Central Bedfordshire Local Plan: Proposed Submission Consultation Representations on Behalf of Wavendon Properties Ltd

The Aspley Guise Triangle

1. The Council identify the Aspley Guise Triangle as one of a number of ‘safeguarded’ locations, which are not allocated within the current draft Local Plan, but which would be considered as a potential location for development within a future partial review of the Plan. We are concerned that the Council’s decision to put off allocating the site at this stage leaves significant uncertainty over when and whether this site will be allocated. It is one of a number of sites which are required to meet current and long-term housing and employment needs, and their early allocaton is required in order to allow for the timely delivery of the housing, jobs and infrastructure required.

The Need for Housing

2. We have commented in our separate representation that the proposed housing target is far too low both to meet immediate housing needs, and also to meet the Governments aspirations for long-term economic growth. There are compelling reasons which suggest a need to substantially increase the housing land suppy within the Borough, both immediately and in the long-term. There is also a pressing need for development which has the potential to make a positive contribution towards development in the Oxford-Milton Keynes-Cambridge arc, which the Government expect to be a major driving force for the national economy into the future. The Government’s Autumn Budget set out a requirement for 1 million new homes in this arc by 2050; this is based on a report by the National Infrastructure Commission (NIC) which sets out the case for effectively doubling the level of house building in the arc over this period. This is the broad context in which the new Local Plan and proposals for housing must be viewed.

3. The SA makes clear that the Council have rushed the current consultation out, so as not to have to provide a higher level of housing1. We believe that the proposed level of housing is far below the level required to meet local needs. This is firstly due to the Council’s having calculated an objectively assessed need (OAN) for housing which is well below the actual level of need. It is also due to their having removed proposals for additional housing, which would provide a contingency against the non-delivery of housing on one or more of the Council’s proposed sites, and which would ensure that the Council would be able to provide a more robust rolling 5-year housing land supply.

4. The draft Local Plan is very substantially short of housing, when compared with the level which is actually required. There is a pressing need to identify further suitable sites immediately. The Council propose to put off the identificaton of further sites to a focussed review of the Plan, but this will simply delay their

1 Central Bedfordshire Council, Sustainability Appraisal, Jan 2018, p.148

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delivery. To do so would both fail to meet immediate needs, and also threaten the success of the Government’s long-term economic objectives, as set out in the NIC report and Autumn Budget.

The Sustainability Appraisal’s Findings

5. The most recent version of the Sustainability Appraisal (SA, January 2018) explains at Table 5.3 that five potential growth scenario options were considered, involving different overall levels of housing, and different potential site allocations. The scenarios ranged from 20,650 to 30,500 additional dwellings; as such, they all represented a greater amount of housing than was actually proposed in the current draft Local Plan, which proposes to allocate a 18,302 additional dwellings.

6. Of the five scenarios considered, four included 3,000 dwellings at Aspley Guise. The scenario which omitted the site was the one which proposed the lowest level of development, albeit it was also the only one which also included an additional 2,500 dwellings to be spread across the villages. This is arguably the least sustainable of all of the scenarios tested, both in terms of the overall level of development proposed, and also the distribution of growth. The inclusion of the Aspley Guise Triangle in all of the more realistic scenarios strongly suggests that the Council intended to allocate the site until a late stage in the plan-making process.

7. When considering these development scenarios, the Council did not consider there to be any impediments to the delivery of housing at Aspley Guise. The SA sets out a very positive view of the site, and at Table 5.7 it identifies that allocation of the site would provide a number of benefits, as follows:

• ‘Proximity to the EW Railway & Ridgmont Station, proposed Expressway, and its location in the Cambridge–Oxford Growth Corridor.

• Opportunity to support travel to work due to proximity to strategic road network and sustainable transport options.

• Potential of the Broad Location to help establish the new Bedford- Milton Keynes Waterway and opportunities for increased biodiversity and open space and leisure opportunities along the waterway, including cycle routes

• Opportunity to create a buffer to protect the setting of Aspley Guise

• Opportunity to designate Green Belt to protect the setting of Aspley Guise.

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• Potential for the provision of a Park and Ride to serve Milton Keynes.’

