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

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

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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.

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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

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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

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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

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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”.

Modification to the Spatial Strategy Approach

2.13 The Response suggests that the Spatial Strategy Approach needs to be written more clearly to incorporate the substance of other paragraphs in Section 5 and to extend the locations for the Review. A modification is suggested as follows:

13 Spatial Strategy Approach, p30 14 ditto 15 PSLP para 5.5.3

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This Plan seeks to:

 Build on our existing and emerging economic strengths in key sectors and deliver a minimum of 24,000 new jobs.

 The Local Plan will deliver around 43,85016 39,350 new homes (this includes 23,845 homes that are already planned for or built) through new villages, moderate extensions to existing towns and villages in line with the provision of new infrastructure and to meet identified housing need

o close to key transport corridors (East-West, A1/East Coast Mainline and M1/Thameslink)

o in the South of the District including the unmet housing needs of Luton

 Balance the delivery of significant sustainable infrastructure and growth with the enhancement and protection of existing communities, landscape, heritage and countryside and actively prevent the coalescence of settlements across the area through the identification of Important Countryside Gaps.

 Maximise potential opportunities for the intensification and redevelopment e.g. RAF Henlow and the regeneration of urban areas (Biggleswade, Dunstable, Houghton Regis, Flitwick, Leighton Linslade & Sandy) through town centre frameworks or masterplans.

 Ensure that growth is designed and delivered in ways which benefit existing neighbouring communities, for example through improved transport facilities or regeneration of local commercial facilities;

 A Review will identify the new levels of growth required for the Cambridge-Milton Keynes-Oxford Corridor and deliver spatial options and strategic opportunities that could provide for longer term economic and housing growth in the District across the corridor including through a Partial Plan Review. Much of this growth will support, and must be supported by, new strategic infrastructure particularly the Oxford – Cambridge Expressway, A1 improvements and new rail stations/transport interchanges along the East West Rail route. The Review will consider the further growth required to accommodate the Government’s methodology for calculating housing need in the South of the District.

16 see Response Section 4

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Comment on Strategic Infrastructure

2.14 The emphasis for the growth areas is heavily focussed and reliant on the transport infrastructure: new road and rail links associated with the CMKOx and the A1 corridors. The National Infrastructure Commission has identified the Oxford Cambridge Arc as key to the country’s growth ambitions. Bedford Borough Council have identified the “Golden Triangle” (Response Appendix 7) for growth. This diagram provides an important context for joint working between the Councils and underlines the importance of the South of the District in that respect.

2.15 The following paragraphs seek to provide input into the Review process, but also include objections and proposed modifications where relevant to the current PSLP.

Oxford-Cambridge Expressway

2.16 It is noted that Figure 2.1 (page 9) of the stage 1C-1D modelling report17, the indicative line shown for the Oxford-Cambridge Expressway is aligned to the south of Milton Keynes (Option A), and this is considered to be the favoured option. This alignment will further enhance accessibility to the South West of the District.

2.17 Objection and Modification: the Key Diagram should show the area of the CMKOx Corridor. It already extends transportation routes extending well outside the District, but should also show the preferred route for the Oxford-Cambridge Expressway to the West which heads south-west to the south of MK and not due west as shown on the Key Diagram.

East-West Rail

2.18 The proposals for Sandy Railway Station are part of the proposals for the central section of the scheme. It is acknowledged that the central section will be the most difficult section. The Network Rail July 2017 document18 states that “Work is now continuing to

17 CBC Transport Evidence Base (strategic transport modelling reports 1C-1D and 2A) 18 NR Central Section Overview July 2017

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identify a more detailed route within this chosen corridor, and following this work, there will be a full public consultation on the proposals.”

A1 corridor

2.19 Under paragraph 2.14 of the 1C-1D report Table 2.2, in terms of the transport infrastructure assumptions, lists the A1 East of England improvements as being substantial upgrades to dual 3 lane carriageways and, along with the East West Rail section, as being delivered circa 2035. In terms of other schemes deemed necessary to tackle the increased traffic and address the mitigation along the A1 corridor, it is interesting to note what is shown in Table 3.2 of the Stage 2A report: three sections of the A1 near Sandy are all shown as being of significant impact with scores of 10/10 and two other sections as 7/10. By any measure the existing A1 corridor is already at breaking point.

2.20 Highways England Route Management Strategy – London to Leeds East (March 2017) examines the A1 and A1(M) and under Section 3 highlights the concerns and constraints about existing highway safety and congestion, and also draws attention to Figure 3.1 to flooding issues and the key challenges shown alongside Figures 3.3. There is other comment regarding the poor alignment and the current limitations posed by the At- Grade junctions. The A1 East of England study is ongoing and again will report back in 2019 with an indication of what can possibly be provided in the next road investment programme (2020-2025). The anticipated requirement for upgrading the roads to 3 lanes will inevitably be costly and disruptive.

2.21 PSLP (paragraph 6.3.3) emphasises that investment in the A1 corridor is “absolutely critical” to enable significant strategic growth as proposed at Tempsford and East of Biggleswade.

Comment on Scale of Growth

2.22 Clearly the spatial strategy would change if, even before the Review, the housing numbers were higher. That is investigated in Section 4 of this Representation.

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2.23 Of greater impact will be the much higher housing numbers brought about by full consideration of the Government’s policy for the Cambridge-Milton Keynes-Oxford: “The Commission’s central finding is that rates of house building will need to double if the arc is to achieve its economic potential.”19

2.24 In addition, the emerging CLG methodology for calculating housing numbers for Local Plans shows that for the District alone the annual housing provision would increase by 60% (1,600 to 2,553 p.a,) and Luton’s number also increases by 60% (890 to 1,417).

2.25 The proposed modification to the ‘Spatial Strategy Approach’ is set out at 2.13 above.

2.26 Until this scale of increase is absorbed and considered, a focus on, and continuation of, the Strategy in the current PSLP (“potential of strategic sites on the East West Rail/Expressway and the A1/East Coast Main Line Corridor”20) is premature. The Review must re-assess the Spatial Strategy afresh and include other strategic sites to the South of the district.

2.27 Without prejudice to that view, comment is made on the suitability and deliverability of the strategic sites in Section 5 below.

2.28 Whilst ‘identified sites’ have been included in the PSLP, these sites cannot form part of the PSLP and be adequately considered at the Examination given that there is no robust evidence base for their inclusion. To include those sites in the PSLP would fail the ‘Justified’ test of soundness.

Duty to Cooperate

Bedford BC - the Cambridge-MK-Oxford Corridor

2.29 The District is within the Cambridge-Milton Keynes-Oxford Growth Corridor. This is recognised in the PSLP:

19 Partnering For Prosperity: A new deal for the Cambridge-Milton Keynes-Oxford Arc. NIC November 2017. Executive Summary p7 20 PSLP para 5.5.3

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1.2.6 Central Bedfordshire is already one of the most highly connected areas but due to its unique location in the centre of the Oxford-Cambridge Corridor, there are a number of key opportunities that this plan is positioned to take full advantage of; including the proposed East West Rail Link (EWR), the Cambridge - Milton Keynes - Oxford Arc and associated high tech employment led growth.

1.2.7 In order to exploit the wider opportunities in the Corridor highlighted in the National Infrastructure Commission Report, the Council is actively leading and driving forward a co-ordinated approach to enhanced growth within the central area of the Corridor and is leading on the identification of a high-level, joint, spatial strategy for the delivery of comprehensive economic-led growth across the corridor through the local planning process.

2.30 The Corridor concept is obviously a matter for sharing with other LPAs. CBC shares its part of the Corridor with Bedford BC and both Authorities are preparing Local Plans with similar timetables:

Table GPL1

Authority Stage next stages Bedford BC 2015 - 35 April 17 Consultation Paper New Settlements Development Strategy/Site Selection

January 2018 Draft Plan for Submission June/July 18 Examination? Dec 18 Adoption? Central Beds 2015 - 35 June 17 Draft Plan

January 2018 Pre-Submission Plan. June/July 18 Examination? Dec 18 Adoption?

2.31 There is no indication in either Local Plan that the collaboration required has yet begun. AWEL has already made representations to Bedford BC on the Consultation Paper, and similar comments apply to this Response to CBC. There is no mention in the Bedford Pre Submission Local Plan (January 2018) of a Review.

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2.32 Clearly, closer examination of the individual Plans may be premature until both Authorities have begun to grapple with the challenge to be jointly addressed (and with others). The submission to Bedford BC has already noted the very small contribution being made in its LP to the CMKOx Corridor (some 1,000 homes at Stewartby). This Response to CBC also makes the point that the proposed housing allocations in the northern part of the District are inadequate.

2.33 These numbers are clearly well below what is likely to be required as the CMKOx Corridor concept moves forward. Surprisingly, there are no allocations in the critical Corridor Area south of Bedford.

Luton BC

2.34 The Luton BC Local Plan was adopted in November 2017, it has a plan period up to 2031, four years less than the CBC Plan. Policy LLP40 of the adopted plan states that that Luton BC will commence preparation of a Review of the Local Plan in 2019

2.35 Whilst the CBC Plan agrees to make provision for 7,350 homes as a contribution to Luton’s unmet needs, clearly that figure would increase if Luton’s Plan were to extend to 2035, and incorporate a Review.

2.36 The submission of this Response is that the Duty to Co-operate may be satisfied for this interim stage of plan making, but that a Review will require extensive collaboration with Bedford and Luton Authorities, yet there is no specific reference to this aspect of the DtC. This is a serious omission. Bringing forward the submission date substantially (see Section 3 below) may also have prevented the proper consideration of the Duty to Co- operate to have been worked through, especially that with the adjoining District of Bedford where joint working on the growth needs of the CMKOx Corridor needed a much more integrated approach.

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3.0 THE REVIEW PROCESS

3.1 The Review will be informed by “a further assessment of the Identified Areas for Future Growth”21 with 3 scenarios for growth

 Base - the site allocations in the PSLP

 Medium - if some but not all of the strategic infrastructure is delivered e.g. East- West Rail Bedford to Cambridge delayed to after 2030, or no major upgrade to the A1 is committed

 High - if strategic infrastructure delivered by 2025-2030 e.g. firm commitment for a new station at Sandy to interchange with East-West rail Bedford to Cambridge.

3.2 The Partial Plan Review22 intends to address further growth in two areas, and this process is addressed in Section 2 above:

 the Cambridge-Milton Keynes-Oxford Corridor (CMKOx), when there is clarity on the provision of new infrastructure

 the A1/East Coast Main Line Corridor, in line with emerging decisions on strategic infrastructure

3.3 The PSLP at Appendix 7 maps four ‘identified locations for further growth’ which are described elsewhere in the Plan, this Response critically examines these sites in Section 5 below:

 East of Biggleswade, 5,000 homes (6.3.7)

 Land around Tempsford, 10,000 (6.3.6)

 West of Luton, 2,000 (6.2.8)

21 PSLP para 5.5.3 22 PSLP para 5.5 onwards p31

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 Aspley Guise, 3,000 (6.4.9)

3.4 Work for the Review is to commence within 6 months of LP adoption, and complete when decisions on routeing of and funding for strategic infrastructure is committed. As already mentioned in Section 2 above, new Regulations make it mandatory to complete a Review within five years of Adoption of the original and it is therefore unlikely that some of the key infrastructure decisions will have been made by that time.

