Central Bedfordshire Pre-Submission Local Plan 2015-2035

Responses on behalf of Rainier Developments

Land North of Greyhound Stadium, Lower Stondon

February 2018

Central Bedfordshire Pre-submission Local Plan 2015-2035

Responses on behalf of Rainier Developments Land North of Greyhound Stadium, Lower Stondon

Project Ref: 28292/A5/P1/PD/SO 28292/A5/P1/PD/SO Status: Draft Final Draft Issue/Rev: 01 02 Date: February 2018 22 February 2018 Prepared by: Paul Derry Paul Derry Checked by: Gareth Wilson Gareth Wilson Authorised by: Gareth Wilson Gareth Wilson

Barton Willmore St Andrews House St Andrews Road Cambridge CB4 1WB

Tel: 01223 345 555 Ref: 28292/A5/P1/PD/SO File Ref: 28292.P1.PSLP.PD Date: February 2018

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CONTENTS

1.0 Introduction 2.0 The Site 3.0 Stondon Site Assessment 4.0 Policy SP1: Growth Strategy 5.0 Policy HA1: Small and Medium Allocations 6.0 Summary

APPENDICES

Appendix 1: Strategic Vision Document Appendix 2: Site Specific Proposal Document Appendix 3: Review of Housing Need and Land Supply Appendix 4: Landscape, Ecological and Arboricultural Assessment Appendix 5: Transport Assessment

Introduction

1.0 INTRODUCTION

1.1 These representations have been prepared by Barton Willmore on behalf of Rainier Developments in respect of the Central Bedfordshire Pre-submission Local Plan 2015- 2035. They are submitted pursuant to the promotion of land north of the Greyhound Stadium, Bedford Road, Lower Stondon (the “Site”). The representations should be read in conjunction with the supporting Vision Documents and accompanying consultant reports (attached as appendices).

1.2 The Site was previously considered by Central Bedfordshire Council (CBC) under the recent Call for Sites exercise as site ALP304 – Land West of Bedford Road (note for the purposes of this document, the site definition has been amended). The result of the associated site assessment stated the following:

“There are concerns relating to the development of the site in that the site forms part of the rural landscape setting to Stondon and it is considered that it should be retained as such to avoid sprawl. The site is also located adjacent to the greyhound stadium and has the potential to form a comprehensive development with appropriate landscape buffering.”

1.3 These representations are accompanied by various assessments, including the Strategic Vision Document and Site Specific Proposal Document, which demonstrate that the Site is suitable for development as a standalone Site, and forms a logical future extension to Lower Stondon.

1.4 These representations provide comment on specific policies within the draft Local Plan. The conclusion of the representations confirms there is no sound reason to exclude the Site, which would be a missed opportunity for the village and CBC.

1.5 Rainier Developments wish to participate within the Examination in Public on the matters discussed below.

28292/A5/P1/PD/SO Page 1 February 2018 The Site

2.0 THE SITE

2.1 The Site extends to 3.41 hectares in area and is located to the west of the A600 Bedford Road. The Site is currently in agricultural use. To the north of the Site are a small number of residential properties and land to the west is currently in agricultural use. To the east is the camp at RAF Henlow and to the south is the Henlow greyhound stadium. Further south, at the junction between the A600, the A659 Hitchin Road, and Station Road, there are numerous retail units and services in a variety of uses.

2.2 Public footpaths run along the southern and western boundaries of the Site. There is good screening along the north and southern boundaries, while the planting along the western boundary would need to be enhanced. The eastern boundary, considered to be the Site frontage, is open. The land rises gently to the west.

2.3 The supporting Vision Document presents the development opportunity within Lower Stondon. It provides a summary of the services and facilities within Stondon and Henlow Camp. Whilst Henlow Camp is within a separate Parish, the built development of the two directly adjoin, and therefore Stondon and Henlow Camp effectively share facilities.

2.4 Using CBC’s site capacity methodology, the Site has the potential to accommodate 61 dwellings. However, detailed capacity studies documented within the Proposal Document demonstrates that the Site could in fact accommodate up to 100 dwellings with open space, landscape buffering and necessary drainage attenuation. CBC’s consideration of site capacity follows a high level assessment, rather than a site specific assessment. As such, CBC’s capacity estimate does not make best use of the sustainable land available.

2.5 The provision of 100 dwellings in this sustainable location would assist CBC in meeting its increased housing need. The Site is immediately available, under single ownership and its capacity ensures it can be delivered within a short timeframe, and will therefore positively contribute to CBC’s five year housing land supply. This is important in an authority reliant upon larger strategic sites which take longer to commence due to complex infrastructure requirements. Reliance on such strategic sites presents the very real risk that the Plan will be found ‘unsound’.

2.6 Rainier Developments have opened discussions with Stondon Parish Council, and will seek to work with them to identify whether the scheme can incorporate or contribute towards any identified needs/facilities within the village.

28292/A5/P1/PD/SO Page 2 February 2018 Stondon Site Assessment

3.0 STONDON SITE ASSESSMENT

3.1 The previous assessment of the Site by CBC (site ALP304 – Land West of Bedford Road) applied a traffic light system for grading sites. The Site scored green with regards to the relationship to the settlement and whether the development forms a logical extension (q.6), with the assessment noting the lack of physical constraints separating the Site from Lower Stondon. However, later in the assessment, it scored red with regards to this relationship (q. 23), which states developing the Site would not be complementary to the existing settlement pattern as the Site ‘does not abut the settlement envelope’.

3.2 As shown, there is a clear contradiction within the assessment. CBC state in question 6 that the Site forms a logical extension to the settlement, and the illustrative layout within the attached Proposal Document clearly demonstrates this to be the case. The Greyhound Stadium itself is built form, with its main ancillary buildings set to the north of the track, close to the Site. This ensures the Site would not be considered detached or isolated from the existing built environment of Stondon. The Site would therefore form the logical next phase of development within Lower Stondon, as demonstrated within the village evolution chapter of the Vision Document.

3.3 This case is strengthened by the Greyhound Stadium being included within draft allocation HAS46, which again demonstrates the sustainability of this area of the settlement. Also, the RAF Henlow site is allocated within the draft Local Plan (policy SE4) for up to 85 hectares of specialist high-technology, science, research and development uses. When developed, the Site will be directly adjacent to built form on two sides. This demonstrates sound planning principles to developing the Site for residential uses adjacent to an employment centre creating a truly sustainable settlement extension.

3.4 The Site scores red on the cumulative impact of development over the last 10 years. The number of dwellings within Stondon is increasing. However, this demonstrates the sustainability of the settlement and the number of facilities within both Stondon and Henlow Camp. The draft allocation of RAF Henlow for employment use further demonstrates the desire for development of the area, which should be supplemented with further housing. The Site should not therefore score negatively on this criteria.

3.5 The Site Assessment demonstrates that the Site can meet the ‘critical infrastructure requirements that will enable delivery’, and scores a green for this criteria. The Site is considered very sustainable given the shared facilities within Stondon and Henlow Camp, all of which will be within a short walking distance. It scores negatively given the lack of

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railway station. However, Stondon is well served by buses, which provide regular services to Bedford, Hitchin and Sandy main line railway stations, and fast connections to central London.

3.6 The Site scores a red with regard to landscape character (q.36), and the overall conclusion suggests this is the key concern preventing the Site coming forward for development.

3.7 A landscape assessment has been prepared which advises the following pertinent points:

• The Site has less of a character, visual and physical, relationship with the wider open countryside, and more of a relationship with the surrounding built up areas; • Due primarily to the enclosure created by existing landscape features within the local context and intervisibility with existing built form, the Site has a reduced landscape sensitivity; • The Site is barely perceptible from the wider setting and has well-established urbanising influences in close proximity to it; and • The development of the Site provides an opportunity to enhance and augment the remaining landscape features across the Site and along its boundaries.

3.8 The landscape assessment clearly demonstrates that development of the Site would not therefore cause harm to the landscape character of the village. Further assessments (attached) cover the disciplines of ecology, highway safety, and arboriculture. No adverse issues have been identified that would prevent development of the Site coming forward. As a result, the Site is considered to meet the criteria for allocation within the Local Plan, and forms a logical extension to the village.

28292/A5/P1/PD/SO Page 4 February 2018 Policy SP1: Growth Strategy

4.0 POLICY SP1: GROWTH STRATEGY

4.1 Policy SP1 builds upon the spatial strategy, which highlights the proposed levels of development within the plan period. We note CBC’s recognition for the need for 39,350 dwellings to be delivered in Central Bedfordshire over the plan period (2015-2035).

4.2 It is evident that the number of homes proposed within policy SP1 remains too low for CBC. The Government’s Standardised Methodology has calculated that CBC’s Objectively Assessed Need (OAN) would rise from 1,600 to 2,553 dwellings per annum, an increase of 60% and 953 dwellings per annum. The proposed housing numbers within Policy SP1 therefore is in direct conflict with the housing numbers highlighted within the standardised methodology. This standardised figure reflects a more accurate need for housing which should be planned for positively across CBC. We therefore emphasis that the Site, considered to be situated in a highly sustainable location, can make an important positive contribution towards CBC’s objectively assessed need.

4.3 A Review of Housing Need and Land Supply has been undertaken by Lichfields in February 2018, and this is available in Appendix 3. This document reviews CBC’s evidence base, appraises the housing trajectory and five year land supply position, and considers whether the Council tested reasonable alternatives in establishing its preferred approach. The conclusions of the report of these topics states the following:

• The evidence base for the SHMA is not robust, and seeks significant downward adjustment to the projections. The demographic assessment within the SHMA is considered flawed, and it does not demonstrate a 10% uplift would reasonably be expected to improve affordability. The Lichfields analysis suggests an uplift of at least 20% would be needed in CBC. • The overall housing trajectory is deficient, with the scale of shortfall too large, and significant enough to require the identification of further supply (sites) now. CBC would not have five year housing land supply when measured against the realistic and achievable land supply. • The Regulation 19 spatial strategy is lower than Regulation 18, with no justification as to why. The growth strategy has not been tested through the Sustainability Assessment procedure, and the Sustainability Assessment has failed to consider all reasonable alternatives in line with policy guidance.

4.4 Paragraph 5.7 of the Lichfield assessment included at appendix 3 states:

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“The alternative estimate of objectively assessed housing need is lower than the CLG proposed standard methodology for local housing need, which is 2,553 dpa for Central Bedfordshire, or 51,000 in total over 20 years, and excludes any further unmet need arising from Luton, which subject to its Local Plan Review could be around 20,000 dwellings. This increased unmet need would most likely need to be met in Central Bedfordshire, given this is where most of Luton’s functional HMA lies, which would equate to a total requirement for Central Bedfordshire would be upwards of 70,000 dwellings over 20 years – almost double the target in the emerging Plan.”

4.5 The Growth Strategy places great emphasis on strategic development. The new sites being proposed include 4,000 homes north of Luton, a new village for 5,000 at Marston Vale, and 2,000 and 1,500 homes east of Arlesey and Biggleswade respectively. These are large scale strategic projects that will require significant planning and upfront infrastructure, that is invariably complex, often with fragmented ownership, and fraught with delays. The new village at Marston Vale, for example, is not expected to be delivering meaningful completions until well in to the 2020s.

4.6 The Lichfield report does critique the north Luton and Marston Vale sites when assessing housing delivery. CBC must have realistic expectations to ensure they commence delivery within the timeframes provided, and the evidence provided suggest the proposed delivery rates are very optimistic. Factors such as the early provision of infrastructure have caused significant delays for strategic allocations throughout the country. Offsetting likely delays with a greater number of smaller allocations will greatly assist this and make the plan more effective in line with paragraph 182 of the NPPF.

4.7 CBC recognises the need to partake in an early review of the Local Plan given various ‘unknowns’ at this time. This includes the Cambridge-Milton Keynes-Oxford arc and East- West rail, details for which are likely to be published in the near future. Both of these significant infrastructure projects will bring great opportunities for Central Bedfordshire, and with it greater demand for housing and employment facilities. In acknowledging the need for a review, CBC must anticipate the need for increased housing and employment numbers.

4.8 CBC will require a number of further sites in order to meet this identified shortfall. Lower Stondon is well placed to accommodate further growth for the reasons discussed in these representations, and the proposed Site is a logical location for housing.

28292/A5/P1/PD/SO Page 6 February 2018 Policy HA1: Small and Medium Allocations

5.0 POLICY HA1: SMALL AND MEDIUM ALLOCATIONS

5.1 We support the provision of smaller and medium sites within the local plan. Typically, such projects have significantly reduced infrastructure requirements when compared to larger allocations. As a result, they can assist CBC in achieving their necessary five year housing land supply by ensuring various schemes are delivering homes at any one time, and where one delay to a scheme would not materially impact delivery rates, unlike a strategic site.

5.2 The latest Annual Monitoring Report 2015/16 demonstrates this need for smaller sites in assisting the maintenance of a five year housing land supply. The information within the report notes that, at the time of writing, the five year housing land supply was 4.76 years as of 1 April 2016, and 4.82 years as of 1 July 2016. Whilst it is acknowledged this information has been updated, it demonstrates the need for further Sites in order to ensure the housing supply is continually met. By providing 100 dwellings within a sustainable location, the Site can assist in ensuring this need is fully met.

5.3 Policy HA1 already demonstrates the sustainable nature of Stondon as a Large Village. The adjacent Henlow Camp has numerous services and facilities, mostly based around the roundabout south the proposed Site. The facilities include two convenience stores, a pharmacy, a post office, an estate agent, takeaway food outlets, a hairdressers, a café and restaurant, a petrol station, a car showroom, and a public house. It is therefore a sustainable settlement. Given its provision of services, it is considered that Stondon has the capacity to accommodate a significant number of dwellings in addition to those committed to.

5.4 The existing RAF Henlow Camp to the east of the Site is considered appropriate for redevelopment in line with Policy SE4 (Former RAF Base, Henlow). The Camp is considered capable of providing 85 hectares of employment land. Given the nature of the employment use (high-technology, science, research and development), this will create a significant level of employment.

5.5 The Site is directly adjacent to RAF Henlow, and is located approximately 650m from the entrance to the Camp. As such, it is within easy walking distance. The Site is therefore in a prime location for new residential development that will assist in meeting the increased housing demand within the village that will benefit the redevelopment of RAF Henlow.

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5.6 We would raise concerns regarding the timeframes for the Local Plan as published in the Local Development Scheme January 2017 (LDS). At present, the deadline for representations is 22 February 2018, and the LDS seeks submission of the Local Plan to the Secretary of State in March 2018 in order to meet the 31st March 2018 deadline where the standardised methodology may then be utilised, subject to the publication of the new NPPF. This does not give adequate time for CBC to assess the proposals adequately to ensure the correct decisions are made. We would reiterate the recommendations for the Site to be reassessed given material changes in circumstances set out in this document.

5.7 The attached site specific Vision Document demonstrates the Site is capable of delivering sustainable development. However, to fully assess this against other sites will take more time than is being allowed. CBC is risking the Local Plan to be found unsound in trying to ‘beat’ the 31 March deadline for submission. The letter dated 30 January 2018 from Steve Quartermain confirms the ambition to publish the final revised NPPF in the summer of 2018, giving CBC more time to properly consider and assess the proposal. All opportunities should be explored to ensure the Plan is robust prior to submission.

28292/A5/P1/PD/SO Page 8 February 2018 Summary

6.0 SUMMARY

6.1 These representations have been drafted on behalf of Rainier Developments, pursuant to land interests north of the Greyhound Stadium, Lower Stondon. The land is considered appropriate for residential development, and would have a capacity for up to 100 dwellings. These representations are accompanied by a Vision Document, which assesses the Site in detail and provides an illustrative masterplan. This shows how the 100 dwellings can easily be achieved on the Site, whilst also providing adequate open space and additional landscape planting.

6.2 The Site was previously assessed by CBC following the Call for Sites exercise, and they identified a concern regarding the impact upon the landscape character of the village. The accompanying EDP Landscape Assessment findings confirm the effect upon the landscape character and visual amenity should not preclude development of the Site. It also notes opportunities for enhancement, which would create benefits for the village as a whole. The previous reasoning for excluding the Site as an allocation is therefore not considered sound.

6.3 Comments are provided regarding two key policies: those relating to the growth strategy and the small and medium housing allocations. These policies are essential in ensuring housing supply meets the need within CBC. Concern is noted regarding the identified objectively assessed housing need, which is significantly lower than when calculated using the proposed standardised methodology. The subsequent Lichfields report concludes the housing need in CBC is significantly higher than estimated.

6.4 The allocation of smaller sites is encouraged. However, the land north of the Greyhound Stadium is not currently one of CBC’s allocations. Having regard to the technical studies enclosed, including the landscape assessment, there is no logical reason for CBC to exclude the Site, particularly noting its proximity to key services and facilities and to the proposed employment allocation at RAF Henlow.

6.5 The Site is immediately available, in single ownership, and is able to deliver 100 dwellings in the short term early in the plan period. This would make an important contribution to CBC’s five year housing land supply.

6.6 The Site on land north of the greyhound stadium is therefore commended to CBC for development and should be allocated accordingly.

28292/A5/P1/PD/SO Page 9 February 2018

APPENDIX 1

Strategic Vision Document

LAND AT LOWER STONDON

CENTRAL BEDFORDSHIRE STRATEGIC VISION DOCUMENT

FEBRUARY 2018 Vision Statement

The Vision for the sites is to create a high quality The development will embrace best practice to create extension to the north and south of Lower Stondon an attractive, safe and sustainable community within Rainier Developments is a privately owned land and that reinforces the identity of the village and is well a strong soft landscape setting in close proximity development company operating across the UK. With extensive integrated both physically and socially. This Document to education, employment, recreation and retail experience within our executive team, chaired by Eric Grove, we identifies two areas that would create a sustainable opportunities. The aesthetic of the Vision will draw work collaboratively with landowners and key stakeholders to extension to Lower Stondon, and provide a mix of upon the best of local distinctiveness, to create bring forward development proposals to benefit all involved. housing types and tenures as well as associated open developments of exceptional quality that are assets to space that will help meet the identified need for the Village in the identified gateway locations. Our experience and track record is across the whole cycle of housing in Central Bedfordshire. As a result, it will the development process from early engagement with the local facilitate improvements to the physical and social community through to delivery. infrastructure of the village. This approach as a land promoter, aided by our carefully selected external consultants, allows us to ensure that each development is brought forward in a sustainable manner with the overriding aim of delivering much needed new housing to help local authorities meet their housing requirements. The land at Lower Stondon is being promoted by Rainier Developments as a sustainable extension to the village, working in conjunction with lead planning consultants Barton Willmore.

Figure 1. Aerial View of Sites

LOWER STONDON STRATEGIC VISION 2 3 LOWER STONDON STRATEGIC VISION ‘Land North of Henlow Greyhound Stadium Introduction is well enclosed on the northern and southern boundaries by mature trees and existing hedgerows that would benefit from new planting and habitat enhancement’ Background The site comprises part of one large field in agricultural (arable) use that extends from the Bedford Road to Manor Farm farmstead This Overarching Vision focusses on two sites within the village to the west. The site is well defined to the north and south by of Lower Stondon, and seeks to assist both Central Bedfordshire tree lined hedgerows. The alignment of a public footpath defines Council and Stondon Parish Council in the provision of sustainable the western boundary of the site. A public footpath also forms residential development. This is a key objective within the draft part of the southern boundary of the site, connecting the Bedford Central Bedfordshire Pre-submission Local Plan 2015-2035. The Road with the Meppershall Road to the west. The majority of the sites are located on the northern and southern edges of Lower land gently rises from east to west, facilitating views up to a local Stondon, a large village around 5 miles to the north of Hitchin and ridgeline around Manor Farm. 3 miles from Arlesey Station. This document has been prepared to facilitate initial discussion with the local community and key Land West of Bedford Road: The site is located at the southern stakeholders. end of the Village to the west of the A600 and comprises some 5.64 ha (13.93ac) of arable land. The line of an existing watercourse and development at Holwellbury Farm Cottages Site Description forms the northern boundary of the site with development at Land North of Henlow Greyhound Stadium: The site extends Plum Tree Road beyond. to approximately 3.41ha (8.43ac) and is located to the west of the Bedford Road, immediately north of the Greyhound Stadium and A treed landscape buffer forms the eastern boundary to Bedford west of the RAF Henlow base. (Figure 2). To the north of the site Road and the site is bounded to the south by a tree lined are a small number of residential properties, with a large pond hedgerow behind The Chestnuts. The western boundary of across the rear gardens associated with a former brick quarry. the site is marked by a linear copse, around which the arable field extends westwards to Holwellbury Farm. The site slopes gently downwards from south west to north east adjacent to the watercourse.

‘Land West of Bedford Road has a treed landscape buffer forming the eastern boundary to Bedford Road and is bounded to the south by a tree lined hedgerow behind The Chestnuts'

Figure 2. Map of Lower Stondon (sites edged red) Figure 3. (Top) View of Land North of Henlow Greyhound Stadium looking east from the PROW. (Bottom) View of Land West of Bedford Road looking west.

LOWER STONDON STRATEGIC VISION 4 5 LOWER STONDON STRATEGIC VISION The scaling of this drawing cannot be assured The scaling of this drawing cannot be assured 1885-1891 1901-1902 1925 1885-1891‘The analysis of the historical Revision 1901-1902 Date Drn Ckd 1925 Revision Date Drn Ckd evolution of Lower Stondon ------illustrates that the Sites are a logical Evolution of Lower Stondon next step in the evolution of the settlement pattern, consistent with the approach of infilling unconstrained areas along radial Introduction Historical Evolution Evolution Summary routes with good access to services Understanding a place is key to delivering integrated and The historical maps set out in Figures 4-7 show how the village The four previous images show how Lower Stondon has grown and public transport routes.’ responsive developments. This is not about copying the past, has changed since the 1890's. This highlights that the village has since the 1880s. Until the 1950s/ 1960s development in the rather it means understanding and interpreting the context of principally expanded around the Bedford Road/ Station Road village was modest (contrasting with the growth of the adjacent a particular site. In order to inform the master plan and design crossroad adjacent to Henlow Camp and north and south along RAF Henlow). From this period and in common with many

proposal for the site, the historic development and character of the Bedford Road. The scaling of otherthis drawing settlements, cannot be assured the village grew along the main radial routesThe scaling of this drawing cannot be assured The scaling of this drawing cannot be assured The scaling of this drawing cannot be assured 1885-1891 Lower1901-19021885-1891 Stondon has been analysed. 19251901-1902 1885-1891 1925Revision (Bedford1901-19021885-1891 Road andDate Station Drn CkdRoad), with infilling betweenRevision and 19251901-1902 Date Drn Ckd 1925Revision Date Drn Ckd Revision Date Drn Ckd - behind existing uses--- including Pollards Way and Orchard- Way west ------of the Bedford Road.

The scaling of this drawing cannot be assured The scaling of this drawing cannot be assured 1885-1891 1901-1902 19381925 1885-1891 1960 Revision 1901-1902 Date Drn Ckd 1977-1979 19381925 1960 Revision Date Drn Ckd 1977-1979 ------

Figure 8. 1885-1891 Figure 9. 1925 Figure 4. Historic Map dated 1885-1891 Figure 5. Historic Map dated 1925 1938 The19601938 historic cores of Lower and Upper Stondon are clearly visible, together with Henlow Lower1977-19791960 Stondon remains little1938 changed with the exception of 2 large commercial buildings 1977-1979 19601938 1977-19791960 1977-1979 Railway Station, public house at the Bedford Road and Station Road crossroads, and south of Station Road. This is in stark contrast with the significant and dramatic change to occasional scattered buildings between. A brick works is identifiable immediately north of land east of the railway with aircraft hangers, employment and accommodation buildings, the Land North of Henlow Greyhound Stadium. hospital, mortuary, rifle range and other uses associated with RAF Henlow clearly evident.

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Golf Couse Golf Couse bartonwillmore.co.uk bartonwillmore.co.uk Stanpit Stanpit Project Project Project Project House House N N N N Drain Drain Track Drain Track Drain Drain Drain Camp Camp Certificate FS 29637 Certificate FS 29637 54m 54m HENLOW CAMP HENLOW CAMP HENLOW CAMP HENLOW CAMP B B E E D D Figure 10. 1960 Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh FigureDrain 6. Historic Map dated 1960 Figure 7.Drain Historic Map dated 1982-1994 Figure 11. 1982-1994 F F O O R R D Derwent D Derwent R Lower School R Lower School Leeds London Manchester Newcastle Reading Southampton Leeds London Manchester Newcastle Reading Southampton St Thomas's O Reproduced fromSt Thomas's the Ordnance Survey Map with the permission of theO Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279. J:\28000 - Reproduced28999\28200 -from 28299\28292 the Ordnance - Henlow Survey Camp\A4 Map - Dwgs with & theRegisters\M permission Planning\28292 of the Controller - RG-M-05 of - HistoricHMSO. Mapping.dwg Crown Copyright - 05-1 (1-20000@A2) Reserved. Licence No. 100019279. J:\28000 - 28999\28200 - 28299\28292 - Henlow Camp\A4 - Dwgs & Registers\M Planning\28292 - RG-M-05 - Historic Mapping.dwg - (1-20000@A2) AD O AD Chapel R Chapel Issues IN Playing Field Issues Playing Field 58m H 1982-1994 Present Day & Future C 1982-1994 Present Day & Future Notwithstanding that development at RAF Henlow seems to have beenT redacted, Infill development comprises much of the visible change to the mid 1990s. This is 9 5I ROAD Issues Path 6H Issues Path Path B Track Path Track Drain Track Drain NUE NUE Drawing Title Drawing Title Drawing Title Drawing Title E E DER AV NUE 48m DER AV NUE 48m TED DrainWOR S AVE TED WOR S AVE HITCHINWH IT T JONE WH IT T JONE Drain H H Drain Drain Drain Drain significant development at Lower Path Stondon has occurred by 1960 in the form of ribbon particularly evident on the southern Path edge of Lower Stondon, north and south of Station Drain Drain Car 43m Car Park Sewage Park Drain HISTORIC PLANSWITH HISTORIC PLANSWITH HISTORIC PLANS HISTORIC PLANS OLDFIELD FARM ROAD Works OLDFIELD FARM ROAD CHAPEL ROAD 48m 48m

Path Stadium DERWENT ROAD Path Stadium DERWENT ROAD

development along Station Road, linking the crossroads with theOLYMPUS ROAD historic core of the Road, along Station Road west of the cross roads and on Bedford RoadOLYMPUS ROAD between Cherry (Greyhound) (Greyhound) PW PW PW PW Track Track Track A600 A600 WITH BASE INFORMATION WITH BASE INFORMATION PO B PO B Stanpit Playground B659 Golf Couse URNE Playground B659 URNE Project Project House N N T T Village. DevelopmentDrain has also started to stretch 51mnorth and southwardsT on the eastern Tree Nurseries and the cross roads. Further expansion51m of land aroundT RAF Henlow is also AV AV PW AVON ROAD PW AVON ROAD Track Drain E E Date Scale Drawn by Check by Date Scale Drawn by Check by Date Scale Drawn by Check by Date Scale Drawn by Check by Drain NU OLDFIELD FARM ROAD NU OLDFIELD FARM ROAD Upper Stondon Camp E 48m Upper Stondon E 48m ALLTON RD Henlow ALLTON RD Henlow 77m 54m Ind Est 77m Ind Est HENLOW CAMP HENLOW CAMP PW B BORTON AVENUE PW BORTON AVENUE PPERS E PPERS 1:20,000@A2 ALC TL 1:20,000@A2 ALC TL 1:20,000@A2 ALC TL 1:20,000@A2 ALC TL D 18.01.18 18.01.18 18.01.18 18.01.18 HAL HAL L Drain F L ROAD War O ROAD War side of BedfordManor Road, with the greyhoundR stadium now visible. visible, in conjunctionManor with the now dismantled railway line. Meml Meml PW Farm D Derwent PW Farm R Lower School St Thomas's O Track D AD Track D Chapel ROA ROA ION Playing Field ION AT B Issues AT B T I T I Stondon S R 51m Drain Stondon S R 51m Drain CH CH Project No Drawing No Revision Project No Drawing No Revision Project No Drawing No Revision Project No Drawing No Revision The Old E Pavilion The Old E Pavilion IssuesManor GR V Manor GR V Rectory Rectory ME O Path Rectory Rectory ME O Pit Path Lindas Grove Pit Lindas Grove Farm P Farm P Track P Drain (disused) 64m Drain Drain P Drain (disused) 64m Drain E Playing Field E Playing Field RSH NUE RSH Drawing Title Drawing Title A E A LL BE R AV NUE 48m LL BE EDDE OR AVE R JU T ITW ES R JU Drain D H T ON Drain D O W H J O Drain Drain Drain Path F Path F

A BIL A BIL Drain O O 28292 RG-M-05-1 28292 RG-M-05-1 28292 RG-M-05 28292 RG-M-05 D D Transport Path RD UE Transport RD UE EE VEN EE VEN T A T A Museum TNU Museum TNU Drain R CL ES R CL ES LOWER STONDON STRATEGIC VISIONOAD H 6 OAD H 7 LOWER STONDON STRATEGIC VISION Car C C 200 600 1000m 200 600 1000m 200 600 1000m 200 600 1000m Three Star SIGNAL Three Star SIGNAL Park CLF CLF

LI Dismantled Railway LI Dismantled Railway G

Caravan Park Caravan Park G H

E H E HISTORIC PLANSWITH HISTORIC PLANS

OLDFIELD FARM ROAD NU NU L

E E L Pavilion T 48m AV E Pavilion T AV E A A THERN A THERN A

R T R T

V P S P S V 0 400 800 0 400 800 0 400 800 0 400 800 Path NO DERWENT ROAD NO H H ENAVETERN AVETERN

Stadium O O C C

Brookvale E Brookvale E WA WESTERN AVENUE E WA WESTERN AVENUE E PW OUR (Greyhound) Y OLYMPUS ROAD PW OUR Y PW N E O N E O Playing CL PW Playing CL T T END AV H V END AV H V E R E R MIDLAND T MIDLAND T Field A Field A A A L L H L H L I THE I THE L L A L L A Track CL VE CL VE SI APPLECROFT C N SI APPLECROFT C N A600 O ERN AVENU O ERN AVENU D H I TH E D H I TH E WITH BASE INFORMATION Lower Y T OU Lower Y T OU E Stondon E E R S E Stondon E E R S Drain V A STA A B Drain V A STA A R I ARD W POR R I ARD W R Golf Playground R H B659 R IL URNE Golf R H R IL O Lower School LD RC P W O Lower School LD RC P W

Savin A EL O L Y Savin A EL O L Y A A

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Course EB Course EB U Y D D Y

LU T LU T

M Stondon Stondon M Nurseries B R Nurseries B R

CH E T CH E

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56m 51mAY T 56m AY T

Y

E Y E RE W W RE

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Track A PW 52m AVON ROAD Track A 52m E

LL A600 E Moat LL E A600 Moat Scale Drawn by Check by Scale Drawn by Check by

W W Date Date PO NU PO

Mount Pleasant R OLDFIELD FARM ROAD Mount Pleasant R Upper Stondon Playground D E 48m Playground D

Farm ALLTON RD Henlow Farm

L ORCHARD A600 L ORCHARD A600 C

Ind Est C 77m P P Playground D BORTON AVENUE Playground D PW O N L A O N L A PPERS NN RO Sluice NN RO Sluice 18.01.18 1:20,000@A2 ALC TL 18.01.18 1:20,000@A2 ALC TL HAL A U E A U E H 56m E Old H 56m E Old L ROAD War D S M T R Drain D S M T R Drain ManorPO A Ramerick Moat PO A Ramerick Moat Meml O Drain O Drain PW Farm R R EET EET N N

I O Holwellbury I O Holwellbury T Track D T A OA Farm Cottages A Farm Cottages OWSW R OWSW T T S ION Golf Ramerick S Golf Ramerick BRITAINS RISE AT B BRITAINS RISE T I Ramerick Ramerick Stondon S Course R 51m Cottages Drain Course Cottages CH Project No Drawing No Revision Project No Drawing No Revision MEAD Cottages MEAD Cottages The Old E Pavilion Manor GR V Rectory Rectory ME O LO 48m LO 48m NGPit Lindas Grove NG Farm P ROAD ROAD DrainON (disused)C 64m Drain ON C P I GT L Playing Field I GT L HI LEL N 56m O HI LL N 56m O S RSH SE Drain S SE Drain AL BE L FA FA

R Planning ● Master Planning & Urban Design ● Architecture ● Planning ● Master Planning & Urban Design ● Architecture ● Planning ● Master Planning & Urban Design ● Architecture ● Planning ● Master Planning & Urban Design ● Architecture ● KE Regency Court JU KE Regency Court Drain D O Trinity CollegeDrain S Path Trinity College S F

A W BIL W

M 49m M 49m Park Homes O Park Homes 28292 RG-M-05-1 28292 RG-M-05 E E

D Track Track Farm L RD E Farm L A Transport U A L EE VEN L Track Y LA Museum The Chestnuts T A Track Y LA The Chestnuts F TNU F 64m N R CL S 64m N Landscape Planning & Design ● Environmental Planning ● Graphic Landscape Planning & Design ● Environmental Planning ● Graphic Landscape Planning & Design ● Environmental Planning ● Graphic Landscape Planning & Design ● Environmental Planning ● Graphic E E OAD H E IE Y C IE Y A 52m A 52m 200 600 1000m 200 600 1000m L Three Star SIGNAL L W W D CLF D

C LI C R N Dismantled Railway R N

E R G E R SC L Caravan Park SC L

O H UE O E C N E C

N H E L N H T V E Communication ● Public Engagement ● Development Economics Communication ● Public Engagement ● Development Economics Communication ● Public Engagement ● Development Economics Communication ● Public Engagement ● Development Economics T Pavilion A T

T A T ERN A E TH E

R T P S V 0 400 800 0 400 800 L W NO L W H ENAVETERN

P C O P A A

Brookvale E WA WESTERN AVENUE E A A H PW UR Y H O N Playing E O M CL Track M Track T END AV H V E R MIDLAND T Field A Holwellbury A Holwellbury 49m L 49m Track H Holwellbury L Track Track Holwellbury Track I THE L L A SI Ppg Farm APPLECROFT CL VE Ppg Farm C N ERN AVENU D H IO TH E E Stondon Lower Y T OU E A E TA R S Drain IV W R S A R Golf R HARD R IL O Lower School LD RC P W

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LU T Stondon M Nurseries B R bartonwillmore.co.uk bartonwillmore.co.uk bartonwillmore.co.uk bartonwillmore.co.uk

CH E

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LL E A600 Moat PO W

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L ORCHARD A600 C Certificate FS 29637 Certificate FS 29637 Certificate FS 29637 Certificate FS 29637 Playground P D O N L A NN RO A U E Sluice H 56m E Old D S M T R Drain PO A Ramerick Moat Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh O Drain R EET N

I O Holwellbury T Leeds London Manchester Newcastle Reading Southampton Leeds London Manchester Newcastle Reading Southampton Leeds London Manchester Newcastle Reading Southampton Leeds London Manchester Newcastle Reading Southampton A Farm Cottages Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279.Reproduced from the Ordnance Survey Map withOWSW the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279. J:\28000 - Reproduced28999\28200 -from 28299\28292 the Ordnance - Henlow Survey Camp\A4 Map - Dwgs with & theRegisters\M permission Planning\28292 of the Controller - RG-M-05 of - HistoricHMSO. Mapping.dwg Crown Copyright - 05-1 (1-20000@A2) Reserved. Licence No.J:\28000 100019279. - Reproduced28999\28200 -from 28299\28292 the Ordnance - Henlow Survey Camp\A4 Map - Dwgs with & theRegisters\M permission Planning\28292 of the Controller - RG-M-05 of - HistoricHMSO. Mapping.dwg Crown Copyright - 05-1 (1-20000@A2) Reserved. Licence No. 100019279. J:\28000 - 28999\28200 - 28299\28292 - Henlow Camp\A4 - Dwgs & Registers\M Planning\28292 - RG-M-05 - Historic Mapping.dwg - (1-20000@A2) J:\28000 - 28999\28200 - 28299\28292 - Henlow Camp\A4 - Dwgs & Registers\M Planning\28292 - RG-M-05 - Historic Mapping.dwg - (1-20000@A2) T S Golf Ramerick BRITAINS RISE Ramerick Course Cottages MEAD Cottages

LO 48m D NG N ROA GT O CL HI LLIN 56m O S SE Drain FA Planning ● Master Planning & Urban Design ● Architecture ● Planning ● Master Planning & Urban Design ● Architecture ● KE Regency Court S Trinity College W

M E Park Homes 49m Farm L Track A L Track Y LA The Chestnuts 64m F N Landscape Planning & Design ● Environmental Planning ● Graphic Landscape Planning & Design ● Environmental Planning ● Graphic E I Y E A L 52m D W CR N E R SC L O E C N H Communication ● Public Engagement ● Development Economics Communication ● Public Engagement ● Development Economics T T

E

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A H M Track Holwellbury Track 49m Holwellbury Track Ppg Farm bartonwillmore.co.uk bartonwillmore.co.uk

Certificate FS 29637 Certificate FS 29637 Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Offices at Birmingham Bristol Cambridge Cardiff Ebbsfleet Edinburgh Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279. J:\28000 - Reproduced28999\28200 -from 28299\28292 the Ordnance - Henlow Survey Camp\A4 Map - Dwgs with & theRegisters\M permission Planning\28292 of the Controller - RG-M-05 of - HistoricHMSO. Mapping.dwg Crown Copyright - 05-1 (1-20000@A2) Reserved. Licence No. 100019279. Leeds London Manchester Newcastle Reading Southampton J:\28000 - 28999\28200 - 28299\28292 - Henlow Camp\A4 - Dwgs & Registers\M Planning\28292 - RG-M-05 - Historic Mapping.dwg - (1-20000@A2) Leeds London Manchester Newcastle Reading Southampton Character of Lower Stondon A B C

Introduction Historic Stondon This section describes the character of Lower Stondon. The The early history of Stondon is characterised by two small rural aesthetic of new development should draw upon the best of local settlements, Lower and Upper, firmly associated with farming distinctiveness, to create development of quality that is an asset occupations. The building groupings within these settlement are Stondon Lower School Royal Air Force to the Village. located at the intersection of key streets, to create a modest key space overlooked and fronted by the adjoining buildings. Historic Cottage Row Figure 12 shows a plan of Lower Stondon and the adjacent built up area of Henlow Camp, illustrating the built form along The urban form tends to comprise narrower buildings with a more This row of cottages was constructed in 1867, and is located at the key routes. The plan highlights some of the key historical areas informal layout. Nearly all building are two-storey in height, with roundabout of Bedford, Hitchin and Station Roads. and some of the more recent development areas within the material comprising a combination of ironstone, soft red brick, settlement as particularly important points of reference to inform white gault brick and painted render with pitched tiled roofs. D E future development.

