14 Historic Environment 0 0 0 ‐? Whilst the parcels which are proposed for allocation are considered to have a neutral impact against this objective, our client’s site is assessed as having a potential minor negative effect. Toddington Conservation Area is located in the centre of the settlement, and the majority of Listed Buildings are located within this Conservation Area, with one located to the north‐west of the site. Indeed it is noted that the Alma Farm site which is proposed for allocation and located in closer proximity to this outlying listed building is also assessed as having a neutral impact. Therefore it unclear why this parcel performs worse than parcels which are closer to these designations. The masterplan for the site will demonstrate that the proposals will not impact on the immediate or wider setting of heritage assets. The Council’s assessment of the site should be updated to reflect this and the scoring updated accordingly.
3.48 In summary, we support the proposed allocation of HAS49 for approximately 92 dwellings. The sustainability credentials of Toddington, and in particular land to the south of the settlement, to accommodate growth have been clearly demonstrated in the Sustainability Appraisal. From our review of the Sustainability Appraisal it is clear that there is no justification for the differences identified in the assessment of our client’s field parcels compared to those allocated by the Council. As such the assessment should be updated and our client’s site included as an extension to the existing proposed allocation. The increased quantum of development which would be achievable would make a proportionately greater contribution towards meeting housing needs and as such perform more strongly against the Sustainability Appraisal objectives.
Land east of Leighton Road – The Opportunity
3.49 Whilst we support the allocation of the northern parcel, we contend that this has potential to form part of a wider allocation. The Council have failed to robustly justify the exclusion of the south western parcel of ‘Land east of Leighton Road’ from the proposed allocation in Policy HA1. The exclusion of this parcel is contrary to the findings of the Council’s own evidence base, as discussed above.
3.50 From our detailed review of the Council’s evidence base it appears that the only apparent justification for the exclusion of the site from the proposed allocation is the lack of early promotion of the site. As is clearly demonstrated by the involvement of our client’s Taylor Wimpey in respect of the site, there is a commitment to bringing forward the site for development and this does not represent a reason not to allocate the site.
3.51 As previously highlighted it is important that the Council have due regard to the requirement of the NPPF to ensure that Green Belt boundaries are capable of enduring beyond the Plan period. The Council have themselves acknowledged that the housing requirement will increase and have committed to an early review of the Plan to seek to address this. We therefore encourage the Council to allocate the whole of ‘Land east of Leighton Road’ for residential development in the Local Plan 2035, or include the south western parcel as a safeguarded site to meet future needs without the need for Green Belt boundaries to be amended again.
3.52 The site represents a suitable location for a sustainable extension to Toddington. The exact number of dwellings to be provided will be determined at application stage, taking into account the constraints of the site.
3.53 The development will provide a mix of housing in line with national and local policy. A range of house types, sizes and tenures are envisaged in order to accommodate a variety of household types, integrating with existing infrastructure and facilities within Toddington.
3.54 The development will provide an appropriate transition between Toddington and the rural landscape to the south and west and will create a strong and defensible Green Belt boundary, creating a distinctive place which respects the existing landscape character. It is considered that the new Green Belt boundary capable of being achieved as a result of a wider allocation including our client’s field parcels, would be
stronger than that achievable based on the current allocation, particularly given the existing hedgerow along the southern boundary.
3.55 The site provides the opportunity to create a high‐quality, well‐designed residential development with a landscape‐led layout.
4. Response to Local Plan – Development Management Policies
H1: Housing Mix
4.1 Policy H1 sets out:
All developments for new dwellings must include a mix of housing types and sizes in order to meet the needs of all sections of the community, to encourage sustainable, inclusive and mixed communities.
Proposals should be accompanied by evidence which demonstrates the development meets these needse through th use of up to date evidence.
Housing should be delivered in various forms of tenure types, e.g. shared ownership, outright purchase, leasehold possibilities, affordable/private rented and other form of intermediate tenures.
4.2 Paragraph 2 of Policy H1 seeks developers to submit ‘up to date’ evidence to demonstrate needs are met through the proposed mix of housing within a development. However the soundness tests set out by the NPPF, seek that in order for the plan to be positively prepared it must meet objectively assessed needs.
4.3 The main evidence base for this policy is the Initial Strategic Housing Market Assessment (SHMA) for Luton and Bedfordshire published in 2017, which sets out the required housing mix for the area over the plan period to 2036. In line with paragraph 50 of the NPPF, local planning authorities should plan for a mix of housing based on current and future trends and it is considered that this has been objectively assessed through the SHMA.
4.4 Whilst a degree of flexibility in how developments seek to meet the need for a range of housing types is supported, the implementation of this policy is likely to lead to delays in the delivery of housing over the plan period due to the need for developers to submit information despite the policy being based on the up to date evidence in the SHMA. This would be contrary to paragraph 47 of the NPPF which seeks to ‘boost the supply of housing’, by ensuring local plans use their evidence base to meet objectively assessed needs in full over the plan period. Whilst the mix and type of housing required may change over the Plan period, and indeed will likely vary by location, it is considered that the Policy as currently worded is unduly onerous. Furthermore it is unclear how the Local Plan can be assessed in respect of its viability without guidance on the overarching housing mix which the Council will be seeking.
4.5 It is considered that Policy H1 has not been positively prepared, nor is it effective or consistent with national planning policy. It is suggested that it should be reworded to refer to the current SHMA mix as the broad mix requirement, or any subsequent updated version. Flexibility needs to be built into this policy, reflecting private and affordable housing requirements, and the need to future proof changing markets.
Policy H2: Housing Standards
4.6 The Policy seeks to introduce a requirement for the implementation of internal space standards in accordance with the optional Nationally Described Space Standards. In addition, the Policy seeks the provision of at least 35% of new homes as adaptable homes (Category 2 Requirement MA (2)) and at least 5% of new homes as wheelchair accessible homes (Category 3 Requirement M4 (3)).
4.7 In introducing the new national technical standards, the Written Ministerial Statement made clear that:
“The optional new technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance.”
4.8 From our review of the evidence base which purports to support this policy, it is clear that no evidence has been provided which seeks to justify the proposed implementation of these new standards. Whilst it is accepted that the provision of a proportion of adaptable or wheelchair accessible homes is likely to be justified on some larger developments, currently insufficient information is provided to justify the proportions of provision sought. Whilst the viability implications of the imposition of these standards has been assessed in the Central Bedfordshire Local Plan (2015‐2035) Viability Report (January 2018) this is insufficient to meet the requirements to allow the introduction of these standards without the necessary clearly evidenced need. As such this Policy requirement is currently considered to be unjustified and should be deleted.
Policy H3: Housing for Older People
4.9 Policy H3 identifies that all new residential development will be required to respond to the challenges relating to older people as set out in this chapter. The proposed policy sets out the following criteria that proposals must achieve:
• To consider the strategic aims of the Council, it is ensuring that mainstream housing, extra‐care homes and nursing care homes are provided throughout the Council area.
• To provide accommodation in suitable and sustainable locations, based on the latest evidence base, these are especially town centres, near transport links, services, and leisure and health facilities.
• To provide accommodation in various forms of tenure types, e.g. shared ownership, outright purchase, leasehold possibilities, affordable/private rented and other form of intermediate tenures.
• To ensure that properties are built to a good quality standard and meet the needs of older people as they progress through their life changes.
• To ensure that supported housing schemes provide the necessary care and support packages required.
• The Council will require the development of bungalows, level access accommodation or low density flats to be provided for older people on development of 100 dwellings or more.
• On larger sites of 200 units or more, the provision of an extra care facility should be investigated taking into consideration site viability and need. Where an extra care facility is not provided applicants must present evidence to support its exclusion from their proposals.
4.10 Policy H3 of the emerging plan seeks to ensure the delivery of housing for older people within all new developments in the authority area. Whilst there is expected to be a rise in the number of older people requiring housing, the NPPF requires that plans are positively prepared through objectively assessed development.
4.11 Whilst there is a suggested need for a total 9050 new dwellings for older to be delivered over the plan period, the strategy to meet this need through the inclusion within every development would not necessarily be the most appropriate method and national policy does not seek its delivery on every residential development site.
4.12 The final criteria of policy H3 seeks that an extra care facility is provided on sites of 200 dwellings or more, and where this is not provided applicants would be required to present evidence to supports its exclusion from their proposals. This does not align with national planning policy which seeks to boost the housing supply, as set out by paragraph 47, and that housing applications should be considered in the context of presumption in favour of sustainable development, paragraph 49.
4.13 The requirement for all sites above 200 homes to deliver an extra care facility on site does not appear to be based on delivering an objectively assessed target, and is not consistent with national planning policy. The proposed policy does not support paragraph 15 of the NPPF which seeks that development that is sustainable can be approved without delay, due to the requirement for detailed evidence to be submitted in regards to the provision of extra care facilities on every development site over 200 homes. Furthermore whilst it is recognised that extra care facilities make an important contribution to meeting the needs of older people, this will not meet all needs and desires of this element of the population. It is unclear whether the requirement for the extra care facility is an addition to the identified capacities in Policy HA1 or whether this requirement would reduce the capacity of these sites and then raise concerns regarding the deliverability of the overall housing requirement.
Policy H4: Affordable Housing
4.14 Policy H4 sets out:
All qualifying sites of 11 or more units or sites of 10 or less units which have a combined gross internal floor space in excess of 1,000 square metres subject to NPPG future revisions and future relevant case law will provide 30% affordable housing.
4.15 It is noted that the policy seeks to introduce flexibility to respond to changing circumstances when a more up to date version of the SHMA is published. Whilst such an approach is supported by paragraph 14 of the NPPF, it is noted that the previous SHMA did not provide advice on the proportion of affordable housing which the Local Plan should seek to achieve. The proposed 30% affordable housing requirement has therefore been led by the conclusions of the viability studies prepared in support of the Local Plan. We support the inclusion of the caveat that the proportion and mix of affordable housing to be provided is subject to viability considerations, which accords with the requirements of the NPPF.
4.16 We note that the policy goes onto state that:
Clusters of no more than 10 affordable units for houses and no more than 15 affordable units for flats on a case by case basis for larger sites.