Comment and Objection

3.5 The PSLP cannot be sound by identifying for the Review to include ‘Identified Areas for Future Growth/Development23’ because “Essentially there is currently insufficient technical evidence and/or supporting infrastructure to support allocation”24 and “This land is not allocated for development at the present time, but subject to further assessment could fulfil its purpose of meeting possible longer-term development needs.”25 By the document’s own admission, there is an insufficient evidence base for inclusion of those sites such that the NPPF ‘justified’ test of soundness would be failed. Either they are fully justified sites which can be debated at the Examination, or they are not. Their lack of any status must be made very clear in the PSLP which should acknowledge that other sites should be considered as part of the Review or included as Identified Areas for Future Growth/Development as part of this process.

3.6 Constraining the Review to areas of growth near to the CMKOx and A1 corridors which are not mapped or accurately defined in the PSLP, and limiting the sites to be considered to the 4 ‘identified sites’ would be a mistake.

3.7 Until the Review has recalculated the scale of growth required it is impossible to limit its site requirements. The Review will have to address what extra housing is required by the new CLG methodology and the Government’s requirements for the CMKOx Corridor. Section 4 below illustrates that the amount of housing even for the PSLP is 4,500 homes

23 PSLP para 7.9.6 24 PSLP para 7.9.2 25 PSLP para 7.9.4

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short. The new CLG methodology will be clarified in a draft new NPPF (by 30.3.18) and a final version by Summer 2018. The September 2017 draft CLG methodology would require a further 27,000 homes to be accommodated as part of the Review. In addition, the NIC proposals for the CMKOx Corridor (November 2017) are that housing delivery should ‘double’, this is being considered by Government, with no date yet set for publication of a definitive policy or framework. It must be the case that the Corridor’s needs are additional to the CLG increase based on a methodology which is for ‘normal’ national application. Both these matters are likely to be confirmed in time for absorption in the Review. Only then will the scale of sites need be clear.

3.8 Also, ignoring the Southern part of the CBC area (except for another modest extension to Luton), would be a mistake. This is an area of high housing demand and parts of the area, especially near to Leighton Linslade, are within the Corridor, and have good connectivity with to London and Milton Keynes. Nor is the Green Belt an absolute constraint, if exceptional circumstances can be demonstrated - such as significant housing demand - then land can, and should, be released from the Green Belt. There needs to be a qualitative assessment of the value of the Green Belt and an acknowledgement that damaged landscapes, for example through quarrying activity, are often better sites to come forward than non-Green Belt sites with higher adverse impacts on AONB’s and other heritage assets. CBC (and many other Local Planning Authorities across the country) has already shown that Green Belt land can and should be released.

3.9 Given the very different circumstances relating to housing need as set out above, and given that the ‘Growth Area Studies’ (South and North) were carried out in Autumn 2017, and the PSLP made its choices in January 2018, the PSLP cannot rely on previous assessments (especially as some - see Section 6 - are factually incorrect). It must cast its net wider to consider potential locations for growth.

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3.10 It is right that the PSLP should include provision for a Review, and states that it will commence “within 6 months of adoption of this plan”26but it should also set out its likely adoption date. By Regulation and through the PPG must be within five years of the PSLP’s Adoption.

3.11 The PSLP should also make clear the reason for the Review which is to absorb and address the much higher levels of growth required as a result of the Government’s proposals for the CMKOx Corridor plus the new methodology for calculating housing numbers for local plans.

3.12 CBC has explained why it has brought forward the Submission27:

This consultation which included the new methodology was then subsequently published on 14th September 2017. The housing need figure for Central Bedfordshire that was generated by this standard approach was 2553 homes per annum. This represented a substantial 60% increase on our current OAN of 1600 homes per annum and was far in excess of the average increase of 35% across local authority areas nationally. It is proposed that this new methodology applies after 31st March 2018 or when the revised National Planning Policy Framework (NPPF) is published; whichever is later.

Therefore in adopting this accelerated timetable, the lower end of the range set out in the first consultation draft has been planned for. The overall plan target is 39,350 homes; this is comprised of the OAN (32,000 homes) and Luton’s residual ‘unmet need’ (7350 homes). This gives rise to the need to plan for up to 20,000 new homes at a range of scales in addition to delivering the growth that is already committed.

3.13 By bringing the submission date forward (it was to have been Autumn 2018), to seek to avoid higher housing number requirements, the PSLP has merely postponed the substantial increase required, and put off the time when it must address the growth requirements of the CMKOx Corridor and CLG methodology.

Proposed Modification

3.14 The PSLP should make the reason for the Review clear by changing the heading at paragraph 1.4 to “Plan Review” (‘partial’ is misleading when the scale of growth could

26 PSLP para 1.5.2 27 CBC Report to the Executive, 9.1.18

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exceed the original by over 60%), deleting ‘Partial Plan Review’ at para 1.5 and continuing the paragraph numbering under the one heading. There are two reasons for the Review, not one.

3.15 The Review has a significant task to firstly calculate the scale of growth as a result of new housing numbers required by the final CLG methodology and those required for the CMKOx corridor. Only then will the Review be able to determine its ‘spatial strategy’ and the number and extent of new sites required. The PSLP is unable to forecast that at this stage so any assumptions about a future spatial strategy and the sites required is premature.

3.16 There are two options open to the Inspector

Option 1: to delete Appendix 7 and any reference to a spatial strategy and ‘identified sites’ for the Review, which will require modifications as follows

Spatial Strategy Approach, point 5:

Identify and deliver spatial options and strategic opportunities that could provide for longer term economic and housing growth for the District, across the corridor including through a Partial Plan Review. This growth will support, and must be supported by, new strategic infrastructure particularly the Oxford – Cambridge Expressway, A1 improvements and new rail stations/transport interchanges along the East West Rail route.

para 5.5.2

Until the scale of additional growth for the CMKOx corridor is known, and the scale of housing growth for the District as a whole as a result of the new CLG housing calculations being determined, it is not possible to identify the ‘spatial strategy’ and identification of sites that will be needed in the Review. The Council has already undertaken a number of studies to help prepare for possible future growth which would realise some of the potential outlined by the National Infrastructure Commission. Much depends on the provision of future infrastructure e.g. but not limited to, the Cambridge-Oxford Expressway and East-West Rail. This Plan therefore identifies no spatial strategy or sites for the Review. firm commitment to some strategic locations where there is a strong existing infrastructure base, such as Marston Vale, to a level of growth which can be supported by that together with firmly committed or achievable additional infrastructure. However in other cases, such as the East West Rail new line to

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Cambridge, further decisions on routeing, timing and commitment, as well as wider investment and delivery support are required before firm allocations can be made.

Para 5.5.3 - delete

Paras 6.2.8, 6.3.6, 6.3.7, Appendix 7 - delete

Option 2: Remove any status or preference for a spatial strategy or sites in the Review

Paragraphs 5.5.3, 7.9.3 and 7.9.4 should be amended as follows:

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7.9.3 The identified land areas respond to proposals for future strategic infrastructure delivery; namely the realignment of the A1 or significant improvements through Central Bedfordshire, East West Rail, the Expressway and the expansion of Luton Airport. In each case these are either expected to enable development or in other cases they may mean that development is not feasible in a location due to the sterilisation of the land by the route of the infrastructure. Whilst all locations however are based on some initial technical assessment and may have potential for future development, they are not proposals of this Plan, will not acquire any status from being illustrated, and are unable to be examined, this being a matter for the Review. Moreover, there will be other areas of the District and other sites for consideration in the Review, which may have been passed over in a wholly different context or may have been wrongly assessed. All of these sites, and the ‘identified’ sites in the PSLP, will need to be assessed afresh and on an equal basis in order that the Review can meet the new requirements for growth.

7.9.4 This land is not allocated for development at the present time, but subject to further assessment, which will be a matter for the Review, along with other sites for the could fulfil its purpose of meeting possible longer-term development needs. Development which would prejudice later comprehensive development will be discouraged, though temporary developments which may assist in ensuring that the land is properly looked after may be acceptable. In addition valuable landscape and wildlife features and existing access for recreation should be protected and enhanced as appropriate.

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4.0 THE SCALE OF GROWTH AND HOUSING REQUIREMENTS

Overview

4.1 The housing numbers in a Local Plan are not only important in their own right, but also act as a proxy for the scale of development growth generally over the plan period - which is the 20 years between 2015-203528. The PSLP provided the basis for the following calculation29:

Table GPL2

a) CBC Housing Need30 32,000 b) Unmet Need from Luton 7,350 Total 39,350 Commitments 23,845 New Allocations required 15,505 Supply Small and medium allocations 5,505 Strategic sites 9,900 Windfall allowance 2,520 Total (a margin of 16%) 17,925 ‘Surplus’ 2,420

The SHMA Calculations

4.2 The starting point in the PSLP are the figures for CBC (32,000) and the unmet need from Luton (7,350). Both are derived from the SHMA31. Luton’s total unmet need was 9,30032, so CBC is absorbing 79% of that but there remains a shortfall.

4.3 The calculations as set out in the January 2018 (or December 2017 ORS document) are shown as follows:

28 Policy SP1 p38 29 PSLP Table 6.1 p39, Table 6.2 p40 and Table 6.3 p41 30 SHMA Jan 18 31 Initial Strategic Housing Market Assessment for Luton and Central Bedfordshire July 2017 Central Bedfordshire Council 32 Luton Local Plan (2011-31), Adopted Nov 17 para 6.9

22 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

23 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

4.4 The following Table illustrates the difference between the CLG/ONS 2016 projections33 and the SHMA. For CBC the SHMA’s housing figure for CBC (31,778) is rounded up to 32,000 homes in PSLP Table 6.1 p39, so is used in the summary Table below:

Table GPL3

2015 - 2035 CBC p.a. LBC p.a. total CLG Table 406 households 34,587 22,948 homes (+4.3%)34 36,074 1,804 23,935 1,197 60,009

SHMA (Jan 18) Fig 92 homes 32,000 1,600 18,810 941 50,810

difference - 4,074 - 5,125 - 9,199

4.5 The reasons provided in the SHMA for ‘adjustments’ to the CLG projections are given as follows

 replace the 5-year migration period with the 10-year migration figure (para 3.43)  “factors affecting local demography” through developing independent household and population projections (para 5.24)  affordable housing need (para 4.28)  employment trends (para 5.32)  market signals (para 5.43)  housing backlog (para 5.80)

4.6 SHMA Fig 92 shows that “local demographic factors and long-term migration trends” are the main reasons for adjustments and these result in a 20% reduction to the CLG household projections. This Response suggests that to challenge CLG’s use of migration patterns and its demographic projections is a fundamental and universal challenge which would render the CLG figures rather worthless. It is to be expected that the CLG

33 Household projections, Communities and Local Government/Office of National Statistics July 2016 Table 406, also summarised in the SHMA Fig 92 p111 34 SHMA Jan 18 para 5.15

24 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

projections should be given additional support because of their independence and transparency.