1960's Residential Development 1980's Residential Development Semi-detached houses, set back from street with driveway / Semi-detached houses, set back from street with driveway / parking area to the front, characterised by small gabled bays parking area to the front, characterised by simple façades and facing the street and small entrance structures. gable end roof structure.

B Recent Development in Lower Stondon C Recent development in Lower Stondon and Henlow Camp has E focused along the Bedford Road (east and west) and Station Road D (backland plots) at Redwing Croft and Meadowsweet. Brown 2 and grey tiles roofs, red brick and render are commonplace with a combination of simple gabled form and projecting gables providing a reference to the traditional character.

1

1 2

A

Historic Areas Bedford Road - East Side Bedford Road - West Side Some of the materials reflect the village’s history, and hedgerow Recent Development Semi-detached and detached houses, set back from street with driveway / parking area to the front and garage structures, which planting softens the street edge of the development. Figure 12. Plan of Built-up Area dominate the street and detract from street scene.

LOWER STONDON STRATEGIC VISION 8 9 LOWER STONDON STRATEGIC VISION Planning Context

With a growing and ageing population, the need for housing remains 650 dwellings. The Council anticipates that these sites will be less high, and a key strategic driver for local authorities. The National Planning constrained and be brought forward for development more quickly Policy Framework (NPPF) sets out the Governments planning policies and to aid housing delivery in the shorter term. how these are expected to be applied. Of note, paragraph 17 confirms Land North of Henlow Greyhound Stadium the role of the planning system is to ‘proactively drive and support Land North of Henlow Greyhound Stadium has been assessed by sustainable economic development to deliver the homes, business and the Council as part of the Call for Sites process. The conclusion industrial units, infrastructure and thriving local places that the country of the Council's assessment states “the site is also located to the needs’. greyhound stadium and has the potential to form a comprehensive Central Bedfordshire is a key area of growth in the region. It is a development with appropriate landscape buffering”. We note the highly connected area given the existing infrastructure provision. This greyhound stadium site and land to the west has been identified as connectivity will increase given Central Bedfordshire’s location within the a draft allocation within draft Central Bedfordshire Pre-submission Oxford-Cambridge corridor, which provides key opportunities including Local Plan 2015-2035. Notwithstanding, this site could come the East-West rail link, and the Cambridge-Milton Keynes-Oxford Arc. The forward independently as an allocation or an application. Council anticipates associated high technology employment led growth, Land West of Bedford Road with significant housing numbers accompanying this. Land West of Bedford Road has been assessed as part of the Call Central Bedfordshire Council is currently reliant upon planning policies for Sites process. The Site was not considered a logical extension to from the Core Strategy and Development Plan Policies DPD 2009 (CSDMP) the village due to the parkland and wetland setting to the northern and the Site Allocations Development Plan Document (SADPD) 2011. The boundary. However, application CB/16/05229/OUT has since District is currently split into north and south areas, with Lower Stondon received a resolution to grant planning permission for up to 85 located within the North area. Within Policy CS1 of the CSDMP, Lower dwellings on land to the north. This includes a new access road and Stondon is classified as a ‘Large Village’. The associated spatial strategy potential sites for self builds along the joint boundary. seeks the Large and Small Villages to provide 10% of new development The Localism Act has given local communities more power to within Central Bedfordshire, with specific residential allocations noted influence the future of places by introducing Neighbourhood with the SADPD. Policies HA28 and HA29 allocate a combined 4.5 Planning. This allows the production of a Neighbourhood Plan, hectares of land to provide approximately 83 dwellings. which can include a range of social, economic and environmental The Council is preparing a new Local Plan to supersede the documents subjects. Stondon Parish Council have commenced the preparation listed above and provide a long term vision to enhance Central of their Neighbourhood Plan through a successful allocation to agree Bedfordshire. The Regulation 19 Pre-Submission Local Plan 2015-2035 is their Neighbourhood Area. This was approved in 2014 and includes at public consultation between 11 January and 22 February 2018. the parish as a whole. Both proposed development sites are located within this area. The Parish Council are seeking to progress the The draft Local Plan seeks the delivery of 39,350 dwellings through drafting of the Neighbourhood Plan itself and Rainier Developments the plan period, which consists of 32,000 dwellings within Central will liaise with the Parish Council through the Neighbourhood Plan Bedfordshire and 7,350 dwellings that form Luton Borough Council’s process. residual ‘unmet need’. 23,845 of the proposed dwellings are already planned for, a figure that includes completions between April 2015 and October 2017, existing allocations, sites with permission and a windfall allowance. The draft Local Plan spatial strategy proposes two new villages at Marston Vale and east of Biggleswade. Extensions to the north of Luton and east of Arlesey have also been proposed.

Further dwellings will be provided through the proposed allocation of Figure 13. Designated Stondon Neighbourhood Plan Area (September 2013) 52 identified sites across Central Bedfordshire on sites ranging from 5 to

N Date: 19 September 2013 © Crown Copyright and database right. 2013 W E Neightbourhood Plan Area Ordnance Survey 100049029. Central Bedfordshire Council. Scale 1:25000 Cities Revealed aerial photography copyright S The GeoInformation Group, 2010 LOWER STONDON STRATEGIC VISION 10 11 LOWER STONDON STRATEGIC VISION Facilities

Retail and Community Facilities Employment The are a variety of facilities in the Lower Stondon, including a There are some limited employment opportunities in Lower convenience store, hairdressers, pharmacy, post office and public Stondon associated with village facilities. However, there are house at the western end of Station Road. Other facilities include easily accessible employment sites on the eastern side of Bedford a petrol filling station on the Bedford Road, the Mount Pleasant Road at Henlow Industrial Estate and Henlow Camp and major Golf Club and an Indian restaurant. In the adjacent Henlow Camp, employment opportunities at Hitchin and Letchworth Garden there are further convenience facilities, including takeaway food City approximately 5 miles to the south east with mainline rail outlets, an estate agent, convenience store, car showroom, connections into London. furniture shop,hairdressers and cafe. Education The Lower Stondon Surgery is a 4GP doctors surgery located on Station Road covering twelve villages in the area, including Lower Stondon Lower School is located in the heart of the historic Stondon and Henlow. village, at the intersection of Station Road and Hillside Road. The Stondon Stompers Pre-School is co-located adjacent to the Lower Two churches offer services within the Parish, including All Saints School within the Village Hall. The Derwent Lower School is also within Upper Stondon and Stondon Baptist Church in Station located off the Hitchin Road within Henlow Camp and Henlow Road. Nursery within RAF Henlow, close to the Bedford Road/ Station Road crossroads. Recreation and Open Space A recreation field with pavilion and car park is located behind Stondon Lower School accessed Meppershall Road and The Pastures. The recreation field includes an equipped children's play area, marked out football pitch and ancillary grassed areas for formal and informal play. Allotment gardens are provided within the village to the west of Three Star Park west of the Bedford Road. An extensive public footpath network radiates from Lower Stondon, linking the surrounding villages of Holwell, Pirton, Shillington and Meppershall.

'The Sites are well related to a wide

range of employment, education and Figure 15. Community Facilities Plan community uses within the Village and adjacent Henlow Camp area east of Bedford Road.' Land North of Henlow Greyhound Stadium is immediately opposite the employment uses at Henlow Camp, is within 400 metres of the Local Centre and commercial bus routes (serving Bedford, Hitchin and surrounding areas) and 1km of the Lower Dewent School. Land West of Bedford Road is on the southern edge of the Village, but is immediately adjacent to the commercial bus route and within 800 metres of the Local Centre, Henlow Industrial Estate and 1.5km from Lower Dewent School.

Figure 14. Village Facilities (from top: All Saints; Golf Club; Figure 16. Community Facilities (from left: Pharmacy and Post Stondon Lower School) Office; Henlow Camp retail; Bedford Road Petrol Filling Station)

LOWER STONDON STRATEGIC VISION 12 13 LOWER STONDON STRATEGIC VISION Strategic Plan Summary

The Illustrative Strategic Plan shows an indicative form of development for both sites that has the potential to respond sensitively to the surrounding context and integrates with the built form and soft landscape structure of Lower Stondon. The sites have a strong relationship to the village and key facilities and services.

Land North of Henlow Greyhound Stadium has the capacity to deliver approximately 100 dwellings in a range of types and tenures to meet identified local need including provision of affordable housing. Land West of Bedford Road could deliver approximately 140 dwellings with a similar range of types and tenures.

The sites are well related to approved development, development recommended for approval and other allocations proposed within Lower Stondon.

This overarching Vision supports two sites identified as being suitable for sustainable residential development within Lower Stondon. This document introduces both sites, whilst also looking at the immediate setting and context.

Both sites have the ability to contribute towards meeting housing need in Central Bedfordshire. They would extend the built-up area of the village but without harming the surrounding countryside. They would also present opportunities to enhance planting and create new habitats within and around the built development.

A team of consultants has been appointed to undertake a detailed analysis of both sites in terms of site constraints, opportunities, capacities, and enhancement opportunities. The results of this analysis have informed the production of a more specific Proposal Document for each separate land parcel. These documents include a proposed concept master plan for each site, taking into account those opportunities and constraints identified.

These individual documents will allow further liaison with Central Bedfordshire Council, Stondon Parish Council and the key stakeholders/consultees identified. The Proposal Documents will be used to enable more specific comment and discussion, which will further shape the sites as the background work progresses.

Figure 17. Illustrative Strategic Plan

LOWER STONDON STRATEGIC VISION 14 15 LOWER STONDON STRATEGIC VISION Document Status: Final Revision: E Author: Various Checked by: TL Authorised by: GW Issue Date: February 2018

LOWER STONDON STRATEGIC VISION 16

APPENDIX 2

Site Specific Proposal Document

PROPOSAL FOR LAND NORTH OF HENLOW GREYHOUND STADIUM

LOWER STONDON CENTRAL BEDFORDSHIRE

FEBRUARY 2018 2 3

Background

The Land at Lower Stondon Strategic Vision Document This Site Proposal document focuses on providing a provides an overarching vision for the sustainable detailed analysis of the site; its relationship to the growth of the village. The Strategic Vision Document wider landscape; connectivity to social infrastructure; assesses the following matters: Evolution of Lower and movement framework. It also sets out the Stondon; Character of Lower Stondon; Planning proposed design rationale underpinning the initial Context; Facilities; and a Strategic Plan. This Site proposals to develop this site. Rainier Developments Proposal document for the Land North of Henlow are committed to working with the Parish Council and Greyhound Stadium builds on and should be read in the local community to develop our proposals and conjunction with the Lower Stondon Strategic Vision deliver a vision for Land North of Henlow Greyhound Document. Stadium.

Figure 1. Map of Lower Stondon (site edged red)

LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION

Site Boundary

N

28292 - RG-M-07 100 300

0 200 4 5

Site Analysis

Topography Noise

The site slopes down gradually from a high point of approximately Bedford Road runs along the eastern boundary of the site, and 56m AOD in the west to approximately 52m AOD in the east lies at the same level as the site, creating noise along this edge. towards Bedford Road. There is a slight camber towards the This will need to be taken consideration when proposing any southern boundary. vegetation of potential noise mitigation. Trees and Vegetation Surface Water Drainage There are mature trees and vegetation running along the northern and southern boundaries. These should, wherever possible, be The site does not fall within flood zones 2 or 3, and therefore protected. There is an opportunity to add to this existing green is located within the area of the lowest annual probability of infrastructure with further perimeter trees and vegetation flooding. Any development will need to provide suitable surface planting. water flood attenuation to deal with the changes in surface water 52.00 52.50

run off and from the new homes themselves. This could include 53.00 Public Rights of Way swales, attenuation ponds and drainage runs. These would be integrated into the landscape and enhanced for ecological gain. 53.50 There are several public right of ways running around and through 54.00 this site. The main public footpath runs along the southern 52.00 54.50 boundary and is accessed from Bedford Road. At the south- Arboricultural Matters 52.50 western corner of the site there is a junction where you can 55.00 continue straight further west, or turn right heading north. This Of the individual and groups surveyed, nine have been identified as 55.50 53.00 north heading public footpath runs along the western boundary category B, of moderate quality and value. These items should be 56.00 and continues to a further network of public footpaths around the prioritised for retention due to their condition, age and retention neighbouring properties to the north. The two public footpaths span. All of the surveyed items are located around the perimeter of the site and, providing that designated RPAs and canopies running along the southern and western boundaries are very well 53.50 used and is important that these are protected and accessibility is are respected, they do not adversely constrain the potential to encouraged. accommodate residential development in the main body of the site. 54.00 Ecological Matters Access The site is relatively unconstrained ecologically, comprising There is a single point of vehicular access proposed off Bedford 54.50 predominantly arable habitat of negligible ecological value. Road, which is the only public highway that abuts the site. Due to No statutory or non-statutory designated sites are considered the scale of the development and as seen for the neighbouring site to be at risk of any material and adverse effects as a result of accesses, it is considered that a simple priority ‘give-way’ t-junction the proposed development. While some of the habitats on- could be formed to serve the site (as seen in Figure 2). 55.00 site, including the hedgerows, scrub and trees, are currently considered, on a precautionary basis, to be of some ecological 55.50 value (local conservation importance), they are largely confined to Geotechnical the external site boundaries. It is therefore likely that they can be The primary contamination risks at the site arise from the previous adequately accommodated and mitigated by the masterplanning 56.00 agricultural site uses. However, in general the contamination of any future development proposals and are therefore not potential of the site is considered to be low. The site conditions considered a constraint to development. are expected to comprise a minimal amount of made ground/ Based on the findings of the Preliminary Ecological Appraisal, topsoil over variable superficial deposits and residual soils. Bedrock the designated sites, habitats and species potentially present is expected to consist of mudstone of the Gault Formation or within and around the site do not pose an ‘in principle’ constraint sandstone of the Woburn Sands Formation. to development of the site. Through the adoption of industry Shallow foundations are likely to be suitable across much of standard impact avoidance and mitigation measures any adverse the site, founding on the superficial deposits, residual soils or effects on protected species can be appropriately addressed to directly onto bedrock. The extent and composition of the site ensure no net loss to biodiversity, in accordance with national soils, together with strength of the underlying bedrock will be planning policy. Site Boundary PRoW Tree - Category B Tall Ruderal determined through appropriate ground investigation techniques.

Flood Zone 54.50 Tree - Category C Immediate Boundaries Infiltration drainage may be feasible in some areas of the Contours site where non-cohesive soils are located, depending upon Water Course Root Protection Area N Development will need to respect the existing residents to the groundwater levels and specific infiltration rates as determined by Proposed Site Access north of the site. ground investigation. 28292 - HS1 - RG-M-Ai02 Proposed Existing Trees and Wet Ditch 100 300 Tree Groupings Infiltration Basin 0 200

Figure 2. Site Analysis Plan

LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION

Site Boundary PRoW Tree - Category B Tall Ruderal

Flood Zone 54.50 Contours Tree - Category C

Water Course Proposed Site Access Root Protection Area N 28292 - HS1 - RG-M-Ai02 Proposed Existing Trees and Wet Ditch 100 300 Tree Groupings Infiltration Basin 0 200 6 7

Landscape Character and Visual Amenity

Landscape The site falls within Landscape Character Type 4C: Upper Ivel Clay However, there were not found to be any views of the site from Valley, which is described as: the wider context looking towards the site in which it would be considered a noticeable or unexpected component of the view. “…flat (ranging from 35m AOD to 51m AOD) and there are some long views over large scale open arable fields which contrast with Visibility to the site is experienced largely by users of the PRoW more intimate, small scale pastures along the courses of the Ivel network, located immediately adjacent to the site boundary and and Hiz. Large and medium size fields of arable are bounded by extending to approximately 800m to the west of the site. Views ditches and hedgerows in mixed condition with some hedgerow are afforded from the Bedford Roads, although again existing trees. …The Upper Ivel Clay Valley has a high density of settlement mature roadside landscape features provide a good visual screen with a number of substantial villages.” beyond the immediate site.

Following a review of the key characteristics identified within the In the wider context, due to built form within the surrounding LCA, in some respects, the site and its context is considered to built up areas and mature landscape fabric, if seen at all, the relate well to its descriptions, largely to those negative aspects site is likely to be glimpsed in views between existing built form which suggest an urbanised setting. from. Similarly, views from receptors up to 2km from the west of the site boundary, are very heavily filtered by existing landscape The site is not located within or in close proximity to any national features. landscape designations; is more than 2km, at its closest point, from the Metropolitan Green Belt; and there are no blocks of For all these reasons the site has less of a character, visual, and ancient woodland within 2km of the Site. physical, relationship with the wider open countryside, and more of a relationship with the surrounding built up areas. The site is not particularly constrained in terms of its landscape fabric and is well bounded and contained within the local Summary landscape. While the northern and eastern areas of the site benefit from visual enclosure created by existing landscape Due primarily to the enclosure created by existing landscape features and built form, consideration should be given to features within the local context and intervisibility with existing development within the western areas of the site which, is built form, the site has a reduced landscape sensitivity. The site is potentially visible in views from receptors to the west of the site. barely perceptible from the wider setting and has well-established urbanising influences in close proximity to it, being well contained In terms of potential impacts on the landscape character of the by both existing built form and mature landscape features. It is site, proposed development offers the opportunity to positively likely that the majority of landscape and visual effects resulting integrate the field boundary hedgerows and trees within the from proposed development within the site would be limited to scheme layout, thus retaining the characteristic vegetation receptors in close proximity to it. elements and pattern prevalent across the site and contribute to biodiversity. The development of the site provides an opportunity to enhance and augment the remaining landscape features across the site and The site is visually well contained, with the zone of primary along its boundaries. visibility being limited to the site itself and parts of the PRoW within 800m of the western site boundary. This containment In the interests of good masterplanning, due to possibility of is due to surrounding urban development, mature landscape views of taller built form within the site from the wider context features aligning the road network and the immediate gently to the west, attention should be given to the western boundary rolling topography. Within the western areas of the site, land is treatment which is currently afforded views looking north-west. more ‘exposed’ due to the absence of mature field boundary.

Figure 3. Panoramic view taken from the North West Corner on Bedford Road looking South Figure 4. Landscape Character Plan

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Connectivity to Social Infrastructure

‘The Site is exceptionally well placed to provide direct, convenient and safe access to key community and educational assets within Lower Stondon by foot and cycle.’

Walking and Cycling Residents will be able to walk easily into the nearby local centre using the footpath running along side Bedford Road heading south. An easy walk of under 10min would also lead to the Henlow Industrial Estate, providing access to potential job opportunities for residents. There is also scope to walk/ cycle to the local school, village hall, Lower Stondon Surgery and Mount Pleasant Golf Club & Course. Overall, the site is already well connected with the existing street network of pavements in the village.

Distance Walking Cycling Facilities from Site Time Time

Local Centre 400m 5min 1min

Henlow Industrial 700m 9min 3min Estate

Lower Stondon 1km 12min 3min Surgery

Mount Pleasant Golf 1.6km 20min 5min Club and Course

Stondon Lower 1.8km 23min 6min School/ Village Hall

Figure 5. Table of Connectivity to Key Social Infrastructure Figure 6. Connectivity to Key Social Infrastructure Plan

LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION 10 11

Access and Movement

Strategic Highway Network The site will be accessed via Bedford Road as illustrated by Figure 2. Heading south this connects through to Hitchin, then continuing westward along the A505 leads to Luton and the connection to the M1 motorway. To the west the A659 connects with the B659 to lead through Stodford to the A1.

Looking northward the A600, Bedford Road, runs through Shefford before heading North-west providing a direct connection into Bedford Town Centre and either north along the A6 or further east using the A421 towards Cambridge. Local Highway Network and Access In terms of the local network, Station Road runs further east and down past Shillington and Apsley End. Public Transport The nearest bus stops are located to the south along Bedford road off the roundabout intersecting Bedford, Hitchin and Station Roads. The two bus stops off this roundabout, one off Station Road to the West and the other to the south off Bedford Road, provide access to all the main bus routes in the area connecting to Bedford, Hitchin and Sandy. Both these stops are located within an easy 5min walking distance of the site. There is an existing footpath running along Bedford Road which provides a safe connection.

Summary Overall, the site is considered to be well connected in terms of vehicular access, including the wider strategic routes, which will reduce the amount of traffic travelling through the village. There are also existing bus connections providing alternatives to driving with scope to support or extend these routes.

Figure 7. Access and Movement Plan

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Design Rationale

This section explains the design rationale that underpins the Emerging Master Plan Concept proposal. The emerging master plan concept illustrates how the landscape The landscape strategy is illustrated by a peripheral green Landscape Strategy and movement principles underpinning the design approach can infrastructure minimising visual impact of the development to come together to create a development that is well contained and its surroundings, combining tree planting, swales and informal The proposal will create a generous new landscape network around and add planting along the western boundary to frame views. assimilated within the wider landscape and built form context. open space. the site that integrates and connects with the wider surrounding The surface water attenuation concept will work with the The approach proposes a lower density at the development edges context through retaining and strengthening existing public rights existing topography of the site to deliver a sustainable drainage with an informal character as a response to the surrounding of way. The landscape strategy will retain existing vegetation at the strategy consisting of a swale and attenuation feature. landscape. peripheral of the site along the northern and southern boundaries,

52.00

52.50

53.00

53.50 Bedford Road

Gradual Slope Down 54.00

54.50

55.00

55.50

56.00

Figure 8. Landscape Strategy Principle Plan Connections There is a single access point proposed off Bedford Road that is Henlow. The road network consists of a main spine road to designed to comply with local authority transport requirements, and ensure ease of connectivity, whilst maximising opportunities for have minimal impact on the existing traffic flow into Lower Stondon/ walking/ cycling accessibility into the village.

BEDFORD

ROAD

S ES ACC AN SINGLE TRI DES ACCESS PE

TO VILLAGE CENTRE & BUS STOPS

LAR ICU VEH

AY OF W RIGHT PUBLIC

Figure 9. Connections Principle Plan Figure 10. Development Concept Plan

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Proposal Summary

The Concept Master Plan below illustrates the design for the development. This has been informed by the site and contextual assessment presented in this document to deliver the vision for this site.

The proposal can provide up to 100 dwellings, together This overarching Vision supports the identified site as being with formal and informal open space open space, to suitable for sustainable residential development within Lower include surface water drainage attenuation. Stondon. This document introduces this site, whilst also looking at the immediate setting and context. There would be one access points off Bedford Road leading into a main spine road. Delivery of this site would have the ability to contribute towards meeting housing need in Central Bedfordshire. It would We envisage the new homes will be two storeys with 1 extend the built-up area of the village but without harming the place making and way-finding objectives achieved surrounding countryside. It would also present opportunities to 2 8 through the materials palette and design of the public 4 enhance planting and create new habitats within and around the realm. There will be a mix of housing types and tenures, built development. including detached, semi-detached and terrace homes. This Site Proposal document provides our initial proposals to develop the Land North of Henlow Greyhound Stadium. Rainier Developments are committed to working with the Parish Council 4 and the local community to develop the vision for this site.

6

4 6 7

5

3

6 1 Single vehicular access from Bedford Road

2 Attenuation and Wetland Meadow (SUD)

3 3 Retained public right of way integrated into green infrastructure 6 4 Proposed footpath

Additional tree planting to create 5 landscape buffer and frame views

6 Existing trees retained and enhanced

7 Main spine street

8 Open space/ SUD

Figure 11. Proposed Masterplan

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Document Status: Final Revision: D Author: EH Checked by: TL Authorised by: GW Issue Date: February 2018

LAND NORTH OF HENLOW RACING GREYHOUND STADIUM VISION

APPENDIX 3

Review of Housing Need and Land Supply

Central Bedfordshire Pre- Submission Local Plan Review of Housing Need and Land Supply

Report on behalf of Abbey Land Developments Ltd, Richborough Estates, Catesby Estates, and Rainier Developments Ltd.

21 February 2018

© 2018 Nathaniel Lichfield & Partners Ltd, trading as Lichfields. All Rights Reserved. Registered in England, no. 2778116. 14 Regent’s Wharf, All Saints Street, London N1 9RL Formatted for double sided printing. Plans based upon Ordnance Survey mapping with the permission of Her Majesty’s Stationery Office. © Crown Copyright reserved. Licence number AL50684A 16230/MS/MSm 15506444v1

Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

Contents

1.0 Introduction 1 Central Bedfordshire Pre-Submission Local Plan 1 Report Structure 1

2.0 Housing Need 3 Policy and Guidance 3 Context 6 Review of Luton & Central Bedfordshire Strategic Housing Market Assessment (2017) 8 Housing Market Area and Duty to Co-operate 23 Standardised Methodology 24 Summary and Conclusions 25

3.0 Housing Delivery 26 Central Bedfordshire Pre-Submission Local Plan Housing Trajectory 26 Lead-in times and Build-out rates 28 Review of Housing Trajectory 32 Review of 5 Year Housing Land Supply 41 Summary and Conclusions 44

4.0 Assessment of Reasonable Alternatives 45 Policy and Guidance 45 Central Bedfordshire Growth Strategy 45 Appraisal of Growth Strategy 46 Summary and Conclusions 50

5.0 Conclusions 51 Housing Need 51 Housing Delivery 52 Spatial Strategy 52

Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

Figures

Figure 2.1 Margins of error around the 2001 and 2011 Censuses (95% level) 9 Figure 2.2 Historic and forecast change in Lower-quartile affordability ratio 17

Tables

Table 2.1 Growth rate and equivalent dwellings per annum 15 Table 2.2 Adopted Housing Targets in post-NPPF Plans 16 Table 2.3 Impact of scales of housing growth on affordability 18 Table 2.4 Outcomes for Central Bedfordshire - Apportionment of National Needs 19 Table 3.1 Existing and Proposed Housing Land Supply 27 Table 3.2 Central Bedfordshire 5YHLS 28 Table 3.3 Average annual delivery rates on sites in Central Bedfordshire over the past 3 years 29 Table 3.4 Past Lead-in Times for Strategic Developments in Central Bedfordshire 31 Table 3.5 Past Delivery Rates/Lead-in Times of Strategic Scale Developments – Bedford Borough Council 32 Table 3.6 Windfall Allowance Calculations 38 Table 3.7 CBC Housing Trajectory Breakdown by Type 40 Table 3.8 CBC 5YHLS (as at 1st April 2018) 43 Table 4.1 Central Bedfordshire Regulation 18 Draft Local Plan Growth Scenarios 46 Table 4.2 Actual Levels of Growth Tested 47

Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

Appendices

Appendix 1: Housing Delivery and Windfall Calculations

Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

1.0 Introduction

1.1 This report has been prepared by Lichfields on behalf of Abbey Land Developments, Richborough Estates, Catesby Estates and Rainier Developments, to support their individual representations in response to the Central Bedfordshire Pre-Submission Local Plan 2015 – 2035 (January 2018) (“the Local Plan” “the Plan”).

1.2 This report provides:

• a review of the Central Bedfordshire Council’s (“the Council” “CBC”) existing evidence on housing needs and establishes the scale of need and demand for housing in the District;

• an appraisal of the housing trajectory and five year land supply position which underpins CBCs Plan; and

• Consideration of whether the Council suitably tested reasonable alternatives in establishing its preferred approach. Central Bedfordshire Pre-Submission Local Plan

1.3 The Local Plan sets out at Policy SP1: Growth Strategy that 39,350 homes will be delivered in Central Bedfordshire over the period 2015 to 2035. This includes the 32,000 of objectively assessed housing needs (“OAHN”) for Central Bedfordshire, and a commitment to facilitate 7,350 of Luton’s unmet need – subject to ongoing duty to co-operate discussions and formal Local Plan Examination. The Plan makes provision for the delivery of a total of 41,830 homes over the plan period, of which c.23,000 are existing commitments, and c.18,000 are a combination of strategic (c.9,900) and small – medium scale (5,505) allocations throughout Central Bedfordshire.

1.4 Our review highlights that on the basis of the flawed approach taken to reaching the 32,000 housing requirement identified within the Central Bedfordshire & Luton Strategic Housing Market Assessment (December 2017) (“the 2017 SHMA”), and prior iterations of that study, that this housing requirement fails to meet the full OAHN for housing, which is significantly higher than the Council has estimated.

1.5 Furthermore, we consider that the Plan would fail to make appropriate provision for sufficient housing to sustainably deliver, in a timely manner, housing in line with the District’s full OAHN, with further site allocations required within this plan in order to ensure an overall strategy that is deliverable and sufficiently flexible to respond to change.

1.6 Finally, the evidence underpinning the Plan’s spatial strategy is flawed, insofar as it has not meaningfully considered all reasonable alternatives, or sufficiently evidenced why the preferred approach has been taken forward, when scenarios with higher levels of growth (including that advocated in the previous Draft of the Plan) appear broadly sustainable. Report Structure

1.7 This report is structured into the following sections:

• Section 2.0 –reviews the robustness of the Council’s evidence on housing need within the District and the wider housing market area, and whether the Council is seeking to meet its objectively assessed housing need;

• Section 3.0 –reviews the Council’s housing trajectory and five year land supply position which underpin the Plan, in respect of realistic and reasonable lead-in times and build-out rates, including presenting a revised trajectory;

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• Section 4.0 –reviews the Council’s evidence on the testing of reasonable alternatives and the selection of appropriate growth levels; and

• Section 5.0 –provides a summary and overall conclusion on the whether the evidence underpinning the Plan is sound, in respect of housing need, housing trajectory and that a range of reasonable alternatives have been tested.

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2.0 Housing Need Policy and Guidance

National Planning Policy Framework

2.1 The National Planning Policy Framework (“NPPF”) outlines that local planning authorities ("LPAs") should positively seek opportunities to meet the development needs of their area (paragraph 14). It adds that, in order to “boost significantly” the supply of housing, they should “use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in the framework…” (paragraph 47)

2.2 The NPPF (paragraph 159) specifies the evidence required to objectively define housing needs within an area, setting out that LPAs should:

"Prepare a Strategic Housing Market Assessment to assess their full housing needs… identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which;

• Meets household and population projections, taking account of migration and demographic change;

• Addresses the needs for all types of housing, including affordable housing… ; and

• Caters for housing demand and the scale of housing supply necessary to meet this demand."

Planning Practice Guidance

2.3 The Planning Practice Guidance (“PPG”) contains a section providing guidance on housing and economic development needs assessments. It identifies that whilst there is no one methodological approach, an OAHN should fulfil the following criteria:

• be proportionate and not consider purely hypothetical future scenarios, only future scenarios that could be reasonably expected to occur (ID: 2a-003);

• be based on facts and unbiased evidence. Constraints should not be applied to the overall assessment of need (ID: 2a-004);

• utilise household projections published by the Department for Communities and Local Government as the starting point estimate of overall housing need (ID: 2a-015);

• consider sensitivity testing, specific to local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates (ID: 2a-017); and

• take account of employment trends (ID: 2a-018), appropriate market signals including market indicators of the balance between the demand for and supply of dwellings (ID: 2a- 019) and affordable housing needs (ID: 2a-029).

Relevant Caselaw

2.4 There have been several key legal judgments which provide clarity on interpreting the NPPF and PPG in terms of how to address the issue of affordable housing need in the context of arriving at a concluded figure for OAHN:

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1 ‘Satnam Millennium Limited and Warrington Borough Council [2015] EWHC 370’ referred to as “Satnam”; 2 ‘Kings Lynn and West Norfolk Borough Council v Secretary of State for Communities and Local Government [2015] EWHC 2464’ referred to as “Kings Lynn”; 3 ‘Barker Mill Estates Trustees v Test Valley BC& Secretary of State for Communities and Local Government [2016] EWHC 3028 (Admin)’ referred to as “Barker Mill”; and 4 ‘Jelson Ltd. v Secretary of State for Communities and Local Government, Hinckley and Bosworth Borough Council [2018] EWCA Civ 24’ referred to as “Hinckley and Bosworth”.

Satnam

2.5 Satnam highlights the importance of considering affordable housing needs as part of – and not separate to – concluding on OAHN. The decision found that the adopted OAHN figure within the Warrington Local Plan was not in compliance with policy in respect of affordable housing because (as set out in paragraph 43) the assessed need for affordable housing was never expressed or included as part of OAHN. The judgment found that the “proper exercise” had not been undertaken, namely:

“(a) having identified the OAHN for affordable housing, that should then be considered in the context of its likely delivery as a proportion of mixed market/affordable housing development; an increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes;

(b) the Local Plan should then meet the OAHN for affordable housing, subject only to the constraints referred to in NPPF, paragraphs 14 and 47.”

2.6 In summary, this judgment establishes that OAHN has to include an assessment of full affordable housing needs, and is not a ‘policy-on’ judgement in determining the housing requirement.

Kings Lynn

2.7 Kings Lynn helps establish how full affordable housing needs should be addressed as part of an OAHN calculation. The judgment identifies that it is the function of a SHMA to address the needs for all types of housing including affordable, but not specifically to meet all these needs in full. The relevant passage on this is to be found in paragraphs 35 to 36 of the judgment:

“At the second stage described by the second sub-bullet point in paragraph 159, the needs for types and tenures of housing should be addressed. That includes the assessment of the need for affordable housing as well as different forms of housing required to meet the needs of all parts of the community. Again, the PPG provides guidance as to how this stage of the assessment should be conducted, including in some detail how the gross unmet need for affordable housing should be calculated. The Framework makes clear these needs should be addressed in determining the FOAHN, but neither the Framework nor the PPG suggest that they have to be met in full when determining that FOAHN. This is no doubt because in practice very often the calculation of unmet affordable housing need will produce a figure which the planning authority has little or no prospect of delivering in practice. That is because the vast majority of delivery will occur as a proportion of open-market schemes and is therefore dependent for its delivery upon market housing being developed. It is no doubt for this reason that the PPG observes at paragraph ID 2a-208-20140306 as follows:

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‘The total affordable housing need should then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes.’

This consideration of an increase to help deliver the required number of affordable homes, rather than an instruction that the requirement be met in total, is consistent with the policy in paragraph 159 of the Framework requiring that the SHMA "addresses" these needs in determining the FOAHN. They should have an important influence increasing the derived FOAHN since they are significant factors in providing for housing needs within an area.” (Lichfields emphasis)

2.8 The judgment is clear that the correct method for considering the amount of housing required to meet full affordable housing needs is to consider the quantum of market housing needed to deliver full affordable housing needs (at a given percentage). However, as the judgment sets out, this can lead to an OAHN figure which is so large that a LPA would have “little or no prospect of delivering [it] in practice”. Therefore, it is clear from Kings Lynn that although it may not be reasonable and therefore should not be expected that the OAHN will include affordable housing needs in full, an uplift or similar consideration of how affordable needs can be ‘addressed’ is necessary as part of the OAHN calculation. This reflects paragraph 159 of the NPPF.

Barker Mill

2.9 The Barker Mill High Court judgment considered uplifts to OAHN to address affordable housing need in the context of a challenge to a Local Plan. The judgment, in the context of a Local Plan process, placed consideration of an uplift for affordable housing into the second of a two stage process, the first being calculation of OAHN and the second being a ‘policy-on’ adjustment (i.e. one that is made through the Local Plan process and thus not part of the OAHN). There is a tension between the findings in this judgment and Kings Lynn.