4.17 Whilst the requirement for affordable housing units to be tenure blind is standard, concern is raised regarding the restrictive nature regarding the clustering of units. Flexibility should be allowed for clusters to exceed the 10 house or 15 flat restriction where this has been agreed with the relevant Registered Provider. The clustering of affordable housing units is generally a practical requirement for Registered Providers for management and maintenance reasons. The policy should allow a degree of flexibility in this regard.
Policy H6: Starter Homes
4.18 Policy H6 sets out:
All qualifying planning applications must have regard for Starter Homes delivery.
4.19 We support the fact that Starter Homes should form part of the Affordable Housing offer, to be determined on a site by site basis, with Central Bedfordshire Council exercising local discretion.
4.20 In the absence of the consultation on Housing White paper being concluded, the requirements are unknown. This policy would sit better within proposed policy H4 (Affordable Housing), in the absence of such detail.
Policy H7: Self and Custom Build Housing
4.21 The Council will require sites of 10 or more dwellings (excluding schemes for 100% flats or conversions) to provide serviced plots to meet demand evidenced by the Register. Up to 20% of the dwelling capacity of these qualifying sites will be required to be delivered as serviced plots.
4.22 Whilst the broad aspirations of the Policy are supported, concern is raised regarding the requirement that “up to 20% of the dwelling capacity will be required to be delivered”. As currently drafted the Policy is unreasonably onerous. This is due to the fact that the number of serviced plots required on larger sites would be unrealistic and disproportionately high. It is indeed questioned whether those seeking plots for self and custom build housing would in any event wish for these to be located on large
housing developments. Whilst it is noted that provision is made for the plots to revert to the developer where they remain unsold, concern is raised regarding the implications this may have for the timescales for delivery of developments and the associated increased costs with developers potentially having to revisit earlier phases in order to complete the dwellings.
4.23 We would also question the number of registered interested parties to the Council’s Self & Custom Build Register, and contend that the high quantity of provision aspired to in the Policy is not truly justified by the number of registered interested parties. We note that the Council’s update on the Custom and Self‐Build Register published in July 2017 confirmed that as of March 2017 147 people had registered and that this was rising currently and as of July 2017 over 200 people had registered. Clearly the initial spike in registrations will tail off given this was the first opportunity presented for interest to be registered and clearly 147 people are unlikely to register every year moving forwards.
4.24 Taking account of the proposed small and medium allocations and strategic allocations in the Local Plan, these are proposed to deliver a total of 15,405 dwellings. Assuming all these sites were to deliver 20% of the units as custom and self‐build housing as required by the Policy, this would deliver 3,081 plots. This is fifteen times the number of people who have registered an interest in the principle of custom and self‐build plots, which is in itself no guarantee that they will actually pursue this option.
4.25 The proposed requirement for 20% of units on sites of 10 or more dwellings is plainly unsound given the lack of justification. Notwithstanding that there is clearly no evidence to support the proportion of provision being proposed, this would result in the delayed delivery of developments, and additional costs which will affect the viability of developments, whilst the requisite period of marketing is undertaken before the plots are returned to the developer.
Policy T1: Travel Plans
4.26 Policy T1 sets out:
Travel plans, travel plan statements and transport assessments will be required for any development which meets or exceeds the Gross Floor Area thresholds set out in the Council’s Guidance on Travel Plans and Transport Assessment.
4.27 This does not consider the submission of outline planning applications for housing whereby the Gross Floor Area is will not be precisely determined or a requirement, and therefore the policy would not meet the NPPF test of soundness as the policy would not be justified as the most appropriate strategy. Furthermore it is unclear why this element of the policy is considered necessary when it can be appropriately required within the Council’s validation checklist for planning applications.
Policy T5: Ultra Low Emission Vehicles
4.28 We recognise that the Council are seeking to allow flexibility through the current wording of the Policy in order to allow it to adapt to the standards of the Local Transport Plan in future. Currently however the Policy provides no clarity on the types
of parking which would require charging points for residential development (i.e. on‐site parking vs. on‐street / unallocated / visitor). Given the lack of certainty, it will have been impossible for the Council to accurately assess the viability implications of requiring the provision of charging points as part of the overall package of measures required by the draft Local Plan. Whilst the Policy could therefore seek to encourage the provision of charging points, it should not seek to enforce the provision of this infrastructure given its potential wider implications for the deliverability of the Plan.
Policy EE1: Green Infrastructure
4.29 We note that the policy is predicated upon ensuring that development provides a “net gain in green infrastructure”. In order to help facilitate development, a more flexible approach will be required. It would be reasonable to state that “where possible, development should provide a net gain in green infrastructure”. The NPPF makes clear that the achievement of sustainable development requires balancing the three dimensions and the proposed amendment to this policy will ensure that it is compliant with national policy.
Policy EE2: Enhancing biodiversity
4.30 The Policy requires that development should provide a “net gain in biodiversity”. We consider that this policy should require “no net loss of biodiversity”. This alternative approach allows for the realities that on some sites it may be possible to protect and enhance some features but that in order to accommodate and facilitate development others may need to be subject to change or reduction in extent/ecological value. In such cases it may still be demonstrated that the development can achieve an overall biodiversity gain whilst this approach also allows for a greater degree of flexibility in the delivery of site/area specific ecological mitigation solutions.
4.31 Further flexibility should be introduced by allowing for bullet points one and two of the policy being delivered either together or separately depending on site circumstances. As currently worded both elements must be delivered on all sites, which clearly will not always be achievable on all development sites.
Policy EE3: Nature conservation
4.32 The broad aspirations of the Policy are supported which seeks to protect important habitats and sites of geological and geomorphological interest. As with our response to Policy EE2, it is considered that flexibility should be introduced to reflect the balancing act of the three pillars of sustainable development required by the NPPF.
4.33 As currently drafted it is unclear as to whether the Council will take account of proposed mitigation against detrimental impacts to the designated sites identified in the Policy. Concern is raised that the Policy as drafted appears to be overly onerous and could potentially significantly restrict the development potential of the authority area unnecessarily. Clarification should be included in the proposed policy wording to confirm that mitigation will be taken account of in order to ensure the policy is effective.
Policy EE4: Trees, woodlands and hedgerows
4.34 It is recognised that existing trees, woodlands and hedgerows can form an important feature in creating the character of new developments and should be incorporated into the development wherever possible. It is important to recognise however that there will be instances where it is not possible, or indeed appropriate, to retain all existing trees, woodlands and hedgerows.
4.35 As currently drafted the policy makes no allowance for instances where trees etc. are required to removed due to disease, age or safety concerns which renders their retention inappropriate. Furthermore, in some instances the removal of such features, in whole or in part, is required in order for the development to be brought forward, such as to allow access to the development. This does not necessarily render the development unacceptable and appropriate mitigation can be put in place, such as translocation of the hedgerow or replacement planting. As currently drafted the policy allows no such considerations to be taken account of and would apparently render a development unacceptable if a single diseased tree were to be removed. Appropriate flexibility should be added to the policy wording to take account of these concerns and ensure the policy is effective.
4.36 The Policy also requires that where trees or hedgerow removal is justified these should be “replaced within the development site with appropriate planting of suitable species of equivalent scale and character, and providing equivalent canopy cover and habitat connectivity.” Although mitigation planting is in principle acceptable, it is important to recognise that a like‐for‐like replacement is not necessarily appropriate. Where a single large tree is removed, a group of younger trees may be more appropriate than seeking to replace with a further mature tree which would have a shorter lifespan.
4.37 Concern is also raised regarding the requirements for new planting in developments. The first bullet point seeks to require new developments to include significant tree feature. Seemingly no account is taken of the scale of development which is being proposed and as currently drafted this requirement is equally applicable to a single house as for a large scale development. Flexibility should be introduced to reflect the differing scales of development which will be brought forward, and the need to take account of the character of the development site and its surrounding area.
Policy EE5: Landscape Character and Value
4.38 The Policy seeks to require that:
“All major development proposals will be required to demonstrate how they incorporate landscape enhancement, in accordance with the guidelines in the LCA, the Central Bedfordshire Design Guide and other relevant documents for specific areas.”
4.39 The policy continues to state that landscape and visual appraisal will also be expected to support planning applications. Further clarity is required as to the Council’s requirements in respect of the assessment of landscape effects. Currently the policy appears to require a landscape and visual assessment of all proposals, and has no regard to where schemes are within existing settlements. Whilst it is assumed that this
requirement is only proposed to be applied to major development proposals, this is again not explicitly stated.
Policy EE6 – Tranquillity
4.40 Policy EE6 sets out that the Council will seek to:
• Ensure that areas of high tranquillity at both strategic and community scales are protected, and that development that harms their recreational and amenity value is not permitted.
• Require planning applications for both major residential and commercial developments to demonstrate how they have assessed the potential impact of their proposals on areas of high tranquillity, including visual intrusion, impact on biodiversity, lighting and noise. Such applications will be required to demonstrate how negative impacts have been avoided and any harmful impacts are adequately mitigated.
• Require planning applications for new residential development of 100 dwellings or more to provide new or enhanced areas of tranquillity as part of proposals.
• Seek opportunities to enhance tranquillity of landscapes and townscapes, including removal of, or appropriate mitigation of, visually intrusive features, sources of disruptive noise and lighting.
4.41 Paragraph 123 of the NPPF sets out that planning policies should “identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason”. Whilst the NPPF supports protection of identified areas of ‘tranquillity’, the proposed Policy EE6 refers to areas of ‘high tranquillity’ whilst providing no definition clarification what this would constitute.
4.42 Furthermore the policy will require developments of over 100 units to deliver ‘areas of tranquillity’. Emerging policy EE6 defines ‘areas of tranquillity’ as being “found in many areas, from large scale tracts of open landscapes to small urban parks, garden oases and informal urban open spaces with a hint of wildness”. This would likely cause confusion alongside the required delivery of open space under policy EE13 – Outdoor Sport, Leisure and Open Space. This policy seeks the new development meets the following criteria:
• The provision of open spaces and outdoor sports facilities in accordance with the Leisure Strategy standards and facility requirements.