4.7 The Local Plan Experts Group35 stated

3.21 Characteristics of the revised approach are the use of a single standard methodology to arrive at an estimate of Full Objectively Assessed Housing Need (FOAHN) which:

i. identifies a common set of data sources to be used;

ii. has clarity on the circumstances in which any adjustment should be made to CLG household projections (in terms of household formation rates and migration) and a standard methodology to apply where such adjustments are necessary to reflect local circumstances;

4.8 The Housing White Paper (HWP) included36 :

“The current approach to identifying housing requirements is particularly complex and lacks transparency. The National Planning Policy Framework (NPPF) sets out clear criteria but is silent on how this should be done. The lack of a standard methodology for doing this makes the process opaque for local people and may mean that the number of homes needed is not fully recognised. It has also led to lengthy debate during local plan examinations about the validity of the particular methodology used, causing unnecessary delay and wasting taxpayers’ money. …”

4.9 In September 2017 CLG published “Planning for the right homes in the right places: consultation proposals” (PFH) refers to the HWP as its starting point. This Response recognises that it is a consultation, and the new methodology will fully apply when incorporated in a revised NPPF planned for Spring/Summer 2018. However, PFH recognises that Local Plans ‘submitted’ before 31.3.18 “will continue with the current plan preparation”37 i.e. the new calculation methodology may not apply this time around, but will do to the Review.

35 Local Plans Expert Group: LOCAL PLANS Report to the Communities Secretary and to the Minister of Housing and Planning (March 2016) 36 ‘Fixing our broken housing market’, February 2017, para 1.12 37 Table 1 p20, Planning for the right homes in the right places: consultation proposals, DCLG, Sept 2017

25 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

4.10 The PFH document identifies the problems of the existing ‘system’ for arriving at the OAN (emphasis added in bold):

12. The lack of a simple, standard approach to assessing local housing need has led to a costly and time-consuming process which lacks transparency:  many local planning authorities spend significant sums of taxpayers’ money employing consultants to come up with a housing need figure, often using different and inconsistent methods. It can cost local planning authorities around £50,000 to prepare a strategic housing market assessment, which could equate to an overall cost to the sector of over £3 million per year;  local planning authorities, developers and local communities often engage in disputes on the method used, which delays the process (by around six months) and adds cost; and  few methods take significant account of the affordability of housing in their area. 13. The Government argued in the housing White Paper that a standard approach to assessing local housing need would be simpler, quicker, and more transparent. This would speed up the time taken to prepare Local Plans and give local communities greater control of development in their area. We consider that a standard method should be based on three key principles: a) Simple – there should be an easy and transparent process for local people and other interests to understand; b) Based on publicly available data – which might include national data such as that from the Office for National Statistics, or robust local data; c) Realistic – to reflect the actual need for homes in each area, taking into account the affordability of homes locally. High house prices indicate a relative imbalance between the supply and demand for new homes, and makes housing less affordable. The affordability of new homes is the best evidence that supply is not keeping up with demand.

4.11 These problems are displayed in the ORS SHMA which is not ‘an easy and transparent process for local people and other interests to understand’ and will result in ‘disputes on the method used’.

26 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Planning for Homes (PFH), CLG September 2017

4.12 The PFH consultation paper also proposes a standardised methodology for calculating housing need. It takes the ONS household projections, adds an uplift and produces a housing target. A new NPPF will incorporate the methodology and is to be consulted ‘before Easter’ 2018 (i.e. by 30.3.18) and publish the final document ‘in the summer’38.

4.13 The PFH consultation included a table illustration what the new methodology would mean for individual LPAs, an extract is as follows showing the housing number p.a.:

Table GPL 4

LPA CLG Local Plan addition over 20 yrs Central Beds 2,553 1,600 19,060 Luton 1,417 890 10,540 Bedford 1,281 950 6,620 Total 36,220

This Representation’s Adjustments

4.14 If the simple ONS household projection number 34,587, converted to dwellings - 36,074, were to be used then the PSLP would be planning for an additional 4,074 homes in the plan period, although the surplus of allocations (2,420) reduces that to a need for an extra 1,654.

4.15 The Luton number is derived from a share of Luton’s housing need less its available capacity within its boundary, as described in its Adopted Local Plan. This Response does not challenge those figures except to note that, importantly, the Luton plan period is 4 years less than the 2035 end date for the CBC Plan. Further Luton need must therefore be expected for the period 2031 to 2035, yet the agreed figure for Luton’s capacity must be regarded as finite. The Luton Plan para 6.6 shows that this capacity is 8,500 homes within Luton’s borders. This is a considerable increase on the original figure of 6,700 and

38 MHCLG Chief Planner letter to LPAs 30.1.18

27 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

whilst described as ‘not a ceiling’39 it must be assumed (with pressure from CBC and other surrounding Districts) that the capacity exercise has examined and added all possible sites that are likely to become available for development.

4.16 Luton’s net extra housing need (additional to commitments) in its plan period up to 2031 is 17,80040 or 890 p.a. It has capacity for 8,500 extra homes within its borders, a total unmet need of 9,300 homes (up to 2031) of which 7,350 (79%) have been met in CBC. However, a further 4 years must be added to gauge the effect of Luton’s unmet need onto adjoining Districts, which totals 3,560 homes (4x890). This is based on the Luton LP and SHMA’s number rather than the ONS household projection number for Luton which is 35% higher. The previous Luton total unmet need was shared between surrounding Districts with CBC taking 79%, so an extension of Luton’s unmet need to 2035 equates to an additional 2,812 homes to be accommodated in CBC.

4.17 In total, therefore, the additional housing that should be accommodated in the PSLP (based on CLG/ONS figures) and the calculated increase required for Luton revises the extra homes allocation as follows:

Table GPL5

revised original a) CBC Housing Need 36,074 32,000 b) Unmet Need from Luton 10,162 7,350 Total 46,236 39,350 Commitments 23,845 23,845 New allocations required 22,391 15,505 Supply from allocated sites 17,925 17,925 ‘Surplus +’ or ‘shortfall -’ -4,466 +2,420

4.18 Thus, for adjustments to be based on the simple and transparent ONS figures, as recommended by the Planning Experts Group and proposed in the CLG Planning for Housing paper, and the addition of Luton number to match the plan period, results in a

39 Luton Local Plan MM12 LP2 40 Luton Adopted Local Plan para 6.1

28 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

need for extra allocations of some 4,500 homes. Even then the margin justified in the PSLP, 2,420 or 16%, is not catered for so 4,500 is an absolute minimum addition.

4.19 This does not factor in any increases required as a result of applying the draft CLG

figures. If those figures become the final version in the new NPPF (likely to be published

in draft in March 2018) then the housing target for CBC would increase by some 19,000

for the District plus an extra of some 8,000 for the CBC share of Luton’s unmet need, a

total of 27,000 extra homes. The impact of the growth needed for the CMKOx Corridor

would be even higher: housing numbers in the Corridor should “double”41.

4.20 These much higher numbers, which are likely to be finalised later in 2018, provide further evidence that the PSLP/ORS figures are way too low.

4.21 This Response therefore objects to the PSLP Policy SP1 housing number of 39,350 homes and proposes a Modification that it be increased at least to an interim 46,250, noting that it will need to be very much higher when the new NPPF Government proposals for the CMKOx Corridor are published .

Delivery and housing land supply

4.22 The PSLP emphasises the importance of maintaining a 5-year supply of housing at para 7.2.3.

4.23 Prior to adoption by CBC of the PSLP, the CBC position was set out in “Five Year Land Supply Statement for the five year period commencing 1 October 2017”. At that time the annual housing delivery target was 1,600 homes p.a., based on the ORS SHMA, which then provided a housing land supply figure of 5.94 years (including an uplift of only 5%). Some pre-PSLP 2017 appeal decisions may have recognised that position.

41 NIC Partnering for Prosperity Nov 17 p3

29 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

4.24 The position on the 5-year housing land supply must be updated by the publication of the PSLP which now requires a revision to that those figures. Whilst the PSLP has not yet been exposed to the scrutiny of the Examination, neither has the ORS SHMA. The PSLP post-dates the SHMA in terms of what level of housing CBC are seeking to now plan for, including the accommodation of 7,350 homes of unmet need from Luton which is endorsed in the PSLP at paras 7.2.3 and 7.2.4 (as well as the figure in the Adopted Luton Local Plan (adopted 7.11.17):

7.2.3 In order to demonstrate a five year supply of housing, significant and demonstrable site specific evidence must be produced. This council regularly contacts housebuilders to determine when their sites will be delivered and this information is added to the Housing Trajectory on a quarterly basis. 7.2.4 In addition to meeting Central Bedfordshire’s housing need, the plan target also includes provision for 7350 homes to meet Luton’s identified ‘unmet need’ as outlined in paragraph 6.2.1.

4.25 To continue to rely on the 1,600 homes p.a. target for housing delivery until the LP is adopted would mean too low a housing target some 4 years into the plan period. That would not encourage the substantial increase in housing delivery signalled in the NPPF para 47 (“boost significantly the supply of housing”), nor in the terms of the Prime Minister’s introduction to the Housing White Paper: “We need to build many more houses, of the type people want to live in, in the places they want to live. To do so requires a comprehensive approach that tackles failure at every point in the system.”

4.26 The Spatial Strategy (p30) and Policy SP1 (p38) state that the Plan will deliver 39,350 homes in the plan period, which equates to 1,968 homes p.a. In the October 2017 paper it was stated that 4,335 homes had been completed in the first 2.5 years of the plan period between 1.4.15 and 30.9.17. The target for that period is now 4,920 homes (1,968 x 2.5) so that completion of only 4,335 homes represents ‘persistent under- delivery’ such that NPPF para 47 pt2 requires that a 20% uplift should be applied.

4.27 The housing land supply position, based on the format of the October 2017 paper, is that currently the 5-year housing supply cannot be met, the figure it equates to is just 4.1 years.

30 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Table GPL6

39,350 - 4,335 35,015 35,015/17.5 years 2,000 2,000 x 5 10,000 10,000 x 1.20% 12,000 5-year trajectory 1.10.17 9,862 % 82 years 4.1

Proposed Modification

4.28 Paragraph 7.2.4 acknowledges that Luton’s unmet need is included in the total housing delivery number in Polcy SP1. The intention is that over 20 years the Plan will deliver 39,350 homes which equates to 1,698 p.a.

4.29 Paragraph 7.2.4 should be amended as follows:

In addition to meeting Central Bedfordshire’s housing need, the plan target also includes provision for 7,350 homes to meet Luton’s identified ‘unmet need’ as outlined in paragraph 6.2.1. Policy SP1 states that the Plan will deliver 39,350 homes over the period 2015 to 2035, which is an average of 1,968 homes p.a. This is the annual figure to be used to calculate the 5-year housing land supply for the District.

31 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

5.0 THE ALLOCATED AND IDENTIFIED SITES

5.1 Having calculated the scale of growth required and the broad spatial strategy, both matters which are disputed in this Representation, the PSLP identifies two broad types of site:

 “allocated sites” - with 4 ‘strategic’ housing sites (listed in SP1) and 52 small and medium sites (identified in Appendix 6) providing housing capacities which, together with commitments etc., make up the required number of homes identified in Policy SP1

 “identified sites” - (shown in Appendix 7) which are not ‘allocations’, do not contribute to the PSLP’s housing targets and are not supported by adequate evidence42

Allocated Sites

Strategic Sites

5.2 This Section of the Response assesses the 4 ‘strategic sites’. It responds only to sites allocated for residential development.