Hinckley and Bosworth

2.10 This judgment is relevant in the context of the findings of the above Barker Mill judgment. In short, in considering the refusal of planning permission for housing, the Inspector in this case, as a matter of planning judgment, accepted the need for affordable housing to make up a necessary component of OAHN for housing in the council's area, or in the context of the Barker Mill judgment, as part of the first stage calculation of OAHN.

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“This case is not analogous to Hunston Properties Ltd. and Gallagher Estates Ltd., where the decision-maker had adopted a level of housing need constrained by policy considerations – so called "policy-on" factors, as they were referred to in Gallagher Estates Ltd.. As Mr Phillpot and Ms Osmund-Smith submitted, the figure of 450 dwellings per annum identified by the inspector as the upper end of her range was not, in fact, a "constrained" figure. In her view, as a matter of planning judgment, it sufficiently embraced the need for affordable housing as a necessary component of the "full, objectively assessed needs" for housing in the council's area. It was the result not of a policy-driven subtraction from the figure of 375 dwellings per annum at the lower end of her range – the figure based on "demographic-led household projections" – but of an appropriate addition to that figure to ensure that the need for affordable housing was not omitted or understated. As the inspector clearly appreciated, a simple addition of the figures of 375 dwellings per annum in the column headed "Demographic-Led Household Projections to 2031" in Table 84 of the SHMA and 248 dwellings per annum in the column headed "Affordable Housing Need per Annum" would have been inappropriate. That would have been, to some degree, double-counting. Planning judgment was required in gauging a suitable uplift to take account of the need for affordable housing, without either understating or overstating that need. The inspector grasped that. She exercised her planning judgment accordingly, doing the best she could on the evidence before her.” (para 36).

2.11 It is also worth noting in this regard that this judgment makes the following comment regarding the Planning Advisory Service (PAS) Technical Advice Note which is sometimes cited at Local Plan Examinations as a reason for excluding affordable housing as a policy-off in terms of FOAHN:

“This is not an official document and the relevant paragraphs cited do appear not to be consistent with case law... It would, of course, have been better had the Inspector either not referred to the Advice at all or recognised that it was (at least arguably) inconsistent with case law.” Context

Luton and Central Bedfordshire SHMA (2015)

2.12 The Luton Local Plan was underpinned by an iteration of the Luton and Central Bedfordshire SHMA published in 2015 (“the 2015 SHMA”), which concluded that OAHN for Luton was 17,800 dwellings over the period 2011-31 (equivalent to 890 dwellings per annum). The 2015 SHMA used ten year migration trends (from the 2001-11 period) and concluded that a market signals uplift of 10% overall was appropriate for the Luton and Central Bedfordshire HMA; it apportioned a 20% uplift to Luton and 5% to Central Bedfordshire (2015 SHMA para 4.105).

Luton Local Plan and Inspectors Report

Luton’s OAHN

2.13 The Council should not – as at is has done - take the Luton Local Plan Inspector’s report as a direct endorsement of the SHMA, not least because the SHMA tested at the Luton Local Plan Examination has now been superseded.

2.14 The Luton Inspector’s report and findings can be summarised as follows: 1 The starting point for assessing need (across both Luton and Central Bedfordshire) was the 2012-based household projections, which show growth of 53,336 households or 2,667 per

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annum (IR 83), and a ten year trend (along with the SHMA’s adjustments) reduces this to 41,345 households (2,067 per annum) (IR 84); 2 The Inspector stated that it was not unreasonable to use a longer term trend (IR 85); 3 When considering the SHMA’s adjustments to the demographic data, the Inspector only explores the adjustments made to the data for Luton (IR 86-89). The issues in Luton related to likely under-counting of the 2001 Census, and the potential over-estimate of migration which subsequently resulted from comparing the 2001 and 2011 Census estimates (IR 86). These issues are very different from the adjustments the SHMA makes in Central Bedfordshire. 4 The Inspector concludes that “the Council’s downward adjustment falls within the bounds of what might reasonably be expected to occur” (IR 89) – “the Council” here being a clear reference to Luton Borough Council and not Central Bedfordshire. The specific adjustments made to the data for Central Bedfordshire (which relate to UPC for the 2001-11 period and further adjustments to post-2011 data by reference to “administrative sources”) were not explored by the Inspector. The adjustments made in Central Bedfordshire were a different type of adjustment to those made in Luton.

For these very simple reasons, the Luton Inspector’s conclusions cannot be interpreted as endorsement of the SHMA’s approach in Central Bedfordshire.

2.15 In addition, the Inspector noted numerous reasons why the OAHN (for either Luton or both Luton and Central Bedfordshire) may be “potentially higher” (IR 97): 1 The 2014-based projections, which were published during the examination, indicate growth of 6,500 households more than the 2012-based projections across Luton and Central Bedfordshire (IR 98). The Inspector noted that there were concerns about “data quality issues”, however stated it is “nevertheless a potentially significant increase”; 2 Luton Council’s concerns about 2001 Census errors now relate to an event which took place 16 years ago, and with the passage of time these issues will diminish. The migration trends (2001-11) upon which the 2015 SHMA drew also ended six years ago (IR 99); 3 Migration pressures from London and/or the result of London not meeting its housing needs, combined with the transport links that exist between London and Luton. However the Inspector ultimately concluded that the GLA had not requested that unmet needs be taken into account, and it was not possible to quantify/distribute these needs (IR 100);

2.16 All of the above factors could have an effect on the OAHN for Luton and its HMA; however the Inspector did not conclude that the examination should be suspended to re-visit housing numbers because:

• The PPG accepts that new projections are not rendered outdated every time new projections are published (IR 102);

• Suspending the examination would create significant delay, whereas adopting the Plan would give some certainty to other authorities on the scale of unmet need (IR 103);

• The previous Luton Local Plan was adopted in 2006 and only covered the period up to 2011 (IR 104); and

• If an updated SHMA showed a higher OAHN, in reality this would affect decisions outside of Luton, not within Luton itself given its constrained position (IR 105).

2.17 In light of the above, the Inspector recommended an early review to deal with housing numbers, which includes a re-assessment of migration trends and, if required, the approach set out in the Government’s ‘Planning for the Right Homes in the Right Places’ consultation.

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Luton’s Housing Capacity

2.18 The Inspector identified Luton’s capacity for housing (over the 2011-31 period) to be 8,500, leaving (against a figure of 17,800) an unmet need of 9,300 dwellings to bet met elsewhere (IR 138). The emerging North Hertfordshire Local Plan makes provision for some of this need (1,950 dwellings) (IR 14), with the remaining likely to fall to Central Bedfordshire. The Inspector notes that Aylesbury Vale is unlikely to be a ‘prime candidate’ to receive any significant quantity of Luton’s unmet needs’ (IR 141), and the emerging Vale of Aylesbury Plan does not make any provision for this.

Summary

2.19 In summary the Luton Local Plan Inspector’s report cannot be viewed as an endorsement of the specific assumptions and methods used to assess OAHN for Central Bedfordshire. These adjustments were beyond the scope of the Luton Plan Inspector’s findings, and the Inspector only explored and accepted the specific demographic adjustments insofar as they related to Luton. The adjustments and issues in Luton are entirely different to those in Central Bedfordshire. In addition, the Luton Local Plan Inspector noted a number of factors which were likely to increase the OAHN, albeit concluding that these issues were likely to affect surrounding authorities more than Luton and that it was more beneficial for Luton to have a plan in place and to undertake an early review, rather than to suspend the examination. Review of Luton & Central Bedfordshire Strategic Housing Market Assessment (2017)

2.20 Since the Luton Local Plan examination, a 2017 SHMA has been prepared. It takes into account more recent data, including the 2014-based household projections and mid-year population estimates up to 2015/16. It concludes that OAHN for Central Bedfordshire is 31,778 dwellings 2015-35, or 1,589 per annum. For Luton it concludes on OAHN of 18,810 dwellings 2015-35, or 940 dwellings per annum (ie c.1,000 more than the OAHN that underpinned the adopted Luton Plan). This equates to a total of 2,529 dpa for the two authorities. Paragraph 47 requires authorities to “use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area” (our emphasis)

Demographic-led Needs

Context

2.21 The PPG at ID 2a-015 is clear that the latest household projections published by the Department for Communities and Local Government1 (DCLG) should form the starting point for the assessment of housing need. Over the 20-year plan period 2015-35, the latest 2014-based projections (published in 2016) project growth of 2,877 households per annum across Luton and Central Bedfordshire see 2017 SHMA (para 3.7), of which 1,729 are in Central Bedfordshire.

2.22 In total over the 20 year period, the household projections therefore project overall growth of 34,580 households. By contrast, the SHMA’s concluded OAHN for Central Bedfordshire (which purports to take into account employment, market signals and affordable housing needs) is less than this, at 31,778. In other words the SHMA concludes that OAHN is less than what the PPG itself defines as the ‘starting point’. Given the PPG (ID2a-017) is clear that the official projections should be regarded as “statistically robust and are based on nationally consistent assumptions” this immediately raises concerns as whether the adjustments made by the SHMA

1 Now Ministry for Housing, Communities and Local Government (MHCLG)

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are reasonable and robust, particularly given Figure 35 of SHMA shows population growth in Central Bedfordshire has been increasing over time.

SHMA adjustments

2.23 The SHMA’s downward adjustment in Central Bedfordshire is not only the result of using long- term migration trends, but is the result of its ‘local demographic adjustments’. In short, the SHMA has adjusted the official mid-year population estimates (MYEs, published by the Office for National Statistics [ONS]) for Central Bedfordshire for the period 2001-11, and made further adjustments to the MYEs for 2011-15. It then uses these ‘adjusted’ estimates to create a scenario based on ten year trends. Below we review whether these adjustments are “clearly explained” based on “established sources of robust evidence”, as required by the PPG in ID 2a-017.

2.24 Paras 3.22-24 and Figure 36 of the 2017 SHMA show that following the 2011 Census, when the MYEs for 2001-11 were revised, international in-migration for Central Bedfordshire was revised upward. In addition, a downward adjustment – known as ‘unattributable population change’ or UPC - was made. The SHMA therefore equates these revised MYEs with a systematic error in migration estimates to Central Bedfordshire. However, this logic is flawed because: 1 Revision to one component of change (in this case, international migration) does not make it directly linked to the UPC adjustment which was subsequently needed; 2 The nature of UPC (being ‘unattributable’) means ONS cannot attribute it to any specific source. There are a number of potential sources of UPC, such as migration (internal or international), as well as errors in the 2001 and/or 2011 Censuses. The Census errors for Central Bedfordshire are shown in Figure 2.1 – they show a margin of error of just over 7,000 people in 2001 and just over 5,500 in 2011, which could explain some of the UPC without any effect on migration estimates. The SHMA does not consider this;

Figure 2.1 Margins of error around the 2001 and 2011 Censuses (95% level)

Source: Lichfields based on ONS confidence intervals for 2001 and 2011 Censuses

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3 ONS itself notes that adjustments to international in-migration were needed in 2011 because the MYEs had missed large numbers of EU8 accession migrants arriving in the UK in the mid-late 2000s2, hence an upward adjustment to international migration is entirely reasonable in this context, and is likely to simply be capturing large numbers of immigrants that were missed; 4 The SHMA’s conclusions imply that ONS’s Migration Statistics Improvement Programme (MSIP) – a programme implemented to improve migration estimates – seemingly significantly worsened migration estimates in Central Bedfordshire, and the SHMA has not provided any evidence to explain why this has supposedly been the case. Taking the neutral stance that MSIP did improve estimates, revised estimates in the latter 2000s are more accurate, and therefore scenario which draw upon 10 year trends (either 2005-15 or 2006- 16, as published by ONS) are robust.

2.25 The SHMA goes on to make adjustments to the MYEs for 2011-15 on the basis that it believes there to be systematic error in ONS’s estimates. As a matter of principle, ONS itself will not have a robust basis for revising the MYEs until a Census is taken (i.e until 2021, which the SHMA acknowledges at para 3.32). The SHMA therefore automatically fails test in PPG which requires alternative assessments to be based on “established sources of robust evidence”.

2.26 The SHMA makes its adjustments because – it claims – there are administrative data sources that imply the MYE’s are showing excessive levels of population growth. The sources cited in the SHMA are the Patient Register, School Census and State Pension data. It is these (and these alone – there is no other narrative to explain what, in the real world, might explain why the growth did not occur) that are used to suggest a systematic error in the migration estimates. Unfortunately, the SHMA’s reliance on these administrative sources is flawed: 1 ONS already uses the Patient Register (“PR”) as one of a number of inputs in its MYEs, using changes in addresses (not the overall population numbers, as the SHMA does) to estimate internal migration. Therefore, ONS has already accounted for the PR in the MYEs; ONS has set its MYEs for Central Bedfordshire in full knowledge of the PR, and on the range of other sources available to them. The SHMA’s approach is clearly circular or ‘double-handling’ (not to mention incorrect), and concluding one should reject the ONS judgment on the MYEs (informed by the PR and a range of other data sources) by reference to the material that ONS already has taken into account is flawed. Further, ONS3 is clear that in its raw format (as used in the SHMA), the PR is not a reliable or robust source of data. It states; “The Patient Register has a number of issues when used for statistical purposes. The source has a number of both under- and over-coverage issues (when compared with the target statistical population) and time lags in the data. The source has limited audit and there is potential for distortive effects because of its role in General Practitioner (GP) finance. The effect of these issues will vary by geography, age and sex, the main variables in demographic statistics.” (p.2) “… NHS England’s Policy Book for Primary Medical Services says “a practice list can hold 3 to 8% of inaccuracy due to patient turnover alone”” (p.13) Only a relatively small difference would be needed in one year to occur, which is not repeated in subsequent years (or not repeated to the same degree) to wipe out the whole

2 ONS Long-Term International Migration estimates methodology, p.5 https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/internationalmigration/methodologies/longte rminternationalmigrationestimatesmethodology/pdf 3 ONS Patient Register: quality assurance of administrative data used in population statistics report, December 2016

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basis for the SHMA’s adjustments. For example, according to the SHMA’s figures, in 2011 the PR recorded 1.8% more residents in Central Bedfordshire than the MYEs (which we can assume were relatively reliable as they were based on the Census). After 4 years (i.e. in 2015) the PR then appears to record 0.8% more residents in Central Bedfordshire than the MYEs for that year show. It could plausibly be the case that that: a In 2011 the PR had an unusually high error (and we take the 2015 error of 0.8% as ‘typical’). If in 2011 the level of error was just 1% higher than the typical error (i.e. in 2011 the PR recorded 2,500 more people than usual), the SHMA’s basis for its adjustment to fall away; or b In 2015 the PR had an unusually low error (and we take the 2011 error of 1.8% as ‘typical’). If in 2012 the level of error was just 1% lower than the typical error (i.e. in 2015 the PR recorded 2,500 fewer people than usual), the SHMA’s basis for its adjustment equally falls away. Further, other ONS Reports on the PR4 note there are a number of limitations that lead to an undercounting of people, and this clearly explains that areas with higher levels of migration (like Central Bedfordshire) are likely to see an undercount in the PR, notably for: those slower to register a change of address, mobile young adults, and international migrants. Between 2011/12 and 2014/15, international in-migration from Central Bedfordshire totalled 6,656. If [hypothetically] one assumed that there were no other changes in errors in the PR for Central Bedfordshire between 2011 and 2015, it would only take around 1 in 3 of these international in-migrants to the District not to register with a GP to explain all of the 2,340 difference between the MYEs and the PR. If these international migrants did not register with a GP they would not appear in the PR, however as ONS produces international migration estimates using a number of data sources (e.g. the international passenger survey) these migrants could have been picked up elsewhere, and hence be included in the MYEs. It is remarkable that the SHMA in using the PR as its primary administrative source fails to acknowledge any of these limitations. Either it was unaware of these limitations or it chose to ignore them and did not bring them to the attention of the local authorities relying upon the SHMA. Clearly, the PR alone does not robustly estimate population or change in Central Bedfordshire, nor does ONS in any way suggest [alone] that it could. It provides no basis for making purported ‘corrections’ to the MYEs in the way the SHMA has done. 2 There are conceptual differences between the School Census (“SC”) and usually resident population, and there is variation in results across local authorities (in terms of how closely aligned the School Census and MYEs are). ONS has also removed SC data from its most recent 2016 MYE Quality Assurance Pack, suggesting in ONS’s view it is no longer fit for making the type of comparison undertaken by the SHMA. For Central Bedfordshire, the accuracy of the SC in 2011 is also very questionable. The figures for the SC and MYEs for 5-9 year olds are similar, however for 10-14 year olds the SC shows c.1,000 fewer than the MYEs. If the starting point is not reliable then any change measured from this point is also not reliable. In addition, by 2015 the SC suggests the number of 10-14 year olds has declined, which appears at odds with growth across most other age groups.

4 Beyond 2011: Administrative Data Sources Report: NHS Patient Register November 2012

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Overall there are clear reasons to doubt the accuracy of the SC altogether, but particularly so in Central Bedfordshire. 3 State Pension Data (“SPD”) for Central Bedfordshire shows an increase of 6,320 people age 65+ compared to 6,850 in the MYEs. This is a difference of c.500 people equivalent to c.100 per year – in population of 45,000 this is a relatively small degree of variation, particularly given we would expect some differences between the two sources in any case.

Summary

2.27 The SHMA’s adjustments to ONS’s official projections are not based on established sources of robust evidence and therefore do not meet the PPG requirements for departing from the official projections. The SHMA has not fully explored potential causes of the UPC between 2001 and 2011, and the logic that upward revisions to international migration led to all of the identified UPC is flawed. The SHMA has also failed to show why in Central Bedfordshire ONS’s migration statistics improvement programme has seemingly had the opposite effect, and there is no reference to what might be happening ‘on the ground’, e.g. if there are difficult populations or specific issues related to students, armed forces, etc. There will also be no robust basis for correcting post-2011 estimates until the 2021 Census (even according to the SHMA itself), and the administrative sources used by the SHMA to make its adjustments do not (either alone or combined) represents a robust basis for making such adjustments. ONS itself makes this clear in a number of published documents.

2.28 There are a number of other reasons to doubt the adjustments made in the SHMA, and revert to the official data sources (e.g. ONS MYEs and the official population/household projections). For example: 1 The SHMA’s immediate assumption is that high growth must mean persistent errors in the data. Rather, historic data shows Central Bedfordshire has been progressively growing faster over time, and the degree of error due to migration in the 2001-11 period has likely been significantly overstated by the SHMA (because it does not consider whether Census error could account for some of this); 2 The SHMA’s approach reads entirely as a statistical exercise and there is no reference to what might be happening ‘in the real world’ which might explain – or not - the supposed ‘systematic errors’ in international migration estimates. For example, the area does not have a high proportion of student populations (which are generally acknowledged to lead to result in distorted international migration estimates for some university town areas); In its “Quality Indicators for Local Authority Mid-year Population Estimates” published alongside the 2016 MYEs, ONS provide estimates of “the percentage of a local authority population that consists of a difficult to estimate group. The higher the percentage, the greater the risk of uncertainty in the mid-year population estimate.” For Central Bedfordshire, the proportion comprising international migration is 0-2%; and 3 Other ONS data5 on the margins of error around the MYEs shows Central Bedfordshire is within the top 25% LPAs in England in terms of accuracy, i.e. the MYEs for Central Bedfordshire are considered by ONS to be amongst the most accurate (i.e. having a small margin of error) in England.

5 ONS Margins of Uncertainty around the MYEs. Based on the Relative Root Mean Square Error (RRMSE), which underpins ONS’s preferred ‘bias-adjusted confidence interval. In Central Beds in 2015 the RRMSE is 1.08, which ranks it 74th out of the 326 English Local Authorities.

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2.29 Given the SHMA’s assessment of demographic-led needs for Central Bedfordshire is fundamentally flawed, any assessment which flows from this (e.g. employment-led, market signals or affordable housing) will also be flawed.

Market Signals

2.30 The PPG sets out a clear two-stepped process to addressing market signals within the calculation of OAHN: 1 Firstly, it is necessary to determine whether a market signals uplift is necessary. This is set out in PPG ID2a-019 within the first sub-paragraph as follows: “Appropriate comparisons of indicators should be made… A worsening trend in any of these indicators will require upward adjustment to planned housing numbers compared to ones based solely on household projections.” 2 Secondly, when a market signals uplift is required, it is necessary to identify at what scale that should be set, with guidance given that it should be set at a level that could be expected to improve affordability. This is set out in PPG ID2a-019 within the second and third sub- paragraphs as follows: “In areas where an upward adjustment is required, plan makers should set this adjustment at a level that is reasonable… they should increase planned supply by an amount that, on reasonable assumptions and consistent with principles of sustainable development, could be expected to improve affordability, and monitor the response of the market over the plan period.”

2.31 The principle of a market signals uplift in Central Bedfordshire (i.e. Stage 1) is not disputed. However, the scale of the uplift is disputed, principally because there no sound basis to conclude that the uplift can be reasonably expected to improve affordability, and the SHMA provides no evidence that it will do so. In addition, as previously noted, because the SHMA has applied its market signals uplift to a flawed demographic-led assessment of need, any figure flowing from this is itself also flawed.

Determining a scale of uplift

1. Review of National position

2.32 Under the current planning system, addressing affordability across the country will be a product of implementing a large number of Local Plans (i.e. a ‘think global, act local’ approach). Each area will have a role in contributing to Government’s aims as expressed in national planning policy. At the national level a number of studies have looked at what scale of housing delivery and dwelling stock growth would be necessary to address affordability problems: 1 The Barker Review of Housing Supply (2004)6 concluded that to reduce the long term house price trend to 1.1% per annum (the average across the EU) would require national delivery totalling 245,000 private dwellings per annum to 2026, alongside an increased provision of social sector housing (23,000 p.a.). The Barker Review concluded that such a level would be necessary for "improving the housing market" and ensure that "affordability is increasingly improved over time" (paras 1.39 and 1.40). Nationally, that scale of growth would represent dwelling stock growth of c.1.13% per annum7.

6 ‘Review of Housing Supply, Delivering Stability: Securing our Future Housing Needs’ (March 2004), Kate Barker - http://news.bbc.co.uk/nol/shared/bsp/hi/pdfs/17_03_04_barker_review.pdf 7 23,733,000 dwelling stock in England in 2016 (CLG Live Table 100)

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2 The National Housing and Planning Advice Unit’s (NHPAU) ‘Developing a target range for the supply of new homes across England’ (October 2007)8 concluded that (para 4.68) the “NHPAU believes that there is a realistic possibility of stabilising the affordability of market housing over the long-term if a supply target for 270,000 net additions to stock, in the right place and of the right type can be adopted through the planning system for delivery before or by 2016.” This would represent a 1.14% per annum scale of stock growth. 3 In July 2016, the House of Lords Select Committee on Economic Affairs published their report ‘Building More Homes’9 which was the output of the House of Lords’ inquiry into the housing market. It drew upon evidence provided to the inquiry by HM Treasury (HMT) indicating that “modelling suggests that in order to keep the house prices to earnings ratio constant, somewhere between 250,000 and 300,000 homes per year need to be built” in arriving at its ultimate conclusion that, “to address the housing crisis at least 300,000 new homes are needed annually for the foreseeable future.” (our emphasis). This would represent a 1.26% per annum scale of stock growth. 4 The Redfern Review10, a 2016 independent review of the causes of falling home ownership and associated housing market challenges, was informed by a housing market model built by Oxford Economics11 which looked at the impacts of different supply assumptions on prices and home ownership. It identified that “To put downward pressure on prices new supply would need to outstrip underlying household formation” modelling a boost in housing supply of 100,000 above their baseline forecast of 210,000 dwellings per annum, concluding that 310,000 dpa “helps to keep prices in check” up to 2026. This would represent a 1.31% per annum growth in dwelling stock.

2.33 What each of the above studies have demonstrated is that increasing dwelling stock growth would be necessary to address and improve affordability at the national level. Across the analysis it suggests that, at the national level, stock growth of between 1.1% and 1.3% per annum could achieve the beneficial impacts on affordability needed (recognising that in local areas this will clearly vary, depending on the local household growth rates). The figures would all represent significant increases above background projected household growth (c.210,000 households p.a. in the CLG 2014-based projections over the period to 2039 is the equivalent to c.215,000 dwellings p.a.) of between 21% and 44%. This gives an indication of the scale of dwelling delivery potentially required to address market signals at the national level.

2.34 Having established its 10% uplift for Central Bedfordshire, the SHMA states:

“The annual OAHN of 2,550 dwellings is the average number of dwellings needed every year over the period 2015-35 and represents an average increase in the dwelling stock of 1.3% each year over the 20-year Plan period, notably higher than the 1.0% growth required across England to deliver 239,500 dwellings annually” (SHMA 2017 para 5.92)

2.35 The source of the cited 239,500 figure appears to be based on the SHMA’s assessment of household growth nationally, accounting for long-term trends, concealed families and second/vacant homes (see SHMA 2017 para 5.7-17). However, in no way does this represent an

8 ‘Developing a target range for the supply of new homes across England’ (October 2007), NHPAU - http://webarchive.nationalarchives.gov.uk/20120919132719/http://www.communities.gov.uk/documents/housing/pdf/5239 84.pdf 9 ‘Building more homes’ 1st Report of Session 2016–17 (15 July 2016) House of Lords Select Committee on Economic Affairs (HL Paper 20) - http://www.publications.parliament.uk/pa/ld201617/ldselect/ldeconaf/20/20.pdf 10 ‘The Redfern Review into the decline of home ownership’ (16 November 2016) - http://www.redfernreview.org/wp- content/uploads/2016/01/TW082_RR_online_PDF.pdf 11 ‘Forecasting UK house prices and home ownership’ (November 2016) Oxford Economics - http://www.redfernreview.org/wp- content/uploads/2016/11/20161114-Redfern-Review-modelling-paper.pdf

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appropriate benchmark for measuring market signals uplifts in a national context given the PPG is clear that the official projections should be utilised.

2.36 The above reports show a clear consensus that around 250,000-300,000 homes per year are needed nationally. The Government’s proposed standardised methodology, which it is seeking to implement before the end of 2018, equates to a national total of 266,0000 homes per year (the figure is 300,000 without the 40% ‘cap’), although the methodology includes a caveat allowing authorities to plan for more than the methodology shows, for example if there are economic reasons12 (this is explored further below).

2.37 In the Autumn 2017 Budget, the Chancellor Phillip Hammond MP set out Government aspirations for housebuilding to reach 300,000 per year13. Overall It is clear that at a national level the consensus is that at least 250,000-300,000 homes per year are needed (not 239,500 cited in the SHMA), and this would represent annual growth in the range of 1.1% to 1.3% (not the 1% cited in the SHMA).

2.38 Given that some areas (i.e. with less affordability pressures) would be expected to do less than their ‘share’ of the nationally needed 1.1% to 1.3%, equally areas which are less affordable would be expected to do more than their ‘share’, i.e. more than 1.3%. As an area where affordability is worse than nationally (for example, the lower quartile resident-based affordability ratio is 9.3 and the lower quartile workplace-based affordability ratio if 11.5, compared to 7.2 for England), Central Bedfordshire needs to do more than the national average to address affordability. Table 2.1 shows the equivalent dwellings per annum under various annual growth rates for Central Bedfordshire.

Table 2.1 Growth rate and equivalent dwellings per annum

Growth rate Dwellings per annum Growth rate Dwellings per annum 1.0% 1,159 1.6% 1,854 1.1% 1,275 1.7% 1,970 1.2% 1,391 1.8% 2,086 1.3% 1,506 1.9% 2,202 1.4% 1,622 2.0% 2,318 1.5% 1,738 2.1% 2,433

Source: Lichfields based on DCLG Council Tax Base data - 115,876 dwelling as at 2016

2.39 For additional context, and to consider what scale of growth might “reasonably be expected to occur”, below reviews stock growth rates in adopted post-NPPF plans. Even the area with the highest growth rate (Cherwell, at 1.82%) will see this increase further soon, when it reviews its Local Plan to include unmet need from Oxford.

12 See ‘Planning for the Right Homes in the Right Places’ consultation 13 See Autumn Budget at https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/661583/autumn_budget_2017_print .pdf

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Table 2.2 Adopted Housing Targets in post-NPPF Plans

Adopted Annual Housing Target Stock 2016 Annual Growth Rate Cherwell* 1,140(+) 62,402 1.82%(+) Taunton Deane 850 52,840 1.61% Milton Keynes 1,750 108,981 1.61% Swindon 1,625** 94,374 1.72% East Cambridgeshire 575 36,971 1.56% Examined but not yet adopted Mid Sussex 1,026 61,878 1.66%

Source: Housing targets - respective Local Plans. Stock - DCLG Council Tax Base data. *Figure for Cherwell will increase following Local Plan Review to take account of additional need from Oxford. **Total housing target 2011-2026 22,000 dwellings (1,467 dpa), however Policy SD2 of Local Plan states average annual housing delivery from 2016-2026 will be higher at 1,625 dpa

2.40 The above figures only cover areas with adopted plans (plus Mid Sussex), which currently stands at only around one-third of all local authorities. It does not include plans currently undergoing examination or any areas which have yet to submit plans, hence should not be viewed as an exhaustive list of areas with high growth rates. There are a number of areas without plans which are likely to see high rates of housing growth, for example Peterborough, Bedford, Southampton, Reading (and many other parts of Berkshire), Harlow and parts of Greater Manchester. As more areas progress through to adoption of their plans, the number of plans across England with high rates of housing growth will inevitably increase.

2. Affordability Modelling based on University of Reading/OBR assumptions

2.41 The Office for Budget Responsibility (OBR) produced Working Paper No.6 Forecasting House Prices in July 2014. The report identifies the following with regards to future average earnings growth and median house price growth (the components of an affordability ratio) in paragraph 3.12:

“Using some long-run assumptions for real income growth (2.2 per cent a year, including growth in the number of households of 1 per cent a year) and housing supply (keeping pace with the number of households), and assuming the housing discount rate and wage share variable are stationary, the model predicts around 3.3 per cent real house price growth a year in steady state. In addition, assuming consumer price inflation in line with the Bank of England’s 2 per cent target implies 5.3 per cent a year nominal house price growth in steady state.”

2.42 The University of Reading's affordability model found a high price elasticity (-2.0) in relation to increases in stock at regional level in England, implying in-effect that for every 1% increase in supply (with housing supply keeping pace with the household projections), relative prices would be expected to fall by 2%. These assumptions have been combined with the wage/house price growth forecasts in the March 2017 OBR Outlook to model affordability outcomes.

2.43 There are a number of examples elsewhere of where this affordability modelling has informed the scale of market signals uplift applied. In Mid Sussex, the Inspector’s interim conclusions on the housing requirement (published February 2017) concluded that:

• The Council’s 24 dpa uplift for market signals was not sufficient, and although it was similar to approaches elsewhere however there have been changes in circumstances and a new approach is needed (p.2/3);

• House prices and affordability have worsened markedly in recent years, and there is a ‘serious and growing affordability problem’ for those on lower incomes (p.3);

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• The approach of comparing a District to its neighbours in terms of market signals is flawed, because if each authority replicated this approach the cycle of worsening affordability would be perpetuated (p.3)

• A significant uplift is needed to improve affordability, and the approach based on OBR/University of Reading has the ‘greatest value’ (p.5);

• An uplift of 20% is well-founded and realistic (p.6).

2.44 On 1st February 2018, the Inspector’s Report on the Waverley Local Plan (part 1) Examination was published. In respect of market signals, the Inspector noted that:

• Affordability is particularly poor in Waverley, it is amongst the least affordable area outside London and affordability is worsening (IR 20);

• The plans requirement, which incorporate a 5% upward adjustment to household formation rates to account for market signals is ‘not capable of addressing the Borough’s serious and worsening problem of housing affordability (IR 21);

• The OBR/University of Reading approach put forward by representors (which yielded a 28.8% uplift) represents a ‘credible approach’ to modelling supply and affordability. Overall an uplift on the starting point of 25% should be applied (IR 22).

2.45 Applying this approach to Central Bedfordshire (for illustrative purposes, lower quartile workplace-based earnings are shown) suggests that 2,550 dwellings per annum are needed to keep affordability at its 2016 level, as shown in Figure 2.2. This is set in the context that affordability has evidently worsened very significantly in the last 3-4 years alone. At the current SHMA OAHN, affordability would continue to worsen to around 15.0 by the end of the plan period.

Figure 2.2 Historic and forecast change in Lower-quartile affordability ratio

16.0

15.0

14.0

13.0 Historic 12.0 Baseline (1,800 dpa) SHMA OAN (1,589 dpa) 11.0 2000 dpa 10.0 2100 dpa 2200 dpa 9.0 Keep ratio constant - 2550 dpa Lower Quartile Workplace-based Affordability Ratio 8.0

7.0

6.0

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 Source: ONS, Lichfields based on OBR/University of Reading/ONS

2.46 Table 2.3 shows the impacts on lower quartile workplace-based affordability as well as median resident-based affordability in the short and long term. It demonstrates a significant worsening at the SHMA’s current OAHN, and a clear improvement which direct relates to the scale of

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housing growth. A level of around 2,550 dwellings per annum would be sufficient to maintain affordability in the longer term, although there may be a marginal increase in the short term still.

Table 2.3 Impact of scales of housing growth on affordability

Lower Quartile, workplace-based Median, resident--based Dwellings per annum Current Ratio in Ratio in Current Ratio in Ratio in ratio 2022 2035 ratio 2021 2035

1,589 (SHMA) 12.9 15.1 9.2 10.8 1,800 12.7 14.3 9.0 10.2 2,000 12.4 13.5 8.9 9.6 11.5 8.2 2,100 12.3 13.1 8.8 9.4 2,200 12.2 12.8 8.7 9.1 2,550 11.7 11.4 8.4 8.2

Source: ONS, Lichfields based on OBR/University of Reading/ONS

2.47 This exercise provides two useful conclusions in assessing what scale of uplift might be needed in Central Bedfordshire: 1 The SHMA’s concluded OAHN would clearly be insufficient to bring about any improvement whatsoever in affordability, and affordability would likely worsen significantly in the short and long term; and 2 Up to 2,550 dwellings per annum would be needed just to maintain affordability at its 2016 (which is the highest level seen in Central Bedfordshire), and arguably this should be treated as a minimum given affordability has worsened significantly in the last few years alone.

3. Apportionment of national needs

2.48 Central Bedfordshire is relatively worse in respect of affordability than the national equivalent. All other things being equal, to improve affordability across the country, Central Bedfordshire and its HMA peers would need to make a proportionately greater uplift than those where affordability issues are less acute. This exercise has been undertaken on the basis that Government now has a clear aim to bring housebuilding to a level of 300,000 per year by the mid-2020s, as set out in the Autumn 2017 budget13 (a level which is consistent with much of the literature review considered earlier in this section). This national total equates to an uplift of 85,000 on the household projections (which suggest a need for c. 215,000 homes per annum).

2.49 It is possible to consider how this required uplift should be shared between 320+ Local Planning Authorities across the country in order to seek to hold the affordability ratio (at least at a national level) constant. Three alternative scenarios for market signals uplifts across the country have been modelled, as follows: 1 Each district with an affordability ratio above the national ratio makes a market signals uplift in proportion to its difference with the national figure; 2 Each district with an affordability ratio above the national ratio makes a market signals uplift in proportion to its difference with the national figure (weighted 50%) and its projected household growth (weighted 50%); and

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3 Every district (whether above or below the national ratio) makes a market signals uplift in proportion to its difference with the lowest affordability ratio, in Copeland at 2.6, (weighted 50%) and its projected household growth (weighted 50%).

2.50 The results for Central Bedfordshire under these methods is shown in Table 2.4. The uplift has been based on a demographic baseline of 18,000 dpa, based on the projections plus a vacancy rate. To meet a national figure of 300,000 per annum the scale of uplift would need to be 24% at least, although taking into account Central Bedfordshire’s relative size this could be as high as 45-49%.

Table 2.4 Outcomes for Central Bedfordshire - Apportionment of National Needs

National total of 300,000 Share of Uplift (to Dwellings 85,000 uplift 1,800) Method 1 0.51% 437 24% Method 2 1.04% 888 49% Method 3 0.96% 816 45%

Source: Lichfields based on ONS/DCLG

2.51 The analysis clearly shows that an uplift well in excess of the 10% put forward in the SHMA would be needed to reasonable expect an improvement in affordability in Central Bedfordshire, and for the District to be contributing to the need nationally for new homes, taking into account affordability and its size. It is notable that using a 300,000 per annum total, the uplift for Central Bedfordshire identified in the Government’s proposed standardised methodology – at 40% - falls within the range (24%-49%) identified through this exercise.