• To provide open spaces and outdoor sports facilities on site unless this is demonstrably inappropriate or impossible.
• Where the provision of open spaces and outdoor sports facilities is not on the development site, the developer will be required to contribute through planning obligations to projects for the provision, enhancement and / or extension of existing facilities in accordance with the Leisure Strategy.
4.43 Existing open space in the authority area is defined in the emerging plan as including ‘formal parks, urban green corridors, informal green spaces, wildlife sites and links to the countryside, as well as local greenspaces and children’s play areas’; the lack of a clear distinction between what constitutes ‘open space’ and ‘areas of tranquillity’ would be likely to cause confusion.
4.44 Whilst the Environmental Framework supports the policy, it does not set out a specific requirement for ‘areas of tranquility’ and therefore Policy EE6 does not appear to have been positively prepared.
Policy EE12: Public Rights of Way
4.45 The Policy requires that “developments should protect, enhance and promote the public rights of way network.” Whilst the principle of this requirement is acceptable, it is important to recognise that in some instances existing public rights of way may require diversion to facilitate development and that this can be an acceptable and appropriate approach. Flexibility should be introduced into the policy wording to reflect this eventuality.
Policy EE13: Outdoor sport, leisure and open space
4.46 Whilst the broad aspirations of the Policy are supported, the third bullet of the Policy should be amended to require developers to provide contributions relating to open spaces and outdoor sports facilities “where justified”. This is so as to reflect the requirements of national policy, which requires that planning obligations meet the following tests; that they are necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind, as set out in the Community Infrastructure Levy Regulations 2010 and as policy tests in the NPPF paragraph 204. As currently drafted concern is raised that the policy is not consistent with national policy, and it should be amended to reflect NPPF paragraph 204 and the Community Infrastructure Levy Regulations 2010 as above.
Policy CC1: Climate Change and Sustainability
4.47 We note that this policy requires major development to “provide for a minimum of 10% of its energy demand to either be reduced through a fabric first approach, deployment of energy efficient technology…or by whatever means are appropriate”. We consider that in order to help facilitate development a more flexible approach will be required. It would be reasonable to state that “where possible, provide for a minimum of 10% of its energy demand The inclusion of this additional wording will allow appropriate flexibility to take account of site constraints which make affect the ability to deliver these requirements (such as heritage constraints) and viability considerations. The policy should also seek to not duplicate requirements set out in Part L of the Building Regulations.
Policy HQ1: High Quality Development
4.48 Whilst the broad aspirations of the Policy are supported, it is important to recognise the requirements of paragraph 60 of the NPPF which states:
“Planning policies and decisions should not attempt to impose architectural styles or particular tastes and they should not stifle innovation, originality or initiative through unsubstantiated requirements to conform to certain development forms or styles. It is, however, proper to seek to promote or reinforce local distinctiveness.”
4.49 As currently drafted concern is raised that the policy does not allow for innovation and originality in the design of developments and appropriate flexibility should be introduced to ensure its consistency with national policy.
Policy HQ2: Planning Obligations and the Community Infrastructure Levy
4.50 Whilst the broad aspirations of the Policy are supported, as it is currently drafted, the first paragraph of the Policy does not make it clear that “compensatory provision” should be proportionate to the development proposed. We suggest that the wording of Policy HQ2 is revisited to prevent such ambiguity.
Policy HQ7: Public Art
4.51 We note that this policy requires Public Art to be provided as part of development consisting of 100 or more units. Whilst in some instances such provision would be appropriate, in others, such as when developments are brought forward in phases by separate developers, a contribution towards a collective piece of public art as part of the wider development may be appropriate. We consider that in order to help facilitate development a more flexible approach will be required.
Policy HQ9: Larger Sites
4.52 Policy HQ9 sets out:
Larger sites are expected to provide a mix of uses to ensure an integrated approach towards delivery of residential, economic and community uses.
Where development exceeds 300 dwellings, where there are complex design or amenity issues, or where the site is sensitive, a Development Brief must be agreed with the Council prior to submission of a Full or Outline planning application
A Design Code will also be required for developments in excess of 300 dwellings [subject to certain requirements].
4.53 Policy HA1 sets out the policy requirements for each of the Small and Medium Allocations. ‘Land East of Leighton Road’ (reference ‘HAS49’) is proposed to be allocated for an approximate capacity of 92 dwellings across 3.85ha, to built at an approximate density of 40dph. Policy HA1 does not allocate non‐residential uses for the site.
4.54 We contend that the mix of uses should be specified in the proposed allocation at Policy HA1. Policy HQ9, in requiring larger sites to provide a mix of uses, appears to contradict with Policy HA1, which in many instances allocates sites for residential use only.
4.55 In order to comply with Policy HQ9, as currently drafted, it would be necessary to revisit / lower the capacity of allocations as stated in Policy HA1 and therefore bring into question the deliverability of the Council’s housing target. We suggest that the wording of Policy HQ9 is revisited to prevent such contradictions.
Policy HE3: Built Heritage
4.56 As it is currently drafted, the second bullet of the Policy states that heritage assets will be preserved, sustained and enhanced. This approach does not allow for the balancing exercise set out in the NPPF where harm is considered against the benefits of a proposal to be taken into account. Whilst the relevant paragraphs of the NPPF are referenced at bullet one, it is considered the contradictory second bullet should be amended to reflect the requirements of national policy.
5. Conclusion
5.1 We are broadly supportive of the Draft Local Plan, in terms of its overall Spatial Strategy and proposed Allocation of site HAS49 in Policy HA1.
5.2 However we consider that a few amendments are required prior to submission of the Plan to the Secretary of State, to ensure that paragraph 182 of the NPPF is satisfied with regards to our client’s interests, as follows:
Positively prepared – There appears to be a reliance on an early review by Central Bedfordshire as part of the Local Plan. As a justification for ‘changing circumstances’, whilst the Council refer to planned infrastructure improvements in paragraph 5.5.4 of the draft Local Plan, no reference is made to the further implications of the new standardised methodology. The new methodology will lead to a 60% increase in the number of homes that would be required to be delivered per annum for Central Bedfordshire ‐ in addition to any unmet housing needs from the neighbouring authorities such as Luton (set to increase from 890 to 1,417dpa). This is a significant increase for both authorities over the plan period, and one which both authorities should be alive to as part of this Local Plan preparation process. At present the Council are adopting a cautionary approach to housing need. In light of forecasts on need, the Council should be planning for this level of delivery now, for the Plan to be considered as having been “positively prepared”.
Justified – The Council have failed to robustly justify the exclusion of the south western parcel of ‘Land east of Leighton Road’ from the proposed allocation in Policy HA1. The exclusion of this parcel seems to contradict the findings of the Council’s own evidence base. Toddington was one of the few settlements found to have medium capacity in the Initial Settlements Capacity Study (May 2017). There is not a large degree of difference in the assessments findings for parcels which pass and fail the assessment in the SA (we question why the south western parcel scores marginally worse on sustainable transport and historic environment). In addition, given the conclusions of the Green Belt Assessment Part 3 are also applicable to the additional field parcels to the south of the proposed allocation, there is no apparent justification for these parcels to not also be released from the Green Belt.
Consistent with national policy – As it currently stands, we consider that Central Bedfordshire should have more robustly tested the suitability of the whole of ‘Land east of Leighton Road’ as an Allocation (or at least an Identified Location for Future Growth, for the excluded south western parcel) as part of this emerging Local Plan. Whilst we support the Council’s commitment to undertaking a Green Belt review as part of its new Local Plan, it is important to recognise the requirements of paragraph 85 of the NPPF. As such, in reviewing the Green Belt boundaries the Council must consider not only the current proposed Local Plan requirements but also the need to meet longer‐term development needs stretching well beyond the plan period, bearing in mind
the knowledge that the standardised OAN may further increase the housing requirements (as well as increases in neighbouring Luton).
5.3 We therefore encourage the Council to allocate the whole of ‘Land east of Leighton Road’ for residential development in the Local Plan 2035.
Appendix 1: Site Location Plan
Proposed Allocation © Crown Copyright and database right. 2017 Ordnance Survey 100049029. Suggested extension to Proposed Central Bedfordshire Council. Allocation within clients control
Appendix 2: Landscape & Visual Appraisal
Land at Leighton Road Toddington, Bedfordshire
Initial Landscape and Visual Appraisal
Prepared by CSA Environmental
on behalf of Taylor Wimpey UK Ltd
Report No: CSA/2922/01
April 2016
1.0
Report Prepared Approved Date Revision Comments Reference by by CSA/2922/01 08/04/2016 - BS CA A BS CA Minor amendments to Site boundary
CONTENTS Page
1.0 Introduction 2
2.0 Landscape Policy Context 4
3.0 Site Context 7
4.0 Site Description and Visibility 11
5.0 Ability of the Site to Accommodate Development 15
6.0 Conclusion 21
Appendices Appendix A: Location Plan Appendix B: Aerial Photograph Appendix C: Photosheets Appendix D: ‘MAGIC’ Map and Heritage Information Appendix E: Extent of Green Belt and Area of Great Landscape Value Appendix F: Methodology
1.0 INTRODUCTION
1.1 CSA Environmental has been appointed by Taylor Wimpey UK Ltd to undertake an initial landscape and visual appraisal of land at Leighton Road, Toddington (‘the Site’). The purpose of this report is to support a call for sites by Central Bedfordshire Council as part of the work on their emerging Local Plan.
1.2 This appraisal describes the existing landscape character and quality of the Site and the surrounding area. The report then goes on to discuss the ability of the Site to accommodate development and the potential landscape and visual effects on the wider area.
1.3 The Site is currently situated within the Green Belt and this report also considers the impact of releasing the Site in terms of the functions and purposes of the Green Belt. The assessment also looks at a wider study area surrounding the Site in order to redefine the Green Belt boundary and determine the extents of developable land.
1.4 For the purpose of this appraisal it has been assumed that the proposed development will comprise: residential development, associated infrastructure and landscaping.
1.5 The Site lies on the south western edge of Toddington in Bedfordshire. It lies within the parish of Toddington, and within Central Bedfordshire.