Policy SA1: North of Luton

5.3 This allocation is for up to 4,000 homes and 20 ha of employment land. The Table at 7.1.2 shows that completions will begin in 2022/23 with 3,100 homes being delivered in the plan period.

5.4 Policy SA1 identifies constraints:

 Green Belt and Chilterns AONB

 pre-provision of a link road from the A6 to M1 junction 11a

42 PSLP para 7.92

32 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

 SSSIs at Sundon Quarry, Galley and Warden Hills, Barton Hills Nature Reserve and SSSI

5.5 This Representation does not object to the North of Luton Site, and recognises that no site is ‘constraint free’, but notes that the site

 represents ‘urban sprawl’ which is contrary to principle 1 of the Green Belt43

 includes and is adjacent to the Chilterns AONB

 requires substantial public and contributory funding (and possible land outside the site) to provide the A6 - M1 link road

 requires mitigation for, or loss of, three SSSIs

 is a true ‘green field’ site

5.6 Delivery is planned to commence 3 years after adoption of the LP which may be ambitious, and unlikely to make either any or, at best, a very small contribution to the immediate 5-year housing supply.

Policy SA2: Marston Vale New Villages

5.7 The proposals map at p63 shows a large area, yet the actual proposal in the Policy is for “two well-designed and sustainable distinct villages separated from existing settlements”. The total capacity is given as 5,000 homes but only 3,700 homes44 will be delivered in the plan period, commencing in 2021/22.

5.8 This Representation objects to Policy SA2. It is the wrong strategy for the CMKOx corridor which calls for a bolder approach. The caveats around creation of ‘two distinct villages’ make the allocation of a large site vague, clarity is required on infrastructure and this is compounded by several important constraints:

43 NPPF para 80 44 PSLP para 7.1.2

33 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

 designated heritage assets

 areas of flood risk

 required improvements to M1 J13 and the Marsh Leys roundabout

 the provision of East-West Rail at Ridgemount Rail Station

 adequate sewage treatment capacity

 a true ‘green field’ site

5.9 A Proposed Modification is that firstly the Plan on p53 should be amended to be more specific on the area of the two villages. Secondly, the third paragraph of the Policy should be followed by:

This is a modest allocation which needs to be followed in the Review, when the CMKOx Corridor strategy and housing numbers are clarified, by the allocation of a significant new settlement in the shared CBC/Bedford area of the Corridor.

Policy SA3: East of Arlesey

5.10 This is a development of 2,000 homes of which 1,600 will be delivered within the plan period, and development is not planned to commence until 2023/24 or 5 years after the LP’s adoption.45

5.11 This representation does not object to Policy SA3 but notes the following constraints:

 the development could result in the coalescence of Arlesey and Fairfield, which would be contrary to Policy SP5; creation of what would be a narrow country park between Fairfield and the development is unlikely to avoid this

 identified protected species and priority habitats

45 PSLP para 7.1.2

34 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

 designated and non-designated heritage assets

 risk of flooding from Pix Brook and River Hiz

 need for the provision of a Relief Road

 a true greenfield site

Policy SA4: East of Biggleswade

5.12 This is a smaller development of 1,500 dwellings yet envisaged as a “well designed sustainable village visibly and physically separate from Biggleswade”.

5.13 This representation does not object to Policy SA4, but observes the following:

 separation from Biggleswade may be difficult to achieve given that the allocated sit actually abuts the urban area of Biggleswade

 a true greenfield site

Small and Medium Sites

5.14 It is not feasible to assess proposed allocations of the large number of small or medium sites.

Chamberlains Barn North (HAS32)

5.15 This Representation supports Policy HA1 and Appendix 6 in terms of the allocation of HAS32, because it would be a logical extension to AWEL’s permitted development at Chamberlains Barn, Leighton Linslade.

5.16 Planning applications for Chamberlains Barn North were submitted in December 201746 and there are a few key differences between the draft allocation and the residential planning application, which need to be addressed further. To that extent this

46 CBC refs. CB/17/05971/FULL and CB/17/06062/FULL

35 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Representation objects to the detail Policy HA1 and its table (p82) regarding the entry for site HAS32 which shows an “approximate density of 30 homes per ha., a site area of 16 ha. and an “approximate capacity” of 175 homes, and these details should be amended.

5.17 An Addendum (January 2018) to the Planning Statement sets this matter out as follows:

These differences should be considered in the context of the range of detailed surveys and reports which have been undertaken by the Applicant in preparing the planning application; and the need identified in Policy HA1 to have regard to site specific issues on a site by site basis.

Firstly, the area of the Site differs from that given in Policy HA1 and as shown in Appendix 6. The residential application Site follows a more logical western boundary, running alongside Cotefield Drive, and totals 9.2 ha in area. This corresponds to the area within the application site of permission CB/11/01937/OUT which was not proposed for built development at that time.

Secondly, as set out in the Design and Access Statement which accompanies the applications, the development of the Site for 253 dwellings represents an average density of 35 dwellings per hectare. As a complementary extension to the wider development at Chamberlain’s Barn, already permitted, this density reflects that which has already been permitted in the vicinity and would be an appropriate form of development.

As such, the residential application proposes a total of 253 dwellings which would make a greater contribution to the Council’s housing needs than currently identified in the Pre-Submission Local Plan. As noted in the Planning Statement which accompanies the applications, the development represents an opportunity to increase the delivery of housing in a sustainable location without increasing the amount of Green Belt land that needs to be released.

5.18 Proposed Modification: HAS32 Chamberlains Barn North (p82) - density should be ‘35’, capacity ‘253’.

Identified Sites

5.19 This Section of the Response assesses the 4 ‘identified sites’ so far as it is able, notwithstanding that Section 3 objects to their inclusion in the PSLP, because they

36 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

cannot be examined without adequate supporting evidence, and should acquire no status from being illustrated. The sites are shown in Appendix 7 and referred to in the Section 6 under the 4 area headings. Contrary to para 7.9.1 “no housing numbers have been attributed to them”, each site has a housing number in Section 6.

5.20 This Response objects to each of the 4 sites notwithstanding its view that they have, or should have, no status conferred on them by being identified. Other more appropriate sites have been excluded. Each of the four included sites have severe constraints and are unworthy of inclusion in the Review.

5.21 Unlike the allocated strategic sites, no constraints are set out in the PSLP itself, so these Response comments are taken from the North Growth Options Study or Draft Local Plan.

East of Biggleswade

5.22 This is another site east of Biggleswade (in addition to the allocated site) with a capacity of 5,000 homes. It is the eastern part of Site N17 (although not all areas were studied) in the North CBC Growth Options Study (July 2017).

5.23 The ‘overall deliverability assessment’ was ‘low’, with the following comments:

 Not within 1.2km of existing public transport interchange, and not within 1.0km of existing strategic road. Development of this scale is likely to require significant improvements to existing transport infrastructure, but none are currently planned. Any known critical strategic utilities requirements are significantly funded.

 Location offers poorer access to quality of life attractions (cultural, sports, leisure and/or natural assets), and moderately convenient access to employment and amenities. These factors are reflected in what are moderate average local residential sales values, although there are some pockets of higher value.

5.24 The constraints listed were:

 Historic environment, Conservation Area  Biodiversity, Priority Habitat Inventory  Landscape, Locally identified sensitive landscape  Soil quality, Grade 1, 2 or 3 agricultural land  Flood risk, Flood Zone 2, Flooding from surface water (1 in 100 year)

37 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

 Energy infrastructure, High voltage electricity line 400 m buffer zone

5.25 This large site is entirely reliant on new strategic infrastructure, as set out in Section 2 above under ‘strategic infrastructure’. Currently there is no certainty about this.

5.26 This appears to be a large detached, free-standing site but immediately to the east of allocated site SA4. There are many constraints and the deliverability assessment is ‘low’. It would seem an odd site to even consider suitable as an ‘identified’ site.

North South and East of Tempsford (E of the A1)

5.27 This is a large site which was proposed as part of the ‘growth strategy’ (Policy SP1) in the Draft Local Plan (DLP) 47, described as a ‘New Market Town’.

5.28 Although located to the east of the A1, with its junction with the A421 to the north-west, the site has many constraints listed in the DLP:

 BMV agricultural land  ancient woodland and county wildlife sites  flood risk - large areas with Flood Zones 2 and 3  many designated heritage assets  Tempsford Airfield is a non-designated heritage asset (WW2)  archaeology  coalescence with Sandy to the south  contaminated land

5.29 Whilst southern parts of the site were assessed in the North CBC Growth Options Study, the northern area was not.

5.30 This large new settlement at Tempsford is entirely reliant on new strategic infrastructure, as set out in Section 2 above under ‘strategic infrastructure’. Currently there is no certainty about this. Delivery is also questionable - new settlements of this

47 Draft Local Plan July 2017 pp 88 - 92

38 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

size and the need for substantial funding and infrastructure make any meaningful housing contribution even beyond 2035 unlikely.

West of Luton

5.31 This site was proposed in the Draft Local Plan as an allocated site, but now seems to have been relegated. It is proposed as an ‘identified site’ in PSLP paragraph 6.2.8 with a capacity of 2,000 homes.

5.32 The DLP states that “This [West Luton] Growth Location is located within the setting of the Chilterns AONB. Great weight is given to conserving the landscape and scenic beauty of the Chilterns AONB, as well as its value for conservation of wildlife and cultural heritage.”

5.33 Other identified constraints are:

 Green Belt  many designated heritage assets  archaeological features  coalescence of Luton, Caddington, Slip End, Woodside and Caddington Woods  the existing highway network serving the site is not designed to cope with the volume of traffic that would result from a strategic scale development in this location  located near to the following sources of air and noise pollution: M1; and London Luton Airport  land contamination  Topography: The gradients of the South Dunstable Chalk landscape to the far north of this Growth Location do not lend that area of the Growth Location readily to development and the topography forms a barrier to the creation of new and/or improved accesses/connections to the north (Hatters Way and Busway) and northeast (to Luton). Development in the latter area would require significant engineering interventions to achieve appropriate gradients for surface water drainage, vehicles, pedestrians, disabled users and cyclists as well as to form new or improved accesses/ connections. Such interventions may cause significant environmental impacts as a result and could be financially costly.

39 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

5.34 This does not seem to be a viable or acceptable site, and as it is in the Green Belt ‘exceptional circumstances’ must be demonstrated. It would have to overcome the GB ‘coalescence’ principle, and the impact on the AONB and landscape impact generally. PSLP accepts that some Green Belt release is necessary in order to satisfy housing need in the south of the plan area. This must include sites found to be ‘sound’48 for release and which should be demonstrated to be the most appropriate when compared to reasonable alternatives. This Response suggests that this site does not compare favourably against other sites on damaged land within Green Belt and also within the Luton HMA.