Summary

2.52 In light of the above analysis, there is a case to be made that at the very least, the market signals uplift for Central Bedfordshire should be at mininum 20%. Taking a demographic-led baseline of 1,800 dpa based on the latest projections, this would equate to c.2,150 dwellings per annum. Analysis of stock growth rates elsewhere shows this is in line with the level seen in Cherwell, and like Central Bedfordshire, Cherwell will need to accommodate additional unmet needs from its neighbour (in Cherwell’s case, from Oxford). OBR modelling suggests that an uplift even greater than this may be needed to improve affordability, however in light of stock growth elsewhere and the outcomes of method (3), a minimum of 20% is considered appropriate.

2.53 This clearly underlines the failure of the SHMA to adequately meet the PPG requirement to set its uplift at a level that is related to the problems of affordability or that could be expected to improve affordability; indeed, the SHMA fails to approach this question at all.

Employment-led Needs

2.54 The SHMA’s employment-led housing need assessment flows from its demographic assessment, which as shown above is fundamentally flawed, and this therefore infects the employment-led need assessment. Notwithstanding, below sets out some additional factors which place further upward pressure on needs overall as a result of economic growth, namely by reference to the National Infrastructure Commission.

National Infrastructure Commission

2.55 The National Infrastructure Commission (NIC) published in November 2017 its report on behalf of Government on the Cambridge-Milton Keynes-Oxford Arc. The NIC was asked by Government to provide “proposals and options to maximise the potential of the Cambridge-

Pg 19 Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

Milton Keynes-Oxford arc”. It published an interim report in November 2016 which identified the key challenges, and its full report re-iterates these challenges and makes recommendations.

2.56 Throughout the report, it is re-iterated that without addressing the chronic shortage of housing in the arc, its economic growth potential is at risk. The very first paragraphs of the report state clearly that:

“The Cambridge-Milton Keynes-Oxford arc must be a national priority. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. Without urgent action, a chronic undersupply of homes could jeopardise growth, limit access to labour and put prosperity at risk.

The Commission’s central finding is that rates of house building will need to double if the arc is to achieve its economic potential.” (P.3) (emphasis added)

2.57 The report also refers to recent housing delivery rates in the arc and the levels needed (in its view). These are:

• 12,250 homes per year delivered 2012-15;

• 14,330 homes delivered in 2016-17;

• 15,926 homes per year provided for in Local Plans;

• 20,135 homes per year in current SHMAs;

• 23,000 homes to meet local needs in full (i.e. needs arising within the arc); and

• 30,000 homes to meet local needs and pressures from land constrained markets (i.e. meeting unmet needs from London and addressing the impact this additional demand could have on the arc’s housing market).

2.58 Further, the report not only addresses the issue of housing supply overall, but mentions numerous times the need for affordable housing and its role in maintaining a varied labour supply. For example, it states that:

“The success of towns and cities across the arc has fuelled demand for homes. But a sustained shortfall in housing supply has led to high house prices and low levels of affordability, for both home ownership and private rental, and an undersupply of affordable housing. This is placing a fundamental constraint on the continued growth of the arc’s most successful economies. Workers at all levels are being priced out of local housing markets, restricting firms’ access to labour and impacting upon competitiveness. From post-doctoral students to professors, and from catering staff to managing directors, finding affordable and good housing is a struggle.” (p.7-8) (emphasis added)

2.59 The report’s findings therefore demonstrate that:

• The economic growth potential in this region is one of national importance, and likely that employment assumptions underpinning the SHMA should be viewed as a minimum. This suggests the employment-led forecasts in the SHMA are too low and do not align with the NICs view of the arc’s economic potential;

• Historically, a ‘chronic’ undersupply of housing, including affordable housing, has led to worsening affordability which is placing a ‘fundamental constraint’ on the arc’s economy. This demonstrates there is a clear case for making a significant market signals uplift both to address affordability and deliver more affordable housing;

• In the future housing supply (along with infrastructure) is one of main barriers to the arc achieving this potential, and demand is likely to be further exacerbated by people migrating

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from London in search of more ‘affordable’ housing, pricing out local people. This re- iterates the findings of the Luton Local Plan Inspector who noted that pressures from London were likely to place additional pressure on housing demand in the area;

• The SHMA’s overall significant downward adjustments to the projected levels of population growth are at clear odds with the overarching thrust of the NIC report and its findings, namely that housebuilding levels need to ‘double’ and for central and local government to agree a deal which commits to ‘faster growth’.

Affordable Housing

2.60 Affordable housing needs are a component part of the OAHN for an area, as has been clarified by a number of recent High Court judgments (see above). In line with the NPPF (para 47, 159), Local Planning Authorities should;

“…use their evidence base to ensure their Local Plan meets the full, objectively assessed needs for market and affordable housing…”

“Local Planning Authorities should…prepare a SHMA which…addresses the need for all types of housing, including affordable.”

2.61 The PPG sets out an approach to identifying affordable housing needs (ID 2a-022 to ID 2a-029), and states that total affordable housing need should be;

“…considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments…an increase in the total housing figures included in the plan should be considered where it could help deliver the required number of affordable homes.”

2.62 The PPG sets out a structured methodology for the calculation of affordable housing needs with clear stages, not least because any deviation from this methodology can start to incorporate double-counting into the calculation.

2.63 The above High Court judgments go to the heart of addressing affordable housing within the identification of OAHN (as set out previously). The decision in Satnam establishes that affordable housing needs are a component part of OAHN, indicating that the “proper exercise” is to identify the full affordable housing needs and then ensure this is considered in the context of its likely delivery as a proportion of mixed market/affordable housing development. The decision in Kings Lynn follows and amplifies the Satnam judgment in establishing that identified affordable housing needs (para 36) “should have an important influence increasing the derived FOAN since they are significant factors in providing for housing needs within an area.” This is mirrored in the Hinckley and Bosworth judgment. It is clear that affordable housing needs are a substantive and highly material driver of any conclusion on full OAHN.

2.64 Unfortunately, the SHMA fails to follow the prescribed methodology of calculating the affordable housing needs as required in the PPG. The SHMA uses its own ‘housing mix model’ as a way of estimating the level of affordable housing need. ORS provides little information about the sources of data which feed into this model, instead preferring a ‘black-box’ approach where it is not possible to assess any inputs or assumptions to test if they are suitable and reasonable.

Housing Benefit

2.65 The SHMA’s approach to determining affordable housing need revolves around an assessment of the number of people claiming housing benefit. The PPG does not state that this should be used in the assessment, rather it clearly states (ID 2a-025):

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“Projections of affordable housing need will need to take into account new household formation, the proportion of newly forming households unable to buy or rent in the market area, and an estimation of the number of existing households falling into need. This process should identify the minimum household income required to access lower quartile (entry level) market housing (plan makers should use current cost in this process, but may wish to factor in changes in house prices and wages). It should then assess what proportion of newly-forming households will be unable to access market housing.”

2.66 The use of housing benefit as a way of assessing affordable housing need will inevitably lead to an under-estimation of affordable housing need, not least due to the strict eligibility criteria that applies. For example, the Government states that groups who are not eligible include:

• Those with savings over £16,000 (some pension exceptions apply). This effectively means those saving to buy would find themselves in an inescapable cycle whereby as soon as they save anything above £16,000 they then become ineligible for housing benefit, so have to spend their savings on housing (meaning they cannot purchase), before becoming eligible for housing benefit again; and

• Those who live in the home of a close relative. This would include, for example, adult children (including couples) who either remain in or move back into the family home, for example after returning from University.

2.67 Further, it will exclude from the assessment of need those who do not receive housing benefit but who spend significantly high proportions of their income on housing. Most SHMAs use a proportion of income as the basis for assessing affordable housing need, and the approach of ORS (the authors of the Central Bedfordshire SHMA) is most unusual in this regard. Interestingly, the same housing benefit-only approach is applied by ORS in its Buckinghamshire Housing and Economic Development Needs Assessment (“HEDNA”) which states (page 96) that:

“The affordability assessment used by the Model is relatively stringent insofar as it is only households that would be eligible for welfare support that are counted within the identified affordable housing need. There are likely to be other households who are spending more than 25% of their gross income (and sometime much more than this proportion), but who are not eligible for welfare support in relation to their housing. The Model’s assessment therefore focuses on those households with the most acute needs, and a broader affordability assessment would probably identify a greater number of households needing affordable housing. The Model therefore identifies a minimum level of affordable housing need.” (HEDNA’s emphasis)

2.68 No such qualification has been provided in the SHMA underpinning the Central Bedfordshire Plan despite the same methodological approach being adopted.

2.69 Only assessing households as unable to afford market housing if they are already claiming housing benefit or if they are not, but would be eligible is clearly an under-estimate of the true level of need given the groups excluded by Government..

2.70 Further, the SHMA assumes a continuing role for the private rented section (PRS) as a means of meeting the assessed affordable housing need. This was dealt with in the Eastleigh Local Plan Inspectors Report (paragraph 34) :

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“…there is no justification in the Framework or Guidance for reducing the identified need for affordable housing by the assumed continued role of the PRS with LHA. This category of housing does not come within the definition of affordable housing in the Framework. There is not the same security of tenure…”

2.71 There is no basis in the PPG for considering housing benefit receipts as part of earnings, or as a means of meeting housing costs. The assertion of ORS that it is appropriate to assume that the figure for those claiming housing benefit in the PRS remains constant because this means that every time someone moves from PRS when claiming housing benefit, they are replaced by a newly forming household in the same position. This may or may not occur in reality (particularly if insufficient affordable housing is provided), but for the purpose of assessing need in the context of the NPPF, a newly forming household who cannot afford market housing without housing benefit is in housing need.

2.72 By assuming and using this constant rate, ORS is significantly and artificially dampening the true scale of affordable housing needs from newly forming households. The assessment is effectively predicated on the false assumption that rather than building enough affordable homes to meet needs, housing benefit and the PRS sector will somehow fill the void and so that the Council do not have to provide affordable homes for their residents. This is a ‘counsel of despair’, and not an approach supported by the NPPF (para 9) or the PPG.

2.73 The SHMA thus cannot be seen to provide an assessment of affordable housing need that is consistent with the PPG or (most importantly) paragraph 9 of the Framework which identifies that pursuing sustainable development is focused on improving the conditions in which people live, and widening the choice of high quality homes.

2.74 The SHMA is almost certainly an under-estimate of the true scale of affordable housing needs in Central Bedfordshire. Housing Market Area and Duty to Co-operate

2.75 The NPPF requires for local authorities to have a “clear understanding of housing needs in their area” (para 159) and to “use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area” (para 47).

2.76 The Luton Local Plan Inspector accepted that Luton’s capacity for housing (over the 2011-31 period) was 8,500, leaving (against a figure of 17,800) an unmet need of 9,300 dwellings to bet met elsewhere (IR 138). As a part of its Duty to Co-operate, and in response to the Examination of the LBC Local Plan, in respect of meeting the unmet needs of Luton, it was established that a Joint Growth Options Study (JGOS) was being undertaken as a joint commission by Central Bedfordshire Council (“CBC”), Luton Borough Council (“LBC”), Aylesbury Vale District Council (“AVDC”) and North Hertfordshire District Council (“NHDC”). The aim of the JGOS was to identify and assess at a high level how Luton’s FOAN could be delivered within Luton’s administrative area and the wider HMA. Subsequently, the NHDC and LBC Statement of Common Ground (“SoCG”) Addendum (October 2017) states that the conclusions of the JGOS study are agreed by all four authorities (LBC, CBC, NHDC and AVDC).

2.77 However, the 2017 SHMA has updated Luton’s OAHN to a new higher figure of 18,810 , and assuming Luton’s capacity remains unchanged this will increase the level of unmet need to be met elsewhere (by c.1,000). A very small part of Luton’s FHMA falls within Aylesbury Vale, however Aylesbury Vale has not indicated any plans to meet Luton’s unmet need (and the District also faces considerable pressure from within the Buckinghamshire HMA). A further small part of Luton’s FHMA falls within North Hertfordshire District, which has indicated that it

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will meet 1,950 of Luton’s unmet need in its emerging Plan14. The remainder of Luton’s unmet need will therefore fall to Central Bedfordshire, which borders most of Luton.

2.78 It is imperative that the unmet needs of Luton are met within the areas of Central Bedfordshire which clearly have functional linkages with Luton. As shown in Figure 26 of the SHMA, Central Bedfordshire overlaps a number of Function Housing Market Areas (FHMAs) – the southern part of the District is within the Luton FHMA, however the western part of the District faces Milton Keynes, the northern part faces Bedford and the eastern part faces Stevenage. Central Bedfordshire borders most of Luton, with the exception of a small part of Luton’s eastern border with North Hertfordshire. Standardised Methodology

2.79 In February 2017 the Government set out its intention to proposed a standardised methodology for assessing housing needs in the Housing White Paper. In September 2017, as part of the Government’s consultation on ‘Planning for the Right Homes in the Right Places’, Government set out this methodology, based on a simple formula using current household projections and current affordability ratio. The scope to adopt figures lower than this is significantly narrowed, however some areas may be required to plan for housing in excess of this (for example, if there is a need to support employment growth) – in instances where local authorities put forward higher figures, Inspectors are advised to accept these approaches as sound.

2.80 At a national level, this standardised methodology produces an aggregate figure of 266,000 homes per annum, which broadly accords with wider targets of 250,000-300,000 homes per annum. Government proposed to introduce either in March 2018 or when the revised NPPF was published (whichever was later); in a letter to Local Authorities on 30 January 2018, Chief Planner at MHCLG15 Steve Quartermain indicated that a revised NPPF was now expected in Summer.

2.81 Based on this new methodology, the housing need figure for Central Bedfordshire would increase substantially compared to its current OAHN, from 1,589 to 2,553 dwellings per annum. The objectively assessed need for Luton would also increase, from 940 to 1,417 dwellings per annum, bringing the HMA total to 3,970 dwellings per annum or almost 80,000 over a 20 year period. Whilst Central Bedfordshire will not be subject to this new methodology in its current iteration of the Plan (provided it is submitted before the new methodology becomes adopted) the new methodology highlights two issues:

• It indicates that, in the Government’s view, the scale of uplifts being applied in current SHMAs is insufficient to address affordability. For Central Bedfordshire (with a median affordability ratio in 2016 of 10.4) the uplift under the standardised methodology is 40%, compared to 10% applied in the current SHMA (and 5% in the previous 2015 version of the SHMA); and

• When Central Bedfordshire Council undertakes its Local Plan review (required within 5 years) it will need to take into account the new methodology, and the Council will need to begin considering additional sites which it can allocate in order to meet this higher need.

14 The LBC and NHDC SoGC Addendum (2017) and CBC and NHDC MoU (2017) states that it is agreed that NHDC can contribute 1,950 new homes, and maximised its contribution to the unmet need of Luton during the NHDC plan period 2011-2031. 15 Ministry for Housing, Communities and Local Government, formerly Department for Communities and Local Government or DCLG

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Summary and Conclusions

2.82 The SHMA’s conclusions are not based on established sources of robust evidence, and it seeks to make significant downward adjustments to the projections by reference to sources which ONS itself describes as not suitable for use in their raw format (as the SHMA has done). The adjustment of MYEs post-2011 is also flawed because there is no robust basis to adjust these figures in Central Bedfordshire and the ONS will have no basis to do so until after the 2021 Census. The SHMA’s adjustments are for reasons that are unrelated to Luton or the Inspector’s consideration of the SHMA for that plan.

2.83 Overall the SHMA fails to provide any ‘real world’ analysis to demonstrate why it should not rely upon the official ONS data, or to explain why ONS methods would have such significant failings specific to Central Bedfordshire. It relies on an abstract statistical analysis (flawed in its own terms due to a failure to recognise the “administrative sources” have their own limitations) that is devoid of context or reasoning. As a result of its flawed demographic assessment, the analysis that flows from it is also infected.

2.84 The SHMA also does not demonstrate that a 10% uplift would reasonably be expected to improve affordability, and our analysis suggests that atleast a 20% uplift would be needed in Central Bedfordshire.

Alternative assessment

2.85 The demographic-led needs should be based on DCLG 2014-based household projections, which show growth of 1,729 households per annum 2015-35. Applying the second home/vacancy rate used in the 2017 SHMA (4%16), this equates to a need for 1,801 dwellings per annum, or 36,020 total over the plan period.

2.86 Our analysis of market signals suggests that at least a 20% uplift is needed to this in order to reasonable expect an improvement in affordability, which would equate to 2,150 dpa over the period, or around 43,000 in total over 20 years. At this OAHN, the Central Bedfordshire Plan would therefore fail to meet all of its own need, let alone make any provision for unmet needs from Luton.

2.87 It is notable that even at an OAHN of 2,150 dpa, the figure is under the Government’s proposed standardised methodology, which gives 2,553 dpa for Central Bedfordshire, or 51,000 in total over 20 years. This standardised methodology yields a figure of 1,417 dpa for Luton, which Luton will need to reflect in its Local Plan review. Based on a supply of 8,500, this would mean unmet need from Luton would then amount to almost 20,000 dwellings, most of which would likely need to be met in Central Bedfordshire given this is where most of Luton’s functional HMA lies. In this case, the total requirement for Central Bedfordshire would be upwards of 70,000 dwellings over 20 years – almost double the target in the emerging Plan.

16 Based on 2017 SHMA Figure 92, which shows 27,738 households generates a need for 28,889 dwellings (96%, or 4% vacancy)

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3.0 Housing Delivery

3.1 Notwithstanding the conclusions on Central Bedfordshire’s OAHN in Section 2.0, this section sets out the Plans housing trajectory, including its components of supply and supporting evidence. It then analyses the Council’s components of supply to establish whether the Council’s housing trajectory has a realistic prospect of being delivered within the Plan period, which includes a review of the Council’s assessment on lead in times and build rates, and meeting the OAHN. It goes onto review whether the Council could demonstrate a five year housing land supply (“5YHLS”) upon adoption of the Plan. Central Bedfordshire Pre-Submission Local Plan Housing Trajectory

Housing Trajectory (2015-2035)

3.2 The requirement set out by the Plan is sourced from the new 2017 SHMA. The Plan sets out at Policy SP1: Growth Strategy that 39,350 homes will be delivered in Central Bedfordshire over the period 2015 to 2035. This includes the 32,000 OAHN for Central Bedfordshire (or 1,600 dpa), and a commitment to facilitate 7,350 of Luton’s unmet need’ – subject to ongoing ‘duty to co-operate’ discussions and formal Local Plan Examination. This equates to an annual housing requirement of 1,968 dwellings per annum.

3.3 Tables 6.2 and 6.3 of Plan sets out that the components of supply included in the housing trajectory for the Plan period 2015 to 2035, as shown in Table 3.1, which is principally evidenced by the Council’s Housing Implementation Strategy (HIS) dated January 2018. The housing trajectory sets out that across the Plan period the Plan would deliver 41,830 against a requirement of 39,350 dwellings, of which 23,528 are existing commitments. The Plan also makes allocations and provision totalling 18,302, which consists of 4 Strategic Sites – which make up over half of all allocations – and 52 Small and Medium sites.

3.4 In respect of the windfall allowance, based on an assessment of windfall completions between 2007 and 2017 across the District and referring only to previously developed sites (excluding garden land), the Council has brought forward a windfall allowance into Plan. The Council has assumed a windfall allowance of 307 dwellings in the first five years of the Plan (years 2-5), and a large windfall allowance of 2,590 dwellings across the remaining Plan period (years 6-15). Cumulatively, this equates to a windfall allowance of 2,897 dwellings across the Plan period.

3.5 The HIS is supported by a schedule of completions and a schedule of commitments as at 31st October 2017. This has formed the basis of Lichfields review of the housing trajectory.

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Table 3.1 Existing and Proposed Housing Land Supply

Existing Commitments Dwellings Local Plan Allocations Dwellings Net Completions (2015-2017) 4,335 Small and Medium 5,505 Existing Allocations 7,742 Strategic Allocations 9,900

Strategic Sites (with P/P) 6,780 Windfall Allowance (post 5 years) 2,590

Large Windfall (with P/P) 4,023 Windfall Allowance (5 year period) 307

Small Windfall (with P/P) 648 Total 23,528 Total 18,302

Source: Table 6.2 and Table 6.2 of the Central Bedfordshire Council Local Plan 2035 Pre-submission January 2018

Five Year Housing Land Supply (1st April 2018-31st March 2023)

3.6 The Council’s 5YHLS position is set out in the HIS, at paragraph 4.2.1 and Figure 4, has a base date of the 1st April 2018 and ends on the 31st March 2023. Against a requirement of 10,781, the Council’s 5YHLS would total 10,976, or surplus of 194.6 dwellings, over the five year period 2018/19 to 2022/23, which results in a 5YHLS of 5.09 years. The 5YHLS position over the five year period 2018/19 to 2022/23 is displayed below in Table 3.2, and the components of supply, which are not explicitly stated, are shown above in Table 3.1. This is based upon a five year housing land supply calculation which:

• Utilises the Plan housing requirement of 1,967.5 dwellings per annum (dpa), which includes the Central Bedfordshire OAHN (1,600 dpa) and Luton unmet need (367.5 dpa);

• Includes the backlog since 2015 (start date of the Plan), which includes partial estimates of completions for Q3-4 of the 207/18 year17. Against a requirement of 5902.5 to date (2015- 2018, 1967.5 x 3), 5,472 dwellings have been delivered, which results in a 430.5 dwelling shortfall;

• Includes a windfall allowance of 307 dwellings for small sites (under 10 dwellings) over years 2-5 of the 2018/19 to 2022/23 five year period; and

• Applies a 5% buffer against the requirement and shortfall to date.

3.7 It is considered that, although not explicitly stated, the 5YHLS is made up of a number of components which are set out in Appendix A of the HIS, and individually listed within Appendix B.

17 “In order to provide a five year housing land supply estimate for 1st April 2018, completions for 2017/18 have been partially estimated.” – Footnote 1 of the Housing Implementation Strategy (January 2018)

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Table 3.2 Central Bedfordshire 5YHLS

Five Year

Period 2018-23

a Plan Requirement 39,350 b Annual Requirement (a/20) 1,967.5 c Requirement to date (b x years) 5,902.5 d Completions 5,472 e Shortfall at 31/3/17 (c-d) 430.5 f Base Requirement over next 5 years (b x 5) 9,837.5 Base Requirement over next 5 years g 10,268 plus shortfall (f + e) 5 Year Requirement and shortfall plus h 10,781.4 5% (g+5%) Revised Annual Requirement over next i 2,156.28 5 years (h/5) j Deliverable Supply over next 5 Years 10,976 Total years supply over next 5 years k 5.09 years (j/i) l ‘Surplus’ (j – h) 194.6

Source: Lichfields based on Housing Implementation Strategy (January 2018) Lead-in times and Build-out rates

3.8 The Plan’s housing trajectory is underpinned by assumptions and judgements made by developers and promoters and the Council’s local analysis regarding how quickly a site will come forward (lead-in time) and how quickly it will deliver (build-out rates). Such assumptions are of particular importance given that over half of the allocations in the Plan are of a strategic scale (1,000+ dwellings) and if sites fail to come forward and deliver at the assumed rate, this will invariably result in a shortfall against the Plan requirement (notwithstanding any critique).

3.9 Large strategic housing schemes typically experience long lead-in times, with long periods between initial identification/promotion, allocation and/or applications and then development getting off the ground, with houses being completed on site. Particularly in the case of very large strategic sites comprising thousands of units, they are often not a short-term or quick solution to housing land supply. Additionally, the rate at which sites can be built out are affected by range of factors from how quickly developers can sell, to availability of materials and labour, to practical site issues such as access and phasing.

3.10 In the context of the housing trajectory, Marston Vale (allocation for c.5,000) is the largest of the four strategic allocations, projected to begin delivering in 2021/22 and c.3,700 across the Plan period (2015-2031), at a peak build rate of c.300 dwelling per annum. When viewed alongside the other strategic sites, in particular North Luton (which has broadly similar projections), there is therefore a necessity to properly evidence assumptions on lead-in times and build-out rates are necessary to ensure the trajectory is justified and that the Districts housing need can be met across the Plan period.

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Strategic Housing Land Availability Assessment: Build-out Rate and Lead- in Time Analysis

3.11 The Central Bedfordshire Council Local Plan (2015-2035) Strategic Housing Land Availability Assessment (January 2018) (“SHLAA”) highlights the importance of understanding how quickly a site will come forward and how quickly it will deliver. It states that site delivery timescales included in the trajectory are based on evidence submitted by site promoters, and informed by the SHLAAs assessment of the site, which includes the impacts of required mitigation (para 3.6.11); and that most of the sites included in the trajectory benefit from site specific evidence (para 3.6.12). However, to ensure a robust trajectory and provide a benchmark for sites with no specific evidence of delivery (e.g. new allocations), the Council has undertaken two assessments underpinned by local examples across the District in respect of lead-in times and build-out rates.

3.12 With regards to the assessment of lead in times, the Council reviewed 26 sites which were under construction at the time, so as to ensure that the assessment reflected the up-to-date practices, to establish the time taken from submission of outline/full applications to the delivery of the first dwellings (shown in Appendix D of the SHLAA). The Council’s assessment concludes that:

• Registration of Outline application to first completion on site – c.3 years and 6 months; and

• Registration of Full application to first completion – c.2 years and 2 months.

3.13 Furthermore, the SHLAA anticipates that a larger number of sites allocated through the Local Plan will come forward with Full applications, on the basis that the principle of the development has already been established, and that where possible, Planning Performance Agreements (PPAs) will ensure a more efficient planning process (para 3.6.12).

3.14 A further assessment of delivery on sites of 10 or more dwellings over the past three to six years was undertaken, so as to ensure that the build rates included in the trajectory are realistic (para 3.6.14). The results of which can be seen in Table 3.3. The results exclude the first and last years of delivery, on the basis that they do not represent a full 12 months.

Table 3.3 Average annual delivery rates on sites in Central Bedfordshire over the past 3 years

Annual average dwellings Site Size delivery 10-20 c.1-2 years 21-50 21 51-100 44 101-200 46 201-500 87

Source: SHLAA (January 2018) – Table 4

National evidence

3.15 Although the Council has undertaken some [limited] analysis of local lead-in times and build- out rates across Central Bedfordshire, it is important to provide some context and reference points for the assumptions made by the Council in housing trajectory, particularly in respect of strategic sites, as the aforementioned analysis only reviewed sites between 0-500 dwellings.

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3.16 In November 2016 Lichfields published a research report entitled ‘Start to Finish: How quickly do large scale housing sites deliver?’18 The report, through the review of more than 150 sites nationally, provides insight to what have become perennial discussions at Local Plan examinations and Section 78 appeals in recent years; what are realistic lead-in times for large scale housing developments, and once the scheme starts delivering, what is a realistic annual build rate?

3.17 Lichfields’ research, in respect of lead-in times, concluded that lead-in times typically average c.3 years for smaller strategic sites (up-to 100 units), but that these increase to an average of c.7 years for larger strategic sites of more than 2,000 units. This reflects the fact that invariably larger sites give rise to complex planning issues related to both the principle of development and the detail of implementation.

3.18 Whilst assumptions about the annual delivery of a site are usually based on the number of sales outlets expected to operate on a site of that size (the number of different house builders or different products being delivered), Lichfields research demonstrated that there is a positive correlation between the strength of the market (as measured by residential land values) and the average annual build rates achieved. Additionally, the build-out rates of strategic schemes are influenced by the number of houses that the market can absorb; the breadth of choice of products on offer (e.g. affordable housing or build to rent) will impact market absorption because a variety of options will appeal to a greater market.

3.19 The research concluded that, on average, annual build rates for smaller strategic sites (up-to 100 units) average c.30 units each year, but these increase to an annual average of c.160 units for larger strategic sites of more than 2,000 units, which reflects the limits to number of sales outlets possible on a site, and overall market absorption rates. It should be noted that a site could be expected to deliver more (or less) than this average, and that build rates on sites fluctuate over their life.

3.20 With regards to extremely large sites that need to span more than a decade, the development will most likely happen in phases. The timing and rate of these phases will be determined by a range of factors including: the physical layout of the site, the ability to sell the homes; trigger points for payment for key social and transport infrastructure obligations; the economic cycle; and local market issues.

Local evidence

3.21 Whist the Council has undertaken an assessment of local lead-in times for development, the sites assessed did not exceed 500 dwellings in capacity, and therefore the resultant lead-in times only represent a valid assumption for some of the housing trajectory. It is therefore important that appropriate, reasonable and realistic assumptions can be made in Central Bedfordshire, in respect of large strategic developments. Accordingly, Lichfields has reviewed large strategic sites currently ongoing in the District and in neighbouring authorities (This analysis is contained within Appendix 1).

3.22 Table 3.4 illustrates that the absolute minimum lead-in times for large strategic developments in Central Bedfordshire is c.3 years, and can extend upwards of 6.5 years; however, it is important to note that none of the sites reviewed have delivered housing to date, and therefore the lead-in times are likely to increase. For example, North Houghton Regis (Site 1) was granted outline planning permission just over one year after submission, but c.four years later has yet to deliver any housing.

18 ‘Start to Finish – how quick do large-scale housing sites deliver?’ Nathaniel Lichfield and Partners (2016). http://nlpplanning.com/nlp-insight?category=1 . The Report won the RTPI Research Aware for 2017

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3.23 Looking to developments in neighbouring authorities, Table 3.5 demonstrates that lead-in times can extend up to 14 years, for developments which have begun to deliver housing, although is not less than seven years. Ultimately, the analysis illustrates that existing lead-in times within the area, and in neighbouring authorities, would tend to support Lichfields research findings on reasonable assumptions of lead-in times nationally, of around 6-7 years for the larger strategic sites allocated. However, this analysis fundamentally highlights that in many instances it appears that housing delivery has been significantly delayed on sites in Central Bedfordshire and neighbouring authorities by long lead-in times.

Table 3.4 Past Lead-in Times for Strategic Developments in Central Bedfordshire

Strategic Application Application Application Time since Delivery Size Development Type Submitted Determined Registration Started

North Houghton 5,150 Outline 21/12/2012 02/06/2014 5.13 years No Regis (Site 1) North Houghton 1,850 Hybrid 26/01/2015 18/11/2015 3.04 years No Regis (Site 2) East of Leighton Linslade 1,210 Outline 28/07/2011 28/08/2015 6.54 years No (Clipstone Park) East of Leighton Linslade 9,50 Outline 03/08/2011 28/08/2015 6.52 years No (Chamberlains Barn)

Source: Lichfields Analysis

3.24 Similarly to the Council’s assessment of local build rates, the assessment only reviewed sites between 10-500 dwellings. Due to large strategic developments in Central Bedfordshire not delivering, Table 3.5 sets out the build rates of developments in the neighbouring District Bedford, for which completion data is available. It is assumed most of these sites operated on the basis of multiple outlets (i.e. more than one ‘sales frontage’) as completions included multiple land parcels or phases, and the rates recorded in individual years up-to c.211 units suggest there may have been four outlets operational at times. These figures tend to be corroborated by the national picture as well as the often used industry rules of thumb which indicate a single outlet can deliver 30-50 units per annum, depending on market strength and amount of affordable housing.

3.25 The analysis demonstrates that on average strategic developments deliver between c.100-120 dpa, with peak delivery rates reaching higher levels. Indeed, the highest build rate recorded was c.211dpa at Great Denham in 2016/17; however, build rates across the life of the development to date have varied significantly, resulting in an average build rate of c.120 dpa. Again, the analysis supports Lichfields research findings that on average strategic sites tend to deliver around c.161 dpa.

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Table 3.5 Past Delivery Rates/Lead-in Times of Strategic Scale Developments – Bedford Borough Council

Past Average Past Peak Delivery Strategic Delivery Rates Rates (dwellings Size Lead-in Times Start Development (dwellings per per annum) annum) Wixams (LPA: Bedford Borough 4,500 9 years 2008/09 101 160 Council) Great Denham (LPA: Bedford Borough 1,712 7 years 2009/10 120 211 Council) West Kempston (LPA: Bedford 1,064 8 years 2010/11 105 195 Borough Council) Land north of Bromham Road (LPA: 1,300 14 years 2016/17 33 ~ Bedford Borough Council)

Overall Average19 ~ 9.5 ~ 109 189

Source: Lichfields Analysis and Bedford Borough Council Annual Monitoring Reviews (2008-1016) Review of Housing Trajectory

3.26 The NPPF sets out that LPAs should identify land supply in order to meet their OAHN and that this should be based upon (para 159) realistic assumptions about the availability, suitability and economic viability of land over the plan period. The NPPF is clear that Plans should be deliverable (para 173), and national policy states that in plan-making it is “important to ensure that there is a reasonable prospect that planning infrastructure is deliverable in a timely fashion.” (para 177).

3.27 Therefore, in order to ensure it is effective, the Central Bedfordshire Local Plan needs to ensure its housing trajectory is sufficient to meet the housing needs of the District, maintain a rolling supply of deliverable land and retain flexibility in order to ensure the Plan’s housing requirement is met.

3.28 It is considered that a majority of the sites included in the Council’s housing trajectory, subject to allocation, would be developed and delivered at some point over the plan period. However, the focus of this review of the housing trajectory has been to address the likely delivery of the larger strategic sites, sites where there are known issues and windfall assumptions.

Strategic Allocations and Commitments

3.29 The housing trajectory includes four large strategic allocations proposed within the Plan; however, the two largest allocations shown below, are expected to come forward within the formative five years of the Plan (e.g. 2021-2022), and are each individually reviewed below:

19 Overall Average of ‘Average Build Rate’ and ‘Peak Built Rate’ exclude Land North of Bromham Road due to the site having only just commenced, with a relatively low first year completion data, which would significantly reduce the average and peak build rates.

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• North of Luton – An allocation for 4,000 dwellings, with 3,100 dwellings anticipated over the plan period, at an average build rate of 238 dwellings per annum and a peak delivery rate of 300 dwellings per annum.

• Marston Vale – An allocation for 5,000 dwellings, with 3,700 dwellings anticipated over the plan period, at an average build rate of 264 dwellings per annum and a peak delivery rate of 300 dwellings per annum.

North of Luton: Policy SA1

3.30 The Plan proposes the allocation of Land North of Luton for c.4,000 dwellings. The housing trajectory (HIS – Appendix B), on the basis of information supplied by the agent and the production of a framework, assumes that the site will commence delivery in 2022/23 with 50 dwellings delivered within the first year, increasing across the five years and then peaking at c.300 dwellings per annum in 2027/28 until the end of the Plan period. In total, the trajectory assumes that the site would deliver c.3,100 dwellings over the Plan period, with the remaining c.900 to be delivered beyond 2035.

3.31 The land is controlled by the multiple parties: the eastern part of the site is controlled by the North of Luton Consortium20 – as well as the Council – and the western part of the site is controlled by AXA. A formal land ownership agreement between the Council and other land owners is currently being undertaken, which the Council do not consider should unduly delay the progression of development.

3.32 Whilst the agent has indicated the expected delivery rates to the Council, it seems overly optimistic that the site will deliver housing within the next four years. Moreover, whilst the site should be considered ‘available’, in the sense that the landowners wish to sell/develop the site, the site should not be considered ‘deliverable’, on the basis that very little evidence has been given in support of this assumption.

3.33 In particular, the housing trajectory acknowledges site specific constraints regarding the issue of multiple land owners and the necessity of flood mitigation measures across the site. Furthermore, the proposed Policy SA1 sets out that prior to the approval of planning permission, a Development Brief including phasing and design codes for each phase will need to be adopted by the Council, and that the “development will be phased in accordance with the timing of supporting infrastructure and community facilities including the delivery of the Link road, which shall be delivered as soon as viably possible…to facilitate access to the first phase of development and Sundon RFI employment allocation.”

3.34 The extent of work to be undertaken in the context of this exceptionally large overall development, including the necessary supporting infrastructure (A6-M1 Link Road), are factors which serve to highlight it is unlikely that the site could begin delivering within the next 4 years. It is more realistic to consider units becoming available in the latter years of the trajectory, and therefore, it is considered that the earliest conceivable delivery will be in 2024/25 – reflecting a conservative six year lead in time.

3.35 In respect of delivery rates, the Council’s housing trajectory assumes that the site will deliver an average of c.238 dwellings per annum, with peak delivery rates reaching c.300 dwellings per annum for the last 8 years of the plan period, which appears overly optimistic in the context of the evidence of previous delivery rates and in the absence of any specific evidence to support how a higher rate would be achieved on the site. In particular, the assumed peak build rate [sustained for over 8 years], when compared to the delivery rates of Wixams, a site of

20 North of Luton Consortium – AXA IM, Martin Grant Homes, Davidsons, Taylor Wimpey, Prologis and Persimmon Homes

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comparable size, the assumed average delivery rate would be over double (c.238 compared to c.101 dwellings per annum), and the peak delivery rate would nearly double (c.300 compared to c.160 dwellings per annum).

3.36 A strategic development of this size is likely to come forward in phases, most likely with multiple outlets operating on the site (North of Luton Consortium); however, both our research and delivery rates on sites of comparable size within the neighbouring authority would indicate that a more realistic and achievable delivery rate of c.225 dwellings per annum (peak), or an average of c.191 dwellings per annum, would be more reasonable. It is considered that adopting a reasonable lead-in time and adopting a realistic trajectory, evidenced by the delivery rates of comparable strategic developments, results in the site delivering c.2,100 across the Plan period, with the remainder delivered post 2035; c.1,000 dwellings less that the Council are currently relying upon for their housing trajectory.