1.6 The Site is approximately 22 acres in size, and comprises a series of small to medium sized pastoral fields. For ease of discussion through the appraisal, these have been labelled A to F on the Aerial Photograph at Appendix B. The location and extent of the Site is shown on the Location Plan at Appendix A.
Methodology
1.7 This appraisal is based on a site visit undertaken by a suitably qualified and experienced Landscape Architect in April 2016. The weather conditions at the time were clear and visibility was good.
1.8 In landscape and visual appraisal, a distinction is drawn between landscape effects (i.e. effects on the character or quality of the landscape irrespective of whether there are any views of the landscape, or viewers to see them) and visual effects (i.e. effects on people’s views of the landscape from public vantage points, including Public Rights of Way and other areas with general public access, as well as effects from any residential properties). This report therefore considers the potential impact of the development on both landscape character and visibility. The methodology utilised in this report is contained in Appendix F.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 2
1.9 Photographs contained within this document (see Appendix C) were taken using a digital camera with a lens focal length approximating to 50mm, to give a similar depth of vision to the human eye. In some instances images have been combined to create a panorama. The photographs perform two functions, the first to show the character of the Site and its surroundings, and the second to show the visibility of the Site.
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2.0 LANDSCAPE POLICY CONTEXT
National Planning Policy Framework (‘NPPF’)
2.1 National policy is set out in The National Planning Policy Framework (‘NPPF’) and those parts relevant to this appraisal are summarised below.
2.2 Paragraph 14 states that at the heart of the NPPF is a presumption in favour of sustainable development, which it states should be seen as a golden thread running through both plan-making and decision-taking.
2.3 Section 7 of the NPPF sets out the requirements of good design and Paragraph 56 states that:
‘Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people.’
2.4 Paragraph 58 states that local and neighbourhood plans should develop robust policies which set out the quality of development which will be expected based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics. Planning policies and decisions among others should aim to ensure development:
will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development; respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation; and are visually attractive as a result of good architecture and appropriate landscaping.
2.5 Paragraph 61 notes that planning policies should address the connections between people and place and the integration of new development into the natural, built and historic environment.
2.6 Section 9 of the NPPF sets out national Green Belt policy and states the essential character of the Green Belt is its openness, permanence and ability to serve the following functions:
to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns; and
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to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.7 Section 11 of the NPPF deals with conserving and enhancing the natural environment. Paragraph 109 of the document states that the planning system should contribute to the protection and enhancement of the natural and local environment through, among others protecting and enhancing valued landscapes.
Central Bedfordshire Local Planning Policy
2.8 For the purposes of local planning policy, the Site is located in the southern part of Central Bedfordshire Council. The council is currently working on their emerging Local Plan which will guide development to 2031. The Local Plan is in the early stages, with the Call for Sites having started on the 22nd February 2016. Until such time as the new Local Plan is formally adopted, the policies contained in the South (Bedfordshire) Local Development Plan (adopted 2004, for the period until 2011) remain relevant, insofar as they are compliant with the NPPF. This development plan consists of a Written Statement setting out the policies and proposals for the area, supported by the Proposals Map. The main landscape policies relevant to the Site are as follows:
2.9 Policy GB1 Control of Development in the Green Belt states that planning permission within the Green Belt will not be granted except in very special circumstances and then sets out the exceptions which include agriculture and forestry, small scale sports and outside recreation facilities, cemeteries, infilling within villages or major previously developed sites, re-use of existing buildings, and engineering or other operations which do not affect the openness of the Green Belt.
2.10 Policy GB3 Green Belt Villages identifies Toddington as one of the Category 3 villages which are excluded from the Green Belt, and therefore where new development and redevelopment will be permitted within their boundaries.
2.11 Policy NE1 Development in the Countryside states that development which is otherwise acceptable in the Green Belt, will not be permitted where it has an adverse effect on the landscape character, important landscape features, or on the existing forms and patterns of settlement, as well as its location siting, scale or design.
2.12 Policy NE3 Areas of Great Landscape Value seeks to protect the landscape character and setting of Areas of Great Landscape Value.
2.13 Policy NE4 Protection and Enhancement of Trees and Woodlands requires the retention of existing trees, woodland and hedgerows in new
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developments where this would result in unacceptable harm to the character, recreational value or ecology of the site or the surrounding area. Where removal is unavoidable, replacement planting will be required and works controlled.
2.14 Policy R10 Children’s Play Area Standard sets out the Council’s requirements for children’s play area provision where a new development comprises 12 or more dwellings. Play areas will be required to be equipped and surfaced, with seating and planting provided.
2.15 Policy R11 Provision of New Urban Open Space in New Residential Developments requires the provision of adequate formal and informal urban open space, with the precise size and type of provision determined according to the nature of the development and type of housing.
2.16 Policy 14 Protection and Improvement of Informal Recreational Facilities in the Countryside states that existing facilities will be improved and protected to ensure access to informal recreation in the countryside. This includes improving access into the wider countryside for walkers, horse riders and cyclists. It goes on to require landscape enhancement, habitat management improvement and resolution of public access issues, especially on the urban fringe.
2.17 Policy R15 Retention of Public Rights of Way Network requires the retention of existing Public Rights of Way, and the opposition to any diversion or closure which would result in restricting access to the countryside for informal recreation.
Central Bedfordshire Council Strategic Housing Land Availability Assessment (SHLAA) June 2014
2.18 The SHLAA was undertaken by Central Bedfordshire Council in 2014 to inform the Local Plan preparation and to provide the council with a general understanding of the development potential of sites within the district.
2.19 The majority of the Site is not identified in the SHLAA except for a small land parcel identified by reference number 323 (Russell Road) which equates to Area D of the Site. The parcel is assessed in the report as being unsuitable for development given its location within the Green Belt and its size, which is not considered suitable as a strategic allocation in the Development Strategy. This is however being reviewed as part of the Call for Sites.
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3.0 SITE CONTEXT
Site Context
3.1 The Site is located adjacent to the south western settlement edge of Toddington. The Site lies north of Dunstable and northeast of Leighton Buzzard, approximately 6.5km and 8.7km respectively.
3.2 To the north west, the Site is bound by Leighton Road, which joins Harlington Road within Toddington, leading to junction 12 of the M1 to the northeast. To the south, Leighton Road becomes Toddington Road joining Watling Street (A5) to the southwest of Toddington.
3.3 To the southwest, the Site is bound by a pair of agricultural fields, with a tree belt on their south western boundary, and further agricultural fields beyond.
3.4 To the southeast, the Site is bound by a wedge-shaped tree belt, the eastern side of which follows the edge of a small watercourse, with an irregularly shaped arable field, and a recent housing development at Randall Close and some allotments further to the east.
3.5 To the northeast the Site is bound by the south western edge of the residential development at Toddington. There is a small children’s play area which serves the existing residential development to the northeast which lies outside of the Site boundary.
National Landscape Character
3.6 Natural England has produced profiles for England’s National Character Areas (‘NCA’), which divides England into 159 distinct natural areas, defined by a unique combination of landscape, biodiversity, geodiversity, cultural and economic activity. The Site lies within the southeast of the Bedfordshire and Cambridgeshire Claylands Character Area (Area profile 88).
3.7 The Bedfordshire and Cambridgeshire Claylands NCA is described as comprising a broad, gently undulating lowland plateau dissected by shallow river valleys. Despite it consisting of predominantly open, large- scale arable farmland, there are a number of semi-natural habitats which support a number of rare and scarce species. Varied scattered woodland, some of which is ancient is a feature. The NCA is sparsely populated away from the urban centres and other settlements which are clustered around the main transport and rail routes. In the areas of urbanisation, there has been a decline in tranquillity. History and a sense of place are supported by the rich geological and archaeological remains in the area.
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District Landscape Character
3.8 The Central Bedfordshire Landscape Character Assessment (2015) was produced by LUC on behalf of Central Bedfordshire Council.
3.9 The Site is situated in the east of the Toddington – Hockliffe Clay Hills Landscape Character Area (LCA) 8A.
3.10 The key characteristics of LCA 8A include:
Agricultural land consists of a mix of land in arable cultivation, with predominantly medium-scale fields, and pasture land; The landscape pattern is clearly defined by hedgerows and scattered, mature hedgerow trees with wide grass verges and drainage channels; Good survival of enclosure fields, many with remaining ridge and furrow pasture; Small woodland copses and areas of ancient woodland are a feature, some contained within historic parks; Views from higher elevations, including the hill top village of Toddington, into the neighbouring LCAs to the east and north, while it is more enclosed on lower elevations; Urban fringe influences around the settlements of Leighton Buzzard on the west and Toddington on the east; Primary transport routes including the M1, A5 (T) Watling Street, A5120, A4012 and their associated infrastructure, with some conifer screening dilute the rural character of the landscape and contrast to the historic winding lanes; The Icknield Way Trail runs to the east of Toddington on the eastern edge of the character area; and Villages generally retain their historic form around village greens and pubs, with late 20th century development at the settlement edges.
3.11 The Landscape Strategy guidelines for the LCA recommend enhancing the landscape by conserving, restoring and improving the positive features of the landscape to strengthen the landscape pattern and visual integrity. The hedgerow network gives the landscape a distinctive land cover pattern and its other features add to a clear sense of place. Where there is new development on the edge of a settlement, care should be taken to ensure an appropriate rural interface between it and the rural landscape beyond.
3.12 From our own assessment of the Site, we would note that it is fairly typical of Landscape Character Area 8A, comprising pastoral fields contained within a strong network of hedgerow lined fields.
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Green Belt
3.13 The Site falls within the Green Belt, the extent of which is shown in Appendix E.
Designated Sites and Heritage Assets
3.14 The Multi Agency Geographic Information for the Countryside Map (‘MAGIC’) and the electronic South Bedfordshire Proposals Map (read in conjunction with the policies contained within the Written Statement) indicate that the Site is not covered by any statutory or non-statutory designations for landscape character or quality (please refer to Appendix D).