Aspley Guise (North of Railway Line)

5.35 This site is ‘identified’ at PSLP para 6.4.9 with a capacity of 3,000 homes and shown in Appendix 7.

5.36 It was assessed in the North CB Growth Options Study (July 2017) as site N5 ‘M1 J13’. That Study identified the following constraints:

 Biodiversity, Priority Habitat Inventory, locally designated wildlife site,  Landscape, Locally identified sensitive landscape  Soil quality, Grade 1, 2 or 3 agricultural land  Flood risk, Flood Zone 2, Flooding from surface water (1 in 100 year)

5.37 Its long northern boundary with the M1 which must raise concern of noise and other intrusion for a residential area. The villages of Aspley Guise and Woburn Sands to the south are of historic character which could be harmed by this adjacent new development.

5.38 The site is remote from employment, secondary education, services and retailing, and too small to provide this ‘infrastructure’ which is essential for sustainability.

48 NPPF para 182

40 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

5.39 Proposed Modification:

The options for ‘the Review’ objection and modifications are set out in the main objection. As to the actual suitability of the 4 sites, para 7.9.4 should be amended as follows:

This land is not allocated for development at the present time, and each of the sites has constraints which can only be but subject to further assessment to test suitability for could fulfil its purpose of meeting possible longer-term development needs. Development which would prejudice later comprehensive development will be discouraged, though temporary developments which may assist in ensuring that the land is properly looked after may be acceptable. In addition valuable landscape and wildlife features and existing access for recreation should be protected and enhanced as appropriate.

41 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

6.0 OTHER POTENTIAL SITES

Strategic Sites

Introduction

6.1 As part of the preparation for the PSLP, CBC commissioned Growth Option Studies to assess strategic sites in the North and South Area. Although many sites were assessed, the outcome in Policy SP1 was the allocation of the North Luton site in the South and Marston Vale, East of Arlesey and East of Biggleswade in the North. This Response has set out the significant constraints as determined by CBC itself in Section 5 above. Other sites were given varying degrees of acceptability, or indeed rejection, but the Review process will need to examine all sites afresh and on an equal basis. Modifications are required to PSLP paras 5.5.3, 7.9.3 and 7.9.4 as detailed in Section 3.

6.2 The result of needing to accommodate much higher levels of growth in the Review, and across the District, not just in the CMKOx or A1 Corridors, will be to look at other sites and not to limit the Review to further assess just the ‘identified’ sites of the PSLP as drafted.

6.3 Whilst this Response objects to the ‘identification’ of the small number (4) of sites for the Review, and proposes modifications to limit their status, the purpose of this Section of the Response is to add the South Area to the two broad areas in para 7.9.3. (CMKOx and A1 corridors) and to propose additions to the various references to ‘identified sites’ in the text of PSLP Section 6, para 7.9.6 and Appendix 7.

The South Area

6.4 The South Area of the District is an area of high demand for housing, mainly because of the connectivity with employment opportunities at Luton, Milton Keynes and London. Growth in the CMKOx corridor and the northern part of the A1 corridor serves a different purpose and has a different housing market.

6.5

42 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Checkley Wood Garden Village (CWGV)

6.6 This Response proposes that CWGV is included as an ‘identified site’. CWGV is a new separate settlement north of Leighton Linslade and will provide some 4,500 homes – some 2,500 within the Plan period.

6.7 Two other sites are proposed for inclusion in the PSLP ‘small or medium allocated sites’ category - New Trees Quarry and land at Stanbridge Road - also detailed below.

6.8 The Luton Housing Market Area Growth Options Study (GOS) report has ‘July 2017’ on the cover, the final report is dated ‘March 2017’, but pages 5 to 70 are a LUC Study dated December 2016.

6.9 The Luton HMA Growth Options Study (GOS) 49 of July 2017 sought to assess sites which could make a contribution to Luton’s unmet housing needs. The definition of its area of search was contentious. It is shown on Fig 1.1 but was defined in the ‘Housing Market Areas in Bedfordshire and surrounding areas Report of Findings, ORS (December 2015)’ on a small-scale map on p47. Much of the HMA definition relies on travel to work patterns using data from the 2011 Census50 which precluded assessing the impact of the A5/M1 link road. AWEL commissioned a Report by GL Hearn51 which demonstrated that the defined area should extend to Leighton Linslade.

6.10 In any event, the CWGV site was accepted as falling within the Luton HMA and was assessed as site ‘North of Leighton Linslade’ Site L16.

Criticisms of CWGV

6.11 Before outlining the many advantages of CWGV and its qualifications to be added to the ‘identified sites’ to be considered by the Review, it is necessary to critically examine the findings of the GOS, which reveals many misconceptions and fundamental errors of fact.

49 Luton HMA Growth Options Study July 2017 50 ORS HMA Report Dec 15 para 3.2 51 Leighton Linslade and Checkley Wood HMA Report Arnold White Estates Ltd, GL Hearn, February 2016

43 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

6.12 Capacity: the GOS assumed that CWGV has a capacity of 10,710 homes52 whereas the ‘call for sites’ submission (March 2016) put forward a capacity of 4,500 homes of which 2,500 could be delivered by 2035.

6.13 The GOS Table 1 includes a figure of housing capacity (120) within the Luton HMA. That clearly is incorrect.

6.14 Deliverability was assessed in the GOS Table 3.5 as ‘low’. That is clearly wrong. The site is deliverable during the early stages of the Plan period. The site is in single ownership and the table itself has ‘highly likely’ ratings for:

 Is the location likely to be available for development and is there a reasonable prospect of delivery of the site within the time period?  Is there likely to be current demand for this scale of development in this location?  Is there likely to be future potential demand for this scale of development in this location, if planned regeneration / employment / infrastructure projects are delivered?

6.15 ‘Is there a reasonable prospect that required strategic infrastructure can be delivered within the time period?’ gets a ‘less likely’ rating. In fact, as the ‘benefits’ section below illustrates, all necessary infrastructure will be delivered well before 2035 as part of the development, including The Eastern Leighton Linslade Link Road, a new link road between the A5 and A505 (with new junctions) together with on-site technical and social facilities.

6.16 There is no basis whatsoever to describe CWGV as having ‘low’ deliverability compared to the ‘high’ judgements for the two urban extensions. There can be no doubt that CWGV is deliverable and has a ‘willing owner’ - the call-for-sites form confirmed AWEL is the majority owner. CWGV is designed as a new settlement where new services would be provided - something which cannot be likely with the two urban extensions. CWGV does not need new strategic infrastructure whereas Luton North needs a ‘new link road’ or ‘Luton Northern bypass’ - which is not in any road programme and for which only

52 GOS Table 3.4, p29

44 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

£32.75m out of £55m of funding has been identified53. No evidence has been presented to show ‘demand for housing’ would be greater for the two urban extensions than for CWGV.

6.17 Viability is rightly assessed as ‘high’ GOS Table 3.6 p38.

Primary Constraints

6.18 The Green Belt is listed as a primary constraint, yet the document does not list AONB, or proximity to it, which is surely a ‘primary constraint’ but is effectively ignored in the GOS assessment.

6.19 The purposes of the Green Belt are re-stated in the NPPF at para 80. Both the Luton urban extensions are by definition ‘urban sprawl’ into the Green Belt. West Luton would merge Caddington with Luton; Luton North would merge Lower Sundon with Luton. In contrast, CWGV would not fail either of these tests and although in ‘the countryside’ (like both Luton extensions) the countryside in which it sits has little visual or other character, being mainly former mineral workings and despoiled land. Both Luton extensions would be in virgin countryside and within or adjacent to the AONB. However, the LUC scoring system (Tables 1 and 3.3) shows that CWGV scores higher for Green Belt impact than either Luton extension, West Luton being summarised as having ‘relatively strong or moderate’ impact despite failing 2 of the NPPF tests. This is inexplicable.

Public Transport

6.20 Proximity to a public transport hub within 1.2km is failed by Luton North and CWGV, this is incorrect - see advantages below.

Secondary Constraints Analysis

6.21 There is a total of twenty-six topics. Seventeen are constraints and nine involve access to services and facilities. Of the seventeen constraints, there are five in which CWGV has

53 CBC press release 13.3.17

45 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

been reported as having the constraint. The following Table is a summary of the secondary constraints which are alleged to apply to CWGV. This Response clearly demonstrates that CWGV is not affected by these constraints and any suggestion that it is therefore inferior to the identified Luton sites is wholly unjustified and wrong.

Table GPL 7

Geological SSSI There are two within the CWGV site. One is accepted by Natural England to be misidentified or lost but they have not removed the designation. The other one is included in the ROMP which includes and permits quarrying the SSSI site.

On this basis, there is no properly assessed constraint as the constraints will not exist at the time of development activity.

Flood Zone 2 (and 3) The Flood Zone area is entirely within the proposed open space to be provided as part of the CWGV scheme. The proposal will also include surface water management that will help to attenuate both fluvial and surface water flooding – a long held ambition of the Environment Agency

The Flood Zones therefore do not constrain development of the site. On the contrary they will help mitigate existing concerns for flooding downstream.

Mineral Safeguarding Area The proposal is for development of restored sand quarries. Development and mineral extraction will be jointly phased so that extraction precedes development to ensure that no mineral is sterilised.

The Mineral Safeguarding Area is therefore not a constraint but mineral working is an opportunity to reuse damaged land as an integral part of the quarrying process.

Sensitive landscapes The Options Study document indicates (Appendix 1, page 3) the basis for this constraint is 'CBC – landscapes identified as having ‘high’ or ‘high-medium’ sensitivity in a landscape character assessment'. This definition would appear to be referring the superseded version of the CBC Landscape Character Assessment. The current, adopted version does not include any ratings such as 'high' or 'medium-high'. These were deliberately excluded as being too crude. They have been replaced by more open ended descriptive indications.

The CWGV straddles two Character Areas, the Wooded Greensand Ridge (Type 6A) and Clay Hills (Type 8A). Because of its position on the edge of the two areas as well as being within a topographically and visually contained basin, the development would have a limited or negligible effect on locally sensitive landscapes.

The existing Checkley Wood site is not a positive part of the character area and so is not sensitive and cannot be accorded the status as being a constraint

Groundwater Source With regard to the Groundwater Source Protection Zone, development has Protection Zone recently been granted consent within the Zone at Chamberlains Barn, Leighton Linslade. The EA is satisfied that the development does not present an issue in

46 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

that case because the site is a restored quarry and includes clay liners where necessary, with clay readily available on site from quarry overburden.

The Source Protection Zone is therefore not a constraint for CWGV as it has been proven that satisfactory protection measures can be applied during the restoration and development process as seen at Chamberlains Barn and elsewhere in the town.

Soils This is a constraint that is shared by many sites in the assessment e.g both Luton sites are Agricultural Land Classification of Grades 1, 2 or 3. As shown in the document 'The Green Belt in Southern Bedfordshire' October 2016, soil grade is identified as a constraint if any part of the site, however small, includes any of the three grades. The majority of the CWGV site will continue to be quarried to extract the nationally important mineral and that same quarrying process will reduce the importance and classification of soils within the site.

On this basis, CWGV will become unconstrained with regard to soil quality.

6.22 As to the nine services and facilities listed in the review, there is only one that CWGV does not have that the two Luton sites do- NHS primary health care (GPs) and hospital provision within 1.2km. As a new settlement of some 4,500 homes CWGV will include a local neighbourhood centre. Furthermore, it would provide a site for an ‘Integrated Health and Care Hub’54, about which there is currently concern in Leighton Linslade. Accordingly, there is no constraint in relation to health care provision.