Marston Vale New Villages: Policy SA2

3.37 The Plan proposes the allocation of Marston Vale for c.5,000 dwellings. The housing trajectory (HIS – Appendix B), on the basis of information supplied by the agent, assumes that the site will commence delivery in 2021/22 with 50 dwellings delivered within the first year, increasing across the following two years and then peaking at c.300 dwellings per annum in 2024/25 until the end of the Plan period. In total, the trajectory assumes that the site would deliver c.3,700 dwellings over the Plan period, with the remaining c.1,300 t be delivered beyond 2035.

3.38 The land is controlled by one owner (O&H Group Ltd), and the agent (David Lock Associates), on behalf of the landowner and in response to the Draft Local Plan (June 2017) (“DLP”), reinforced that the “with an effective planning framework, delivery can commence within 5 years” and that the landowner “welcome discussions with CBC regarding mechanisms to facilitate early delivery” (Appendix 1 Site Assessment Review - Delivery). Furthermore, an Indicative Framework Plan was submitted in support of the representation; however, is not available for review.

3.39 Whilst the agent has indicated, subject to an effective framework, that the site could begin delivery within 4 years, it is considered that such assumptions are optimistic. It is unclear as to what evidence has been submitted by the landowner to demonstrate to the Council that such a timescale could be feasible and achievable, however, on the basis that the Council has provided very little evidence in support of this assumption, it is reasonable to conclude that a site of such scale would not begin delivering until much later in the plan period.

3.40 In particular, as with all strategic allocations, prior to the approval of planning permission, a Development Brief including phasing and design codes for each phase will need to be adopted by the Council. Much like other strategic sites of this scale, both within the District and in neighbouring authorities, it is reasonable to assume that the scheme would be developed through a number of phases, and that accordingly reserved matters applications would be required for each phase. Furthermore, the land parcels would need to be sold to housebuilders prior to commencement. On the basis of uncertainty surrounding these matters, it is considered that this assumed speed of delivery is unjustified and there is no evidence that this is realistically achievable, and therefore a more realistic start date would be 2024/25.

3.41 It is also considered that the delivery rate contained within the housing trajectory is unrealistic or has not been sufficiently justified. It would be reasonable to assume that on a site of this scale, multiple housebuilders would operate across various phases; however, at present it’s unclear and uncertain as to how many housebuilders would potentially operate on site. Moreover, similar to the above critique of Policy SA1, the assumed peak delivery rate of c.300 dwellings per annum [sustained for 10 years] would far exceed that recorded in a scheme of

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comparable size (Wixams), and would be almost double the average national delivery rates, as per Lichfields research.

3.42 The PPG provides guidance on assessing the availability of a site, and in particular, refers to the need to consider “the delivery record of the developers or landowners putting forward sites” (ID: 3-020). In this context, the assumed build rates at Marston Vale would be faster than the rates achieved by the landowner (O&H Group Ltd) at one of its other flagship schemes – the 6,320 Unit Hamptons Scheme in Peterborough – where average delivery rates have been c.224 dwellings per annum.

3.43 Against this context, it would be more reasonable to assume a realistic and achievable delivery rate of 225 dpa. As such the site would deliver c.2,100 dwellings across the Plan period, with the remainder delivered post 2035; c.1,600 dwellings less that the Council are currently relying upon for their housing trajectory.

Windfall

3.44 The NPPF, at paragraph 48, sets out that LPAs may include a windfall allowance sites in the five-year supply; however, is clear that any windfalls allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends, and should not include residential gardens. Moreover, the PPG states that LPAs can include this windfall allowance in broad locations in years 6-15 of the Local Plan, based on a geographical area, and subject to the criteria in paragraph 48 of the NPPF (ID: 03- 24).

3.45 The Council has included two windfall allowances in its housing trajectory of both the SHLAA and HIS, which are underpinned by the Windfall Topic Paper (2017) (“the Topic Paper”), which includes an assessment of windfall completions between 2007 and 2017 across the District and referring only to previously developed sites (excluding garden land):

• Small windfall allowance (sites under 10 dwellings) – Five year supply only; and

• Windfall allowance (Based on broad locations) – Years 6 to 15 only.

3.46 The Topic Paper recommends a small site windfall allowance of 140 dpa in years 1 to 5, and broad locations windfall allowance for all sites of 287 dpa in years 6 to 15 of the Plan period. However, the SHLAA highlights that it is important to ensure that any windfall does not double count with the existing committed windfall sites included in the housing trajectory. Accordingly, reductions are made for years where committed windfall sites are scheduled for delivery (para 3.7.4).

3.47 The reduced figures are set out in full in the housing trajectory and Table 6 of the SHLAA, which anticipates a small windfall allowance of 307 dwellings in the first five years of the Plan (years 2-5), and a broad location windfall allowance of 2,590 dwellings across the remaining plan period (years 6-15). Cumulatively, this equates to a windfall allowance of 2,897 dwellings across the Plan period. However, there are a number of discrepancies with the Council’s evidence, particularly in relation to the inclusion of a combined small and large windfall allowance in years 6 to 15 of the housing trajectory. The assumed windfall allowances are of particular importance, as the Plan states these components of the housing trajectory have been included to provide a contingency on the plan target (para 6.10.1).

Windfall Topic Paper (January 2018)

3.48 The Topic Paper examines the past trends and potential for future delivery of housing on windfall sites, across the 2007 to 2017 (10 year period), to establish whether a windfall

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allowance for residential development should be included within the five year supply of deliverable housing land and beyond – summarised in Appendix 1.

3.49 Across April 2007 to April 2017 in Central Bedfordshire 12,694 dwellings were completed, of which 5,442 dwellings were on windfall land. This on average equates to around 544 dwellings per annum, or 44% of the average (1,269) annual completions. However, 12% of this was on ‘garden land’. Therefore, when excluding garden land, between 2007 and 2017, there have been a total of 4,782 windfall completions or 478 dwellings per annum. The assessment then breaks this down into two categories – small windfall (under 10 dwellings) and large windfall (over 10 dwellings). Of the 4,782, only 31% (1,481 or 148 dwellings per annum) were small windfall sites, with the remainder being on larger windfall sites. The initial assessment concludes that, in respect of a small sites windfall allowance, that an allowance should be included (para 2.3.7); however, in respect of larger sites, that there is no case to add such an allowance within the five year period, although it would be reasonable to include such an allowance in years 6-15 of the housing trajectory (para 2.3.9)

3.50 In respect of the small windfall allowance (e.g. five year supply period) (140 dpa), the assessment goes onto calculate the average expiry and completion rates for windfall on small sites between 2012 and 2016. It concludes that on average 34.43% will be completed whilst permission will expire for 4.40% in the following 12 months (para 3.1.2); however, to ensure a robust trajectory, an expiry rate of 10% is recommended (para 3.1.3). Moreover, the Topic Paper recognises that the delivery of large strategic sites may impact on windfall rates, and accordingly has reviewed the impacts of two large sites (Land East of Biggleswade and Land South of Leighton Buzzard) on windfall rates. Based on this analysis, the Topic Paper concludes that the impacts of large strategic sites on future windfall delivery will be negligible, however recommends a 5% deduction. Applying the above analysis and assessments to the initial average windfall allowance (148 dpa) gives 141 dwellings per annum, however, this is reduced to 140 dwellings per annum in the interest of robustness.

3.51 With regards to the PPG and the inclusion of broad location windfall allowances in years 6 to 15 of the housing trajectory, the Topic Paper states that there is a case for a windfall allowance for sites of all sizes to be included in the Trajectory after the first five years (para 5.3.2). It then undertakes analysis of the geographical distribution of windfall development over the past 10 years. The analysis indicates that predominantly windfall has been distributed throughout the District, although typically urban parishes contribute the most, which aligns with Major and Minor Services Centres in the Plan. With regards to non-implementation rates, the Topic Paper acknowledges that some permissions will expire; however, due to individual assessments of larger sites in the housing trajectory, a non-implementation rate is not necessary.

3.52 In respect of the PPG and the inclusion of broad location windfall allowances in years 6 to 15 of the housing trajectory, the Topic Paper states that there is a case for a windfall allowance for sites of all sizes to be included in the Trajectory after the first five years (para 5.3.2). It then undertakes analysis of the geographical distribution of windfall development over the past 10 years. The analysis indicates that predominantly windfall has been distributed throughout the District, although typically urban parishes contribute the most, which aligns with Major and Minor Services Centres in the Plan. With regards to non-implementation rates, the Topic Paper acknowledges that some permissions will expire; however, due to individual assessments of larger sites in the housing trajectory, a non-implementation rate is not necessary.

3.53 In establishing the potential impact of large strategic sites on future windfall sites (of all sizes), the Topic Paper indicates that its analysis of the impacts of two large sites (Land East of Biggleswade and Land South of Leighton Buzzard) on windfall rates as whole is more notable, and therefore tested reductions of 20%, 30% and 40% to the broad location annual average

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delivery rates of all windfall sites, and concludes that although ‘the supply of windfall sites does not appear to be diminishing it is important for the Local Plan to not be overly reliant on this source of supply’ and recommended that a conservative approach is adopted and a 40% reduction should be applied to all broad locations (para 5.3.2). As such, the Topic Paper concludes that the initial average total windfall allowance of 478 should be reduced to 278 dwellings per annum in years 6 to 15.

Lichfields Review of Windfall Allowances

3.54 In respect of small windfall allowance, it is considered that the windfall allowance is evidenced by the Topic Paper, which specifies the historic windfall completions, accounting for lapse rates and the impact of large sites on the delivery of windfall sites, and therefore, the inclusion of the small windfall allowance in the housing trajectory, and subsequent 5YHLS, is broadly acceptable. Whilst the standard practice is to only apply it to years 3-5 of the current five year period to ensure there is no double counting with planning permissions which are currently being built out to come forward as windfalls (i.e. small site permissions), and the Council have applied this rate to years 2-5 of the five year period, as stated above, the SHLAA has reduced anticipated small windfall allowances on the basis of existing committed windfall sites included in the housing trajectory, and therefore does not double count (para 3.7.4). It is however, the ‘broad location’ windfall allowance in years 6 to 15 of the housing trajectory that is of significant concern.

3.55 The broad location windfall allowance includes all sites (e.g. small and large windfall sites) for years 6 to 15. Whilst the inclusion of a windfall allowance for broad locations in years 6 to 15 is considered acceptable, the inclusion of large windfall sites (10 dwellings and above) is not considered to be justified or in accordance with the PPG.

3.56 Whilst the it is noted that the importance of windfall sites, despite the proposed allocation of several strategic level sites, will remain, it should be noted that the Council acknowledge that the increase in permitted large windfall sites in the past is in part due to the effects of the ‘presumption in favour of sustainable development’ (para 2.3.8, Windfall Topic Paper January 2018). Therefore, where historically the Council has been unable to demonstrate a 5YHLS, in accordance with paragraph 47 of the NPPF, the number of ‘large windfall sites’ has increased. However, if the Plan were to be adopted, the Council is required to allocate a sufficient and flexible amount of housing within its housing trajectory (para 14 of the NPPF) so as to ensure that the Council should be able to demonstrate a 5YHLS across the plan period. Critically, this means that the number of ‘presumption in favour of sustainable development21’ large windfall sites permitted should be nil.

3.57 In essence, the failure of CBC to have an up-to-date Local Plan has artificially inflated ‘windfall’ supply. The appropriate response to this is to ensure a proper plan-led response, not an assumption that such ‘windfall’ rates will continue in the future. Indeed, assuming it will, suggests that the Plan doesn’t have sufficient in-built flexibility.

3.58 Furthermore, paragraph 48 of the NPPF is clear that windfall allowances should be realistic having regard to the Strategic Housing Land Availability Assessment. In its assessment of sites, the SHLAA only considered sites of 10 dwellings and above, and of the 756 sites assessed, only 69 were considered ‘deliverable’ and 20 considered ‘developable’. Notwithstanding any critique of the SHLAAs assessment criteria, the Council’s evidence (e.g. the SHLAA) states that only 89 sites across the District are acceptable for development within the plan period. So long as the

21 Paragraph 14 of the National Planning Policy Framework 2012

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Council maintains a 5YHLS, sites identified in the SHLAA as unsuitable, should not come forward under the ‘presumption in favour of sustainable development’.

Table 3.6 Windfall Allowance Calculations

Council’s Windfall Calculation Annual Average Local Plan Supply Over Windfall Allowance Deduction Delivery Allowance Plan Period Council’s Windfall Calculation Small Windfall (five year supply 148 5% 140 307 period only) All Windfall from broad 478 40% 287 2,59022 locations (years 6-15 only)

Lichfields Windfall Calculation

Small Windfall (five year supply 148 5% 140 307 period only) Small Windfall from broad 148 5% 140 1,37323 locations (years 6-15 only)

Source: Lichfields based on Windfall Topic Paper (January 2018)

3.59 Therefore, any broad location windfall allowance should only include small sites. On this basis, as evidenced in Appendix 1, applying the small sites annual average (c.31%) across the broad locations and working on the Council’s reduction (5%), to take account of the potential impact of large allocated sites, Table 3.6 shows a revised broad location allowance for years 6 to 15 of the housing trajectory. This position includes a discount for those windfall sites which are already listed in the HIS, to ensure that there is no double counting. As a result, the revised broad location windfall allowance would equate to 140 dwellings per annum, or 1,373 dwellings over the Plan period, a -1,217 dwelling reduction.

Flexibility and security of land supply

3.60 The NPPF sets out at para 14 that Local Plans should retain “sufficient flexibility to adapt to rapid change”. In practice this means ensuring a housing trajectory has sufficient land supply across the Plan period so that it can adjust and accommodate any unforeseen circumstances. Critically, this means that to achieve a housing requirement a Local Plan must release sufficient land, or allow sufficient headroom, so that there is an appropriate buffer within the overall planned supply. This is separate from a buffer on the 5YHLS, although there is some overlap of function between the headroom and buffer; headroom covers the eventuality that across the plan period some sites may not come forward – at all, or at the allocated rates – and ensures that the minimum target is met.

3.61 The Plan, at Tables 6.2 and 6.3, evidenced by the trajectory in the HIS, sets out that the Plan makes provision for a supply of 41,830 dwellings over the plan period (2015-2035), which the HIS states results in a 2,480 – or 6% – surplus against the Plans requirement (39,350 dwellings). The Plan goes onto state that a “modest contingency on the ‘supply’ of sites has been applied to provide a failsafe if sites fail to come forward as scheduled in our delivery plan” to ensure that the plan will deliver throughout the plan period and so that Council can maintain a 5YHLS (para 6.6.2), which is principally achieved through the inclusion of a ‘moderate amount of windfall’ (para 6.10.1). Moreover, the Plan has identified Future Growth areas which may be required to “serve development needs in the longer term beyond the plan period or potentially

22 Excluding existing small and large windfall commitments included in the housing trajectory. 23 Excluding existing small windfall commitments included in the housing trajectory.

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at an earlier point in time if the wider context changes” (para 7.9.1), subject to the Partial Review.

3.62 This contingency (6%) is lower than that included in the DLP, which at Table 7.2 included two contingency uplifts to the housing requirement [and unmet need] – 10% and 20% – which resulted in a range of between 19,000 to 31,000 dwellings. Whilst it is noted that the DLP stated that the next version of the Plan is likely to contain a certain level of growth, including a contingency, the Plan’s contingency is lower than the 10% identified as the “lower end of the range” in the DLP.

3.63 Notwithstanding the critique of the Council’s strategic site allocations above, it is considered that the Plans housing trajectory allows for limited flexibility in meeting the proposed 39,350 housing figure to respond to changing circumstances. If any single component of supply does not come forward or if, for example, the strategic sites falls behind the timescales indicated in the trajectory the housing figure is unlikely to be fulfilled and the housing needs will not be met.

3.64 In particular, the Council’s contingency relies significantly on the inclusion of two windfall allowances, despite the Topic Paper, in its recommendation for windfall allowances in the District, stating that “though the supply of windfall sites does not appear to be diminishing it is important for the Local Plan to not be overly reliant on this source of supply” (para 5.3.2). In line with the critique of the Council’s windfall allowances above, the housing trajectories headroom would further decrease by c.1,217. Moreover, whilst it is noted that future growth areas identified could come forward within the plan period ‘if the wider context changes’, these sites are not allocated in the Plan as reserve sites, are subject to further assessment, and therefore do not facilitate, nor constitute, additional headroom in the trajectory.

3.65 In the context of the above critiques on the Plans trajectory, including assumptions on strategic sites and windfall allowances, it is strongly recommended that greater flexibility be built into the Plan, through the allocation of further sites, to provide more headroom in the trajectory over the lifetime of the plan, irrespective of the Plan identifying future areas for growth.

Lichfields Alternative Trajectory

3.66 On the basis of the above housing trajectory review, it is considered that the housing trajectory for Central Bedfordshire across the plan period(2015-2035) is deficient, with the plan failing to identify sufficient sources of supply to meet its housing needs over the plan period. This is principally a result of over-optimistic assumptions regarding lead-in times and build-out rates at proposed strategic allocations, and a contingency rate underpinned on the incorrect application of a windfall rate across the latter part of the plan period. This is demonstrated in Table 3.7, which shows the supply against the housing requirement.

3.67 The Council’s trajectory includes a 2,480 surplus – or 6% contingency – against the housing requirement, which is primarily through the inclusion of a large windfall rate of c.2,590 in the latter part of the plan period. Under our trajectory, which includes more realistic, and achievable lead-in times and build-out rates, and the correct application of a windfall rate, the Council’s housing trajectory would not meet the housing requirement, with a shortfall of c.- 1,337 over the plan period (or a 3% shortfall) – a summary of our amendments can be found in Appendix 1.

3.68 When including a reasonable – if not necessary – 10% contingency buffer, even the Council’s housing trajectory would require the further identification and allocation of a further c.1,500 dwellings, to ensure that the housing trajectory is sufficiently flexible. However, this gap significantly increases on the basis of Lichfields more realistic trajectory, to c.5,300. Fundamentally, it is considered that the scale of shortfall (including a 10% contingency buffer)

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in the trajectory for the plan period is significant, strategic in scale and would require the Local Plan to make additional allocations at vari0us scales. This is necessary in order to address the scale of the shortfall and ensure that a supply of specific sites or broad locations is available for the whole plan period as required by NPPF para 47.

3.69 In conclusion, even against the Council’s own housing requirement, notwithstanding our critique in Section 2.0, it is considered that the Local Plan would fail to make appropriate provision for sufficient housing to meet the housing requirement, with further site allocations required within this plan in order to ensure an overall strategy that is deliverable and sufficiently flexible to respond to change. Moreover, this does not factor in any increase to the Council’s OAHN – which Lichfields consider it should – and therefore, this undersupply would likely increase significantly, further emphasising that the Council will need to allocate more sites of varying sizes to ensure a robust trajectory, with sufficient flexibility, to meet housing needs across the plan period.

Table 3.7 CBC Housing Trajectory Breakdown by Type

Lichfields CBC (CBC Housing Target) Total Housing Requirement 39,350 Housing Requirement (including 41,711 6% contingency) Housing Requirement (including 43,285 10% contingency) Supply Net Completions (2015-2017) 4,335 4,335 Existing Commitments Existing Allocations 7,742 7,742 Strategic Sites (with P/P) 6,780 6,780 Large Windfall (with P/P) 4,023 4,023 Small Windfall (with P/P) 648 648 Total Existing Commitments 23,528 23,528 Local Plan Allocations Strategic Allocations 9,900 7,300 Small and Medium 5,505 5,505 Windfall Allowance (post 5 years) 2,590 1,373 Windfall Allowance (5 year 307 307 period) Total Local Plan Allocations 18,302 14,485 Total Supply against Requirement Total Supply 41,830 38,013 Shortfall/Surplus 2,480 (6%) -1,337 (3%) Gap (shortfall and 6-10% c.0-1,455 c.3,898-5,272 contingency)

Source: Housing Implementation Strategy (January 2018) and Appendices

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Review of 5 Year Housing Land Supply

3.70 The NPPF sets out (para 47) that Local Planning Authorities should demonstrate a five year supply of housing (including an additional buffer) and that this should be maintained throughout the plan period. Upon adoption, it is crucial that the Central Bedfordshire Local Plan has a robust five year housing land supply.

Housing Requirement

3.71 Notwithstanding our critique of the Council’s OAHN and unmet needs, against the Council’s housing requirement set out in the Plan of 32,350, the Council identifies that over a five year period this amounts to 9,837.5 units (1,967.5 x 5). It is considered that this is calculated using the ‘Sedgefield’ approach to shortfall (e.g. including backlog in the five year period), including applying a 5% buffer. However, as set out in Section 2.0, Lichfields consider the proposed housing requirement would not meet the full OAHN of the District, or make contribution to the unmet needs of other parts of the housing market area.

3.72 The following reviews the assumed key components of the Council’s stated position from their Housing Implementation Strategy (HIS, January 2018 – Appendix B). The Council has used a base date of 1st April 2018.

Backlog and Buffer

3.73 The Council include backlog since the 2015 base date of the Plan. The HIS, at Appendix B, indicates that between 2015 and 2018 the Council has delivered 5,472 dwellings, which includes a partial estimate of Q3-4 of the 2017/18 period (equating to 1,137 dwellings). This result in a shortfall of -430.5 comparative to the need of 5,902.5 dwellings (1,967.5 x 4) over the same period. The Council acknowledges this under delivery, and applies a 5% buffer, as required under paragraph 47 of the NPPF, in order to:

“Provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land.”

Housing Supply

3.74 The following sections review the sites included within the HIS (January 2018) to assess whether they are deliverable in the 5 year period. ‘Deliverable’ is defined in footnote 11 of the NPPF as sites which are available now, suitable now and achievable (including whether they are viable). However, the HIS is unclear as to what forms the components of supply in the Council’s 5YHLS, as it only states the total supply of c.10,976 over the period 2018/19 to 2023/24.

3.75 It is presumed that all sites, including allocations in the Plan, that are considered deliverable (e.g. within five years), and form part of the housing trajectory also form the 5YHLS. On this basis, we have reviewed the housing trajectory assumptions on lead-in times and build-out rates to determine whether there is a realistic prospect of the sites coming forward within the five year period. It is considered that largely the sites included in the Council’s 5YHLS could be considered deliverable against footnote 11 of the NPPF; however, the key issues arising from the Council’s five year housing land supply position are identified below under the different ‘presumed’ components of supply.

Strategic Allocations

3.76 As set out above, the Plan includes two strategic allocations – North of Luton and Marston Vale – which are assumed to begin delivering within the five year period (2018/19-2023/24), equating to c.200 dwellings across the later stage of the five year period. However, it can be

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considered that the Council’s inclusion of these dwellings in the next five years is extremely unlikely to be delivered, as demonstrated above. Accordingly, it is considered that these sites are discounted form the 5YHLS, resulting in a reduction of c.200 dwellings.

Existing Allocations and Commitments 1 East of Leighton Linslade (Clipstone Park) – Outline planning permission (Ref: CB/11/02827/OUT) was granted in 28/08/2015 for c1,280 dwellings. The Council has included the site in the housing trajectory, with an assumed start date of 2019/20 at c.80 dpa, increasing to c.150 dpa in the second year. The site is expected to deliver c.530 dwellings in the five year period. The housing trajectory indicates that the housebuilders assumed a start date of 2018/19 and delivery rates of c.150 dpa; however, the Council have pushed the start date back by 1 year and included a c.80 dpa first year completion rate. Moreover, it states that applications for the service roads were expected in 2017, and the first reserved matters application to be submitted in January 2018. Notwithstanding the sale of the site, nor the uncertainty of the housebuilders that may be involved in the site, it does not appear that either of the necessary applications has been submitted. It is considered that the assumed lead in time of 1 year would not be sufficient time to secure both a reserved matters application, permission for services roads, and undertake the appropriate opening up works. Accordingly, it would be more realistic – if not conservative – to push the start date back by a further year, to 2020/21. As such, the sites would only deliver c.380 dpa in the five year period, a c.150 reduction. 2 East of Leighton Linslade (Chamberlains Barn) – The site benefits from outline planning consent (Ref: CB/11/01937/OUT) c.950 dwellings, granted 28/08/2015, and full permission for the necessary opening up works (Ref: CB/11/01940/FULL, granted 28/08/2015). The housing trajectory anticipates the site to deliver c.100 dwellings in 2019/20, increasing in the second year to c.150 dwellings per annum, and delivering c.550 dwellings over the five year period. The trajectory states the housing will be delivered prior to the completion of the access road, that groundworks are underway, and that 16 of the 17 pre-commencement conditions have been discharged, with the agreement of a ‘Area Design Code’ to be finalised and that a reserved matters application was to be submitted in December 2017. Furthermore, it notes that the agent (Savills) provided build rates of c.20 dwellings per annum in 208/19, increasing to c.150 dwellings per annum thereafter; however the Council have taken a conservative approach and pushed the assumed delivery date back by 1 year to 2019/20. However, although some work on the Area Design Code is underway, on the basis that no Reserved Matters applications have been submitted as yet, the lack of certainty or involvement of a housebuilder, and extent of work still to be undertaken in the context of the above, it is considered that the Council’s ‘conservative’ approach (e.g. pushing delivery back by 1 year) is not sufficient enough time to ensure that a Reserved Matters is secured and for development to commence. An assumed start date of 2020/21 ensures a more realistic 2 year lead-in time. Furthermore, whilst the agent (Savills) has indicated the expected delivery rates to the Council, it is considered that, in the absence of any specific evidence to support how a higher rate would be achieved, the assumed build rates are overly optimistic and unrealistic for the following reasons. Firstly, the assumed first year build rate (c.100) is contrary to the evidence given by the agent, who stated that the first year would deliver c.20 dwellings. Secondly, the housing trajectory states that the land is currently being sold to a housebuilder. On the basis that only one outlet would be operating on site (and there is no evidence to the contrary), it is considered that the Council’s assumed delivery rates of

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c.100dpa and c.150dpa are not realistic or achievable. As such, it would be more realistic and achievable to assume a build rate of 100 dpa. As such, the assumed build rate has been reduced to c.20 in 2020/21, increasing to c.100 in the following years, which would reduce the sites output from c.550 to c.220 in the 2018/19-2022/23 five year period – a reduction of c.330 dwellings.

Concluded five year housing land supply

3.77 The above review of the Council’s five year land supply position from its HIS is summarised in the table below and a summary of Lichfields amendments can be found in Appendix 1. It measures the Council’s five year supply against its stated position and Lichfields’ housing land supply position, underpinned by the above review of housing supply, assessed against the Council’s requirement.

Table 3.8 CBC 5YHLS (as at 1st April 2018)

CBC Scenario 1

a Plan Requirement 39,350 39,350 b Annual Requirement (a/20) 1,967.5 1,967.5 c Requirement to date (b x years) 5,902.5 5,902.5 d Completions 5,472 5,472 e Shortfall at 31/3/17 (c-d) 430.5 430.5 Base Requirement over next 5 years (b f 9,837.5 9,837.5 x 5) Base Requirement over next 5 years g 10,268 10,268 plus shortfall (f + e) 5 Year Requirement and shortfall h 10,781.4 10,781.4 plus5% (g+5%) 5 Revised Annual Requirement over i 2,156.28 2,156.28 next 5 years (h/5) j Deliverable Supply over next 5 Years 10,976 10,296 Total years supply over next 5 years k 5.09 years 4.77 (j/i) l ‘Surplus’ (j – h) 194.6 -485.4

Source: Lichfields based on Housing Implementation Strategy (January 2018)

3.78 The 5YHLS includes a number of strategic level sites, expected to begin delivering within the latter part of the five year period (2018/19-2023/24). The above review has demonstrated that a number of these sites include unrealistic and unjustified lead-in times and build-out rates, with little evidence to suggest that such assumptions are realistic and achievable, and as such should either be discounted or removed from the supply.

3.79 The review shows that against the Plan requirement (39,350) that the Central Bedfordshire does not have a five year housing land supply, with a housing land supply of 4.77 years and a shortfall of c.-485.4 dwellings. This shortfall is against the Council’s OAN and Luton’s unmet need; however, were the Council’s OAHN to increase, this shortfall would obviously increase more significantly.

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Summary and Conclusions

3.80 In summary, the Council consider that the housing trajectory set out in the HIS, underpinning the Plan, over the period 2015-2035, would equate to a 2,480 surplus (or 6% contingency) against the Plan requirement of 39,350. Furthermore, the Council also consider that the Plan would be able to demonstrate a 5YHLS of 5.09 years, with a surplus of c.194.6 dwellings over the five year period 2018/19 to 2023/24. However, the following conclusions can be drawn from Lichfields review of the housing trajectory and 5YHLS: 1 National and local evidence of comparable strategic schemes suggest average lead-in times of over 6 years, with average build rates of 120 dwellings per annum, and peak build rate of 211 dwellings per annum; 2 Both the North Luton and Marston Vale strategic allocations are unlikely to come forward until 2024/25, and not at the Council’s assumed peak delivery rate of 300 dwellings per annum; 3 The Council incorrectly includes a windfall allowance in the later part of the plan period which includes both small and large sites (over 10 dwellings); and 4 East of Leighton Linsdale – Clipstone Park and Chamberlains Barn are unlikely to come forward in the manner envisaged by the Council.

3.81 In conclusion, the above review of the Council’s housing trajectory and 5YHLS means that: 1 The overall the housing trajectory for the plan period is deficient and the scale of shortfall is considered too large and significant enough to require the identification of further supply, at varying sizes, now; 2 The Council does not have a five year housing land supply, particularly against Lichfields realistic and achievable land supply, with a shortfall of 437.6 dwellings; and 3 More flexibility should be put into the housing trajectory to ensure that the full housing need can be met across the whole of the Plan period, even against the Council’s flawed plan requirement.

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4.0 Assessment of Reasonable Alternatives

4.1 The Council has concluded through the latest (January 2018) iteration of the Sustainability Appraisal (“the 2018 SA”) that the most appropriate and sustainable spatial strategy for the District is to meet Central Bedfordshire’s OAHN (32,000) and the unmet need of LBC (7,350). The purpose of this section is to review whether the Council suitably tested reasonable alternatives for growth in line with national planning policy and guidance requirements in selecting the appropriate level of growth, including the balancing of housing delivery against the wider sustainability objectives, and, in particular in electing to reduce its housing trajectory from the ranges identified in the DLP consultation. Policy and Guidance

4.2 The PPG sets out the requirements for SA based on the relevant legal framework. The 2004 Regulations set out the basis for Sustainability Appraisal (SA) of Plans with regulation 12(2) necessitating the assessment of reasonable alternatives in the context of the objectives and geographic scope of the Plan.

4.3 The PPG sets out that the SA is to ensure that the proposals of the Plan are the most appropriate (ID: 11-001), given the potential effects of its policies on environmental, social and economic conditions and the requirements of the NPPF at paragraph 152. The PPG defines that reasonable alternatives should be considered at an early stage (ID: 11-017) and compared on a like-for-like basis at the same level of detail (ID: 11-018). The PPG states reasonable alternatives should be:

• Realistic and deliverable;

• Sufficiently distinct to highlight different sustainability implications of each; and

• Allow for meaningful comparison.

4.4 The PPG (ID: 11-018) requires SA should outline why the chosen alternatives were selected and, once these are appraised, outline the reasons rejected options were not taken forward and the reasons for selecting the preferred approach. Central Bedfordshire Growth Strategy

4.5 The DLP set out a Growth Strategy that included ranges of growth for the District, stating that the Plan sought to “deliver between 20,000 and 30,000 homes”, across four ‘Growth Areas’ (A- D) over the plan period 2015 to 2035. This range was underpinned by the Sustainability Appraisal (July 2017) (“the 2017 SA”), which identified a number of potential ‘Growth Scenarios’ at varying ‘Growth Locations’, which were formulated through the SA assessment framework, site assessments, and growth option studies (as shown in Table 4.1).

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Table 4.1 Central Bedfordshire Regulation 18 Draft Local Plan Growth Scenarios

Growth Scenario Options Potential Housing Numbers Scenarios 1 2 3 4 5 Area A North of Luton 4,000 4,000 4,000 0 4,000 Green Belt Villages 2,000 2,000 2,000 0 3,000 West of Luton 2,000 0 2,000 0 0 Area B Tempsford 7,000 7,000 0 7,000 0 East of Biggleswade 3,000 0 0 3,000 0 Biggleswade 0 0 500 0 0 East of Arlesey 2,000 2,000 2,000 2,000 2,000 Villages 0 0 500 0 2,500 Area C Marston Vale 5,000 5,000 5,000 5,000 5,000 Apsley Guise 3,000 3,000 3,000 3,000 0 Wixams South 1,000 1,000 1,000 1,000 1,000 Villages 0 0 0 0 650 Area D RAF Henlow 1,000 1,000 1,000 1,000 1,000 Villages 500 500 500 500 1,500 Totals 30,500 25,500 21,500 22,500 20,650

Source: Sustainability Appraisal (January 2018)

4.6 The Plan confirms the Council’s preferred approach to the growth strategy, which at Policy SP1 makes provision for the delivery of 41,830 homes over the plan period, of which c.23,528 are existing commitments, and c.18,302 are a combination of strategic (c.9,900) and small – medium scale (5,505) allocations throughout Central Bedfordshire, and a windfall allowance (c. 2,897 ), against a housing requirement of 39,350 over the period 2015 to 2035. This includes the 32,000 OAHN for Central Bedfordshire, and a commitment to facilitate 7,350 of Luton’s ‘unmet need’ – subject to ongoing ‘duty to co-operate’ discussions and formal Local Plan Examination. Appraisal of Growth Strategy

Levels of Growth

4.7 As noted above, the DLP set out a range of growth (20,000 to 30,000), underpinned by five growth scenarios tested in the 2017 SA. However, it is not clear [if not opaque] to what extent the range of development proposed planned for, in so far as it is understood that the figures tested represent ‘new dwellings’ over the plan period, exclusive of existing commitments. The 2017 SA and the DLP figures are therefore not accurate representations of the level of growth planned for over the plan period. Including existing commitments, as stated in the 2018 SA (23,85424), it is considered that the 2017 SA tested a range of growth scenarios with a minimum amount of 44,504 and maximum amount of 54,354 (as shown in Table 4.2).

24 This figure is reported lower (23,528) in both the Central Bedfordshire Pre-Submission Local Plan 2015-2035 (January 2018) and Housing Implementation Strategy (January 2018) although it presumed that these documents were finalised prior to the 2018 SA.

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Table 4.2 Actual Levels of Growth Tested

Growth Scenario Options Potential Housing Numbers 1 2 3 4 5 Totals 30,500 25,500 21,500 22,500 20,650 Including existing commitments 54,354 49,354 45,354 46,354 44,504 (23,854)

Source: Lichfields based on Sustainability Appraisal (January 2018)

4.8 At the Regulation 19 stage, taking into account consultation comments received and updated evidence, the Council decided to progress an approach to the Spatial Strategy, confirmed with the proposed SP1: Growth Strategy that aligns with Scenarios 3 and 5, with additional small- medium allocations in villages throughout the District. This is on the basis of a housing requirement of 39,350, which consists of the Central Bedfordshire OAN and Luton HMA unmet need, which the 2018 SA states falls at the lower end of the ranges identified at the Regulation 18 stage (para 8.10).

4.9 In its justification for the progression of the preferred spatial strategy, the 2018 SA sets out the reasons for selection/rejection of the growth scenarios in Table 8.2. This can be summarised as follows:

• Scenarios 1 and 2 – This has not been progressed as it proposes high levels of growth in Area B and C which are reliant on significant infrastructure delivery; and

• Scenario 4 – Not progressed as would not contribute to the unmet housing needs for Luton within the Duty to Cooperate for the Councils; nor provide opportunities from limited new development in the Green Belt in Area A. Development in the Green Belt will take pressure away from non-Green Belt areas to help avoid the coalescence of settlements in non-Green Belt areas.

4.10 However, we consider that the 2018 SA is fundamentally unclear in respect of how the Council arrived at their preferred approach for a number of reasons, and that there is no definitive conclusion as to why the progressed spatial strategy is lower than those tested throughout the SA process.

4.11 Firstly – and fundamentally – the Council’s assertion that the spatial strategy progressed at Regulation 19 stage is at the lower end of the ranges identified at the Regulation 18 stage is factually incorrect. Whilst it is noted that all scenarios tested (inclusive of existing commitments) would meet the Council’s housing requirement (39,350), it should also be noted that the growth strategy set out in Policy SP1 has not in itself been tested as a reasonable alternative through the SA process. This is evident by the fact that the growth strategy proposed is actually c.5,154 lower than the lowest scenario tested (39,350 compared to 44,504 - Scenario 5) in the 2017 SA. Although it is acknowledged that this figure was tested later in the Regulation 19 stage through the testing of the strategic policies (Policy SP1 - Appendix VI Strategic Policies), the spatial strategy should have been tested as a reasonable alternative growth scenario at the Regulation 19 stage, rather than its assessment as the preferred approach through strategic policy SP1. As such, the SA process has not ever properly tested the growth option taken forward by the Council, so as to draw meaningful comparison between the growth options tested throughout the SA process.