3.15 There are no Scheduled Monuments or Listed Buildings on the Site. The nearest Listed Buildings lie respectively northwest and southeast of the Site, being the Grade II Listed Herne Poplar Farmhouse and the Grade I listed Church of All Saints, Chalgrave. There are a number of listed buildings between 1km and 2km from the Site to the northwest and southeast, and several contained within the Toddington and Tebworth Conservation Areas. The Toddington Conservation Area covers the northern part of the settlement, approximately 0.4km to the northeast of the Site (see Appendix D). Adjacent to the northern edge of Toddington, and extending north and west, is an area designated locally as an Area of Great Landscape Value (see Appendix E).
Tree Preservation Orders
3.16 There are a number of Tree Preservation Orders (‘TPO’) covering trees on the northern, eastern and western boundaries of field E of the Site. These are T169 to T177 which are covered by TPO No2 1972. This was ascertained by studying The Toddington Parish Tree Preservation Order citation and the accompanying Tree Preservation Order Map from Central Bedfordshire Council’s website under reference SB/TPO/72/0002 on 6th April 2016.
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Public Rights of Way
3.17 There are no Public Rights of Way which run through the Site.
3.18 Public footpath FP62 runs within the tree belt adjacent to the south eastern boundary of the Site, linking the southern residential area of Toddington to the wider countryside. Where it crosses the parish boundary between Toddington and Chalgrave parishes, it becomes footpath number FP9, joining Toddington Road to the southwest.
3.19 Leaving from the same point as public footpath FP62, public footpath FPA62 runs within agricultural fields roughly south. It becomes FP23 from the parish boundary between Toddington and Chalgrave parishes, joining Chalgrave Road north of College Farm. A small spur extends east to join Dunstable Road between the allotment gardens and the southern edge of the settlement within Randall Close (FP89).
3.20 Public footpath FP64 runs along the external side of the south western Site boundary, linking Toddington Road to public footpath FP62 at the south eastern corner of the Site.
3.21 To the west of the Site there is a large network of public footpaths which cross the landscape. The closest of which is public footpath (FPA3), running south off public footpath FP13, which extends from the western settlement edge of Toddington into the arable fields to the west.
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4.0 SITE DESCRIPTION AND VISIBILITY
Site Description
4.1 The Site comprises six small to medium sized, roughly rectangular fields, which have been subdivided into parcels for the purpose of the Site description, as shown on the Aerial Photograph at Appendix B.
4.2 Area A comprises a small rectangular field. The edge of Toddington forms the north eastern boundary, with residential properties on Frenchmans Close overlooking the parcel. The parcel is bound to the north west by Leighton Road.
4.3 Area B is a narrow strip of land comprising a mixed deciduous and evergreen tree belt with scrub, indented to the southwest by a clearing for some farm buildings. The area extends from the rear garden of the neighbouring property on Leighton Road towards the southeast, ending roughly in the centre of the Site, abutting Area E. There is a children’s play area adjacent to its north eastern corner associated with the residential properties on the edge of Toddington to the north.
4.4 Area C, abutting Area B to the southwest, comprises a small pastoral field, with a group of mature trees, some of which are evergreen along Leighton Road. There are further scattered trees in the interior of the parcel to the west. Hedgerows line the south western and south eastern boundaries, while to the northeast it is bound by the tree belt of Area B.
4.5 Area D, abutting Area C to the southwest, comprises a small pastoral field, with mainly dense hedgerows forming the boundary to the northwest with Leighton Road, and those to the northeast and southeast. To the southwest, the boundary is dominated by brambles, with public footpath FP64 on its external edge, adjacent to a large arable field.
4.6 Area E is the largest parcel, located to the east of Area B, comprising a medium sized pastoral field. The edge of Toddington forms the north eastern boundary, with the residential properties on Russell Road and Bryant Way overlooking the parcel. Vegetated garden hedgerows and trees line this boundary. Strong hedgerows form the boundaries to the southwest and northwest, supported on the latter by the tree belt in Area B. To the southeast, outside the parcel, a wedge shaped tree belt forms the boundary.
4.7 Area F is a medium sized pastoral field, abutting Area E to the southwest. The wedge shaped tree belt continues as the south eastern boundary of this parcel, with dense hedgerows marking the remaining boundaries.
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Topography
4.8 The topography of the Site slopes from the northwest to the southeast, with the high point at around 150m Above Ordinance Datum (‘AOD’), falling gradually to the stream which passes the south eastern corner at 130m AOD.
4.9 The land surrounding the Site is undulating, with gentle valleys formed around a series of streams. To the north of the Site, Toddington sits on a local high point at approximately 154m AOD, with the valleys to its north and south typically falling up to 50m, to 100m AOD.
Visibility
4.10 The level of vegetation cover to the field boundaries within and bounding the Site, provide a good level of screening to the majority of the Site from its surroundings, although there are some more open views particularly from the south west.
4.11 The following section describes representative views of the Site from public vantage points in the vicinity.
West 4.12 Views of the Site from Leighton Road running adjacent to the north western Site boundary are largely screened by the boundary hedgerow and trees. Views over the hedgerow are possible although limited to views of parcel D and trees along the Site’s internal field boundaries (Photograph 3). Glimpsed views into parcel A are also possible (Photograph 1).
4.13 Views from properties on the eastern side of Leighton Road immediately adjacent to the western Site boundary look out across the western part of the Site, from predominantly first floor windows. Tree cover offers some screening of the rest of the Site from these properties. Views from properties on the western side of Leighton Road to the north west and south west are more oblique, with vegetation to the property boundaries and on the edge of the Site screening the majority of the Site from view.
4.14 Occasional glimpsed views of the Site are possible from a short section of public footpath FPA3 to the north west of the Site, although field boundary vegetation screens the majority of Site from view.
South 4.15 Views of the Site from public footpath FP64 running adjacent to the south western boundary are partially screened by hedgerow vegetation along the Site boundary. The boundary adjacent to parcel D comprises a low bramble hedgerow, with views into the Site possible over the
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hedgerow (Photograph 4 & 5). The hedgerow is more substantial adjacent to parcel F and screens views into the Site, except for the occasional glimpsed views through gaps (Photographs 6 & 7).
4.16 Views of the Site from public footpaths FP62 and FPA62 to the south are filtered by vegetation along the various field boundaries. The southern boundary hedgerow and trees are visible along this route as well as properties on the edge of Toddington (Photographs 14 – 17). Views from these routes further to the south become increasingly screened by the woodland belt stretching between Toddington Road and Dunstable Road.
4.17 Long distance views of the Site from public footpath FP23 adjacent to Chalgrave Road (a localised high point) are possible, seen in the context of the surrounding fields, with the properties on the edge of Toddington visible on the horizon (Photograph 18).
East 4.18 Views of the Site from public footpath FP62 running adjacent to the eastern Site boundary are predominantly screened by the tree belt along the Site boundary, with occasional glimpsed views of parcels E & F visible through gaps in the vegetation (Photograph 9).
4.19 Views of the Site from public footpath FPA62 which is more elevated, is similarly screened to the north by the boundary tree belt (Photograph12), although views over the vegetation into parcel F are possible to the south with the roofs of housing immediately north of the Site also visible (Photograph 13).
4.20 Views of the Site from properties on the edge of Randall Drive have first floor views looking towards the Site with parcel F visible above the tree belt and the rest of the Site being largely screened from view.
North 4.21 Views of the Site are possible from a number of properties on Russell Road, Frenchmans Close and Bryant Way where vegetation along the norther boundary is limited. Views into the Site are also possible from the end of Russell Road where there is field gated access into the Site (Photograph 11).
4.22 Views of the Site from the children’s playground to the immediate north of the Site are screened by the established vegetation along the northern Site boundary (Photograph 10).
4.23 Views of the Site from Leighton Road to the north are largely screened by Site boundary vegetation, with some glimpsed views into parcel A (Photographs 1 & 2).
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Landscape Quality, Value and Sensitivity
4.24 The Site comprises a series of small to medium sized fields, with field boundaries defined by hedgerows and scattered trees and a narrow tree belt. The field boundary hedgerows are generally assessed as having medium landscape value with the mature trees located along the eastern boundary and within the tree belt assessed as having high landscape value. There is no public access across the Site although the pastoral fields within the Site are overlooked by a number of properties to the north and users of the public footpath to the south and are likely to be valued at a local level. These fields are assessed as being of medium landscape value.
4.25 The overall landscape character of the Site is fairly typical of the Hockliffe Clay Hills LCA, comprising pastoral fields bound by a network of hedgerow field boundaries. The Site’s overall landscape character is assessed as being of Medium quality and Medium sensitivity.
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5.0 ABILITY OF THE SITE TO ACCOMMODATE DEVELOPMENT
5.1 This section provides a brief appraisal of the ability of the Site to accommodate a mixed use development, in terms of the landscape and visual constraints and effects. It then continues to consider the implications of releasing the land from the Green Belt.
5.2 It is anticipated that the proposed development will comprise residential development and is assumed that the built form will be between 2 and 2.5 storeys.
5.3 The following landscape opportunities and constraints should be considered in any development proposals and include:
Creation of strong pedestrian links to the surrounding Public Rights of Way to the south and east, as well as links to the children’s play area to the north. Retention of the existing landscape framework of field boundary hedgerows, tree belt and individual trees where practicable. Retention of trees covered by Tree Preservation Orders and suitable buffer to ensure safeguarding of these trees. Creation of new areas of public open space including opportunities for informal play and recreation. Enhancement of the north eastern boundary adjacent to properties on Russell Road, Frenchmans Close and Bryant Way with new hedgerow and tree planting; Enhancement of the south eastern and south western Site boundaries with new hedgerow and tree planting, reducing the visibility of the Site from the south. Proposed built form to positively address Leighton Road and the south western approach into Toddington.
Relationship to Existing Development
5.4 The Site is bound to the north east by the settlement of Toddington, and to the northwest by Leighton Road. There are also a number of terraced houses along Leighton Road to the north of the Site, which lie outside of the settlement boundary.
5.5 Development of the Site should maximise opportunities to interact with the surrounding built form, with strong links to existing amenities and transport links along Leighton Road. It is anticipated that proposed vehicular access into the Site would be off Leighton Road and proposed development should positively address Leighton Road, set back with
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new landscape proposals to provide an attractive new entrance into the settlement.