Access to Services and Facilities

6.23 There does not appear to be an appendix in the Options Study that explains the basis for this part of the assessment or gives more detailed definitions. For example, there is no definition as to what constitutes a 'major employment area' or why the particular distances have been chosen - such as 0.8km distance from a town centre/out of town shopping centre.

6.24 If a development provides the necessary facilities and services within reasonable walking distance within the development, then it is clearly as sustainable as sites within reasonable walking distance to existing services and facilities. Indeed, some of the

54 PSLP para 7.6, p50

47 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

existing services may already be at or over capacity. In the case of CWGV, one of the core principles of the proposal is to create a new settlement that is sufficiently large to support provision of the key services and facilities in a neighbourhood centre, so it is plainly wrong for the site to be scored against proximity to existing services.

6.25 In the end, the only services/facilities not within the identified distance of CWGV, that would not be provided by the development itself, would be a town centre/retail park, FE college and hospital but these will be readily accessible from the Transport Hub. It should also be recorded that the intention is to provide a Health and Care hub within the site. AWEL is committed to such provision. In Southern Leighton Linslade AWEL, in conjunction with the Authority and Aldwyck Housing, helped to facilitate the provision of an elderly care facility, thus relieving pressure on the NHS.

Other assessment

6.26 CWGV is also assessed as site ALP066 and NLP074 in the Site Assessment Technical Document Appendix D: Preliminary Site Assessment Results (July 2017). The ‘outcome’ is that the site is excluded from the LP process, with the following justification:

Failed at Stage 2 based on an overall consideration using planning balance. The following issues have been identified: The site is not suitable for development, based on comments regarding the impacts the site would have on the visual relationship with surrounding villages and historic estates, the topography is also very rolling and higher views will affect the wider setting of the site. Furthermore the site contains a number of mineral working areas that are essential for ecological benefits to the area; this includes a number of SSSIs. Plus past quarry uses has already damaged important archaeological sites within the site area and further damage is unacceptable.

6.27 This assessment is fundamentally wrong for the following reasons.

 ‘Visual relationship with surrounding villages and historic estates’ This is unexplained and unreferenced. The site has a wind Turbine (some 145m to the tip) and planning consent for a second similarly sized turbine. Both turbine sites were approved and supported by CBC. CWGV would be an independent village detached from Leighton Linslade and Heath & Reach. The countryside is characterised by former and active mineral workings and despoiled land which

48 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

cannot be described as ‘rolling’. The CWGV straddles two Character Areas, the Wooded Greensand Ridge (Type 6A) and Clay Hills (Type 8A). Because of its position on the edge of the two areas as well as being within a topographically and visually contained basin, the development would have a limited or negligible effect on locally sensitive landscapes. The ridge lines will be largely reinstated where they have been affected by quarrying activity as part of the restoration schemes.

 ‘The site contains a number of mineral working areas that are essential for ecological benefits to the area’. The existing minerals consents will continue to be implemented and further extensive areas of agricultural land will be quarried during the DLP period. The ROMP, (the minerals restoration plan), will see the restoration of the quarry as part of an integrated approach to provide, on an ongoing basis, the development platform as an essential part of the quarrying activity. This is already planned for within the ROMP. That same document provides for extensive areas of ecological improvement sitting alongside, and designed into, the CWGV scheme. There exists, therefore, a major opportunity for joined up thinking to be applied which marries the need to extract minerals, improve ecology and to use despoiled land to assist in satisfying housing need. AWEL has already successfully demonstrated at Southern Leighton Linslade that these aspirations can be successfully planned and implemented as one continuous operation.

 ‘essential for ecological benefits to the area; this includes a number of SSSIs’. The purported SSSIs are geological, not environmental so it is clear that the conclusions in this respect are wrong. There are two SSSIs within the quarries. One is accepted by Natural England to be misidentified or lost but they have not as yet removed the designation. The other one is included in the ROMP which includes and permits quarrying the SSSI site. On this basis, there is no properly assessed constraint.

 ‘plus past quarry uses has already damaged important archaeological sites within the site area and further damage is unacceptable.’ This is factually incorrect and is a reference to the quarrying in the 1920s near Broomhills Farm on Chamberlains Barn – an entirely different quarry, some distance away. Indeed, the CWGV proposals have been modified to respect and enhance the setting around the medieval settlement of Overend Green.

49 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Checkley Wood Garden Village: the advantages

The Location

6.28 The PSLP goes to some length to explain the Council’s Spatial Strategy and this has been commented on within Section 2 of this response.

6.29 CWGV sits comfortably within the PSLP’s ambitions. The site is located within the Luton HMA. It is within the “Golden Triangle” (Appendix 7) above and will be just a short distance from the Expressway and the East West Rail corridor. It already benefits from the recently completed A5/M1 link – some 5 miles away and will have exemplar linkages to Leighton Linslade station from the new housing and from the park and ride/transport hub to be provided. There will be fast and easy access to Luton’s business areas, and Luton Airport, through the guided busway.

6.30 In short this is a very well located and sustainable site.

Use of damaged land

6.31 This site is located primarily and adversely by quarrying over most of its area through existing mineral consents (some completed, some still to be carried out). The quarrying activity, by its very nature, destroys the agricultural landscape but care has been taken to ensure that the agreed restoration plan provides the development platform for the CWGV scheme and phasing will ensure that new development can follow on from quarrying, as has already been achieved in Southern and Easter Leighton Linslade. Development on this land, which is already damaged and cannot replicate a green field character, even after restoration, is surely preferable to the development of virgin countryside. The result will be that CWGV will be an exemplar green garden village of 4,500 homes set within its own surroundings which will improve the accessibility, character and quality of the Green Belt in line with the PSLP objectives.

6.32 Indeed, the PSLP at para 8.4.1 highlights the desirability of improving Green Belt land (emphasis added in bold):

50 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

In addition to its role in preventing coalescence and urban sprawl etc., Green Belt land can also have a positive role to play in terms of environmental quality and access. It may, for example, provide access to open countryside and opportunities for quiet recreation and sport. Green Belt can also help retain valued landscapes and protect biodiversity and it provides many possibilities to protect and improve green infrastructure, especially in urban fringe locations. The Council is committed to improving the environmental quality and accessibility of its Green Belt, and will favourably consider development proposals that will actively improve the character and quality of our Green Belt.

Identity 6.33 CWGV would be a separate settlement which would have the opportunity of creating a ‘garden village’ with its own identity, a concept favourably mentioned in the NPPF55 and the DCLG Prospectus56.

Coalescence

Checkley Wood sits within its own distinct basin, as do Heath and Reach to the West and Leighton Linslade the South. There is no question of coalescence or visual impact and in fact, the ridges that separate the basins will in themselves be reinforced with planting, new public access and biodiversity gains to emphasise and underpin separation and non- coalescence of settlements.

Transportation

6.34 CWGV offers the opportunity for providing the ‘missing link’ on the highway network - between the A5 and A505 (both with new junctions). This new link road will provide a gateway to the north from, and strategic approach to, Leighton Linslade to the A5 with a new road and a new and safe junction.

6.35 The proposed Heath & Reach relief road will significantly relieve traffic through the village via Heath Road. In doing so, it will improve air quality and reduce traffic noise and significantly improve the quality of life for the residents of Heath & Reach.

55 NPPF para 52 56 Locally-Led Garden Villages, Towns and Cities DCLG (March 2016)

51 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

6.36 The Transport Hub will create an important nodal point just south of the East West Express way at Fenny Stratford to the north, the A5/M1 link road to the south whilst offering express public transport routes which circumnavigate the lights (cross roads) at Hockliffe, a known congestion hotspot on the A5.

6.37 The delivery of CWGV will open up the opportunities of creating new public rights of way thereby linking the severed communities of Heath & Reach with Pottsgrove, Woburn and Battelsden.

6.38 CWGV would wholly fund and deliver a new ‘21st Century’ public transport hub which will embrace evolving technology and recognise the Government’s ambitions to reduce reliance on traditional modes of transport. This hub will provide fast and easy access to the growth areas and help accelerate modal shift - something which AWEL have successfully achieved elsewhere in the District.

Delivery

6.39 AWEL owns the CWGV site and works closely with Aggregate Industries, the quarry operator, to ensure that land formation and quarrying activity are a seamless operation.

6.40 AWEL has a proven track record in Central Bedfordshire of delivering viable exemplar travel plans in collaboration with key stakeholders. A similar approach will be taken at CWGV.

Technology

6.41 AWEL pioneered new technology in Southern Leighton Linslade with real time bus information in every home and at bus stops and operating an efficient and popular bus service, the Dash Direct.

6.42 AWEL will invest in gigabyte speed communications in CWGV and Leighton Linslade to give the area a real chance to compete with the plans to make Milton Keynes the UK’s 2nd Gigabyte city. Fast communications will be key to attracting knowledge-based

52 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

industries that sit at the core of the academic Golden Triangle (UCL, Oxford & Cambridge Universities) and the Cambridge, Milton Keynes and Oxford Arc.

6.43 AWEL is working with Warwick University to pave the way for electric autominous vehicles that will form the key plank to the Transport Hub, powered by renewable energy that AWEL generates on site.

Sustainable Energy

6.44 The location of the Double Arches wind turbine and the newly consented Checkley Wood Turbine offer a unique opportunity for a truly green-powered garden village, carefully designed to support a community that has a deep connection with its immediate natural environment.

6.45 PSLP Policy CC2 ‘Sustainable energy development’ is applicable and supported.

Ecology

6.46 CWGV will deliver a new settlement set within a wooded framework and critically creating a significant green infrastructure asset running along the north south ridge linking the approved Shenley Hill Country Park on Chamberlains Barn to Kings Wood and Bakers Heath National Nature reserve (and SSSI) to the north. This is very much in line with the aims set out in the recently approved Nature Improvement Area for the Greensand Ridge.

Archaeology

6.47 The SHLAA states erroneously that quarrying in the area of CWGV has already damaged important archaeology. This is factually incorrect and is a reference to the quarrying in the 1920s near Broomhills Farm on Chamberlains Barn – an entirely different quarry. Adverse archaeology comments also make reference to the importance of preserving the area around the medieval settlement of Overend Green. The CWGV proposals do just that ensuring no development or planting in the vicinity of Overend Green.

53 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Heritage

6.48 CWGV will give the opportunity to extend one of the District’s primary tourist attractions – The Leighton Buzzard Narrow Gauge Railway - by incorporating an extension northwards along the historic track bed, to create a new terminus with a museum and workshops close to the new village centre, thus helping to ensure the Railway’s long- term sustainability and viability as well as greatly enhancing the tourism opportunity.