4.12 Secondly, at the Regulation 18 stage it was unclear as to why the Council had set out a range of growth options in the DLP, although it was presumed to be in accordance with the testing of reasonable alternatives. However, the 2018 SA appears to present two main justifications. The 2018 SA highlights that the Council were aware of Governments proposals for a standardised methodology for the calculation objectively assessed needs and therefore tested a range of

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growth levels accordingly, and that the Council decided not to progress a preferred approach at the Regulation 18 stage, so that the views of consultees can be taken into consideration at the next stage of developing the Local Plan (para 5.117).

4.13 Subsequent to the consultation of the DLP, in September 2017 the Government published ‘Planning for the right homes in the right places’, which amongst other things, set out the Government’s proposals for a standardised methodology for calculation objectively assessed need in order to remove much of the complexity that exists within the current system (“CLG Methodology”). The 2018 SA acknowledges that CLG Methodology would result in a local housing need of 51,060 new homes over the plan period (or 2,553 dwellings per annum) (“the CLG LHN”), which the SA states represented a 60% increase on the current OAHN and was far in excess of the average increase of 35% across local authority areas nationally (para 8.4).

4.14 Consequently, on the basis of current delivery figures within the District (c.1,800 dpa), the Council considered that such a significant increase in requirement could not practically be delivered due “to lack of skilled labour, materials and potentially land banking by developers” (para 8.4). It goes onto state that against the CLG LHN, the Council would not be able to demonstrate a five year housing land supply and so consequently it would be more difficult to resist speculative planning applications leading to unplanned and unsustainable development.

4.15 We consider that the implications of the CLG LHN appear in part to have influenced the Council’s adoption of the preferred spatial approach, with the 2018 SA stating that on the basis of the above the Council chose to retain the published OAHN of 32,000, and updated its Local Plan timetable to allow submission of the Central Bedfordshire Local Plan before 31 March 2018 – and thus allowing the use of the current housing need figure (32,000 new homes) as the basis for plan-making. Whilst this approach is not necessarily unreasonable, insofar as the Framework states that the Council should plan to meet its housing needs (para 14) [notwithstanding our critique of the Council’s OAHN], it is considered that the Council’s justification for being unable to meet the identified need is unreasonable, and ultimately not based on evidence (for example on the lack of skills and materials or allegations of land banking).

4.16 Higher level growth scenarios were tested (i.e. 54,354), which exceeded the Council’s housing requirement; however, against the CLG LHN (51,060) and the Luton HMA unmet need (7,350), the upper end of the ranges tested would fall significantly short – c.4,000. The PPG clearly states that reasonable alternatives should be identified, as the assessment of these should inform the local planning authority in choosing its preferred approach (ID: 11-017). Indeed the Friends of the Earth High Court judgment25 states that ‘Reasonable alternatives’ have to be identified described and evaluated because, without this, there cannot be a proper environmental evaluation of the plan. And although the CLG Methodology was published towards the latter stages of the plan making process, it is considered that the Council, prior to the adoption of the preferred approach, should have assessed all reasonable alternatives, rather than updating the Local Plan timetable to avoid the application of the CLG LHN.

4.17 Therefore, at the Regulation 19 stage and prior to pursuing a preferred approach, it is considered that the CLG LHN should have fed-back into new testing which assessed a higher growth scenario including the unmet need of the Luton HMA (58,410), so as to demonstrate whether or not such levels of growth could be sustainably delivered across the Plan period, and to therefore inform the selection of the preferred approach.

25 Paragraph 88 of R (Friends of the Earth England, Wales and Northern Ireland Ltd) v The Welsh Ministers [2015] EWHC 776 (Admin)

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4.18 However, in the absence of this reasonable alternative being tested in the SA, and irrespective of the Council’s lack of evidence to suggest that Central Bedfordshire could not practically deliver higher levels of housing in terms of lack of materials, skilled labour and land banking, the 2018 SAs justification therefore does not present meaningful or sufficient evidence to inform the application of the tilted balance to weigh up the relative benefits vs the harm of higher levels of growth in the District. This is of particular importance, as the results of the Regulation 18 2017 SA did not demonstrate that all of the reasonable alternatives, including the higher end of the scale, were unsustainable and unsuitable. It appears implicit that they were therefore broadly acceptable. As such, it is considered that the Council has therefore failed to demonstrate or sufficiently evidence how such levels of growth, in respect of the CLG LHN as a reasonable alternative, could not be sustainably delivered within the District across the Plan period.

4.19 In view of the above, it is considered that the Council should have tested further reasonable alternatives at the Regulation 19 stage; which include the growth strategy set out in Policy SP1, and the higher levels of growth set out in the CLG LHN. It would therefore be reasonable to conclude that the SA has failed to consider all reasonable alternatives.

4.20 Furthermore, in respect of the sustainability of higher levels of growth, and when viewed in the context of our critique of the Central Bedfordshire and Luton Strategic Housing Market Assessment (2018) (SHMA) – set out in Section 2.0 – which Lichfields consider makes a number of questionable assumptions, resulting in downward adjustments to the Council’s OAN to align with the Plan housing requirement, the Councils decision to not pursue a growth strategy with higher levels of growth despite being considered broadly sustainable, and instead adopt a growth strategy significantly below those tested in the SA further emphasises the lack of clarity in the Council’s evidence.

4.21 Fundamentally, the option to deliver the 39,350, as set out in Policy SP1 of the Plan, is not adequately justified or evidenced in respect of its preference to higher levels of growth, which the SA found to be broadly sustainable. Crucially, neither the level of growth planned for, nor the CLG LHN and LBC unmet need have been tested in the 2018 SA as reasonable alternatives, so no meaningful comparison can be drawn from the SA. In particular, it appears that the implications of the CLG LHN figure on Central Bedfordshire have unduly and unjustifiably contaminated the Councils adoption of the proposed spatial strategy, in so far as the Council elected to pursue a preferred option, with a smaller level of growth across the Plan period, despite indications that greater levels of growth were broadly sustainable and could have been delivered over the plan period. Ultimately, this failure to test all reasonable alternatives, has resulted in a spatial strategy set out in policy SP1 that has not been informed by robust evidence, or an objective view on the reasonable alternatives, and is therefore not justified.

Distribution of Growth

4.22 Lichfields consider that the Council’s rejection of higher levels of growth is fundamentally predicated on the 2017 SAs intrinsic linkage of higher level growth scenarios (Scenarios 1 and 2) with specific combinations of strategic sites. The 2017 and 2018 SAs do not disaggregate the assessment of these (i.e. the distribution of growth or spatial strategy) from the assessment of the overall growth.

4.23 It is unclear as to why such an approach has been adopted, principally as the sustainable spatial distribution of growth and levels of growth should be decoupled. Through the identification of a sustainable spatial distribution of growth, at Regulation 19 stage, there is an opportunity – if not necessity – to establish whether the preferred spatial distribution, which in this case is a hybrid combination of Scenarios 3 and 5, could sustainably deliver higher levels of growth, such as those tested at the higher ranges (Scenarios 1 and 2).

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4.24 Indeed, the Council broadly acknowledge this decoupling by way of progressing an approach to the Spatial Strategy which aligns with growth scenarios 3 and 5. However, any balance weighing environmental harm against social and economic benefits of increasing the level of growth across the preferred spatial distribution was not revisited in light of the existing evidence indicating that the higher level growth scenarios were broadly sustainable, which ultimately should have fed-back into new testing of previously-judged alternative growth locations and sites. By way of example, there are further options for growth in Luton, Marston Moretaine and throughout the villages in the District which could still facilitate further growth in a sustainable manner without fundamentally altering the preferred spatial strategy; however, the 2018 has failed to test how an increase in growth across the preferred spatial approach would impact sustainability.

4.25 Fundamentally, the [unclear] reasons for the rejection of higher growth within the District are not considered adequate in the justification of why the most sustainable spatial distribution could not sustainably facilitate the higher levels of growth in Scenarios 1 and 2, or indeed the CLG LHN. Moreover, alternative levels of growth across the preferred spatial distribution have not been tested, so it is not possible to draw meaningful conclusions as to whether the higher levels of growth could not be sustainably delivered throughout the District. Summary and Conclusions

4.26 In summary, there is no robust evidence base produced by the Council to justify the spatial growth approach progressed by the Council, and contained within Policy SP1 of the Plan. Set out below are the main reasons why we consider that the evidence underpinning the Council’s proposed spatial strategy is seriously flawed:

• The spatial strategy progressed at Regulation 19 stage is lower than those tested at the Regulation 18 stage (39,350 compared to 44,504), with no clear evidence or justification;

• The growth strategy set out in Policy SP1 has not in itself been tested through the SA process. As such, the Council has not ever properly tested the growth option taken forward in the Plan and no meaningful comparison between the growth options tested throughout the SA process can be made;

• Aware of the CLOG LHN, the Council failed to test a higher level growth option to meet this identified need, and the implications of the CLG LHN on Central Bedfordshire appear to have unduly and unjustifiably contaminated the Councils adoption of the proposed spatial strategy, despite the evidence indicating that higher levels of growth were broadly sustainable; and

• The spatial strategy progressed is underpinned by an SA that has failed to consider all reasonable alternatives in line with national policy and guidance, which has resulted in a spatial strategy, set out in policy SP1, that has not been informed by robust evidence, or an objective view on the reasonable alternatives, and is therefore not justified.

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5.0 Conclusions

5.1 This report has considered the evidence underpinning the Central Bedfordshire Pre-Submission Local Plan 2015-2035 (January 2018) and in particular has reviewed the existing evidence on housing needs (to establish the scale of need and demand for housing in the District), the housing trajectory and five year land supply position which underpins the Plan, and whether the Council suitably tested reasonable alternatives in establishing its preferred approach. The analysis is prepared on behalf of Abbey Land Developments, Richborough Estates, Catesby Estates and Rainier Developments. The key points are summarised below: Housing Need

5.2 The 2017 SHMA, and its previous iterations, contain a number of fundamental flaws specific to Central Bedfordshire which mean it does not form a robust evidence base. In particular, the 2017 SHMA, makes significant downward adjustments to the projections for the District, in respect of sources which ONS itself describes as not suitable for that type of use in their raw format. The adjustment of MYEs post-2011 is also fundamentally flawed as there is no robust basis to adjust these figures in Central Bedfordshire. As a result of its flawed demographic assessment, the analysis which flows from this is also flawed. The SHMAs conclusions are therefore not based on established sources of robust evidence, and further fails to provide any ‘on the ground’ analysis to explain clearly why statistically robust official ONS data should not be relied upon for Central Bedfordshire. The approach of the SHMA to Central Bedfordshire is distinct from that in Luton, and no weight should be given to the fact the SHMA’s demographic approach was accepted by the Luton Local Plan Inspector (albeit the Inspector suggested the SHMA under-estimated need in Luton).

5.3 Further, the SHMA’s 10% market signals uplift is insufficient and there is no evidence to show – as required by the PPG – that it could be reasonably expected to improve housing affordability.

5.4 The 2017 SHMA also fails to follow the prescribed methodology of calculating the affordable housing needs of the HMA as required in the PPG, and its assessment is based only on analysis of housing benefit claimants, which is flawed, failing to recognise that many people who spend significant proportions of their income on rent and who would be eligible and in need of affordable housing, will not themselves be eligible for housing benefit. Alongside this, the 2017 SHMA also fails to engage with how affordable housing needs should influence overall OAHN.

5.5 Our appropriate and robust assessment, in line with the PPG, demonstrates that:

• The demographic-led needs should be based on the latest, official DCLG 2014-based household projections;

• DCLG 2014-based household projections show a growth of 1,729 households per annum over the plan period (2015-2035);

26 • Applying a second home/vacancy rate of 4% , as used in the 2017 SHMA, equates to a need for 1,801 dwellings per annum, or 36,020 total over the plan period; and

• A 20% market signals uplift is necessary in order to reasonably expect an improvement in affordability, which would equate to 2,150 dpa over the period, or around 43,000 in total over 20 years.

26 Based on 2017 SHMA Figure 92, which shows 27,738 households generates a need for 28,889 dwellings (96%, or 4% vacancy)

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5.6 On the basis of the above OAHN, Lichfields consider that the Central Bedfordshire Plan would therefore fail to meet all of its own need, let alone make any provision for unmet needs from Luton.

5.7 This alternative estimate of OAHN is lower than the CLG proposed standard methodology for local housing need,which is 2,553 dpa for Central Bedfordshire, or 51,000 in total over 20 years, and excludes any further unmet need arising from Luton, which subject to its Local Plan Review could be around 20,000 dwellings27. This increased unmet need would most likely need to be met in Central Bedfordshire, given this is where most of Luton’s functional HMA lies, which would equate to a total requirement for Central Bedfordshire would be upwards of 70,000 dwellings over 20 years – almost double the target in the emerging Plan. Housing Delivery

5.8 A review of the supply position suggests that housing trajectory underpinning the Plan has been informed by a number of unrealistic, unachievable and overly optimistic assumptions regarding the delivery of sites within the District, with limited evidence given in support of the assumed rates of delivery being realistically achievable.

5.9 In particular, the Council assumes that two strategic level schemes would begin delivering within 3-4 years of the Plan being adopted, despite existing strategic scale commitments within the District and neighbouring authorities having lead-in times of over 5 years, and slower build- out rates. Moreover, this is further exacerbated by the inclusion of an incorrect and unreasonable windfall allowance in the later part of the plan period. As a result of these assumptions, and that two existing large scale commitments are unlikely to come forward in the manner envisaged by the Council, the Plan would be unable to demonstrate a five year housing land supply.

5.10 On this basis, Lichfields consider that the housing trajectory for the Plan plan period is insufficient, and that the scale of shortfall, particularly when including a reasonable 10% contingency buffer to ensure sufficient flexibility over the plan period, would be of a significant scale that would require the identification of further sites at varying sizes to meet the Council’s housing needs. Spatial Strategy

5.11 The growth option (39,350) progressed by the Council is lower than those tested at the Regulation 18 stage (44,504 and 54,354), with insufficient or unclear justification for such an approach in the evidence base. Fundamentally, and more importantly, the level of growth planned for in the Plan has not ever properly been tested as a reasonable alternative through the SA process.

5.12 Furthermore, although the 2017 SA tested higher level growth options, which were considered broadly sustainable, the Council has failed to test a reasonable alternative in line with the emerging CLG standardised methodology. The methodology was published during the plan- making process, however should have fed-back into new testing at the Regulation 19 stage which assessed a higher growth scenario (58,410 - CLG LHN and unmet need), so as to demonstrate whether or not such levels of growth could be sustainably delivered across the Plan period, and to therefore inform the selection of the preferred approach.

5.13 As such, the 2018 SA underpinning the Plan growth strategy, set out at Policy SP1, has fundamentally failed to consider all reasonable alternatives in line with national policy and

27 Based on the CLG standardised methodology figure of 1,417 dpa, and a supply of 8,500.

Pg 52 Central Bedfordshire Pre-Submission Local Plan : Review of Housing Need and Land Supply

guidance, and therefore has not been informed by robust evidence, or an objective and meaningful view on the reasonable alternatives, and is therefore not justified. In summary, there is no compelling evidence base produced by the Council to justify the spatial growth approach progressed by the Council, and contained within Policy SP1 of the Plan.

Pg 53

Appendix 1: Housing Delivery and Windfall Calculations

Central Bedfordshire Pre-Submission Local Plan: Appendix 1: Housing Delivery and Windfall Calculations

Table A1.1 Past Delivery Rates/Lead-in Times of Strategic Scale Developments – Bedford Borough Council

Full Average Peak No. Application Application Years to First Lead-in Completions Site Lead-in Build Build Dwellings Received Approved Determine Completion Time to Date 31 32 2008/9 2008/9

2009/10 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 Time Rate Rate

Wixams 4,500 17/11/1999 02/06/2006 6.5 8 190 160 138 113 109 109 44 37 2008 2 9 908 101 160 Great Denham 1,712 28/03/2002 26/09/2007 5.5 0 92 150 159 71 122 150 125 211 2009 2 7 1,080 120 211 West Kempston 1,064 28/03/2002 20/03/2007 5.0 0 0 43 102 192 167 144 195 103 2010 3 8 946 105 195 Land north of 1,300 09/01/2002 27/03/2014 12.2 0 0 0 0 0 0 0 0 33 2016 2 14 33 33 33 Bromham Road Overall Average33 2.3 9.5 109 189

Source: Lichfields Analysis and Bedford Borough Council Annual Monitoring Reviews (2008-1016)

31 Dwellings per annum. 32 Dwellings per annum. 33 Overall Average of ‘Average Build Rate’ and ‘Peak Built Rate’ exclude Land North of Bromham Road due to the site having only just commenced, with a relatively low first year completion data, which would significantly reduce the average and peak build rates.

Central Bedfordshire Pre-Submission Local Plan: Appendix 1: Housing Delivery and Windfall Calculations

Table A1.2 Historic Windfall Rates – Previously Developed Land and Size Completions Previously Developed Land Small and Large Sites (April 2007-April 2017) Windfall not Small Sites Large Sites Windfall on Year Completions Windfalls on garden (<10 (10+ garden land land dwellings) dwellings) 2007/08 1,367 643 (47%) 491 (76%) 152 (14%) 195 (40%) 296 (60%) 2008/09 937 562 (60%) 497 (88%) 65 (12%) 170 (34%) 327 (66%) 2009/10 700 331 (47%) 274 (83%) 57 (17%) 74 (27%) 200 (73%) 2010/11 1,227 716 (58%) 641 (90%) 75 (10%) 118 (18%) 523 (82%) 2011/12 1,310 598 (46%) 556 (93%) 42 (7%) 128 (23%) 428 (77%) 2012/13 965 317 (33%) 277 (87%) 40 (13%) 125 (45%) 152 (55%) 2013/14 1,264 439 (35%) 368 (84%) 71 (16%) 150 (41%) 218 (59%) 2014/15 1,522 564 (37 %) 502 (89%) 62 (11%) 180 (36%) 322 (64%) 2015/16 1,626 511 (31%) 475 (93%) 36 (7%) 115 (24%) 360 (76%) 2016/17 1,773 761 (43%) 701 (92%) 60 (8%) 226 (32%) 475 (68%) Total 12,691 5,442 (43%) 4,782 (88%) 660 (12%) 1,481 (31%) 3,301 (69%) P/A 1,269 544 (43%) 478 (88%) 66 (12%) 148 (31%) 330 (69%)

Source: Lichfields based on Windfall Topic Paper (January 2018)

Table A1.3 Lichfields Broad Location Windfall Allowance All Sites Annual Small Sites Annual Broad Location Average Broad Location Average Delivery (2007- (Inc. 5% Delivery (2007- 2017) Reduction) 2017) Dunstable and Houghton Regis 166 51 (35%) 49 Leighton Linslade 73 23 (15%) 21 Biggleswade, Sandy and Potton 54 17 (11%) 16 Ampthill, Flitwick and Maulden 32 10 (7%) 9 Stotfold, Arlesey and Stondon 34 11 (7%) 10 Shefford, Clifton and Henlow 34 11 (7%) 10 Cranfield and Marston Moretaine 6 2 (1%) 2 Barton, Toddington and 11 3 (2%) 3 Harlington The rest of Central Bedfordshire 69 21 (14%) 20 Total 479 148 141

Source: Lichfields based on Windfall Topic Paper (January 2018)

Central Bedfordshire Pre-Submission Local Plan: Appendix 1: Housing Delivery and Windfall Calculations

Table A1.4 Broad Location Windfall Allowance - Trajectory

2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 Total Small Windfall 0 0 0 0 0 0 0 0 12 7 4 3 1 0 0 0 0 0 0 0 27 Commitments35 Broad Location Windfall 0 0 0 0 0 0 0 0 140 140 140 140 140 140 140 140 140 140 0 0 1,400 Allowance Broad Location Windfall Allowance (excluding 0 0 0 0 0 0 0 0 128 133 136 137 139 140 140 140 140 140 0 0 1,373 existing commitments)

Source: Lichfields

35 Figures sourced from housing trajectory in Housing Implementation Strategy (January 2018) – Appendix B

Central Bedfordshire Pre-Submission Local Plan: Appendix 1: Housing Delivery and Windfall Calculations

Table A1.5 Lichfields housing trajectory and 5YHLS amendments

Site 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 2031/32 2032/33 2033/34 2034/35 5 Year Total Trajectory Total Plan Post 5YHLS Reduction Trajectory Reduction 2015/16 2016/17 Central Bedfordshire Council Housing Trajectory – Site Specific Details and Windfall Rate North of Luton 0 0 0 0 0 0 0 50 100 150 200 200 300 300 300 300 300 300 300 300 50 3,100 900 ~ ~ Marston Vale 0 0 0 0 0 0 50 100 250 300 300 300 300 300 300 300 300 300 300 300 150 3,700 1,300 ~ ~ East of Leighton Linslade (Clipstone 0 0 0 0 80 150 150 150 150 150 150 150 150 0 0 0 0 0 0 0 530 1,280 0 ~ ~ Park) East of Leighton Linslade 0 0 0 0 100 150 150 150 150 150 100 0 0 0 0 0 0 0 0 0 550 950 0 ~ ~ (Chamberlains Barn) Windfall Allowance (based on broad 0 0 0 0 0 0 0 0 133 250 283 284 205 287 287 287 287 287 0 0 0 2,590 0 ~ ~ locations) Total 730 10,670 2,200 ~ ~ Lichfields Alternative Housing Trajectory – Site Specific Amendments and Updated Windfall Calculation North of Luton 0 0 0 0 0 0 0 0 0 50 100 150 225 225 225 225 225 225 225 225 0 2,100 1,900 -50 -1,000 Marston Vale 0 0 0 0 0 0 0 0 0 50 100 150 225 225 225 225 225 225 225 225 0 2,100 2,900 -150 -1,600 East of Leighton Linslade (Clipstone 0 0 0 0 0 80 150 150 150 150 150 150 150 150 0 0 0 0 0 0 380 1,280 0 -150 0 Park) East of Leighton Linslade 0 0 0 0 0 20 100 100 100 100 100 100 100 100 100 30 0 0 0 0 220 950 0 -330 0 (Chamberlains Barn) Windfall Allowance (based on broad 0 0 0 0 0 0 0 0 128 133 136 137 139 140 140 140 140 140 0 0 0 1373 0 0 -1217 locations) Total 600 7,803 4,800 -680 -3,817

Source: Lichfields based on Housing Implementation Strategy (January 2018)

APPENDIX 4

Landscape, Ecological and Arboricultural Assessment

Land North of the Greyhound Stadium, Lower Stondon

Representations in Respect of Landscape, Ecological and Arboricultural Circumstances

Prepared by: The Environmental Dimension Partnership Ltd

On behalf of: Rainier Developments Limited

February 2018 Report Reference edp4594_r001a Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Contents

Section 1 Introduction and Key Conclusions ...... 1

Section 2 Landscape and Visual Matters ...... 5

Section 3 Ecological Matters ...... 11

Section 4 Arboricultural Matters ...... 17

Appendices

Appendix EDP 1 Photographic Plates Illustrating Landscape and Visual Context

Appendix EDP 2 Ecology Non-Statutory Designations

Appendix EDP 3 Schedule EDP 1 Tree Survey Key and Schedule

Appendix EDP 4 Schedule EDP 2 Tree Constraints Schedule

Plans

Plan EDP 1 Site Context (edp4594/d001a 20 February 2018 BC/WG)

Plan EDP 2 Environmental Constraints and Opportunities Plan (edp4594/d007a 20 February 2018 PD/WG)

Plan EDP L1 Environmental Planning Context (edp4594/d004a 20 February 2018 BC/JTF)

Plan EDP L2 Published Landscape Character (edp4594/d005a 20 February 2018 BC/JTF)

Plan EDP C1 Extended Phase 1 Habitat Survey (edp4594/d003a 20 February 2018 GY/ND)

Plan EDP T1 Tree Constraints Plan (edp4594/d006a 20 February 2018 GY/LT)

This version is intended for electronic viewing only For EDP use Report no. edp4594_r001a

Authors Will Gardner, Lindsey Mulraine & Nick Donkin Formatted Emma Read Proofed Laura Lloyd Proof Date 20 February 2018

Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Section 1 Introduction and Key Conclusions

1.1 Rainier Developments Limited have appointed the Environmental Dimension Partnership Ltd (EDP) to undertake a series of preliminary environmental appraisals on a site known as Land North of the Greyhound Stadium, Lower Stondon. The location and boundaries of the site are illustrated on Plan EDP 1.

1.2 EDP is an independent environmental consultancy providing advice to landowner and property development clients in the public and private sectors in the fields of landscape, ecology, heritage, arboriculture and masterplanning. EDP is a Registered Practice of the Landscape Institute and a Corporate Member of IEMA. The Practice operates throughout the UK from offices in Cirencester, Cardiff and Shrewsbury. Details of the Practice can be obtained at www.edp-uk.co.uk.

1.3 To date, the purpose of EDP’s work has been to gain an early understanding of the environmental issues likely to affect the site’s ‘in principle’ suitability for development and its potential capacity. To this end, the following specific work items have been undertaken:

• Data trawl of relevant landscape designations and considerations and assessment of the site’s character and zone of primary visibility;

• Data trawl of relevant local ecological designations and extended Phase 1 habitat assessment; and

• Preliminary Arboricultural assessment including a walkover survey.

1.4 The site is located to the west of RAF Henlow within the northern areas of the parish of Stondon and within the administrative area of Central Bedfordshire Council. It comprises a single agricultural field, lying adjacent to the A600, located immediately to the north of the Henlow Racing greyhound stadium. Henlow Airfield lies to the north-east. The site context is illustrated overleaf in Image EDP 1.

1 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Image EDP 1: Aerial view of the site. Source: Google Map data 2018

Key Conclusions of EDP’s Assessments to Date

1.5 EDP has not found any ‘in principle’ issue which would preclude the site’s allocation for built development; indeed, it is not especially constrained in environmental terms.

Landscape Matters

1.6 Due primarily to the enclosure created by existing landscape features within the local context and intervisibility with existing built form, the site has a reduced landscape sensitivity.

1.7 The site is barely perceptible from the wider setting and has well-established urbanising influences in close proximity to it, being well contained by both existing built form and mature landscape features. It is likely that the majority of landscape and visual effects resulting from the proposed development within the site would be limited to receptors in close proximity to it.

1.8 The development of the site provides an opportunity to enhance and augment the remaining landscape features across the site and along its boundaries.

1.9 In the interests of good masterplanning, due to the possibility of views of taller built form within the site from the wider context to the west, attention should be given to the western boundary treatment which currently affords views looking north-west.

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Ecological Matters

1.10 Based on the findings of EDP’s Preliminary Ecological Appraisal, the designated sites, habitats and species potentially present within and around the site do not pose an ‘in principle’ constraint to development of the site.

1.11 The site is relatively unconstrained ecologically, comprising predominantly arable habitat of negligible ecological value. No statutory or non-statutory designated sites are considered to be at risk of any material and adverse effects as a result of the proposed development.

1.12 While some of the habitats on-site, including the hedgerows, scrub and trees, are currently considered, on a precautionary basis, to be of some ecological value (local conservation importance), they are largely confined to the external site boundaries. It is therefore likely that they can be adequately accommodated and mitigated by the masterplanning of any future development proposals and are therefore, not considered a constraint to development.

1.13 A number of detailed baseline protected species surveys will be required to accompany any planning application for the site, together with an assessment of potential effects and strategies to avoid, mitigate or compensate for such effects. However, it is considered that through the adoption of industry standard impact avoidance and mitigation measures, any adverse effects on protected species can be appropriately addressed to ensure no net loss to biodiversity, in accordance with national planning policy.

Arboricultural Matters

1.14 Of the items surveyed, nine have been identified as category B, of moderate quality and value. These items should be prioritised for retention due to their condition, age and retention span.

1.15 All of the surveyed items are located around the perimeter of the site and, providing that designated RPAs and canopies are respected, they do not adversely constrain the potential to accommodate residential development in the main body of the site.

1.16 Once the Masterplan has been fixed, an Arboricultural Impact Assessment and Tree Protection Plan will be undertaken to support the Outline Planning Application and to ensure the safe, long-term retention of the arboricultural items for the Site.

Overall Conclusion

1.17 For the above reasons, EDP’s overall conclusion at this stage is that the site is eminently suited to accommodate some development to help meet the Council’s housing need and is capable of being developed in accordance with relevant environmental policy at local and national levels.

1.18 Further detail of EDP’s desk and field assessments can be found on the following pages.

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Section 2 Landscape and Visual Matters

2.1 Following desk-based analysis of local landscape-related planning policy, designations and character, a site appraisal was undertaken, by an experienced Landscape Architect, in January 2018. This involved walking and driving the local area to understand the character and context of the site to assess the likely landscape and visual effects that would arise from development of the site.

Planning Policy and Landscape-related Designations

2.2 The site is located within the Central Bedfordshire Council administrative area. The extant planning policy at a local level is contained within Central Bedfordshire Core Strategy (November 2009), including:

• Policy CS14: ‘High Quality Development’ requires proposed development to respect “…local context, the varied character and the local distinctiveness of Mid Bedfordshire’s places, spaces and buildings”;

• Policy CS16: ‘Landscape and Woodland’ requires the Council to (inter alia) “…conserve and enhance the varied countryside character and local distinctiveness in accordance with the findings of the Mid Bedfordshire Landscape Character Assessment” and “Resist development where it will have an adverse effect on important landscape features or highly sensitive landscapes”;

• Policy CS17: ‘Green Infrastructure’ states that “The Council will require new development to contribute towards the delivery of new green infrastructure and the management of a linked network of new and enhanced open spaces and corridors”;

• Policy DM14: ‘Landscape and Woodland’ states that “Proposals for development within the Northern Marston Vale, the Forest of Marston Vale, Ivel Valley, the urban fringe around the major service centres and along the main road corridors will be required to provide landscape enhancement on or adjacent to the development site or contribute towards landscape enhancement in these areas”.

• Policy DM16: ‘Green infrastructure’ states that the Council will “…promote and protect green infrastructure by ensuring that proposed residential and commercial development which adversely affects identified green infrastructure assets and/or prevents the implementation of green infrastructure projects will not be permitted”.

2.3 Plan EDP L1 shows the environmental context of the site and, with regard to landscape and visual issues, those designations that may impose various levels of constraint on new development. Plan EDP L1 shows that:

5 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

• The site is not located within or in close proximity to any national landscape designations;

• The site lies more than 2km, at its closest point, from the Metropolitan Green Belt;

• There are no blocks of ancient woodland within 2km of the Site;

• Although there are no Public Rights of Way (PRoW) crossing the site, PRoW No. FP4 runs along the entire length of the western boundary and No. FP5 runs along the eastern and of the southern boundary. There are relatively few within the wider context, particularly those that afford views of the site. A single promoted footpath is located approximately 2km of the Site, namely the John Bunyan Trail which is located to the north-west and runs through the settlement of Meppershall;

• The nearest Conservation Area is located over 2km to the west at Meppershall. Other Conservation Areas located within 3km of the site include those at Clifton and Henlow. However, there was not found to be any intervisibility between the core of any of these Conservation Areas and the site;

• There are a number of listed buildings throughout the wider context, with the nearest being located within the RAF Henlow Camp; and

• There are no SSSIs, SPAs or SACs within 5km of the site.

2.4 Following this initial review, it has been found that no part of the site is designated for its landscape value or scenic qualities at any level.

Landscape Character

EDP’s Assessment

2.5 As shown on Plan EDP 1, and illustrated in Appendix EDP 1, Plate EDP 1, the site primarily comprises a single medium-sized agricultural field enclosed by detached properties and a large waterbody to the north, Bedford Road to the east and Henlow Racing Greyhound Circuit to the south.

2.6 The site’s boundaries are formed by a mixture of hedgerows (refer to Section 3), and poor quality agricultural fencing and wet ditches. The main character and valuable fabric within the site is to be found along the boundaries (illustrated in Appendix EDP 1, Plate EDP 2). This, in addition to existing built form immediately to the north and south, busy road, and a variety of poor quality agricultural fencing and gate access points, serve to reduce tranquillity within the site.

2.7 The site is not particularly constrained in terms of its landscape fabric and is well bounded and contained within the local landscape. While the northern and eastern areas of the site benefit from visual enclosure created by existing landscape features and built form,

6 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

consideration should be given to development within the western areas of the site which, is potentially visible in views from receptors to the west of the site.

2.8 In terms of potential impacts on the landscape character of the site, proposed development offers the opportunity to positively integrate the field boundary hedgerows and trees within the scheme layout, thus retaining the characteristic vegetation elements and pattern prevalent across the site and contribute to biodiversity.

2.9 The site is visually well contained, with the zone of primary visibility being limited to the site itself and parts of the PRoW within 800m of the western site boundary. This containment is due to surrounding urban development, mature landscape features aligning the road network and the immediate gently rolling topography. Within the western areas of the site, land is more ‘exposed’ due to the absence of mature field boundary. However, there were not found to be any views of the site from the wider context looking towards the site in which it would be considered a noticeable or unexpected component of the view.

2.10 Visibility to the site is experienced largely by users of the PRoW network, located immediately adjacent to the site boundary and extending to approximately 800m to the west of the site. Views are afforded from the Bedford Roads, although again existing mature roadside landscape features provide a good visual screen beyond the immediate site.

2.11 In the wider context, due to built form within the surrounding built up areas and mature landscape fabric, if seen at all, the site is likely to be glimpsed in views between existing built form. Similarly, views from receptors up to 2km from the west of the site boundary, are very heavily filtered by existing landscape features.

2.12 For all these reasons the site has less of a character, visual, and physical, relationship with the wider open countryside, and more of a relationship with the surrounding built up areas.

Published Landscape Character Assessments

2.13 The most recent assessment of landscape character was undertaken in January 2015 (Plan EDP 2), by Land Use Consultants on behalf of Central Bedfordshire Council. It defines the site aa falling within Landscape Character Type 4C: Upper Ivel Clay Valley, which is described as:

“…flat (ranging from 35m AOD to 51m AOD) and there are some long views over large scale open arable fields which contrast with more intimate, small scale pastures along the courses of the Ivel and Hiz. Large and medium size fields of arable are bounded by ditches and hedgerows in mixed condition with some hedgerow trees. …The Upper Ivel Clay Valley has a high density of settlement with a number of substantial villages.”

2.1 Following a review of the key characteristics identified within the LCA, in some respects, the site and its context is considered to relate well to its descriptions, largely to those negative aspects which suggest an urbanised setting. Those of relevance to the site have been emphasised by EDP below:

7 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

• “A level wide river valley founded on Gault Clay, Chalk and Alluvium with deposits of Glacial Gravel and Valley Gravel;

• The River Ivel, the River Hiz and the disused Ivel Navigation run through the area with tributary streams and open water bodies deriving from mineral workings, the latter concentrated between Henlow and Langford;

• Mixed land use predominantly of arable farmland with some pasture along the river courses plus substantial areas of settlement;

• Large and medium scale geometric arable fields are bounded by hedgerows in mixed condition with some hedgerow trees, with more intimate scale pastoral fields along the River Ivel;

• Scattered woodland blocks and belts create a semi-enclosed landscape along the River Ivel and River Hiz;

• Dense settlement of medium and large scale villages often expanded along roads, plus a few scattered farmsteads;

• Historic centres of villages (such as Langford, Clifton and Henlow) feature stone churches, red and yellow brick and render buildings with clay tile and slate roofs, while on the outskirts of settlements and spreading along roads there is more modern development in mixed materials; and

• Open views over level arable farmland contrast with more intimate, enclosed pastures along the immediate river corridors.”

2.2 In relation to the visual and perceptual character, the LCA states that “The flat landscape results in some long views over large scale open arable fields”, although it is noted that “Overall it is a fragmented landscape with the immediate river corridors hidden by buildings and woodland and the wide views over the level arable fields sometimes interrupted by abrupt settlement edges.”

2.3 In relation to the site and its context, past changes to this LCA include the “Loss of hedgerows and hedgerow trees” and the “Expansion of towns and villages”.

2.4 The key landscape sensitivities of this LCA largely relate to characteristics associated with existing watercourse, namely the Ivel and the Hiz Rivers where, according to the LCA, “minor roads and bridges over the Ivel and the Hiz which reinforce the rural character of the area”.

2.5 With regard to visual sensitivities, the LCA references “The open views over level arable farmland to adjoining rural areas on higher ground”, and “The corridor and enclosed rural views along the river corridors and across small scale pastures adjacent to rivers.”