8. A more dertailed assessment is contained in Appendix VIIb of the SA, which considers all of the ‘safeguarded broad location options’. This sets out a number of key positive effects, which relate to matters such as its suitable location on the edge of Milton Keynes, its existing rail, bus and road linkages, and the potential to enhance these, as well as providing the park and ride site mentioned above. The site is also close to existing employment areas. It is seen as having the potential to achieve enhacements to net biodiversity, the landscape and green infrastructure, and a reduction in carbon emissions through its facilitation of sustainable transport.

9. In contrast to what are 11 key positive effects, only two potential negative effects are listed, which relate to the loss of agricultural land, and the potential for an increase in traffic on the local road network. With regard to the first of these, agricultural land classification maps indicate that the area is Grade 3, which may be best and most versatile (Grade 3a) or not (Grade 3b); nearby land is Grade 4, which suggests that the land in this area is not of the highest quality. We also note that the loss of agricultural land is inevitable in a number of locations, if the housing and jobs required are to be provided. With regard to the second point, the SA notes that a negative effect on the road network is uncertain, as there is both the scope for junction improvements to accompany the new development (and the provision of the Expressway), and the provision of a park and ride within the site, plus bus and rail connections, will provide many opportunities for travel by sustainable means.

10. There is no suggestion in the SA that the Aspley Guise Triangle is anything other than a suitable location for development.

Discussion of the Local Plan’s Proposals

11. The draft Local Plan gives the following explanation for the failure to allocate the site:

‘Not progressed as a Strategic Allocation to allow time for identification of the proposed Expressway and associated road and junction improvements.’

12. The decision on the route of the proposed Expressway is anticipated in 2021, at which time the local plan will still have 14 years left to run. The route of the Expressway may have an effect on the capacity of the Aspley Guise Triangle, but it would not preclude development taking place. The site is large enough to accommodate 3,000 dwellings, a park and ride, employment and substantial

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green infrastructure. Should the Expressway be routed through the site, it will inevitably influence the design of a future Masterplan, but it would not sterilise the site, or prevent it from providing a substantial amount of new development.

13. Looking a short distance across the Borough boundary from the Aspley Guise Triangle, Milton Keynes Borough, who published their pre-submission draft Local Plan at the end of 2017, are seeking to allocate a similarly sized new residential development of around 3,000 dwellings on the route of the east-west rail line (referred to as the South East MK Urban Extension). Policy SD13 of the draft Plan:MK simply states that ‘Planning permission for housing and associated uses will not be permitted until 2019/20, once the detailed alignment of the Cambridge–Milton Keynes-Oxford Expressway is known’. It is unclear why a similar approach could not be taken for the Aspley Guise Triangle.

14. Major new development sites take years to deliver, irrespective of wider infrastructure constraints. A recent report by Nathaniel Lichfield and Partners has examined average delivery times for large housing sites2 (defined as sites delivering 500 or more dwellings). It points to an average lead time for large sites, prior to the submission of a planning application, of 3.9 years, and an average of 5 years for planning approval to be issued, once applications are submitted. This planning process period rises to an average 6.1 years for sites involving 2,000+ dwellings. The evidence suggests that long lead times do not correlate with a short planning period. Thus, the averages can realistically be considered to be cumulative – an average 3.9 year lead time will on average be followed by a 6.1 year approval period for large sites. For sites of over 2,000 dwellings this average time increases to nearly 7 years.

15. The Council propose to wait until there is certainty over the route and funding of new strategic infrastructure before identifying new development opportunities. The Council’s stance suggests that they may not make any substantive progress on a new Local Plan until after the Government has made a series of announcements about this new infrastructure, which may happen as late as 2021. By the time such a Local Plan had then been drafted and subject to examination, it may well not be adopted until closer to the mid-2020s. Adding the average time to deliver large sites, such as the Aspley Guise Triangle (c. 3,000 dwellings), it could be close to the end of the Plan period before any housing is provided. Other sites, such as a larger new settlement for instance, may take longer to deliver.