Conclusion

6.49 The CWGV proposals are far from being at variance with the PSLP Policies, but actually chimes with those Policies as follows:

 Acknowledging the ‘Vision for 2035’ and the impacts of the CMKOx arc

 Policy SP4 - Development in the Green Belt

 Policy SP5 – Preventing Coalescence

 Policy EMP3 – Employment Proposals Within or Adjacent to Settlement Envelopes

 Policy EMP4 – Rural and Visitor Economy

 Policy T4 – Public Transport Interchanges

 Policy T5 - Ultra low Emission Vehicles

 Policy EE3 – Nature Conservation

 Policy EE8 – Greensand Ridge Nature Improvement Area

 Policy EE14 - Minerals and Waste

 Policy CC2 - Sustainable Energy Development

 Policy CC3 – Flood Risk Management

54 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

 Policy CC5 - Sustainable Drainage

 Policy CC6 – Water Quality

 Policy HQ4 - Indoor Sport and Leisure Facilities

 Policy HQ5 – Broadband and Telecommunications Infrastructure

Summary

6.50 Checkley Wood Garden Village should either be added or substituted as an ‘identified’ site in para 6.2.8, the Key Diagram, Appendix 7, for the Review to consider, because:

 the future housing numbers for the District will require substantial additional sites

 the South of the District is an area of high demand for housing with good connectivity to employment and other attractions at Luton, Milton Keynes and London

 CWGV will utilise damaged land and has a positive impact on the Green Belt

 transportation infrastructure will be of major public benefit, including a Heath and Reach bypass and a A5/A505 link, and requires no public funding

 the constraints have been wrongly assessed and are not such that they represent a significant and demonstrable case against the site

 the inclusion of new technology and renewable energy is an integral feature of the development

 ecological factors such as landscape, heritage, archaeology can be enhanced

 the proposals chime with the PLSP’s emerging policies

6.51 Of course, the Review should then go on to ‘allocate’ CWGV but this is not a decision for the PSLP. The Review should be given the opportunity to assess this major site

55 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

(probably the only such site in Southern Central Bedfordshire) and to leave it out would be a huge missed opportunity.

6.52 Modification

Add Checkley Wood Garden Village to PSLP Appendix 7 and section 7.9, with consequential amendments.

South Area Potential Small and Medium Sites

6.53 Whilst the allocation of Chamberlains Barn North (HAS32) is welcome and supported, two other sites around Leighton Linslade should be allocated in the LP.

6.54 There are infrastructure difficulties which are delaying the full implementation of the urban extension East of Leighton Linslade (Clipstone Park, Chamberlains Barn and Stearn consented schemes). Large tranches of these sites will not be able to be counted as forming part of the 5-year housing land supply given the triggers which are dependent on what happens south of Van Dyke Road, and the fact that electricity apparently needs to be brought in from Sundon. It is estimated that elements of the ELL scheme will not be able to commence building activities for perhaps 7 years.

6.55 Other small sites can bridge this gap and provide the stimulus for infrastructure provision. These sites are:-

New Trees, Leighton Linslade

6.56 This is a modest site with a capacity of some 100 homes and the response to the call-for- sites included the provision of a 39ha country park. The ‘concept masterplan’ is attached at Appendix 3.

6.57 This site is a logical northern extension to Leighton Linslade on the northern side of Shenley Hill Road, opposite Chamberlains Barn North and the East Leighton Linslade urban extension. The residential element (approximately 100 homes) is modest, yet a good contribution to the 5 year housing land supply which is currently deficient. The

56 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

proposals include major benefits to the communities of Leighton Linslade and Heath and Reach through the provision of the first phase of the Heath and Reach relief road between Shenley Hill Road and Eastern Way, and a major new area of Country Park thus extending the Shenley Hill Country Park. In addition, the proposals would restore the former minerals working at ‘New Trees’ which has no adopted restoration plan or any requirement to restore whilst respecting policies on coalescence which AWEL supports.

6.58 The site was assessed in the 2016 SHLAA under ref NLP457 and the Appendix D comments are:

Site fails at Stage 1B. Site causes coalescence in the Green Belt between Heath and Reach and Leighton Buzzard and has a poor relationship with both settlements.

6.59 Appendix 3 shows that the ‘coalescence’ point has no validity. When viewed as a minor extension to the north of Leighton Linslade, surrounded on three sides by a proposed country park, the site would be an entirely appropriate allocation for development and again would see the utilisation of despoiled land.

Stanbridge Road, Leighton Linslade

6.60 The capacity of the site is 240 homes.

6.61 The site is located directly opposite the southern boundary of the East Leighton Linslade urban extension granted planning permission (CB/11/02827OUT) on 28.8.15. There is existing residential development to the immediate west of the site. Development of the site would ‘round off’ the south-eastern’ urban boundary of Leighton Linslade. It would make a useful contribution to the housing shortfall including the shortfall in housing numbers from those originally anticipated as being provided in the South Leighton Buzzard Development Brief. Other Southern Leighton Linslade sites in the adopted Local Plan and Development Brief will not deliver the quantum of development originally envisaged due to the retention of the electricity line and a reduction in housing numbers at RAF Stanbridge.

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6.62 The SHLAA assessed this site (ref NLP072) and Appendix D concluded as follows, “to be excluded from LP process”:

Site fails at Stage 2, based on an overall consideration using planning balance. The following issues have been identified: There is a key concern with the site’s impact on the landscape; the topography of the site is such that there are long ranging views between the site and the surrounding landscape. Due to the topography of the site it is considered that soft landscaping would not mitigate the visual impact of the development upon the wider landscape causing substantial harm to the intrinsic character and beauty of the countryside. Whereby it is not considered that the benefits of development would outweigh this substantial harm identified. For the reasons outlined above, it is considered that the site is not worthy of further consideration for development. Any alteration to the greenbelt boundaries will require exceptional circumstances to be demonstrated.

6.63 As can be seen from the concept masterplan at Appendix 4 the site is bounded by urban development to the north and west, and is not part of open landscape. The land rises uniformly from Stanbridge Road looking south and there is a ridgeline roughly along the southern boundary of the site. It is a featureless arable site with no vegetation apart from a modest and well-trimmed hedge alongside the road. Development would be unremarkable, and similar to many on the edge of an urban area in this locality.

6.64 The site would make a valuable contribution to housing land supply.

6.65 In conclusion, these two sites are modest and unremarkable extensions to the edge of Leighton Linslade which is a sustainable settlement with many services, schools, retail, employment, a railway station, good inter and urban transportation. The non-permitted sites have a have a combined capacity of 340 homes and would make a worthwhile contribution to housing needs and, being modest in size, would contribute to 5-year housing needs.

6.66 Proposed Modification

The Policy Table at HA1 should add the sites ‘New Trees’ and ‘Stanbridge Road’, Leighton Linslade to the list of Small and Medium Allocations.

58 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

East-West Plan Area

6.67 Section 2 above has already raised the absence of the Duty to Cooperate between CBC and Bedford BC on the provision for the CMKOx corridor. The PSLP also makes very little provision in the East-West plan area.

6.68 A Marston Vale Concept Masterplan was submitted to Bedford BC in May 2017 in response to the LP consultation. It is attached to this Submission at Appendix 5. To be clear, this is an illustration of what could be achieved in the CMKOx Corridor in this key location, it shows land in various ownerships. This shows a series of linked areas forming a large new settlement to the south of Bedford, bounded by the A421 and A6, to include existing settlements of The Wixams and Stewartby, to which is added areas known as Broadmead, Kempston Hardwick and Camel/Houghton Conquest. This could involve a new combined settlement with some 10,000 new homes. The Corridor’s key infrastructure which would serve this new area is East-West Rail, the new Wixams main line railway station and the Oxford to Cambridge Expressway.

6.69 Two sites owned by AWEL are within CBC and these are detailed below. These sites should be viewed in the context of the other land owned by AWEL which falls within the Bedford BC administrative area. Both were submitted in response to the call-for-sites in 2016.

Camel/Houghton Conquest

6.70 The site could deliver some 825 dwellings in a ‘Growth Area’ defined in national and local policy documents over many years. It lies immediately to the south of the recently permitted southern extension to the Wixams. Quest Quarry to the west received a planning consent for the NIRAH development. There are other ‘urban uses’ around the site as shown on the location plan. The site is bounded by the B530 to the east. Appendix 6 is the location plan with Camel and Quest concept plans.

59 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

6.71 SHLAA Appendix D assessed the site (ref NLP070) ‘to be excluded from the LP process’ as follows:

Failed at Stage 1B. The site has a poor relationship with Houghton Conquest and causes coalescence between Houghton Conquest and Stewartby.

6.72 The Northern Growth Options Study examined an area which included this site, but linked to the Quest Quarry opposite (N9). Many of the constraints (biodiversity, flood risk, mineral resources) cannot apply to the Houghton Conquest site.

6.73 Clearly, such comments have been overtaken by events and a bolder strategy is now required which combines these sites with others to deliver substantial new growth.

Quest North

6.74 The site could be deliver some 264 dwellings in a ‘Growth Area’. It lies immediately to the west of the recently permitted southern extension to the Wixams. It is the northern section of a former Quest quarry, although never worked for brick clay because the deposits were uneconomic. Quest was permitted for the NIRAH development. There are other ‘urban uses’ around the site as shown on the location plan. The site is bounded by the B530 to the east and the railway to the west. The site is ideally suited as a further extension of the Wixams “Garden Town”, or the larger growth proposals set out above. Appendix 6 includes the Quest North plan.

6.75 SHLAA Appendix D assessed the site (ref NLP071) ‘to be excluded from the LP process’ as follows:

Site fails at Stage 1A. Site is 50% or more within Flood Zones 2 and 3.

6.76 This is clearly wrong. Whilst the southern part of the area was part of the excavated area of Quest Pit, for which planning consent was granted by CBC for the failed NIRAH scheme, the triangle of unworked, flat land to the north is well above flood risk levels

60 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

and was anticipated in the approved NIRAH masterplan as coming forward as a sustainable eco residential development. The principle of development on the site would appear to have been already accepted by CBC.

6.77 In conclusion, the implications of the substantial growth required in the CMKOx Corridor have not yet been grasped by CBC and Bedford BC. These will require substantial changes to the planning system either by Local Authorities or a Government Agency. The two sites put forward by AWEL have not been assessed in this context, but both are well placed for further development as part of the Wixams expansion, if not the larger growth proposals set out above.

6.78 Both sites are within the strategically important transport corridor and are close to the existing railway stations on the east-west rail line, the A421 dual carriageway and the approved Wixams main line railway station.

6.79 Proposed Modification

The Policy Table at HA1 should add the sites ‘Camel/Houghton Conquest’ and ‘Quest North’, Marston Vale to the list of Small and Medium Allocations

61 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

7.0 SUMMARY AND CONCLUSIONS

7.1 This Response is the response to the consultation on the CBC Pre Submission Local Plan. It is more detailed and complex than the on-line form allows.

7.2 This Response, in Section 2, submits that the PSLP Spatial Strategy Approach is unsound, even though some matters may be addressed in the Review, because:

 the full impact of impending growth, in terms of housing numbers, has not been tackled.

 any continuation of the Spatial Strategy as drafted would not be justified. This Response supports the intention to undertake a Review and suggests modifications (set out in Section 2) which define the areas of growth of CMKOx and A1 corridors, to which should be added the South Area.

 Inadequate provision is made for new homes (as demonstrated in Section 4)

 Inadequate provision has been made for the South Area and CMKOx Corridor.