5.6 Development of the Site has the potential to deliver new areas of public open space and informal play facilities, serving both new and existing residents, maximising pedestrian links to the existing residential area to the north. Development also creates an opportunity to provide improved connections to recreation including the surrounding network of public footpaths.
Landscape Features
5.7 The Site is in pastoral use, and the main landscape features, including established hedgerows, trees and the tree belt are largely contained to the field boundaries. The Site has the potential to be developed, while retaining the existing landscape framework of trees and hedgerows.
5.8 The Site has the opportunity to be enhanced, with new landscape proposals including reinforced tree and hedgerow planting to Site boundaries as well as new areas of public open space and informal play opportunities.
Public Rights of Way
5.9 There are no Public Rights of Way within the Site however two footpaths run adjacent to the south west (FP64) and south east (FP62) Site boundaries. Development of the Site creates an opportunity to provide pedestrian links to both of these public footpaths, linking to the network of public footpaths to the south and east.
5.10 The landscape character along the public footpaths adjacent to the Site boundaries, will remain similar to that of the existing character through the retention of existing boundary vegetation, with views looking out across the fields to the south and east of the Site. Proposed development will be more prominent along these routes, albeit the retained boundary vegetation will provide a good level of screening.
Visibility
5.11 The visual appraisal in Section 4 identifies that the Site is generally well contained by the network of boundary hedgerows and tree belts which help to screen views of the Site. Views from the east are more elevated and look into parcel F in the south of the Site. The northern part of the Site is also overlooked by a number of properties on the edge of Toddington.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 16
West 5.12 The proposed development will be visible from Leighton Road to the west of the Site, above the retained boundary hedgerow. The new vehicular access junction into the Site will also provide more open views into the Site. New tree planting to the Site entrance will help to soften views of new housing and infrastructure.
5.13 Views of the proposed development in parcels A & C will be possible from the first floor of properties on the eastern side of Leighton Road, with the retained tree belt helping to screen views of the rest of the Site. Views from properties on the western side of Leighton Road will be predominantly screened by vegetation although views of the proposed access road junction will be possible.
South 5.14 The proposed development will be visible from public footpath FP64 running adjacent to the southern Site boundary. Views of the proposed built form will be possible from the western section of this route, over the top of the existing low boundary hedgerow. Views from the eastern section of the route will be predominantly screened by the established boundary hedgerow, with glimpsed views through occasional gaps. New enhancement planting along the southern Site boundary will further screen the development from this route.
5.15 Views of the proposed development from public footpaths FP62 and FPA62 to the south will be predominantly of the first floors and roofs of built form, visible above the retained southern boundary hedgerow. The proposed development will be seen in the context of existing built from on the southern edge of Toddington in these views and enhancement planting along the southern Site boundary will provide further screening.
5.16 Long distance views of the proposed development from public footpath FP23 adjacent to Chalgrave Road (a localised highpoint) will be possible above the boundary vegetation. Proposed development will be seen in the context of existing built form on the edge of Toddington in these views and enhancement planting along the southern Site boundary will provide further screening.
East 5.17 The proposed built form will be predominantly screened in views from public footpath FP62 adjacent to the eastern Site boundary. Glimpsed views of the proposed built form will be possible through gaps in the boundary vegetation, although enhancement planting along the eastern boundary will provide further screening.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 17
5.18 Views of the proposed development from the elevated public footpath FPA62 and properties on the edge of Randall Drive will be primarily of built form within parcel F, with retained boundary vegetation helping to screen the rest of the Site from view. Enhancement planting along the eastern Site boundary will further reduce views of the built form.
North 5.19 Views of the proposed development from properties on the edge of Russell Road, Frenchmans Close and Bryant Way will be of the proposed built form in parcels A and E, with the retained tree belt in parcel B screening development in the western part of the Site. Enhancement planting along the northern Site boundary will help to provide further screening of the built form in these views.
5.20 Views of the proposed built form from the children’s play area to the immediate north of the Site will be screened by the existing established boundary vegetation although new pedestrian links to the play area from the proposed development will open up glimpsed views of new housing.
5.21 Views of the proposed development from Leighton Road to the north will be predominantly screened by the retained tree belt in parcel B and vegetation to the Site boundary. Views of the proposed built form in parcel A will be possible above the retained vegetation.
Landscape Quality and Value
5.22 As set out in Section 4, the Site is not covered by any statutory or non- statutory designations for landscape character or quality. A number of the trees along the boundaries of the Site are however covered by a Tree Preservation Order.
5.23 The majority of the important landscape features occur along the field boundaries and include a number of mature trees and established tree belt. These features of high landscape importance are all capable of being retained and incorporated within a development scheme. Short sections of hedgerow will require removal to facilitate vehicular access into and through the Site.
5.24 New areas of public open space could be created with improved connectivity to the surrounding Public Rights of Way, as well as new informal play facilities, improving recreation opportunities in the local area.
5.25 We consider that the Site can be developed in line with the principles set out above to provide a well-integrated extension to the existing Toddington settlement. Appropriate landscape led development
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 18
proposals can be accommodated on Site without resulting in material harm to the surrounding countryside’s landscape and visual character.
Impact of Releasing the Site from the Green Belt
5.26 The Site lies within the Green Belt and the following section considers whether release of the Site would impact on the Green Belt purposes identified in the NPPF. The NPPF at paragraph 80 identifies the five purposes of Green Belts as:
to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
5.27 The NPPF states at paragraphs 79 and 80, that the essential character of Green Belts is their openness, their permanence and their ability to serve the functions as set out above. The Framework notes that when defining Green Belt boundaries, local authorities should take account of the need to promote sustainable patterns of development and ensure that there would be sufficient safeguarded land outside the Green Belt in order to meet the long term development needs of the area. It continues to say that Green Belt boundaries should be defined clearly along physical features which are readily recognisable and likely to be permanent.
5.28 The Site is bound by existing built form along the north eastern boundary at Russell Road, Frenchmans Close & Bryant Way, with some scattered built form adjacent to the north east boundary along Leighton Road. It is also bound by a main road into Toddington from the south west. New housing would be well related to the adjoining urban edge and by designing the proposed built form with a strong relationship to the existing settlement and a robust boundary to the wider countryside, encroachment into the wider Green Belt will be prevented. As such the planned release of land for development on the Site would not encroach into the wider countryside or result in unrestricted urban sprawl.
5.29 In terms of the Site and neighbouring towns merging, the nearest settlement to the south west of Toddington is approximately 2km away at Tebworth. Development of the Site would lead to a relatively minor reduction in the gap between settlements and would not lead to these settlements merging.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 19
5.30 The conservation area within Toddington lies some distance from the Site in the north of the settlement and there is no inter visibility between the Site and the Conservation Area. As such development would not affect the setting or special character of any historic town.
5.31 In terms of the 5th purpose of the Green Belt, the Call for Sites process recognises that there will be some requirement for release of Green Belt land to meet the district’s housing needs.
Overview of Green Belt at the periphery of Toddington
5.32 An overview of Green Belt land surrounding Toddington was carried out by a suitably qualified and experienced landscape architect in March 2016 and found that land to the south west of the settlement was most suitable for release from the Green Belt when assessed against the five purposes.
5.33 Land to the north east of the settlement lies adjacent to the Toddington Conservation Area, with the existing settlement edge strongly defined by woodland copses. The land here falls steeply and is visually prominent in long distance views from the north east. Development of land to the north east is likely to result in significant encroachment into the countryside and potentially affect the setting of the Conservation Area.
5.34 Land to the north west of the settlement lies within an Area of Great Landscape Value and slopes steeply away from the existing settlement edge. The countryside to the north west is open with long distance views and very few logical boundaries to define potential expansion of the urban area. Development of land to the north west is likely to result in significant encroachment into the countryside and potentially unrestricted sprawl.
5.35 Land to the south east of the settlement edge falls steeply to the east and is visually prominent in long distance views. The existing settlement edge is well defined by woodland copses. Development of land to the south east is likely to result in significant encroachment into the countryside.
5.36 Land to the south west of the settlement is flatter and visually well contained by tree belts. An established tree belt to the south west of the existing settlement could form a strong boundary to development, without resulting in significant encroachment into the countryside.
5.37 The Site could be taken out of the Green Belt and the boundary redefined along the established tree belt to the south west, forming a strong defensible boundary to the settlement and ensuring the countryside beyond the Site is safeguarded.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 20
6.0 CONCLUSION
6.1 The Site is located on the edge of the settlement of Toddington, in the district of Central Bedfordshire. It comprises approximately 22 acres of small to medium sized pastoral fields with a landscape framework of field boundary hedgerows and tree belts. The Site is assessed as being of an overall medium quality in terms of landscape character.
6.2 The Site is visually well contained by the network of boundary hedgerows and tree belts. Filtered views into the southern part of the Site are possible from public footpaths and a number of properties to the east. The northern part of the Site is also overlooked by a number of properties on the southern edge of Toddington.
6.3 The Site is located wholly within the Green Belt and any proposed development of the Site would need to come forward as part of a planned release of land from the Green Belt.
6.4 Development of the Site allows the opportunity to create new areas of public open space together with informal play facilities for the benefit of new and existing residents. Strong pedestrian links through the Site will also improve recreational access to the network of surrounding Public Rights of Way.
6.5 The majority of existing landscape features on the Site including the hedgerows, tree belt and individual trees have the potential to be retained in development proposals. Enhancement planting to the southern Site boundary will help to provide a strong physical boundary to the edge of development.
6.6 This appraisal found that the Site is capable of accommodating development in line with the principles set out in section 5, without resulting in material harm to the surrounding countryside’s landscape and visual character, or the objectives and purposes of the Green Belt.
Land at Leighton Road, Toddington, Bedfordshire – Initial Landscape and Visual Appraisal Page 21
Appendix A
Site Location Plan
FP13
FPA3
FP64
FP89 16 14 17 15 FP62 FPA62 FP9
FP23
18
Central Bedfordshire Council Footpath Site Location X Photograph Locations FPXX Reference No.
