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Central Bedfordshire Local Plan 2015 - 2035

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Central Bedfordshire Local Plan 2015 - 2035 CENTRAL BEDFORDSHIRE LOCAL PLAN 2015 - 2035 PRE-SUBMISSION PLAN JANUARY 2018 CONSULTATION RESPONSE ARNOLD WHITE ESTATES LTD Project reference GP 002 Date 19 February 2018 Gardner Planning Ltd Down Ampney Bendlowes Road Great Bardfield Essex CM7 4RR 07887 662166 [email protected] COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Gardner Planning Ltd. CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL Contents 1. Introduction 2. Spatial Strategy 3. Review Process 4. Scale of Growth and Housing Requirements 5. Allocated and Identified Sites 6. Other Potential Sites 7. Summary and Conclusions Appendices 1. Summary of Representation 2. Checkley Wood Garden Village Concept Diagram and Transport Plan 3. New Trees concept masterplan 4. Stanbridge Road concept masterplan 5. Marston Vale concept masterplan 6. Location plan with Camel and Quest concept plans. 7. The Cambridge Milton Keynes Oxford ‘Golden Arc’ 2 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL 1.0 INTRODUCTION 1.1 This Representation is a response to the consultation on the Central Bedfordshire Council (CBC) Pre-Submission Local Plan January 2018 (PSLP). The agent and objector contact details are on the cover of this Response. This format is necessary, rather than the on-line response form, due to the extent and complexity of the representations. However, Appendix 1 is the Summary of Representations by policy, paragraph, table or diagram. The deadline for responses is 22.2.18. 1.2 These representations are made by Gardner Planning Ltd (GPL) on behalf of Arnold White Estates Ltd (AWEL) which is a former locally based quarrying business (Arnold Sands) with long historical links to the area. It is now primarily a development company with extensive land interests in Central Bedfordshire, Bedford Borough and Aylesbury Vale. AWEL are also involved in the successful delivery of substantial development to the south and east of Leighton Linslade. 1.3 This Representation has considered the PSLP against the tests of soundness in the National Planning Policy Framework (NPPF) 1 which are that the LP must be: Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework. 1 NPPF para 182 3 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL 1.4 The Representation concludes that, as drafted, the PSLP would not pass these tests of soundness for a number of reasons, including: Positively prepared: the strategy will not meet development requirements Justified: it is not the most appropriate strategy and not based on proportionate evidence Effective: it is not based on cross-boundary strategic priorities It is not consistent with Government policy in several important respects including correctly identifying the scale of growth required. 1.5 Nevertheless, it is believed that with suitable modifications as set out herein, the PSLP may be able to be made compliant with the tests of soundness. In particular, the planned Review of the PSLP needs to be widened in scope to meet identified housing need in the South of the District including the unmet housing needs of Luton. 4 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL 2.0 SPATIAL STRATEGY 2.1 The ‘Spatial Strategy Approach’2 - PSLP Section 5 - proposes to: deliver 24,000 new jobs deliver around 39,3503 new homes enhance and protect communities and prevent coalescence of settlements maximise opportunities for intensification and redevelopment 2.2 The ‘Approach’ identifies areas of growth, firstly for this current PSLP: meet identified housing need close to key transport corridors o East-west o A1/East Coast Mainline and o M1/Thameslink meet housing need identified for the Luton HMA and some unmet need from Luton close to where it arises through a strategic extension close to Luton’s urban edge and moderate extensions to existing villages and towns with good connectivity and access to services. This will mean releasing some Green Belt 2.3 Secondly, the ‘Approach’ identifies longer term growth through a ‘Partial Plan Review’ (The Review) “across the corridor” which is not defined but appears to be within 2 PSLP para 5.4 p30 3 there is a footnote reference 4 here but without any text 5 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL o the “Cambridge-Milton Keynes-Oxford Arc”4 also described as the “East West” corridor5 o “A1/East Coast Mainline” corridor6 2.4 This further growth to be allocated in the Review is dependent on “new strategic infrastructure” being: The Oxford-Cambridge Expressway (The Expressway) The A1 road improvements The East-West Rail link including new rail stations/transport interchanges 2.5 It is recognised in the PSLP that the Government’s ‘proposed standardised methodology for calculating housing need’ has not been addressed7. Nor has the PSLP addressed ‘the potential of Central Bedfordshire to play a core role in relation to the Cambridge-Milton Keynes-Oxford Arc as acknowledged in the recent National Infrastructure Commission reports, and the Government's response in the Autumn Budget 2017’8. 