8 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

2.6 The Central Bedfordshire Landscape Character Assessment includes a set of guidelines for new development, of which the Proposed development can contribute to the following:

• “Resist development that will result in further loss/fragmentation of hedgerows and hedgerow trees. Enhance hedgerows by replanting;

• Create new wetlands and enhance existing open water bodies and their margins to increase biodiversity interest and strengthen character;

• Safeguard the rural character and qualities of the Ivel corridor. Plant further woodlands (in particular wet woodlands) that will create a more rural edge to development on the margins of villages;

• Create further connections between the villages and the rivers and floodplain through for instance tree planting or wetland habitat creation that would enhance access links;

• Avoid the coalescence of towns and villages (e.g. the linear merging of Shefford and Clifton along the road);

• Enhance landscape boundaries at exposed urban edges;

• Conserve the historic cores of the villages and distinctive features such as footpath links to riverside pasture, village ponds and historic bridges;

• Conserve the character of secondary roads, limiting urbanising influences e.g. kerbing and widening and ensure that traffic management measures are sympathetic to those sections of the area with a rural character;

• Safeguard the distinctive character of Astwick, with its historic pattern of small fields; and

• Explore options for improving low key recreational opportunities and informal access to the river. Monitor the associated development of facilities e.g. visitor centres and car parking that might impact upon the surviving sections of rural, tranquil character in the immediate river corridor.”

2.7 According to the LCA, “The landscape strategy for the Upper Ivel Clay Valley is to enhance elements that have become degraded or been lost such as the hedgerows, pollarded willows, pastures and water meadows and to create new features to enhance and strengthen the river valley character such as new wetlands, wet woodlands and tree planting to screen harsh urban boundaries and roads and increase biodiversity interest.”

2.8 EDP found that the published assessment does not go to a fine enough grain to assess the influences on the character and sensitivity of the site land itself, being located at the south- western edge of, and forming a small part of, the host character area.

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Key Constraints and Opportunities – Masterplanning Principles

2.9 With the exception of longer distance views from elevated ground to the west of the site, the site is considered to be relatively visually unconstrained. Proposed development should respect the surrounding built environment visual amenity and characteristics, including massing, scale and materials, and respond to the more ‘exposed’ western boundary.

2.10 Key considerations in relation to landscape and visual terms are:

• Visual amenity of residential properties with existing views of the site, along Shillington and Station Road;

• Visual amenity of footpaths, which runs immediately adjacent to the southern and western boundary of the site and from the agricultural landscape with 2km to the west;

• Landscape character: retention and reinforcement of key hedgerow boundaries and mature trees that contribute to local landscape character;

• Relationship of new development with the surrounding built environment characteristics, including massing, scale and materials; and

• Respond to the more ‘exposed’ land at the western boundary.

Conclusions in Respect of Landscape Matters

2.11 From a landscape perspective, it is EDP’s opinion that there are no ‘in principle’ constraints with regard to future built development of the site. However, in the interests of good masterplanning, attention should be given to interface with agricultural landscape to the west of the site, where built form has the potential to be visible from receptors on footpaths and in the fringes of Meppershall. In addition, the key landscape features (hedgerows and trees) should be retained and enhanced to mitigate landscape and visual effects and help integrate the site into its context.

2.12 Further, landscaping measures included within any promoted development would be able to provide targeted mitigation where necessary, which would be effective at promoting biodiversity gains, particularly within that part of the site.

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Section 3 Ecological Matters

Introduction and Methodology

3.1 This Preliminary Ecological Appraisal addresses the ecology issues pertaining to the site’s potential to accommodate residential development, and in doing so identifies constraints and opportunities that influence its design, deliverability and/or capacity in this respect.

3.2 This Preliminary Ecological Appraisal has been informed by a desk study and Extended Phase 1 Habitat Survey. The desk study involved collation of information on designated sites and species records from online sources, Bedfordshire and Luton Biodiversity Recording and Monitoring Centre (BMERC), Herts Environmental Records Centre (HERC) and a site walkover survey undertaken by an experienced ecologist on 17 January 2018. Although January is considered to be a sub-optimal time of year for such surveys, given the nature of habitats present (predominantly arable) and the requirement to principally provide high level information to inform the site’s promotion, the findings are not considered to be significantly limited by the timings of the survey.

Preliminary Ecological Baseline

Designated Sites

3.3 No part of the site is covered by any statutory designation and there are no such designated sites within 5km of the site.

3.4 No non-statutory designated sites are located within the site, but three non-statutory designated sites are located within 2km. These consist of two County Wildlife Sites (CWS) namely the Henlow Pit CWS located 1.2km north and the River Ivel and Hiz CWS located 1.8km south-east. The third non-statutory site is the Henlow Bypass Roadside Nature Reserve (RNR) located 1.7km to the north. Full details of all the non-statutory designations are provided in Appendix EDP 2.

3.5 The Henlow Pit CWS is located closest to the site, it comprises a water filled, disused gravel pit surrounded by dense scrub, scattered mature trees and a small area of neutral grassland. Given the spatial separation of the CWS from the site and the lack of any direct receptor pathways it is considered that the Henlow Pit CWS is unlikely to be subject to any significant increase in disturbance as a result of the proposed development.

3.6 Owing to their reasons for designation and/or their spatial separation from the site, it is considered extremely unlikely that any material and adverse effects will occur to any of the off-site designations as a result of development of the site.

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Habitats and Species

3.7 There are no records of Priority Habitats occurring with the site, other than hedgerows. The following UK priority habitats are known to be located within 2km of the site:

• Lowland deciduous woodland; and

• Traditional Orchards.

3.8 None of these priority habitats occur within 500m of the site, and as such it is considered extremely unlikely that any material and adverse effects will occur to these habitats as a result of development of the site.

3.9 The desk study returned many records of protected/notable species within 2km of the site. These include many records of bird including farmland species which could be present within the site including yellow hammer (Emberiza citrinella), song thrush (Turdus philomelos), house sparrow (Passer domesticus), grey wagtail (Motacilla cinerea), redwing (Turdus iliacus) and fieldfare (Turdus pilaris). Low numbers of common and widespread bat species have also been recorded in the wider landscape around the site. Other records of protected/priority species in the wider area include barn owl (Tyto alba), brown hare (Lepus europaeus), harvest mouse (Micromys minutus), common frog (Rana temporaria) and toad (Bufo bufo), smooth newt (Lissotriton vulgaris) and white clawed crayfish (Austropotamobius pallipes).

3.10 Given the lack of high value habitats present and the intensive management of the majority of the field parcel, it is considered unlikely that any of the species above would be significantly impacted by development within the site.

3.11 No records of other European Protected Species (EPS) within 2km of the site were returned from the desk study.

3.12 As illustrated on Plan EDP C1, the majority of the site comprises a single arable field bounded to the north, south and west with hedgerows, scrub and scattered trees of variable species richness, whilst the eastern boundary is delineated by a well vegetated wet ditch opening directly onto the field parcel. Wet ditches are also present to along the southern and northern boundaries though these are heavily shaded by the adjacent hedgerows and thereby support little vegetation. The arable field has a narrow 0.5-1m margin of species poor semi-improved grassland along the northern and eastern boundaries however, this widens in the north-eastern corner of the site where the fence- line dips into the field leaving a 4-5m wide section of rough grasses and tall ruderal vegetation.

3.13 The onsite hedgerow network (with scattered trees and dense scrub) is considered to be of local ecological value, although the habitats in themselves are predominantly considered to be of low (site level) value, e.g. species-poor semi-improved grassland and tall ruderal. By its nature, arable grassland is heavily managed and is therefore considered of negligible value. Despite the predominantly low level of ecological value, the habitats do

12 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

still have potential to support protected/notable species including birds, bats, badger, great crested newts and reptiles.

3.14 The hedgerows, dense scrub and trees within the site have the potential to support breeding birds, foraging/commuting and roosting bats, and badgers. The semi-improved grassland, field margins and tall ruderal; together with the hedgerows and nearby offsite woodland and ponds; have the potential to support great crested newts and reptiles. The arable fields have the potential to support ground-nesting birds and foraging badgers.

3.15 Although the site is considered to provide opportunities for several protected or notable species, these opportunities are primarily restricted to the boundary habitats, owing to the predominance of arable cultivation and management.

Key Constraints and Opportunities – Masterplanning Principles

3.16 On the basis of the preliminary investigations the following standard detailed (Phase 2) surveys are likely to be needed to support any future planning application:

• Breeding bird survey;

• Bat roost assessment of trees;

• Bat activity survey;

• Badger survey;

• Great crested newt survey (including off-site ponds within 500m); and

• Reptile survey.

3.17 The actual need and scope of further Phase 2 surveys will be subject to the nature of the development proposals and consultation with the Local Planning Authority (LPA) Ecologist. For instance, possible reptile presence could potentially be dealt with through precautionary site clearance measures and the need for surveys scoped out. Owing to the limited extent and nature of habitats on the site, other commonly undertaken surveys (e.g. botanical or invertebrate surveys) are considered unlikely to be necessary, subject to consultation.

3.18 Subject to confirmation through consultation and further baseline investigation, the hedgerows, dense scrub and trees across the site are, on a precautionary basis, potentially notable ecological constraints requiring some level of on-site retention, buffering or compensation involving additional habitat creation and enhancement of retained features to improve value for wildlife.

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3.19 Subject to further surveys and identification of further protected/notable species interests, the following recommendations are therefore made to inform the masterplanning of any future development proposals:

• Retention and enhancement, where possible, of existing hedgerows, particularly those that are species-rich, including utilising existing gaps for infrastructure crossings and the provision of at least 3-5m development buffers;

• Retention and suitable buffering where possible, of the nearby offsite woodland/dense scrub copses;

• Integrated sustainable urban drainage system (SuDs) including the provision of open water/marginal aquatic habitats on-site to prevent adverse changes in the volume or quality of run-off entering existing watercourses and to increase habitat diversity on- site; and

• Establishment of species-rich grasslands in suitable areas to encourage structural and botanical diversity within the site.

Overall Conclusions in Respect of Ecology

3.20 The site is relatively unconstrained ecologically, comprising predominantly arable habitat of negligible ecological value. No statutory or non-statutory designated sites are considered to be at risk of any material and adverse effects as a result of the proposed development. Only a limited suite of further Phase 2 surveys would therefore be required to support any future planning application given the nature and extent of habitats present within the site.

3.21 While some of the habitats on-site, including the hedgerows, scrub and trees, are currently considered, on a precautionary basis, to be of some ecological value (local conservation importance), they are largely confined to the external site boundaries. It is therefore likely that they can be adequately accommodated and mitigated by the masterplanning of any future development proposals and are therefore, not considered a constraint to development.

3.22 The possible presence of breeding birds, bats, badgers, great crested newts and reptiles is potentially considered to be the most sensitive ecological receptor. However, if these protected species are found to be present, the populations could be readily safeguarded through appropriate mitigation measures and sensitive timing of works. Opportunities for any protected species potentially present could be provided in the long-term through appropriate design of any future development proposals and through the incorporation of additional ecological enhancements.

3.23 The site is not subject to any ‘in principle’ ecological constraints, and offers sufficient flexibility to ensure compliance with paragraph 118 of the National Planning Policy Framework (NPPF) through the avoidance of ‘significant harm’ to biodiversity. Furthermore,

14 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

an appropriately designed development incorporating appropriate mitigation and enhancement has the potential to deliver a significant net gain in biodiversity.

3.24 On this basis, EDP finds that by virtue of the relatively limited constraint posed by the site’s habitats and protected species interest, coupled with the flexibility in design response, the scheme is capable of compliance with relevant planning policy for the conservation of the natural environment at all levels. There is therefore no reason, in ecological terms, why this site should not be promoted as an ecologically sensitive response to the provision of new housing within Henlow Camp, and as such is commended to Central Bedfordshire Council.

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Section 4 Arboricultural Matters

Methodology

4.1 The methodology adopted for this survey is based on guidelines set out in BS 5837:2012 Trees in Relation to Design, Demolition and Construction, especially Section 4.4, ‘Tree Survey’. Site trees and other significant vegetation are as noted on Plan EDP T1: Tree Constraints Plan. This is derived from the topographic survey data. All surveyed items are detailed in Schedule EDP 1 (Appendix EDP 3). No other trees are covered by this survey.

4.2 All trees have been visually inspected from ground level unless otherwise stated, with no climbing or further detailed investigative tests being undertaken. The comments on their condition are based on observable factors present at the time of inspection. All measurements are metric and have been recorded in accordance with the measurement conventions set out in Section 4.4.2.6 of BS 5837:2012.

4.3 Any recommendations given regarding longer-term management are made on the basis of optimising the life expectancy of site trees, given their current situation and any effects that may result from the development proposals.

4.4 Schedule EDP 1 provides information about the following factors in accordance with paragraph 4.4.2.5 of BS 5837:2012:

• Sequential reference number (recorded on Annex EDP 1);

• Species;

• Height;

• Stem diameter;

• Branch spread;

• Existing height above ground level;

• Life stage;

• Physiological condition;

• Structural condition;

• Preliminary management recommendations;

• Estimated remaining contribution;

17 Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

• Category grading; and

• Tree works priority codes.

4.5 Due to the changing nature of trees and other site circumstances, this report and any recommendations made are limited to a 24 month period from the survey date. Any alterations to the Site or the development proposals could change the current circumstances and may invalidate this report and any recommendations made.

4.6 Trees are dynamic structures that can never be guaranteed 100% safe; even those in good condition can suffer damage under average conditions. Regular inspections can help to identify potential problems before they become acute.

4.7 A lack of recommended work does not imply that a tree is safe and likewise, it should not be implied that a tree will be made safe following the completion of any recommended work.

4.8 The subject trees have not been tagged for identification purposes.

Aims and Objectives

4.9 The arboricultural tree constraints information contained within this Technical Note will feed into the masterplanning for the Site and in turn, inform the Arboricultural Impact Assessment and support the Outline Planning Application.

Overview of Tree Stock

4.10 The survey has identified five individual trees and eight groups of trees totalling 13 items. Of these 13 items, nine have been categorised as B, of moderate quality; and four have been categorised as C, of low quality.

4.11 All surveyed items are as noted on Plan EDP T1 and detailed in Schedule EDP 1 (Appendix EDP 3).

Statutory Protection

Tree Preservation Orders and Conservation Areas

4.12 Review of CBC’s online resource has confirmed that no Tree Preservation Orders (TPO) are registered against this Site, nor does the Site lie within a designated conservation area.

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4.13 Notwithstanding the above, it is advisable to contact CBC’s Tree Officer directly to confirm this.

Site Constraints

4.14 Any items identified as being located off-site remain outside of the direct control of the scheme, however, their above- and below-ground constraints will need to be considered in during the design process.

4.15 The required RPA for each item is as described in Schedule EDP 2 (Appendix EDP 4) and is depicted on Plan EDP T1. To ensure appropriate protection is afforded to the roots, the extent of the RPA shall be defined by means of the installation of protective barriers in accordance with the recommendations given in Section 6.2 of BS 5837:2012. The extent of this enclosed area, known as the Construction Exclusion Zone (CEZ), will be depicted on a Tree Protection Plan, to follow on with the Arboricultural Method Statement.

4.16 Potential shading from the off-site ash trees along the south boundary has been assessed in accordance with BS5837:2012 and shade arcs have been provided on Plan EDP T1 and concludes that the potential for shading into the site is minimal.

4.17 All of the surveyed items are located around the perimeter of the site and, providing that designated RPAs and canopies are respected, they do not adversely constrain the potential to accommodate residential development in the main body of the site.

Conclusion

4.18 Of the items surveyed, nine have been identified as category B, of moderate quality and value. These items should be prioritised for retention due to their condition, age and retention span.

4.19 The arboricultural constraints information provided with this Technical Note will feed into the masterplanning for the site.

4.20 Once the Masterplan has been fixed, an Arboricultural Impact Assessment and Tree Protection Plan will be undertaken to support the Outline Planning Application and to ensure the safe, long-term retention of the arboricultural items for the Site.

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Appendix EDP 1 Photographic Plates Illustrating Landscape and Visual Context

Plate EDP 1: The site, shown in the foreground, comprises an agricultural field.

Plate EDP 2: The main character and valuable fabric within the site is to be found along the boundaries.

Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Plate EDP 3: More open western boundary of the site affords views looking west towards Meppershall.

Plate EDP 4: Adjoining mature landscape fabric restricts intervisibility with the wider landscape.

Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Plate EDP 5: The surrounding land uses reduce tranquillity across the site and urbanise its character.

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Appendix EDP 2 Designated Ecology Sites

Table EDP A2.1: Non-statutory Designated Sites Within 2km of the Site Site Name Description Approximate Approximate Site Grid Distance Reference from Site Henlow Pit A water filled disused gravel pit surrounded by dense TL 156 374 1.2km N CWS scrub with occasional mature trees; a small water filled disused gravel pit at with a small area of neutral grassland adjacent to the west and a small area of ephemeral/short perennial vegetation adjacent to the east. Henlow The Shefford-Henlow Bypass RNR is located on the TL 142383, 1.7km N Bypass RNR north side of the bypass at four locations. All areas TL 148381, were seeded with wildflowers when the bypass was TL 165375, constructed. TL 169378

Rivers Ivel River system with associated wet grassland and TL13 1.8km SE and Hiz CWS reedbeds. Supports populations of water vole.

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Appendix EDP 3 Schedule EDP 1 Tree Survey Key and Schedule

Sequential Reference T ‐ Individual specimen; Number G ‐ Group, Trees that form cohesive arboricultural features either aerodynamically, visually or culturally; H ‐ Linear group of specimens that form a hedge or boundary; and W ‐ A larger group or area of trees that should be regarded as a single woodland unit Species Common English names are used wherever possible for simplicity Height An approximation of height (in metres) is provided for the highest point of the tree. Stem Diameter This is the measurement of stem diameter in millimetres taken in accordance with Annex C of BS 5837:2012. Branch Spread This is taken at four cardinal points, with a stated value in metres to enable an accurate representation of the crown, as shown on Plan EDP T1. Existing Height Above An approximation of height (in metres) of crown clearance above adjacent Ground Level ground level. Life Stage There are six classes to which trees are assigned:

Young;

Semi Mature;

Early Mature;

Mature;

Over Mature; and

Veteran. Physiological An indication of the tree's physiological condition is represented and classed Condition as good, fair, poor or dead, this is informed by the following:

Canopy Density: It should be taken that, unless otherwise stated with each individual entry, the canopy density of the trees is typical of the species; and

Leaf Size and Colouration: It should be taken that, unless otherwise stated with each individual entry, leaf size and colouration is typical of the species. Structural Condition Additional notes are provided giving details of the tree's structural condition. This is informed by “the presence of any decay and physical defect1”. Preliminary These are made on the basis of optimising the life expectancy of site trees, Management given their current situation and that which may result from the development Recommendations proposals. The survey process pays particular attention to implications for life and/or property; defects recorded under the structural condition have the necessary mitigation measures proposed within this section of the schedule.

1 BS 5837:2012 Section 4.4.2.5

Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Estimated Remaining The definitions of the terms used are as follows and describe the estimated Contribution length of time (in years) over which the tree can be expected to make a safe contribution to local amenity:

Less than 10;

10+;

20+; and

40+.

Category Grading Trees have been assigned ‘U’ or Category Grading ‘A’ to ‘C’ in accordance with the Cascade Chart given in BS 5837:2012. Tree Works Priority Priority codes from 1 to 3 have been given for trees requiring work. The Codes definition of the codes used is as follows:

Priority 1: Work that should be undertaken urgently due to the identification of a potential hazard;

Priority 2: Work that should be undertaken prior to any works commencing on site; and

Priority 3: Work that should be undertaken following the completion of the development.

Lower Stondon, Henlow Camp 1 Client: Rainer Developments Limited Site: Date of 18/01/2018 Consultant Luke Tamblyn Survey:

Tagged N/A Weather Overcast

Branch Spread (m) Estimated Sequential Stem Canopy Physiological Remaining Category Species Height (m) Life Stage Structural Condition Comments / Notes Recommendations Priority Reference No. Diameter (mm) Clearance (m) Condition Contribution Grading North East South West (Years)

Ash sp. (Fraxinus sp.);Ivy sp. (Hedera sp.);Blackthorn Access to inspect base - Not possible; Access to inspect base - Restricted / (Prunus spinosa);Willow sp. G1 8 190# 2 2 2 2 0 Mature Fair Fair obscured; Root environment - Restricted; Ivy or climbing plant; Arboricultural work No Work Recommended 10+ C1;2 N/A (Salix sp.);Elder sp. - Historic; Group predominantly located south of significant wet ditch (Sambucus sp.);Elm sp. (Ulmus sp.)

Access to inspect base - Not possible; Access to inspect base - Restricted / T2 Ash sp. (Fraxinus sp.) 12 500# 5 5 4 5 0 Mature Fair Fair No Work Recommended 10+ C1 N/A obscured; Root environment - Restricted; Ivy or climbing plant;

Access to inspect base - Not possible; Access to inspect base - Restricted / T3 Ash sp. (Fraxinus sp.) 14 110# 6 7 5 5 0 Mature Fair Fair No Work Recommended 20+ B1 N/A obscured; Root environment - Restricted; Ivy or climbing plant; Deadwood - Minor;

Access to inspect base - Not possible; Access to inspect base - Restricted / G4 Ash sp. (Fraxinus sp.) 13 200# 5 5 5 5 0 Mature Fair Fair obscured; Root environment - Restricted; Group located south of significant wet No Work Recommended 20+ B1;2 N/A ditch

Hawthorn sp. (Crataegus Access to inspect base - Not possible; Access to inspect base - Restricted / sp.);Ash sp. (Fraxinus G5 7 160 2 2 2 2 0 Mature Fair Fair obscured; Root environment - Restricted; Hedgerow - Neglected / overgrown; No Work Recommended 10+ C1;2 N/A sp.);Bramble sp. (Rubus Field boundary, located south of significant wet ditch sp.);Elder sp. (Sambucus sp.)

Access to inspect base - Not possible; Access to inspect base - Restricted / G6 Ash sp. (Fraxinus sp.) 13 230 5 5 5 5 0 Mature Fair Fair obscured; Root environment - Restricted; Fallen tree / trees - Whole tree; Located No Work Recommended 20+ B1;2 N/A south of significant wet ditch

Access to inspect base - Not possible; Access to inspect base - Restricted / T7 Poplar sp. (Populus sp.) 16 280# 5 5 4 4 0 Mature Fair Fair No Work Recommended 20+ B1 N/A obscured; Root environment - Restricted; Off-site tree, all readings estimated;

Hawthorn sp. (Crataegus sp.);Cypress sp. (Cupressus Access to inspect base - Not possible; Access to inspect base - Restricted / G8 sp.);Ash sp. (Fraxinus 10 200# 3 3 3 3 0 Mature Fair Fair obscured; Root environment - Restricted; Off-site tree, all readings estimated; No Work Recommended 20+ B1;2 N/A sp.);Willow sp. (Salix Located north of significant wet ditch sp.);Elder sp. (Sambucus sp.)

Access to inspect base - Not possible; Access to inspect base - Restricted / Laurel species (Prunus G9 4 90 1 1 1 1 0 Early Mature Fair Fair obscured; Root environment - Restricted; Off-site tree, all readings estimated; No Work Recommended 20+ B1;2 N/A laurocerasus sp.) Located north of significant wet ditch Access to inspect base - Not possible; Access to inspect base - Restricted / G10 Cypress sp. (Cupressus sp.) 10 220 4 4 4 4 0 Mature Fair Fair obscured; Root environment - Restricted; Off-site tree, all readings estimated; No Work Recommended 20+ B1;2 N/A Located north of significant wet ditch Access to inspect base - Not possible; Access to inspect base - Restricted / G11 Hawthorn sp. (Crataegus sp.) 2 70 1 1 1 1 0 Young Fair Fair obscured; Root environment - Restricted; Off-site tree, all readings estimated; No Work Recommended 10+ C1;2 N/A Located north of significant wet ditch

Golden weeping willow (Salix x Access to inspect base - Not possible; Access to inspect base - Restricted / T12 12 500# 3 4 7 7 0 Mature Fair Fair No Work Recommended 20+ B1 N/A sepulcralis 'Chrysocoma') obscured; Root environment - Restricted; Off-site tree, all readings estimated;

Access to inspect base - Not possible; Access to inspect base - Restricted / T13 Cypress sp. (Cupressus sp.) 14 480# 2 5 5 4 0 Mature Fair Fair No Work Recommended 20+ B1 N/A obscured; Root environment - Restricted; Off-site tree, all readings estimated; Land North of the Greyhound Stadium, Lower Stondon Representations in Respect of Ecological, Landscape and Arboricultural Circumstances edp4594_r001a

Appendix EDP 4 Schedule EDP 2 Tree Constraints Schedule

RPA Ultimate Crown Spread (m) Reference Cat No of RPA Area Ultimate Radius No. Grading stems m2 Height (m) (m) N E S W

G1 C1;2 1 2.3 16.3 10 2 2 2 2

T2 C1 1 6.0 113.1 15 6 6 5 6

T3 B1 2 1.3 5.5 18 7 8 6 6

G4 B1;2 1 2.4 18.1 16 6 6 6 6

G5 C1;2 1 1.9 11.6 9 2 2 2 2

G6 B1;2 1 2.8 23.9 16 6 6 6 6

T7 B1 1 3.3 34.2 20 6 6 5 5

G8 B1;2 1 2.4 18.1 13 4 4 4 4

G9 B1;2 1 1.1 3.7 5 1 1 1 1

G10 B1;2 1 2.6 21.9 13 5 5 5 5

G11 C1;2 1 0.8 2.2 3 1 1 1 1

T12 B1 1 6.0 113.1 15 4 5 8 8

T13 B1 1 5.8 104.2 18 2 6 6 5

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Plans

Plan EDP 1 Site Context (edp4594/d001a 20 February 2018 BC/WG)

Plan EDP 2 Environmental Constraints and Opportunities Plan (edp4594/d007a 20 February 2018 PD/WG)

Plan EDP L1 Environmental Planning Context (edp4594/d004a 20 February 2018 BC/JTF)

Plan EDP L2 Published Landscape Character (edp4594/d005a 20 February 2018 BC/JTF)

Plan EDP C1 Extended Phase 1 Habitat Survey (edp4594/d003a 20 February 2018 GY/ND)

Plan EDP T1 Tree Constraints Plan (edp4594/d006a 20 February 2018 GY/LT)

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APPENDIX 5

Transport Assessment

Preliminary Transport Review

Land North of Henlow Greyhound Stadium Lower Stondon, Central Bedfordshire

PREPARED BY: FOR: DATE: REFERENCE: Jubb Consulting Engineers Ltd. Rainier Developments Ltd Feb 2018 18109/PTR/01 v2

Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Contents

1 Project Information ...... 3 1.1 Project Information...... 3 1.2 Project Details ...... 3 1.3 Report Details ...... 3 1.4 Project Authorisation ...... 3 2 Introduction ...... 4 2.1 Preamble ...... 4 2.2 Scope of Report ...... 4 3 Site Location and Development Proposals ...... 5 3.1 Site Location ...... 5 3.2 Development Proposals ...... 6 3.3 Planning Context ...... 6 4 Development Proposals ...... 11 4.1 Introduction ...... 11 4.2 Vehicular Access Strategy ...... 11 4.3 Pedestrian and Cyclist Access Strategy ...... 13 4.4 Internal Road Layout ...... 14 4.5 Travel Plan ...... 14 5 Site Accessibility ...... 15 5.1 Accessibility to Facilities and Services ...... 15 5.2 Pedestrian Accessibility ...... 18 5.3 Cyclist Accessibility ...... 21 5.4 Public Transport Accessibility ...... 22 6 Development Trip Generation and Trip Distribution ...... 26 6.1 Trip Rates and Trip Generation ...... 26 6.2 Trip Distribution ...... 27 6.3 Key Highway Constraints ...... 28 7 Summary and Conclusions ...... 29 7.1 Summary ...... 29 7.2 Conclusion ...... 30 Appendix A: Site Location Plans ...... Appendix B: Central Bedfordshire Local Plan – Proposed Allocations ...... Appendix C: Proposed Site Access (Preliminary Design) ...... Appendix D: 2km Walking Isochrone and Facilities Map ...... Appendix E: 5km Cycling Isochrone Map ...... Appendix F: Key Walking Routes Plan ......

18109/PTR/01 v2 1 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix G: Public Rights of Way Plan ...... Appendix H: Bus Routes Map ......

18109/PTR/01 v2 2 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

1 Project Information

1.1 Project Information

Client Rainier Developments Ltd

1.2 Project Details

Project Name Land North of Henlow Greyhound Stadium

Location Lower Stondon, Central Bedfordshire

Jubb Project Number 18109

1.3 Report Details

Version v2

Status Issue

Date 20-02-18

1.4 Project Authorisation

ISSUE HISTORY: AUTHORISATION:

Version Date Detail Prepared By Approved By v1 26-01-18 First Draft AK MPG v2 20-02-18 Issue AK MPG

18109/PTR/01 v2 3 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

2 Introduction

2.1 Preamble

2.1.1 Jubb have been commissioned by Rainier Developments Ltd to provide transport and highways advice in support of the promotion of land for residential development through the local plan process.

2.1.2 The proposed site, known as Land North of Henlow Greyhound Stadium is located immediately north of the Henlow Greyhound Stadium and the main built-up area of the settlement of Lower Stondon and west of RAF Henlow which is situated on the opposite side of the A600 Bedford Road.

2.1.3 This Preliminary Transport Review (PTR) provides an overview of pertinent transport and highways matters related to the promotion of the proposed site for residential development. The scope of this PTR is outlined in the following section.

2.2 Scope of Report

2.2.1 The scope of this PTR is as below:

Section 3 Sets out the location of the proposed site, the development proposals, and relevant planning context;

Section 4 Presents the strategy for vehicular, pedestrian and cyclist access into the proposed site;

Section 5 Audits the accessibility of the proposed site, options to link into existing sustainable transport network including public transport;

Section 6 Summarises the likely trip generation and distribution on to the local highway network and provides a high-level review of junction capacity;

Section 7 Presents the summary and conclusion of the PTR.

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3 Site Location and Development Proposals

3.1 Site Location

3.1.1 Lower Stondon is a small village settlement located in the Central Bedfordshire unitary authority area. In the 2011 Census it had a recorded population of around 3,900 people.

3.1.2 Lower Stondon lies approximately 6.2km northwest of Letchworth Garden City, 6.7km north of Hitchin, 16.4km northeast of Luton and 18.1km southeast of Bedford.

3.1.3 The site being promoted for residential development is located immediately north of the built-up area of the village located approximately 0.5km north of the main local centre of Lower Stondon. The site sits within the Central Bedfordshire authority area.

3.1.4 Figure 3.1 below shows the location of Lower Stondon in the regional context while Figure 3.2 on the following page shows the proposed site in the context of Lower Stondon – both are extracted from the drawings provided at Appendix A.

Figure 3.1 – Location of Lower Stondon (Regional context)

18109/PTR/01 v2 5 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Figure 3.2 – Site Location Plan (Local Context of Lower Stondon)

3.1.5 The proposed site occupies an area of approximately 3.41ha, across an area of arable farmland. The site is bounded by the A600 Bedford Road to the east, the Henlow Stadium Greyhound Track to the south, open farmland to the west and a residential property to the north.

3.2 Development Proposals

3.2.1 The current proposals would see the use of the site change from its current agricultural land use to residential use. It is anticipated that the site would be able to yield around 100 residential dwellings.

3.3 Planning Context

Local Plan

3.3.1 Central Bedfordshire is currently preparing its Local Plan to cover the period up to the year 2035 – the Plan is at the pre-submission stage and is currently the subject of a public consultation following which it will be submitted to the secretary of state for examination.

3.3.2 In the Local Plan, Lower Stondon is listed as Large Village which is the third tier (of four) of settlement categories in Central Bedfordshire.

3.3.3 Policy SP7 of the emerging Local Plan states that small-scale housing and employment uses together with new retail, service and community facilities to serve the village and its catchment will be supported.

3.3.4 Considering the Lower Stondon area, the village sees a number of proposed allocations. The main proposed strategic allocation in Lower Stondon is that on land currently occupied by RAF Station Henlow.

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3.3.5 In September 2016, the then Defence Secretary, Michael Fallon, announced that 13 Ministry of Defence sites, including RAF Henlow, were to be sold for redevelopment including housing with the anticipated closure of the bases by the year 2020.

3.3.6 Policy SE4 of the Local Plan proposes that the site be allocated for a mixed-use development to:

▪ provide for up to 130 hectares of developable land comprising: o up to 85 hectares of specialist high-technology, science, research and development uses to the north of the A659 Hitchin Road; and o a mixed-use visitor-economy and residential scheme of up to 45 hectares to the south of the A659 Hitchin Road. ▪ deliver necessary improvements to the road network maintaining suitable access to the site; and ▪ provide opportunities for sustainable transport links to be determined through a Transport Assessment.

3.3.7 The area covered under the RAF Henlow allocation is shown in Figure 3.3 (provided in full at Appendix B) below as prepared by Central Bedfordshire council and which is extracted from the pre-submission draft Local Plan document.

Figure 3.4 – Proposed RAF Henlow Allocation (source Central Bedfordshire pre-submission Local Draft)

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3.3.8 Beyond the proposed strategic allocation at RAF Henlow, there are several other proposed allocations which are as follows;

▪ HAS23 – Approx. 100 dwellings on Land Adjacent to Derwent Lower School; ▪ HAS46 – Approx. 244 dwellings on Land rear of Station Road (Lower Stondon Northern Expansion); and ▪ HAS47 – Approx. 33 dwellings on Land off the Pastures, Lower Stondon.

3.3.9 The locations of these proposed allocations are shown in Figure 3.5 (provided in full at Appendix B) below as prepared by Central Bedfordshire council and which is extracted from the pre-submission draft Local Plan document.

Figure 3.5 – Proposed Allocations in Lower Stondon (source Central Bedfordshire pre-submission Local Draft)

Local Transport Plan

3.3.10 Central Bedfordshire have prepared a Local Transport Plan for the authority area and within it identifies a several schemes to improve transport in the local area. For the ‘Stondon’ area the following priorities including Figure 7.6 are extracted from the Local Transport Plan and provided on the following page.

“The A600 Bedford Road runs between Stondon and Henlow and causes some degree of severance between the two areas. There are concerns as to the speed of traffic on the road both in terms of that approaching the village from Shefford in the north and Hitchin in the south, and the concerns over speed discourage walking and cycling in the area and add to the perceived barrier the road creates for east-west movements.

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The parade of shops close to the Henlow Camp RAF base, at the junction of Bedford Road and Hitchin Road, together with the lower school in Lower Stondon, are key trip attractors in the area and generate significant parking concerns at peak times. On-street parking also impedes the smooth and efficient flow of traffic at these peak times, whilst also accentuating road safety concerns. Figure 7.6 details the key localities where these concerns arise.”

Figure 7.6 – Priorities in Stondon (as prepared by Central Bedfordshire Council)

3.3.11 Clearly from the above the western route into the village is a source of some concern for locals with concern over parking, speeding and access to local schools. There is also concern over speeding on the northern approach to the village and the volume/speed of traffic on the A600 Bedford Road causing issues of severance.

3.3.12 In addition to these priorities, the LTP also lists measures to assist in the improvement of the local transport network as well as consultation responses from local Parish Councils which informed the development of the LTP. Those which are pertinent to the ‘Stondon’ area are listed below:

▪ Real Time Bus Information at stops in each of the main settlements in the Plan area on stops serving a number of services including the No.71, No. 188 and No.190; ▪ 40 mph speed limit signs in advance of 30mph speed limits on the approaches into Stondon on the A600 from Hitchin and the A600 from Shefford (understood to be already implemented); ▪ Raised pedestrian crossings [to reduce vehicle speed/improve pedestrian safety]: o Station Road – adjacent to the Doctors Surgery o Station Road – adjacent to the Golf Club o Bedford Road A600 – to location of the existing Pelican Crossing o Bedford Road A600 – south of the Orchard Way/Bedford Road/Station Road roundabout to slow traffic approaching from Hitchin o Bedford Road A600 – north of the Orchard Way/Bedford Road/Station Road roundabout to slow traffic approaching from the Bird in Hand Roundabout o Shillington Road near Brittains Rise

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o Hillside Road – opposite the Village Hall o Bedford Road A600 – between the south of the Bird in Hand Roundabout and north of the Orchard Way/Bedford Road/Station Road roundabout, cycle lanes, to reduce carriage way width to slow traffic on the road and encourage cycling within the village with a possible 20 mph limit for this area.

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4 Development Proposals

4.1 Introduction

4.1.1 This section sets out the strategy for vehicular, pedestrian and cyclist access to the proposed development. This strategy has been prepared following a study of the surrounding highway network.

4.1.2 It is important to note that whilst the proposed strategy for access to the site is set out, the exact form and location of the proposed accesses remains flexible to an extent and could be altered if necessary.