16. These timescales must be considered in light of the requirements set out in the NIC report and Autumn Budget, for 1 million new homes to be provided in this arc by 2050. If it is necessary to effectively double the current level of supply in a

2 Nathaniel Lichfield and Partners ‘Start to Finish: How Quickly do Large Housing Sites Deliver?’ (Nov 2016).

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period of 32 years, it is essential that this process should happen as quickly as possible, to provide the best possible prospect that it wil happen. If, however, the sites to do this will not have planning permissions in place until, say, 14 years have elapsed, it becomes highly unlikely that the Government’s target will be met in the remaining 18 years.

17. The essential problem with the draft Local Plan is that it seeks to put off the difficult decisions until an unspecified future time. This will simply lead to a further delay in the delivery of new housing and jobs. What is required is a strategic lead from the current draft Local Plan. It can, at the very least, identify broad areas for new development. This would provide the development industry with certainty, and allow it to begin work on their planning and delivery. This would in turn enable the timely delivery of new development.

18. The Council’s track record is also relevant. They have consistently failed to provide more housing than the absolute minimum possible. Their own SA indicates that this has once again been their aim. The draft Local Plan appears to be attempting to cover its own deficiencies with a claim that all will be made good in a future review. The issue which must be considered in the examination of this Local Plan is whether it meets the relevant requirements now.

19. The Council’s long-term desire to restrict development has led to the past two iterations of the Local Plan being abandoned. The first in 2011, when Luton Borough withdrew their support for a Joint Core Strategy which would not have adequately met their housing needs. The second was in 2015, when an Inspector concluded the Council had not met the Duty to Co-Operate, again in relation to Luton’s housing needs. The housing numbers being considered then were small in comparison to those implied by the need to boost housing to meet the Government’s objectives.

20. We believe that there is a substantial risk that the Council will not make the rapid progress required in a review of its Local Plan. To adopt the Local Plan as it is drafted would confirm an unacceptably low level of housing, and presumably provide the Council with a viable 5 year housing land supply. There would be no clear incentive for the Council to make rapid progress in identifying further sites for development, in a move which would be entirely contrary to its recent track record.

Conclusions

21. There is a substantial and pressing need for housing, both to meet local needs, and the Government’s strategic economic objectives. The Council have given no good reason for not allocating a number of sites, including the Aspley Guise Triangle, within the current draft Local Plan. The Plan is very short of housing sites, providing as it does a lower level of housing to that envisaged by the

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previous Local Plan consultation, and little contingency against the non-delivery of one or more of its strategic sites.

22. The Council has, however, already concluded that the Aspley Guise Triangle would be a suitable location for development. The SA notes a long list of social, economic and environmental benefits, and little or no substantive negative effects. The Council’s stated reason for delaying the allocation of the site, in waiting for the route of the new east-west Expressway, does not stand up to scrutiny; it would not prevent development, and would simply need to be considered in the development of the Masterplan.

23. There is a clear benefit in allocating this site now. It would provide certainty to developers and landowners, allowing preliminary work to be begun, so as to shorten the lead time in delivering the site after the announcement of the route of the Expressway in 2021. In light of our comments above, we believe that the Local Plan must be amended to allocate the Aspley Guise Triangle.

Soundness

24. The Local Plan is unsound, because it has not been positively prepared to enable the new housing, jobs and infrastructure which are clearly required. The SA is clear in its explanation that the Plan has been prepared in a hurry, so as to allow the Council to adopt a constrained housing target, in advance of the Government’s proposals to introduce a standardised approach to calculating housing need. The Council have identified suitable sites, but then simply decided not to allocate them at this stage.

25. The Local Plan would not be effective in meeting the long-term need for housing jobs and infrasructure in a timely manner, due to the Council’s proposal to leave the allocation of key sites to a later date. It is not certain whether or when these sites would be allocated, despite their having been shown to be both required and suitable.

26. The Council’s decision to omit this site is not justified. The presence or otherwise of the east west Expressway will not prevent the Aspley Guise Triangle from being delivered.

27. Due to the various shortcomings listed above, and particularly the fact that the Plan fails to respond to the requirements of the Autumn Budget, the proposed level of housing is not consistent with national policy.

Required Change to the Plan

28. The Aspley Guise Triangle should be allocated for development within this Local Plan, and the matter should not be left to a future review.

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