Drawing No. Rev Project Land at Leighton Road, Toddington Dixies Barns, High Street, CSA/2922/100 A Ashwell, Hertfordshire SG7 5NT Drawing Location Plan Scale @ A4 Drawn t 01462 743647 Title Not to Scale ES e [email protected] Date Checked w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd April 2016 BS
© CSA Landscapes Ltd. Do not scale from this drawing. Refer to figured dimensions only.
Appendix B
Aerial Photograph
1
2
10 11
3 4
5 12
9 6 7
8 13
Site Location X Photograph Locations
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Date April 2016 Drawing No. CSA/2922/101 Ashwell, Hertfordshire SG7 5NT Drawing Title Scale @ A4 t 01462 743647 Aerial Photograph NTS Rev A e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd. Drawn SH Checked BS
© CSA Landscapes Ltd. Do not scale from this drawing. Refer to figured dimensions only.
Appendix C
Photosheets
View south west along Leighton Road, adjacent to the northern corner of the Site Photograph 01
View south west along Leighton Road, adjacent to existing properties Photograph 02
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View north east across Leighton Road looking along the north western Site boundary Photograph 03
View into the Site from Public Footpath FP64, adjacent to the junction with Leighton Road Photograph 04
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View north across the Site from Public Footpath FP64 Photograph 05
View north west along Public Footpath FP64, adjacent to the south western Site boundary Photograph 06
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View south east along Public Footpath FP64, adjacent to the south western Site boundary Photograph 07
View from Public Footpath FP62 towards the southern corner of Site Photograph 08
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View of boundary vegetation along south eastern boundary from Public Footpath FP62 Photograph 09
View across the children’s play area to the north of the Site Photograph 10
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View from Frenchmans Close towards the north eastern Site boundary Photograph 11
View from the junction of Public Footpath FP62 and FPA62, towards the south eastern Site boundary Photograph 12
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View towards the south eastern Site boundary from Public Footpath FPA62 Photograph 13
View towards the south eastern Site boundary from Public Footpath FP62, adjacent to the field boundary Photograph 14
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View towards the south eastern Site boundary from Public Footpath FP62, adjacent to the woodland belt Photograph 15
View towards the south western Site boundary from Public Footpath FP62 Photograph 16
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd. View north towards the Site from Public Footpath FP62 Photograph 17
View from the junction of Public Footpath FP23 and Chalgrove Road, looking north towards the Site Photograph 18
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Drawing No. CSA/2922/103 Rev A Ashwell, Hertfordshire SG7 5NT Drawing Title Date t 01462 743647 Photosheets April 2016 e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd Drawn ES Checked BS
© CSA Landscapes Ltd.
Appendix D
‘MAGIC’ map and Heritage Information
Site Location
Site of Special Scientific Interest
Scheduled Monument
Ancient and Semi- 4 5 Natural Woodland 2 3 Ancient Replanted Woodland
6 Area of Outstanding 7 8 Natural Beauty - The Chiltern 1 1 Conservation Areas
Grade I Listed Buildings 1 x k 2 1. Church of St George m
k m 2: Church of All Saints
x Grade II Listed Buildings (Outside of Conservation 11 Area) 10 1: Herne Poplar Farmhouse 9 2: Herne Manor Farmhouse 3. Park House 2 4. Stables at Toddington Manor 5. Toddington Manor 6. Lodge to Toddington 7. 33 park Road 12 8. Foxton House 13 9. Barn at Stockwell Farm 10. Willow Farmhouse 11. Fancott Arms Public House 12. C18 Range of outbuildings to north east of Chalgrave Manor Farmhouse 13. Chalgrave Manor Farmhouse
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Date April 2016 Drawing No. CSA/2922/102 Ashwell, Hertfordshire SG7 5NT Drawing Title Scale @ A4 t 01462 743647 MAGIC Map Extract and Heritage Information NTS Rev A e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd. Drawn SH Checked BS
© CSA Landscapes Ltd. Do not scale from this drawing. Refer to figured dimensions only.
Appendix E
Extent of Green Belt and Area of Great Landscape Value
Site Location
Greenbelt
Area of Great Landscape Value
1
k
2 m
k
m
Dixies Barns, High Street, Project Land at Leighton Road, Toddington Date April 2016 Drawing No. CSA/2922/104 Ashwell, Hertfordshire SG7 5NT Drawing Title Scale @ A4 t 01462 743647 Extent of Green Belt and Area of Great Landscape Value NTS Rev A e [email protected] w csaenvironmental.co.uk Client Taylor Wimpey UK Ltd. Drawn ES Checked BS
© CSA Landscapes Ltd. Do not scale from this drawing. Refer to figured dimensions only.
Appendix F
Methodology
METHODOLOGY FOR LANDSCAPE AND VISUAL APPRAISALS
M1 In landscape and visual appraisal, a distinction is normally drawn between landscape/townscape effects (i.e. effects on the character or quality of the landscape (or townscape), irrespective of whether there are any views of the landscape, or viewers to see them) and visual effects (i.e. effects on people’s views of the landscape, principally from residential properties, but also from public rights of way and other areas with public access). Thus, a development may have extensive landscape effects but few visual effects (if, for example, there are no properties or public viewpoints nearby), or few landscape effects but substantial visual effects (if, for example, the landscape is already degraded or the development is not out of character with it, but can clearly be seen from many residential properties and/or public areas).
M2 The assessment of landscape & visual effects is less amenable to scientific or statistical analysis than some environmental topics and inherently contains an element of subjectivity. However, the appraisal should still be undertaken in a logical, consistent and rigorous manner, based on experience and judgement, and any conclusions should be able to demonstrate a clear rationale. To this end, various guidelines have been published, the most relevant of which (for appraisals of the effects of a development, rather than of the character or quality of the landscape itself), form the basis of the assessment and are as follows:-
‘Guidelines for Landscape & Visual Impact Assessment’, produced jointly by the Institute of Environmental Assessment and the Landscape Institute (GLVIA 3rd edition 2013); and ‘Landscape Character Assessment, Guidance for England and Scotland, 2002’, to which reference is also made. This stresses the need for a holistic assessment of landscape character, including physical, biological and social factors.
LANDSCAPE/TOWNSCAPE EFFECTS
M3 Landscape/townscape quality is a subjective judgement based on the value and significance of a landscape/townscape. It will often be informed by national, regional or local designations made upon it in respect of its quality e.g. AONB. Sensitivity relates to the ability of that landscape/townscape to accommodate change.
Landscape sensitivity can vary with:-
(i) existing land use; (ii) the pattern and scale of the landscape; (iii) visual enclosure/openness of views, and distribution of visual receptors; (iv) the scope for mitigation, which would be in character with the existing landscape; and (v) the value placed on the landscape.
M4 There is a strong inter-relationship between landscape/townscape quality and sensitivity as high quality landscapes/townscapes usually have a low ability to accommodate change.
M5 For the purpose of our appraisal, landscape/townscape quality and sensitivity has been combined and is assessed using the criteria in Table LE1. Typically, landscapes/townscapes which carry a quality designation and which are otherwise attractive or unspoilt will in general be more sensitive, while those which are less attractive or already affected by significant visual detractors and disturbance will be generally less sensitive.
M6 The concept of landscape/townscape value is also considered, in order to avoid consideration only of how scenically attractive an area may be, and thus to avoid undervaluing areas of strong character but little scenic beauty. Landscape value is:
‘The relative value that is attached to different landscapes by society, bearing in mind that a landscape may be valued by different stakeholders for a whole variety of reasons.’
M7 Nationally valued landscapes are recognised by designation, such as National Parks and Areas of Outstanding Natural Beauty (‘AONB’) which have particular planning policies applied to them. Nationally valued townscapes are typically those covered by a Conservation Area or similar designation.
M8 The magnitude of change is the scale, extent and duration of change to a landscape arising from the proposed development and was assessed using the criteria in Table LE2.
M9 Landscape/townscape effects were assessed in terms of the interaction between the magnitude of the change brought about by the development and the quality, value & sensitivity of the landscape resource affected. The landscape/townscape effects can be either beneficial or adverse.
M10 In this way, landscapes of the highest sensitivity and quality, when subjected to a high magnitude of change from the proposed development, are likely to give rise to ‘substantial’ landscape effects which can be either adverse or beneficial. Conversely, landscapes of low sensitivity and quality, when subjected to a low magnitude of change from the proposed development, are likely to give rise to only ‘slight’ or neutral landscape effects. Beneficial landscape effects may arise from such things as the creation of new landscape features, changes to management practices and improved public access. For the purpose of this appraisal the landscape effects have been assessed at completion of the development.
VISUAL EFFECTS
M11 Visual effects are concerned with people’s views of the landscape/townscape and the change that will occur. Like landscape effects, viewers or receptors are categorised by their sensitivity. For example, views from private dwellings are generally of a higher sensitivity than those from places of work. M12 In describing the content of a view the following terms are used:- No view - no views of the development; Glimpse - a fleeting or distant view of the development, often in the context of wider views of the landscape; Partial - a clear view of part of the development only; Filtered - views to the development which are partially screened, usually by intervening vegetation - the degree of filtering may change with the seasons; Open - a clear view to the development.
M13 The sensitivity of the receptor was assessed using the criteria in Table VE1.
M14 The magnitude of change is the degree in which the view(s) may be altered as a result of the proposed development and will generally decrease with distance from its source, until a point is reached where there is no discernible change. The magnitude of change in regard to the views was assessed using the criteria in Table VE2.
M15 Visual effects were then assessed in terms of the interaction between the magnitude of the change brought about by the development and also the sensitivity of the visual receptor affected.
M16 Photographs were taken with a digital camera with a lens that approximates to 50mm, to give a similar depth of view to the human eye. In some cases images have been joined together to form a panorama. The prevailing weather and atmospheric conditions, and any effects on visibility are noted.
M17 Unless specific slab levels of buildings have been specified, the appraisal has assumed that slab levels will be within 750mm of existing ground level.