2.6 The proposed site allocations are addressed in Section 5 below, but the Strategy highlights four areas9: South Area: this includes 7,350 homes to contribute to Luton’s unmet need within Central Bedfordshire and within the Luton Housing Market Area, which includes Green Belt release. A1 Corridor Area. Great potential for large scale growth resulting from service improvements to East Coast Mainline. Greater clarity is required on further improvements to the Expressway and the Central Section of East-West (EW) Rail, 4 para 5.1.1 5 para 5.1.5 6 PSLP para 5.1.5 7 PSLP para 1.4.1 8 PSLP 1.5.1 9 these areas are mapped in the PSLP Key Diagram para 7.4 p48 6 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL and the capacity of the A1 (which is “absolutely critical”), which will be examined as part of the Review. East West Area. Opportunities for growth related to an upgraded A421 and M1, and the planned Western Section of EW Rail between Oxford and Bedford. Future opportunities for consideration in the Review related to EW Rail and Oxford- Cambridge Expressway, and “National Infrastructure Commission’s central finding that the Oxford-Cambridge area which runs through Central Bedfordshire provides a ‘once in a generation opportunity’ to be the UK’s Silicon Valley, delivering growth in science, technology and innovation. When delivered, these will strongly support the development potential of further large-scale growth in the Marston Vale.” Central Area: which the PSLP suggests has limited scope options for residential growth 2.7 The overall plan target is to deliver 39,350 homes10 plus a “modest contingency on the ‘supply’ of sites … to provide a failsafe if sites fail to come forward as scheduled in our delivery plan” and “in particular [to] … maintain a rolling 5-year housing land supply”. Also, the full quantum of housing in the allocation sites will not be achieved within the plan period so that only a proportion is counted towards the target11 2.8 The ‘strategic allocations’ are set out in Policy SP1 (this policy considered in Sections 4 and 5 below) “have been selected with regard to their overall sustainability based on the evidence presented in the Growth Options Studies for the Luton HMA and the North of Central Bedfordshire, technical site assessment work, the Sustainability Appraisal, transport modelling and other technical evidence studies”12. 10 with an unknown caveat 11 as detailed in the Table at para 7.1.2. 12 PSLP para 6.6.1 7 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL Comment on the Spatial Strategy 2.9 The scale of growth, specifically the quantum of housing, is addressed in Section 4 below. The sites are addressed in Section 5 below. 2.10 The Spatial Strategy for the PSLP, which is based on the overall housing number and a limited number of strategic sites, is therefore relatively modest. The current PSLP proposes to locate such growth as there is (given that “23,845 homes are already planned for or built”13) on “new villages, moderate extensions to existing towns and villages” in the “corridors (East-west, A1/East Coast Mainline and M1/Thameslink)”14 and “Luton HMA”. In the limited way in which this is approached, this Strategy is generally supported. 2.11 It is the Review which will consider growth needs based on much higher housing need (examined in Section 4 below). However, the location for this second wave of housing supply is seemingly limited to two ‘corridors’ defined by strategic infrastructure “the East West Rail/Expressway” and “the A1/East Coast Main Line Corridor”.15 2.12 This Response objects to the stated restriction in the Spatial Strategy Approach for the Review to just consider the areas of the CMKOx and A1 corridors This seems to leave out the South area – much of which is within the Luton HMA - and fails to accord with the PSLP principle that housing provision in the Luton HMA should be “close to where it [need] arises”.
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