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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 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore Planning LLP. All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. 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 28292/A5/P1/PD/SO Page 3 February 2018 Stondon Site Assessment 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.