MITIGATION AND RESIDUAL EFFECTS
M18 Mitigation measures are described as those measures, including any process or activity, designed to avoid, reduce and compensate for adverse landscape and/or visual effects of the proposed development.
M19 In situations where proposed mitigation measures are likely to change over time, as with planting to screen a development, it is important to make a distinction between any likely effects that will arise in the short-time and those that will occur in the long- term or ‘residual effects’ once mitigation measures have established. In this assessment, the visual effects of the development have been considered at completion of the entire project and once any landscape mitigation has had an opportunity to establish.
M20 Mitigation measures can have a residual, positive impact on the effects arising from a development, whereas the short-term impact may be adverse.
ASSESSMENT OF EFFECTS
M21 The appraisal concisely considers and describes the main landscape and visual effects resulting from the proposed development. The narrative text demonstrates the reasoning behind judgements concerning the landscape and visual effects of the proposals. Where appropriate the text is supported by tables which summarise the sensitivity of the views/ landscape, the magnitude of change and describe any resulting effects.
CUMULATIVE EFFECTS
M22 Cumulative effects are ‘the additional changes caused by a proposed development in conjunction with other similar developments or as the combined effect of a set of developments, taken together.’
M23 In carrying out landscape appraisal it is for the author to form a judgement on whether or not it is necessary to consider any planned developments and to form a judgement on how these could potentially affect a project.
ZONE OF THEORETICAL VISIBILITY (ZTV)
M24 A ZTV map can help to determine the potential visibility of the site and identify those locations where development at the site is likely to be most visible from the surrounding area. Where a ZTV is considered appropriate for a proposed development the following methodology is used.
M25 The process is in two stages, and for each, a digital terrain model (‘DTM’) using Key TERRA-FIRMA computer software is produced and mapped onto an OS map. The DTM is based on Ordnance Survey Landform Profile tiles, providing a digital record of existing landform across the UK, based on a 10 metre grid. There is the potential for minor discrepancies between the DTM and the actual landform where there are topographic features that are too small to be picked up by the 10 metre grid. A judgement will be made to determine the extent of the study area based on the specific site and the nature of the proposed change, and the reasons for the choice will be set out in the report. The proposed development is introduced into the model as either a representative spot height, or a series of heights, or a detailed 3D model of the development, and a viewer height of 1.7m is used. This is the first stage, or ‘bare earth’ ZTV which illustrates the theoretical visibility of a proposed development based on topography alone and does not take account of any landscape features such as buildings, woodland or settlements.
M26 The second stage is to produce a ‘with obstructions’ ZTV with the same base as the ‘bare earth’ ZTV, but which gives a more accurate representation of what is ‘on the ground’. Different heights are assigned to significant features such as buildings and woodland thus refining the model to aid further analysis. This data is derived from OS Maps and aerial photographs, and verified during the fieldwork, with any significant discrepancies in the data being noted and the map adjusted accordingly. Fieldwork is confined to accessible parts of the site, public rights of way, the highway network and other publically accessible areas.
M27 The model is based on available data and fieldwork and therefore may not take into account all development or woodland throughout the study area, nor the effect of smaller scale planting or hedgerows. It also does not take into account areas of recent or continuous topographic change from, for instance, mining operations.
Table LE 1 LANDSCAPE / TOWNSCAPE QUALITY, SENSITIVITY AND VALUE
Very High High Medium Low
Landscape Quality: Intact and very attractive landscape which may benationally recognised/designated for its scenic beauty. e.g. National Park or Area of Outstanding National Beauty
Townscape Quality: A townscape of very high quality which is unique in its character, and recognised nationally/internationally. e.g. World Heritage Site
Sensitivity: A landscape/townscape with a very low ability to accommodate change because such change would lead to a significant loss of valuable features or elements, resulting in a significant loss of character and quality. Development of the type proposed would be discordant and prominent.
Value: Very high quality landscape or townscape Landscape Quality: A landscape, usually combining varied with Statuatory designation for landscape/ topography, historic features and few visual detractors. A landscape townscape quality, eg. National Park, known and cherished by many people from across the region. e.g. conservation area or registered park or County Landscape Site such as a Special Landscape Area. garden. Townscape Quality: A well designed townscape of high quality with a locally recognised and distinctive character e.g. Conservation Area
Sensitivity: A landscape/townscape with limited ability to accommodate change because such change would lead to some loss of valuable features or elements, resulting in a significant loss of character and quality. Development of the type proposed would likely be discordant with the character of the landscape/townscape.
Value: High quality landscape or lower quality landscape or with un-fettered public access, eg. commons, public park Landscape Quality: Non-designated landscape area, generally or designated landscape. pleasant but with no distinctive features, often displaying relatively ordinary characteristics.
Townscape Quality: A typical, pleasant townscape with a coherent urban form but with no distinguishing features or designation for quality.
Sensitivity: A landscape/townscape with reasonable ability to accommodate change. Change would lead to a limited loss of some features or elements, resulting in some loss of character and quality. Development of the type proposed Landscape / Townscape Quality: Unattractive or degraded would not be especially discordant. landscape/townscape, affected by numerous detracting elements e.g. industrial areas, infrastructure routes and un- Value: A landscape of local value which may have restored mineral extractions. limited public access. No recognised statutory Description of the Landscape/Townscape designation for landscape / townscape quality. Sensitivity: A landscape/townscape with good ability to accommodate change. Change would not lead to a significant loss of features or elements, and there would be no significant loss of character or quality. Development of the type proposed would not be discordant with the landscape/townscape in which it is set.
Value: Landscape generally of poor quality with no public access, no designations or recognised cultural significance.
Footnote: 1. A distinction has been drawn between landscape/townscape quality and sensitivity. Quality is as a subjective judgement on perception and value of a landscape/townscape and may be informed by any national, regional or local designations for its quality. Sensitivity relates to the ability of that landscape/townscape to accommodate change. Table LE 2 LANDSCAPE / TOWNSCAPE MAGNITUDE OF CHANGE Table LE 3 LANDSCAPE / TOWNSCAPE EFFECTS
High Medium Low Negligible Neutral Substantial Moderate Slight Neutral
The proposals are damaging to the Total loss of or landscape/townscape in that they: severe damage to key characteristics, • are at variance with the landform, features or scale and pattern of the landscape/ elements townscape; • are visually intrusive and would disrupt important views; • are likely to degrade or diminish the integrity of a range of characteristic Partial loss of or features and elements and their damage to key setting; characteristics, • will be damaging to a high quality features or or highly vulnerable landscape/ townscape; elements • cannot be adequately mitigated. The proposals are:
• out of scale or at odds with the landscape; • are visually intrusive and will adversely impact on the Minor loss of or landscape/townscape;
alteration to one or • not possible to fully mitigate; • will have an adverse impact more key landscape/ on a landscape/townscape townscape of recognised quality or on characteristics, vulnerable and important features or elements characteristic features or elements.
The proposals:
• do not quite fit the landform Very minor loss and scale of the landscape/ townscape; or alteration to • will impact on certain views into one or more key Description of the Effect and across the area; landscape/townscape • cannot be completely mitigated characteristics, features for because of the nature of the or elements proposal or the character of the landscape/townscape; • affect an area of recognised Description of the Change predicted landscape/townscape quality.
The proposals:
No loss or alteration • complement the scale, landform and of key landscape/ pattern of the landscape/townscape; • incorporate measures for mitigation to townscape ensure that the scheme will blend in characteristics, well with the surrounding landscape/ features or elements townscape; • avoid being visually intrusive and adversely effecting the landscape/ townscape; • maintain or improve existing landscape/townscape character.
Footnote: 1. Each level (other than neutral) of change identified can be either regarded as ‘beneficial’ or ‘adverse’.
Table VE 1 VISUAL SENSITIVITY
High Medium Low
Residential properties with predominantly open views from windows, garden or curtilage. Views will normally be from ground and first floors and from two or more windows of rooms in use during the day.
Users of Public Rights of Way with predominantly open views in sensitive or unspoilt areas.
Non-motorised users of minor or unclassified roads in the countryside.
Visitors to recognised viewpoints or beauty spots.
Users of outdoor recreational facilities with predominantly open views where the purpose of that recreation is enjoyment of the countryside - e.g. Country Parks, National Trust or other access land etc.
Residential properties with partial views from windows, garden or curtilage. Views will normally be from first floor windows only, or an oblique view from one ground floor window, or may be partially obscured by garden or other intervening vegetation.
Users of Public Rights of Way with restricted views, in less sensitive areas or where there are significant existing intrusive features.
Users of outdoor recreational facilities with restricted views or where the purpose of that recreation is incidental to the view e.g. sports fields.
Schools and other institutional buildings, and their outdoor areas.
Users of minor or unclassified roads in the countryside, whether motorised or not. Description of the Receptor
People in their place of work.
Users of main roads or passengers in public transport on main routes.
Users of outdoor recreational facilities with restricted views and where the purpose of that recreation is unrelated to the view e.g. go-karting track. Table VE 2 VISUAL MAGNITUDE OF CHANGE Table VE 3 VISUAL EFFECTS
High Medium Low Negligible Neutral Substantial Moderate Slight Insignificant Neutral
Dominating changes The proposals would over all or most of the cause significant damage view(s). (or improvement) to a view from a sensitive receptor, or less damage (or improvement) to a view from a more sensitive receptor, and would be an obvious or dominant element in the view.
Major changes over a large proportion of the view(s). The proposals would cause some damage (or improvement) to a view from a sensitive receptor, or less damage (or improvement) to a view from a more sensitive receptor, and would be a readily discernible element in the view.
Major changes over a small proportion of the The proposals would view(s). cause limited damage (or improvement) to a view from a receptor of medium sensitivity, but would still be a noticeable element within the view, or greater damage (or improvement) to a view from a receptor of low Description of the Effects sensitivity.
Minor changes over a small Description of the Change predicted proportion of the view(s).
The proposals would not significantly change the view but would still be discernible.
No discernable change to the view(s) No change in the view.
Footnote: 1. Each level (other than neutral) of change identified can be either regarded as ‘beneficial’ or ‘adverse’.
Turley Office The Pinnacle 20 Tudor Road Reading RG1 1NH
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