4.2 Vehicular Access Strategy

Existing Vehicular Access

4.2.1 The site is abutted on it eastern side by the A600 Bedford Road and enjoys a contiguous boundary with the adopted public highway.

4.2.2 At present, there is no direct vehicular access from the A600 Bedford Road to the site, however there appears to have been informal access to the field in the past as evidenced by Google street view imagery (circa May 2009) as shown in Figure 4.1 below. This informal access was blocked through the presence of farm machinery – the access has since been long out of use and is significantly overgrown with vegetation.

Figure 4.1 – Previous Informal Access (source Google Street View circa May 2009 - image data: Google)

4.2.3 Thus, at present, vehicular access to the site is afforded by way of the farmland immediately west of the proposed development site which itself is accessed via Meppershall Road to the west. Figure 4.2 on the following page sets out the location of the existing vehicular access to the site.

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Figure 4.2 – Existing Vehicular Access

4.2.4 The A600 Bedford Road is wide single carriageway road which in the vicinity of the site provides a width of 6.5m and has a single running lane in each direction (thus each lane is circa 3.25m wide) – a single 1.3m wide footway is provided on the eastern side of the carriageway. In the wider context, the A600 runs from Bedford (to the north) and Hitchin (to the south).

4.2.5 Along the site frontage, the A600 Bedford Road is unlit and traffic travelling along the A600 Bedford Road is subject to the ‘national speed limit’ (60mph for cars and light vehicles and 50 for heavy vehicles); the speed limit reduces to 40mph at the site’s southern boundary and further reduces to 30mph approximately 220m south of the site boundary as the A600 Bedford Road enters the main built-up area of Lower Stondon; from here the A600 is street-lit.

4.2.6 Given that the A600 Bedford Road is the only public highway that abuts the site and that the existing vehicular access is contingent on access via third party land, or at least over land which is not under the direct control of the developer, it is clear that the primary vehicular access to the proposed site should be taken from the A600 Bedford Road.

4.2.7 While there are currently no other committed developments on RAF Henlow opposite, it should be borne in mind that the RAF Henlow site is currently allocated within the emerging Local Plan and access to that allocation may be sought off the A600 Bedford Road in the future.

Proposed Vehicular Access

4.2.8 Considering the scale of the development, it is proposed that the Land North of Henlow Greyhound Stadium would be served by a single point of vehicular access off the A600 Bedford Road.

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4.2.9 Due to the scale of the development and as seen for the neighbouring site accesses, it is considered that a simple priority ‘give-way’ t-junction could be formed to serve the site. A proposed site access junction drawing is shown below at Figure 4.3 and is taken as an extract from the scaled drawing provided at Appendix C.

Figure 4.3 – Proposed Site Access Arrangement

4.2.10 The site access has been located to ensure that the required visibility splays can be achieved and to maintain maximum separation for the neighbouring site accesses.

4.2.11 Should the local highway authority require the provision of a right turn lane, there would be the possibility of the provision for such a faciality to serve the proposed development site, however, due to the extent of site frontage and adopted public highway available, a right turn lane faciality would need to be developed using some of the site land.

4.2.12 Should the local highway authority seek an alternative junction form arrangement then an alternative may include a roundabout option, however in order to achieve this it would result in a small loss of net developable area and may require a reduction in the speed limit on the A600 Bedford Road so that the required forward visibilities can be achieved.

4.3 Pedestrian and Cyclist Access Strategy

4.3.1 Given the setting of the site immediately north of the main built-up area of Lower Stondon, the key pedestrian and cyclist desire line will be to the south of the site towards the local centre where the shops, services and facilities are concentrated.

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4.3.2 However, as stated earlier, currently there is no footway provision on the western side of the carriageway of the A600 Bedford Road; provision currently only exists on the eastern side of the carriageway.

4.3.3 Thus to cater for the key pedestrian desire to the Lower Standon local centre, it is envisaged that a new section of foot/cycleway is provided on the western side of the A600 Bedford Road. The new section of the foot/cycleway would project south from the vehicular site access towards the built-up area of Lower Standon.

4.3.4 From the site access a 3.0m wide shared foot/cycleway would route south running adjacent the carriageway of the A600 Bedford Road and would link into the existing provision which currently ends just south of the secondary vehicular access to the Henlow Stadium Greyhound Racing Track.

4.3.5 It is noted that an extensive verge, which includes a drainage ditch, abuts the A600 Bedford Road on its western side at present. However, it has not yet been established whether this land is adopted public highway and a search of the adopted highway plans by the local highway authority is still being undertaken.

4.3.6 The return of the result of this search will confirm the deliverability of this provision. If such a provision cannot be achieved, an alternative arrangement will need to be sought, but this too is contingent on the return of the adopted public highway search.

4.4 Internal Road Layout

4.4.1 The internal road network will be designed in line with Manual for Streets and Central Bedfordshire guidance, focussing on the creation of safe routes through the site to promote access on foot and by bicycle.

4.4.2 The internal road network will be designed so as to cater for the likely volume and type of trips on each link, as well as the number of dwellings accessed. The internal road network would likely be restricted to 20mph.

4.4.3 To encourage sustainable travel, suitable cycle parking storage will be provided within the proposed development.

4.4.4 To promote the creation of a sustainable development, development proposals will be sensitively designed to promote the delivery of a high-quality layout and environment, that will assist in maximising transport sustainability and integration.

4.5 Travel Plan

4.5.1 A Travel Plan will be prepared to support any future application and be prepared to:

▪ Raise awareness of sustainable travel; ▪ Reduce dependency on usage of the private car; ▪ Discourage unnecessary car journeys; and ▪ Encourage modal shift towards sustainable modes of transport.

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5 Site Accessibility

5.1 Accessibility to Facilities and Services

5.1.1 This section sets out the location of the proposed site in relation to a range of local facilities and services that meet day-to-day needs. The need to locate residential developments within walking distance of day- to-day needs is outlined in the National Planning Policy Framework (NPPF, 2012), which states that developments that would generate significant movement should be located “where the need to travel will be minimised and the use of sustainable transport modes can be maximised”.

5.1.2 As stated earlier in this report, the principle of small scale development in Large Villages is considered acceptable in the emerging Local Plan.

Walking Distance

5.1.3 The proposed site is well-related to a range of existing shops, services and facilities that are concentrated around the local centre in Lower Stondon which is focussed around the roundabout junction between the A600 Bedford Road/Hitchin Road and Station Road to the south.

5.1.4 On the basis that a direct connection into the existing footway network can be achieve, the sites location adjacent the existing built-up area of the village and its relative proximity close to the heart of the local centre it is considered that the location of the proposed site presents the opportunity for journeys, by active modes of travel, to a number of day-to-day needs.

5.1.5 Figure 5.1 on the following page (which is extracted from Appendix D) shows the range of local facilities and services that can be reached from the proposed site within a reasonable walking distance. This figure presents a non-exhaustive overview of the range of facilities that meet a number of day-to-day needs that lie within a 2000m walk of the Land North of Henlow Greyhound Stadium Site.

5.1.6 2000m, which is equivalent to a 25-minute walk, is widely-recognised as a reasonable walking distance. As such, this 2000m walking isochrone demonstrates the area surrounding the proposed site that can be reached within reasonable walking distance. This isochrone is measured from the centre of the proposed site and is based on a sole point of access onto the A600 Bedford Road.

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Figure 5.1 – Accessibility to Local Facilities and Services – 2km Walk Isochrone

5.1.7 As shown in the above figure, the proposed site is well-related to a range of existing shops, services and facilities in the village which are mainly concentrated around the village’s local centre. These include:

▪ A Post Office; ▪ A GP Surgery; ▪ A Pharmacy; ▪ Convenience Stores; ▪ Petrol Filling Station; ▪ Public Houses; ▪ Recreation facilities (including a children’s play area); and ▪ Primary Education; and ▪ An Employment area.

Cycling Distance

5.1.8 It is also important to note that a much larger surrounding area can be reached within reasonable cycling distance, 5000m (which is equivalent to a 21-minute cycle), of the proposed site. 5000m was originally identified in the now superseded Planning Policy Guidance 13: Transport (2011) as a distance within which cycling has potential to replace car journeys, and it is still widely-acknowledged as a reasonable cycling distance.

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5.1.9 Figure 5.2 below (which is extracted from Appendix E) sets out the area surrounding the proposed site that lies within a 5000m cycle journey. This cycling isochrone is measured from the centre of the proposed site and is based on egress from the site by way of the proposed access onto the A600 Bedford Road.

Figure 5.2 – 5km Cycle Isochrone

5.1.10 As can be seen from the above figure, the entire Lower Stondon settlement, including the local centre, is well within a reasonable cycle distance from the site as indeed are other nearby settlements including Shefford, Clifton, Henlow and Arlesey to the north with the northern fringe of Hitchin to the south. Being only a further 1.0km (or 4 minutes cycling time) south of the 5km isochrone.

5.1.11 Importantly, a number of employment hubs sit within this distance; these include the Henlow Industrial Estate, RAF Henlow (which is identified as a future high-tech employment zone in the emerging local plan) and the Shefford Industrial Park. It should also be noted that Arlesey Railway Station sits within the 5km cycle isochrone – accessibility by rail is covered in greater detail later in this report.

5.1.12 As such, given employment opportunities and access to the railway station at Arlesey are readily accessible from the proposed site by bicycle, it should be considered that there will not be a need to rely on the use of the private car for day-to-day trips to these destinations.

Summary

5.1.13 In summary, it has been demonstrated that existing offering of shops, services and facilities in Lower Stondon are within a reasonable walk or cycle distance from the site and hence are accessible.

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5.1.14 The Royal Air Force station, RAF Henlow, is also accessible from the site; although it was announced that RAF Henlow will be closed by the year 2020, the site is likely to offer significant, high-technology, science, research and development and employment uses in the future which the proposed site will be well placed to access.

5.1.15 These offerings, combined with the proximity of the proposed site to these amenities, means that active modes of travel represent a genuine alternative to the use of the private car for daily trips to these destinations.

5.1.16 Therefore, it is reasonable to conclude that the proposed site is positioned in a sustainable location, and there will not be a requirement to rely on the use of the private car for daily trips.

5.2 Pedestrian Accessibility

5.2.1 Walking is a major mode of travel for local journeys and is widely-recognised as the most sustainable form of travel (IHT, 2000). As such, walking is an important component of sustainable growth, and the NPPF states that large-scale residential developments should be located within walking distance of day- to-day facilities and services, such as primary education.

5.2.2 As discussed in the previous section (Section 5.1 ‘Accessibility to Facilities and Services’) the proposed site is well-related to a range of existing and forthcoming facilities and services, and these will be readily accessible from the proposed site on foot.

5.2.3 Access to these locales for pedestrians will be facilitated by the existing network of footways, and footpaths, that permeate through the area to the south of the proposed site. Generally, this network provides streetlights, footway/footpath of a reasonable quality and pedestrian crossing facilities.

5.2.4 In combination, this pedestrian network will present continuous, comfortable and safe connections between the proposed site and important local destinations.

5.2.5 Considering the predominant routes between the proposed site and important destinations lying within reasonable walking distance, three ‘key routes’ have been identified. These routes, and the features along them, are shown in Figure 5.3 (which is extracted from Appendix F) on the following page and are thereafter described.

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Figure 5.3 – Key Walking Routes

Key Route 1 – Local Centre

5.2.6 The first of the key identified key walking routes runs from the proposed site to the local centre. The local centre and the area surrounding it house a significant number of shops, services and facilities including convenience store, health care and primary school and post office.

5.2.7 From the proposed site and the proposed access onto the A600 Bedford Road, it is envisaged that pedestrians would route south along a new section of shared foot/cycleway (subject to confirmation) which would connect into the existing provision approximately 230m south of the site.

5.2.8 From here, pedestrians would continue south following the A600 Bedford Road and after some 110m enter the Local Centre.

5.2.9 The A600 Bedford Road/Hitchin Road/Station Road junction incorporates uncontrolled pedestrian crossing facilities (formed of dropped kerbs and tactile paviours) in the central splitter islands on the northern, southern and western approaches.

5.2.10 Depending on the results of the adopted public highway search, it may be possible to improve the existing footway provision to a shared foot/cycleway standard to link directly into the local centre. It is however noted that BT cabinets are located at southern end of the existing verge and may need to be relocated.

5.2.11 In summary, subject to the envisaged provision being achievable, there would be a clear continuous pedestrian link between the site and the local centre providing direct access to the shops, services and facilities concentrated here.

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Key Route 2 – Local Centre Eastern Branch

5.2.12 Branching off from the first key route, the second key route leads north east from the local centre to the RAF Station Henlow, the Merry Poppets Day Care Nursery and the Derwent Lower School.

5.2.13 Starting from the A600 Bedford Road/Hitchin Road/Station Road junction, the eastern branch follows the Hitchin Road. Hitchin Road is street-lit and provides footways on both sides of the road and where Hitchin Road meets a side road, pedestrians are typically afforded an uncontrolled pedestrian crossing point comprising dropped kerbs.

5.2.14 Approximately 210m east, Hitchin Road meets the main gate to RAF Henlow at a signal-controlled junction; signal-controlled pedestrian crossing facilities are incorporated into the northern, eastern and western arms while a ‘zebra’ crossing is provided on the southern arm. Here, access to RAF Henlow is possible.

5.2.15 The footways continue east along Hitchin Road where after approximately 140m it meets Oldfield Farm Road which leads to Merry Poppets Day Care Nursery (a further 250m from the junction); Oldfield Farm Road has footways both sides of the road and is street-lit.

5.2.16 Returning to Hitchin Road, the footways continue to follow the road as it starts to route north east where after approximately 210m it links with the access to Derwent Lower School.

5.2.17 In summary, there would be a continuous pedestrian link between the site and the local education/child care facilities and existing/future employment zones.

Key Route 3 – Local Centre Western Branch

5.2.18 The third and final of the key routes, similarly branches off the first key route from the local centre and leads west from the local centre to the medical facilities (i.e. the GP surgery and pharmacy) found here.

5.2.19 Starting from the A600 Bedford Road/Hitchin Road/Station Road junction, the western branch follows Station Road. Like Hitchin Road, Station Road too is street-lit and provides footways on both sides of the road and at side road junctions pedestrians are typically afforded an uncontrolled pedestrian crossing point comprising dropped kerbs.

5.2.20 Approximately 90m west of the A600 Bedford Road/Hitchin Road/Station Road junction, the pharmacy is located on the northern side of the road while further 500m west, the GP Surgery is also located on the northern side.

5.2.21 In summary, there would be a continuous pedestrian link between the site and the local health care and primary education facilities.

Public Rights of Way

5.2.22 The accessibility of the proposed site for pedestrians is further enhanced by a number of Public Rights of Way (PRoW) that run through the surrounding area.

5.2.23 Figure 5.4 on the following page (which is extracted from Appendix G) sets out the PRoW that run through the surrounding area.

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Figure 5.4 – PRoW (Source: as informed from Central Bedfordshire and Hertfordshire Council PRoW Mapping)

5.2.24 As shown in the above plan, there is an extensive network of public rights of way that permeate through the open countryside that surrounds the site; by virtue of these PRoWs, leisure links to the surrounding rural settlements is possible.

5.2.25 The site is well placed to the access the PRoW network with the main link to the PRoWs to the west the site being located some 220m north of the site and the main link to the east of the site being located some 1.0km to the east of the site.

Summary

5.2.26 As set out in the preceding section, the proposed site is well-located to connect into the existing network of footways and PRoW that permeate through the surrounding area.

5.3 Cyclist Accessibility

5.3.1 Cycling is recognised as one of the most sustainable modes of transport (as per CIHT’s Planning for Cycling, 2015). This guidance notes that whilst 80% of cycle trips are for short distances, less than 8km, 67% of trips by all modes are less than this distance. Thus, it is suggested that cycling is a potential mode of transport for journeys less than 8000m, and as such cycling should be encouraged in new residential developments.

5.3.2 As discussed earlier (Section 5.1 ‘Accessibility to Facilities and Services’) the proposed site is well- positioned to encourage travel by bicycle, as a number of important employment hubs Arlesey Railway Station lies within a reasonable cycling distance.

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5.3.3 Whilst there is no direct cycle infrastructure or identified local routes near the site, Route 12 of the National Cycle Network (NCN) passes to the east of the site and through the village of Arlesey and Letchworth Garden City – this is shown in Figure 5.5 below.

Figure 5.5 – National Cycle Route 12 (Source: Sustrans Online Mapping www.sustran.org,uk))

5.3.4 Route 12 the Great North Way is a strategic long-distance cycle route comprising both on and off-road sections which, when complete will run from North London to Spalding (Lincolnshire) via Welwyn Garden City, Stevenage, Letchworth Garden City, St Neots, Huntingdon and Peterborough.

5.3.5 In the local context, NCN Route 12 can be accessed at Arlesey (opposite the railway station) which is within a 5.0km ride from the proposed development site or at Letchworth (at Icknield Way) which is approximately 8.2km ride from the proposed development site.

5.3.6 From Arlesey, NCN Route 12 routes south east towards Stotfold after which the route turns south towards Letchworth. From Letchworth NCN Route 12 continues south towards Welwyn Garden City.

5.4 Public Transport Accessibility

Bus

5.4.1 Currently, the closest pair of bus stops to the site are located on the Hitchin Road opposite RAF Henlow and are approximately 580m walk from the site.

5.4.2 The eastbound stop is provided with a bus shelter, flag and pole (with timetable information), a bus layby (allowing buses to wait clear of the carriageway) and bus boarder kerbs (to aid boarding and alighting). In the westbound direction, the stop is provided with a bus cage on the carriageway, a simple flag and pole (with timetable information) and raised bus boarder kerbs. These stops are served by the No. 71 service, the No.188 service and the No.190 service.

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5.4.3 The closest single bus stop to the site is the westbound stop on Station Road opposite Henlow Pharmacy and is approximately a 480m walk from the site.

5.4.4 This stop is provided with a flag (mounted to a lighting column), bench seating and a bin. This stop is served by the No.89.

5.4.5 The sister stop to this (which serves the No.89 in the opposite direction) is situated on the A600 Bedford Road, approximately 100m south of the junction between the A600 Bedford Road/Hitchin Road/Station Road Roundabout junction and approximately a 530m walk from the site.

5.4.6 This stop (which is also served by the No. 71 service, the No.188 service and the No.190 service) is provided with a bus shelter, bench seating, timetable information, a flag (mounted to a lighting column), bus boarder kerbs (to aid boarding and alighting) and a bus cage on the carriageway.

5.4.7 Figure 5.6 below shows an extract from the bus route map provided Appendix H.

Figure 5.6 – Local Bus Routes

5.4.8 As shown, on the above plan, there are four bus services that route within a reasonable walk distance of the proposed site: the No. 71 service, the No.89 service, the No.188 service and the No.190 service.

5.4.9 The No. 71 service, operated by Stagecoach, routes between Bedford and Hitchin, via Lower Stondon, Henlow and Shefford. The service operates Monday through to Saturday typically on an hourly frequency. The approximate journey time to Hitchin is around 15 minutes while to Bedford it is around 50 minutes.

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5.4.10 The No. 89 service, operated by Centrebus South, routes between Lower Stondon and Hitchin, via Upper Stondon, Meppershall, Shillington and Pirton. The service operates Monday through to Saturday and provides two service running through Lower Stondon on a weekday and a single service running through Lower Stondon on a Saturday.

5.4.11 The No. 188 service, operated by Centrebus South, routes between Hitchin and Sandy, via Lower Stondon, Henlow, Langford, Biggleswade and Potton. The service operates Monday through to Saturday and provides five services a day with an approximate frequency of 120 minutes.

5.4.12 The No. 190 service, operated by Centrebus South, also routes between Hitchin and Sandy, via Lower Stondon, Henlow, Langford, Biggleswade, Potton and Gamlingay. The service operates Monday through to Saturday and provides five services a day with an approximate frequency of 120 minutes.

5.4.13 In summary, it can be seen that there are several services that provide links with a number of nearby villages and settlements while there is also a regular frequent bus service to the major settlements of Hitchin (to the south) and Bedford to the north.

Rail

5.4.14 The nearest railway station to the proposed station is Arlesey Railway Station, lying some 3.5km to the north east of the site.

5.4.15 Arlesey Railway Station is operated by Great Northern, the station is positioned on the East Coast Main Line (ECML) which runs between London Kings Cross Station and Edinburgh Waverley, though services stopping at Arlesey run between London Kings Cross and Peterborough.

5.4.16 Figure 5.7 below shows the location of Arlesey Railway Station within the rail network.

Figure 5.7 – Local Rail Network (Source: extract from National Rail Timetable)

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5.4.17 Arlesey Railway Station offers regular, frequent services towards London Kings Cross and Peterborough. At the London terminus, access to other mainline rail services and Thameslink services is possible.

5.4.18 At Hitchin and Stevenage, access to the Hertford Loop Line and line to Cambridge is possible, while at Peterborough access to ECML destinations to the north, including Doncaster, York, Newcastle and Edinburgh is possible.

5.4.19 Table 5.1 below summarises the services that call at Arlesey Railway Station, setting out the approximate frequency and journey time to a selection of destinations on a typical weekday.

Destination Approximate Journey Time Approximate Frequency Towards Peterborough Peterborough 40 minutes 30 minutes Huntingdon 25 minutes 30 minutes St Neots 20 minutes 30 minutes Biggleswade 5 minutes 30 minutes Towards London London Kings Cross 50 minutes 30 minutes Hitchin 7 minutes 30 minutes Stevenage 12 minutes 30 minutes Welwyn Garden City 25 minutes 60 minutes Hatfield 28 minutes 60 minutes Potters Bar 35 minutes 60 minutes Table 5.1 – Summary of Train Services from Arlesey

5.4.20 Arlesey station is within a cyclable distance (4.3km or approximately 18 minutes) of the proposed development site or can be reached using the No. 71 bus service, which stops at nearby village of Henlow and is within a 10-11 minute walk from Arlesey station.

5.4.21 Thus, it is considered that Arlesey Railway Station could be accessed from the proposed site by sustainable means, either by way of the existing bus service or by way of a short cycle ride and as such, the proposed development could derive benefit from the regular services that are offered towards Peterborough and London.

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6 Development Trip Generation and Trip Distribution

6.1 Trip Rates and Trip Generation

6.1.1 To quantify the traffic generated by the proposed development, a review of nearby residential development applications has been undertaken.

6.1.2 In an application by Welbeck Land at land to the west of Bedford Road (ref no. CB/16/05229/OUT) to the south and at the opposite end of the village, the trip rates set out in Table 6.1 below were agreed with the local highway authority (Central Bedfordshire) it should be noted that this development benefits from a resolution to grant planning permission subject to the signing of s106 legal agreement.

Time ARR DEP TOT Vehicle Trip Rates AM 0.168 0.363 0.531 PM 0.362 0.234 0.596

Table 6.1 – Welbeck Strategic Land – Agreed Residential Development Trip Rates

6.1.3 In a current live application by Barratt David Wilson homes at land to the east of Bedford Road, again to the south of the site and at the opposite end of the village, the trip rates that have been submitted in support of the proposed development are set out in Table 6.2 below – it should be noted that this development is located in the neighbouring local highway authority area of Hertfordshire.

Time ARR DEP TOT Vehicle Trip Rates AM 0.102 0.472 0.574 PM 0.403 0.199 0.602

Table 6.2 – Barratt David Wilson - Residential Development Trip Rates

6.1.4 As can be seen from the above tables, the trip rates are of a similar magnitude with the Barratt David Wilson trip rates being marginally higher than those of the Welbeck site. For the purposes of this review the Barratt David Wilson trip rates are used to inform the trip generation associated with the proposed development site.

6.1.5 The anticipated quantum of development for the site has been based on the assumption that 100 dwellings are delivered - the resulting peak hour arrival and departure trips for the proposed development.

Time ARR DEP TOT Vehicle Trip Rates AM 0.102 0.472 0.574 PM 0.403 0.199 0.602 Vehicle Trip Generation (100 dwellings) AM 10 47 57 PM 40 20 60

Table 6.3 – Vehicle Trip Rates and Vehicle Trip Generation

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6.1.6 As demonstrated in the above table, the proposed development is predicted to generate around 57 two- way trips in the AM peak hour, and 60 two-way trips in the PM peak hour. This equates to approximately one additional trip on the local highway network every 60 seconds.

6.1.7 It should be considered that this assessment provides a robust assessment of the potential impact of the proposed development as these are based on local residential applications.

6.1.8 As previously set out, the proposed site is well-positioned to access the Lower Stondon local centre and a regular bus service is within a reasonable walk distance of the site and links Lower Stondon with the large settlements of Hitchin to the south and Bedford to the north.

6.2 Trip Distribution

6.2.1 To establish an existing travel pattern for the area, and therefore the anticipated trip distribution of the proposed development, again a review of nearby residential development applications has been undertaken.

6.2.2 From the Welbeck land application, the distribution of trips onto the A600 Bedford Road can be simply summarised as follows:

▪ 45.8% to/from the north; and ▪ 54.2% to/from the south.

6.2.3 From the Barratt David Wilson application, the distribution of trips onto the A600 Bedford Road can be simply summarised as follows:

▪ 52% to/from the north; and ▪ 48% to/from the south.

6.2.4 As can be seen from the above, there are slightly different results between the two sites; this is due to the slightly differencing methods employed for each site. The Welbeck site uses 2011 Census data alone, while the Barratt David Wilson site uses 2011 Census data coupled with a simple ‘gravity’ model.

6.2.5 For the purposes of this review distribution for the Welbeck Land site is assumed as this is based on 2011 Census data for Central Bedfordshire (as opposed to neighbouring Hertfordshire); the proposed development site sits wholly within the Central Bedfordshire area. The resulting broad distribution is set out in Table 6.4 below.

Direction ARR DEP TOT AM Peak To/from North 5 22 27 To/from South 5 25 30 TOTAL 10 47 57 PM Peak To/from North 18 9 27 To/from South 22 11 33 TOTAL 40 20 60

Table 6.4 – Vehicle Trips and Broad Distribution

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6.3 Key Highway Constraints

6.3.1 A review of the nearby applications shows the extent of the local highway network that will likely require consideration as part of any forthcoming planning application.

6.3.2 The Welbeck Strategic Land Application considered the following junctions:

▪ A600 Bedford Road/Hitchin Road/Station Road Roundabout (Lower Stondon); ▪ A600 Bedford Road/Site Access (Lower Stondon); and ▪ A600 Hitchin Road/A507/Chapel Road Roundabout (north of Lower Stondon).

6.3.3 The Barratt David Wilson Application considered the following junctions:

▪ A600 Bedford Road/Hitchin Road/Station Road Roundabout (Lower Stondon); ▪ A600 Hitchin Road/A507/Chapel Road Roundabout (north of Lower Stondon); ▪ A600 Bedford Road/Westmill Lane/Turnpike Lane Mini-Roundabout (North of Hitchin); ▪ A600 Bedford Road/Bearton Road/Redhill Road Double Mini-Roundabouts (Hitchin); and ▪ A600 Bedford Road/Fishponds Road Roundabout (Hitchin).

6.3.4 It is considered that due to the location of the proposed development site which while within the Central Bedfordshire planning authority but gaining access to the Hertfordshire adopted road network that the entire network listed above will require consideration.

6.3.5 The junction capacity assessments have also been reviewed to determine whether there are or likely to be underlying capacity issues that will detail study and possibly require mitigation. The following junctions were noted to operating with potential for underlying capacity issues in the predicted future with development scenario:

▪ A600 Hitchin Road/A507/Chapel Road Roundabout (north of Lower Stondon); o One arm operates at 0.8 RFC in the AM peak and two arms operate at over 0.8 RFC in the PM peak; ▪ A600 Bedford Road/Westmill Lane/Turnpike Lane Mini-Roundabout (North of Hitchin); o Two arms operate close 1.0 RFC in the AM peak and one arm operates close to 1.0 RFC in the PM peak ▪ A600 Bedford Road/Bearton Road/Redhill Road Double Mini-Roundabouts (Hitchin); and o In the AM peak, three arms operate at over 0.8 RFC, one arm at over 0.9 RFC and one arm at over 1.0 RFC in the AM while in the PM one arm operates at 0.8 RFC and one arm at over 0.9 RFC; and ▪ A600 Bedford Road/Fishponds Road Roundabout (Hitchin); o One arm operates at over 1.0 RFC in the AM peak and one arm operate at over 0.9 RFC in the PM peak.

6.3.6 Hence it is clear that some of the junctions will require more detailed consideration and means to mitigate the developments impact may be required.

6.3.7 Recalling the priorities and schemes summarised in section three as taken from the Local Transport Plan the local highway authority may, seek financial contributions towards these where these are both reasonable and relatable to the impact on the network due to the proposed development.

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7 Summary and Conclusions

7.1 Summary

7.1.1 This PTR has provided a review of pertinent transport and highways matters to the proposed site.

7.1.2 Pertinent Local Plan and Local Transport Plan policies have been outlined, including the status of the settlement of Lower Stondon, proposed allocation sites and key transport priorities identified for the settlement of Lower Stondon.

7.1.3 The site enjoys a contiguous boundary with the adopted public highway, the A600 Bedford Road, on its eastern frontage. A single access option, taking the form of a priority ‘give-way’ T-junction, has been prepared at this stage.

7.1.4 Alternative junction arrangements could be considered though may result in a loss of some net developable area.

7.1.5 Pedestrian and cycle access to the site would be achieved through the single point of vehicular access onto the A600 Bedford Road; some additional infrastructure will be required to support pedestrian and cyclist movements along the key desire line towards the Local Centre.

7.1.6 It is envisaged that this could be delivered by way of shared foot/cycle link to the local centre, however this is subject to the results of an adopted public highway search currently being undertaken.

7.1.7 The proposed site is in a sustainable position, with a wide range of local facilities and services, including Lower Stondon’s Local Centre, lying within a reasonable walking and cycling distance.

7.1.8 Thus, subject to the envisaged pedestrian/cycle infrastructure being provided, the proposed site is well- located to connect into the existing network of footways that permeate through Lower Stondon, there are however there are no local identified cycle routes.

7.1.9 A regular bus service that links Lower Stondon with major settlements to the north and south passes within a reasonable walk distance of the site and provides a link to the nearest railway station at Arlesey. As such, there are realistic opportunities to reduce reliance on the use of the private car.

7.1.10 A preliminary assessment of the trip generation of the proposed development has been undertaken. This assessment anticipates that the proposed development would generate one additional trip on the local highway network every 6 seconds.

7.1.11 Based on the existing travel pattern as derived from 2011 Census data for the local MSOA, it is anticipated just over 50% of traffic would route south (towards Hitchin) and just under 50% to the north (towards Bedford).

7.1.12 A review of the Transport Assessment for the Barratt David Wilson Site (17/02175/1) reveals that a number of junctions on the local highway network are likely to suffer strains on capacity in the future and measures to mitigate any impact due to the development may be required.

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7.2 Conclusion

7.2.1 It is therefore concluded that there are no transport or highways matters that make this site unsuitable for residential development, although further consideration of a number of matters is required.

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Appendix A: Site Location Plans

18109/PTR/01 v2 31 N KEY

NORTH A600 Site Boundary (Illustrative)

A507 A507

A507 A1

A600 A659 A507

Proposed Site

A1(M)

P1 23.01.18 Preliminary issue BJ AK Rev Date Description By Apvd Lower Stondon PROJECT: LAND NORTH OF HENLOW GREYHOUND STADIUM

TITLE: LOCATION OF LOWER STONDON (REGIONAL CONTEXT) A600 CLIENT:

RAINIER DEVELOPMENTS LTD.

SCALE@A3: NTS

PROJECT REF: 18109 DRAWING No: REV: FIGURE 3.1 -

Bristol, Cardiff, Plymouth, Winchester jubb.uk.com St James Court, St James Parade, Bristol BS1 3LH +44(0)117 922 6266 N KEY

NORTH Site Boundary (Illustrative)

P1 23.01.18 Preliminary issue BJ AK Rev Date Description By Apvd

PROJECT: LAND NORTH OF HENLOW GREYHOUND STADIUM

TITLE: SITE LOCATION PLAN (LOCAL CONTEXT OF LOWER STONDON) CLIENT:

RAINIER DEVELOPMENTS LTD.

SCALE@A3: NTS

PROJECT REF: 18109 DRAWING No: REV: FIGURE 3.2 -

Bristol, Cardiff, Plymouth, Winchester jubb.uk.com St James Court, St James Parade, Bristol BS1 3LH +44(0)117 922 6266 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix B: Central Bedfordshire Local Plan – Proposed Allocations

18109/PTR/01 v2 32 Policy SE4

N Date: 22 December 2017 Former RAF Base, Henlow © Crown Copyright and database right. 2017 Ordnance Survey 100049029. W E Central Bedfordshire Council.

Scale 1:20000 Cities Revealed aerial photography copyright S Proposed Allocation The GeoInformation Group, 2010 HAS39

HAS23

HAS46

HAS47

N Date: 22 December 2017 © Crown Copyright and database right. 2017 Ordnance Survey 100049029. W E Proposed Allocation Central Bedfordshire Council. Cities Revealed aerial photography copyright Scale 1:15000 The GeoInformation Group, 2010 S Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix C: Proposed Site Access (Preliminary Design)

18109/PTR/01 v2 33 N

NORTH

R6.00m

R6.00m

2.00m

6.00m

2.00m 2.4m x 250m Visibility Splay (60mph DMRB)

BEDFORD ROAD

S1 P1 18.01.18 Preliminary issue BJ AK Rev Date Description By Apvd

PROJECT: LAND NORTH OF HENLOW GREYHOUND STADIUM

TITLE: PROPOSED SITE ACCESS

BEDFORD ROAD

S2

CLIENT: S6 RAINIER DEVELOPMENTS LTD.

SCALE@A3: 1:1000 - Detail: 1:250

PROJECT REF: 18109 DRAWING No: REV: SK_005 -

S1A KEY Site Boundary (Illustrative)

Assumed Highway Boundary S3 2.4m x 120m Visibility Splay (40mph DMRB) Visibility Splays (2.4m x 250m / 120m)

Bristol, Cardiff, Plymouth, Winchester jubb.uk.com St James Court, St James Parade, Bristol BS1 3LH +44(0)117 922 6266 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix D: 2km Walking Isochrone and Facilities Map

18109/PTR/01 v2 34 N

NORTH

P1 23.01.18 Preliminary issue BJ AK KEY Rev Date Description By Apvd Site Boundary (Illustrative) PROJECT: Isochrone Origin LAND NORTH OF HENLOW GREYHOUND STADIUM 2000m Walking Isochrone Convenience Stores TITLE: (Cornwell Garages, One Stop, Nisa Local) LOCAL FACILITIES PLAN Employment (Peckworth Industrial Estate, Bedford Road Businesses, Henlow Industrial Estate, Savin Nurseries, Stondon Manor Farm Businesses, Rectory Farm Business Park) CLIENT: GP Surgery (The Hawthorns Surgery) RAINIER DEVELOPMENTS LTD. Hairdressers (Hair Factory Hairdressers)

SCALE@A3: Pharmacy (Henlow Pharmacy) NTS Place of Worship PROJECT REF: Post Office (Henlow Camp Post Office) 18109 DRAWING No: REV: Primary Schools FIGURE X - (Merry Poppets Henlow Child Care and Nursery, Derwent Lower School, Stondon Lower School)

Primary Shopping Frontage

Public House / Takeaways (Bird in Hand Public House, Golden Well, Henlow Tandoori, Breadcrumbs / Cafe Milano)

Recreation / Race Course (Henlow Racing)

Garage (Cornwell Garages)

Golf Course (Henlow Golf Club)

Bristol, Cardiff, Plymouth, Winchester jubb.uk.com St James Court, St James Parade, Bristol BS1 3LH +44(0)117 922 6266 Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix E: 5km Cycling Isochrone Map

18109/PTR/01 v2 35 N KEY

NORTH Site Boundary (Illustrative)

Arlesey Railway Station

Isochrone Origin

Cyclist Access ARLESEY 5000m Cycling Isochrone

Employment

- Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix F: Key Walking Routes Plan

18109/PTR/01 v2 36 N KEY

NORTH Site Boundary (Illustrative)

Pedestrian Access

Key Route 1

Key Route 2

Key Route 3

Pelican Crossings

- Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix G: Public Rights of Way Plan

18109/PTR/01 v2 37 N KEY

NORTH Site Boundary (Illustrative)

Public Rights of Way

- Land North of Henlow Greyhound Stadium Rainier Developments Ltd.

Appendix H: Bus Routes Map

18109/PTR/01 v2 38 N KEY

NORTH Site Boundary (Illustrative)

Bus Stops

71 Bus Service - Hourly Service (Bedford - Shefford - Henlow - Hitchin) 89 Bus Service - Two Services in Morning and Afternoon (Henlow Camp - Hitchin) 188 Bus Service - Every Two Hours (Hitchin - Biggleswade - Wrestlingworth - Potton - Sandy) 190 Bus Service - Every Two Hours (Hitchin - Bigglewade - Potton - Gamlingay - Sandy)

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