7.3 The housing numbers, which form the basis of the Plan, are too low. Section 4 of this Response demonstrates that by giving greater weight to the CLG/ONS 2016 household projections, having regard to the Government’s intention to simplify the process, means that the Plan must allocate some 4,500 extra homes above the levels in the PSLP. Policy SP1 (and other references to housing numbers) is therefore unsound. The changes proposed in this Response would require modifications to the Plan with a Review to follow later.

7.4 Whilst the Review provision is supported, strong objections are raised in this Response to the limitations placed upon it in the PSLP because the proposals are incapable of testing through the Examination process. Until the higher housing numbers are available - and Section 4 of the Response illustrates that at least 27,000 extra homes will be required, plus any that are derived from the Government’s intentions for the CMKOx

62 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

corridor - the Review cannot be fettered to look only at only limited areas of the District with only 4 ‘identified’ sites. In any event, the Response objects to the claimed attributes of these 4 sites.

7.5 The PSLP offers two options to address these points as set out in full 3.16 above:

1. either delete reference to the PSLP’s intentions for the Review’s spatial strategy and ‘identified site ‘in the Spatial Strategy Approach, Appendix 7, para 5.5.2 and delete paras 5.5.3, 6.2.8, 6,3.6, 6.3.7 2. or paras 5.5.3, 7.9.3, 7.9.4 and Appendix 7 should be modified so that the areas and sites have no status and that the Review should be assessing other sites. Until this is addressed, the Response suggests that the PSLP cannot be found to be sound.

7.6 The Response demonstrates failings of the ‘allocated sites’ but only objects and finds the PSLP unsound in respect of Policy SA2 (Marston Vale Villages) because it is the wrong strategy and too vague to be allocated. There remain questions on deliverability.

7.7 Notwithstanding the objection to the status of the ‘identified sites’, the Response puts forward an additional strategic site, Checkley Wood Garden Village, in the South Area which should be assessed alongside the ‘identified’ sites in the Review.

7.8 CWGV has a capacity of some 4,500 homes and will make a major contribution to the housing shortfall. Without the inclusion of CWGV as an ‘identified’ site for the review, the PSLP would be unsound having not properly considered reasonable alternatives having regard to the fact that the PSLP conclusions were based on non-robust evidence and inaccuracies. The full benefits of CWGV are summarised in para 6.49 above.

7.9 This Response also highlights the merits of allocating the Leighton Linslade sites at New Trees and Stanbridge Road (Section 6) with a combined capacity of 340 homes.

7.10 In the northern plan area, the implications of the substantial growth required in the CMKOx Corridor have not yet been grasped by CBC and Bedford BC. This may fail the

63 CBC Pre-Submission Local Plan January 2018 Gardner Planning on behalf of AWEL

Duty to Cooperate but will, at least, need to be fully addressed in the Review. Two sites within the CBC administrative area are put forward in this Submission (Camel and Houghton Conquest and Quest North) which have not been assessed in this context, but both are worthy of further consideration as part of a larger settlement south of Bedford which should include other AWEL land in the area. (see Section 6).

7.11 This Response has assessed the PSLP against the tests of soundness in the NPPF and reached the conclusion that the Plan, without modifications as suggested herein, would be unsound.

64 Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response

Arnold White Estates Ltd

February 2018

Appendix

1. Summary of Representation

1 CBC Pre-Submission Local Plan Summary of Representations

Gardner Planning Ltd, on behalf of Arnold White Estates Ltd

For all representations:

 the Plan is considered Legally Compliant and the Duty to Cooperate has been complied with  the Plan is unsound in parts  we request an appearance at the Examination, for all objections listed below.  we did make Representations to the Draft Local Plan (July 2017)  the full response is contained in our ‘Response’, the following is a summary

1. Spatial Strategy

Policy number Text or Table para 5.4 number The Spatial Strategy Summary of Objection The Response ref. paras 2.9 - 2.26 The Spatial Strategy numbers are too low. The growth areas for the PSLP and the Review should include the South of the District. The ‘ terms’ for the Review ignore the impact of even higher housing numbers for Cambridge-Milton Keynes-Oxford Corridor (CMKOx) and the CLG methodology. Until this scale of increase is absorbed and considered, a focus on, and continuation of, the Strategy in the current PSLP (“potential of strategic sites on the East West Rail/Expressway and the A1/East Coast Main Line Corridor” ) is premature. The Review must re-assess the Spatial Strategy afresh and include other strategic sites to the South of the district. Proposed Modification The Response ref. 2.13 A modification is suggested as follows:

This Plan seeks to:

 Build on our existing and emerging economic strengths in key sectors and deliver a minimum of 24,000 new jobs.  The Local Plan will deliver around 43,8501 39,350 new homes (this includes 23,845 homes that are already planned for or built) through new villages, moderate extensions to existing towns and villages in line with the provision of new infrastructure and to meet identified housing need o close to key transport corridors (East-West, A1/East Coast Mainline and M1/Thameslink)

1 see Response Section 4

2 o in the South of the District including the unmet housing needs of Luton  Balance the delivery of significant sustainable infrastructure and growth with the enhancement and protection of existing communities, landscape, heritage and countryside and actively prevent the coalescence of settlements across the area through the identification of Important Countryside Gaps.  Maximise potential opportunities for the intensification and redevelopment e.g. RAF Henlow and the regeneration of urban areas (Biggleswade, Dunstable, Houghton Regis, Flitwick, Leighton Linslade & Sandy) through town centre frameworks or masterplans.  Ensure that growth is designed and delivered in ways which benefit existing neighbouring communities, for example through improved transport facilities or regeneration of local commercial facilities;  A Review will identify the new levels of growth required for the Cambridge-Milton Keynes-Oxford Corridor and deliver spatial options and strategic opportunities that could provide for longer term economic and housing growth in the District across the corridor including through a Partial Plan Review. Much of this growth will support, and must be supported by, new strategic infrastructure particularly the Oxford – Cambridge Expressway, A1 improvements and new rail stations/transport interchanges along the East West Rail route. The Review will consider the further growth required to accommodate the Government’s methodology for calculating housing need in the South of the District.

2. Key Diagram

Policy number Text or Table para 7.24 and Key number Diagram Summary of Objection The Response ref. para 2.16 and Appendix 7 The Key Diagram should show the extent of the CMKOx Corridor, to mirror what is shown in the Bedford Local Plan. Proposed Modification The Response ref. para 2.17 The Key Diagram should show the area of the CMKOx Corridor. It already extends transportation routes extending well outside the District, but should also show the preferred route for the Oxford-Cambridge Expressway to the West which heads south- west to the south of MK and not due west as shown on the Key Diagram.

3 3. The Review

Policy number Text or Table paras 5.5 and 7.9.1 - number 7.9.6 The Review Summary of Objection The Response ref. Section 3 The scope of the Review cannot be prescribed by the PSLP because the scale of future growth is unknown, which will affect the identification of the ‘growth areas’ for the Review and identification of sites. The ‘identified’ sites have inadequate supporting evidence. As drafted, the PSLP fails the ‘justified’ test of soundness. Proposed Modification The Response ref. para 3.16 The PSLP should make the reason for the Review clear by changing the heading at paragraph 1.4 to “Plan Review” (‘partial’ is misleading when the scale of growth could exceed the original by over 60%), deleting ‘Partial Plan Review’ at para 1.5 and continuing the paragraph numbering under the one heading. There are two reasons for the Review, not one.

The Review has a significant task to firstly calculate the scale of growth as a result of new housing numbers required by the final CLG methodology and those required for the CMKOx corridor. Only then will the Review be able to determine its ‘spatial strategy’ and the number and extent of new sites required. The PSLP is unable to forecast that at this stage so any assumptions about a future spatial strategy and the sites required is premature.

There are two options open to the Inspector Option 1: to delete Appendix 7 and any reference to a spatial strategy and ‘identified sites’ for the Review, which will require modifications as follows Spatial Strategy Approach, point 5: Identify and deliver spatial options and strategic opportunities that could provide for longer term economic and housing growth for the District, across the corridor including through a Partial Plan Review. This growth will support, and must be supported by, new strategic infrastructure particularly the Oxford – Cambridge Expressway, A1 improvements and new rail stations/transport interchanges along the East West Rail route. para 5.5.2 Until the scale of additional growth for the CMKOx corridor is known, and the scale of housing growth for the District as a whole as a result of the new CLG housing calculations being determined, it is not possible to identify the ‘spatial strategy’ and identification of sites that will be needed in the Review. The Council has already undertaken a number of studies to help prepare for possible future growth which would realise some of the potential outlined by the National Infrastructure Commission. Much depends on the provision of future infrastructure e.g. but not limited to, the Cambridge-Oxford Expressway and East-West Rail. This Plan therefore identifies no spatial strategy or sites for the Review. firm commitment to some strategic locations where there is a strong existing infrastructure base, such as Marston Vale, to a level of growth which can be supported by that together with firmly committed or achievable additional infrastructure. However in other cases, such as the East West Rail new line to

4 Cambridge, further decisions on routeing, timing and commitment, as well as wider investment and delivery support are required before firm allocations can be made. Para 5.5.3 - delete Paras 6.2.8, 6.3.6, 6.3.7, Appendix 7 - delete

Option 2: Remove any status or preference for a spatial strategy or sites in the Review Paragraphs 5.5.3, 7.9.3 and 7.9.4 should be amended as follows:

5.5.3 The Council is therefore putting in hand a further assessment of the Identified Areas for Future Growth (see section 7.9 7.10) to look at the potential of strategic sites on the East West Rail/Expressway and the A1/East Coast Main Line Corridor routes in line with emerging decisions on this strategic infrastructure. This will enable further growth potential to be looked at in line with decisions to be taken on routes, timing and services, together with provision of wider infrastructure and delivery support. This assessment will inform a Partial Review of this Plan and will contribute to the ongoing work in the Central Corridor Area. In addition, other sites will need to be considered when the full extent of future growth is known, not just that required for the CMKOx/A1 Corridors. The Partial Review will look at an improved evidence base on issues where work is ongoing and in particular at capacity for and deliverability of further growth on the strategic sites. It will consider whether there is delivery potential for years 10-15 (2030-2035) for the current Plan period or whether this would fall in the next Plan period, given long lead times for these large sites. Paras 6.2.8, 6.3.6, 6.3.4 make reference to ‘identified sites’ in Appendix 7 but these sites have no special status as a revised ‘spatial strategy’ and new site allocations will be a matter for the Review. It will look at 3 scenarios for growth: … 7.9.3 The identified land areas respond to proposals for future strategic infrastructure delivery; namely the realignment of the A1 or significant improvements through Central Bedfordshire, East West Rail, the Expressway and the expansion of Luton Airport. In each case these are either expected to enable development or in other cases they may mean that development is not feasible in a location due to the sterilisation of the land by the route of the infrastructure. Whilst all locations however are based on some initial technical assessment and may have potential for future development, they are not proposals of this Plan, will not acquire any status from being illustrated, and are unable to be examined, this being a matter for the Review. Moreover, there will be other areas of the District and other sites for consideration in the Review, which may have been passed over in a wholly different context or may have been wrongly assessed. All of these sites, and the ‘identified’ sites in the PSLP, will need to be assessed afresh and on an equal basis in order that the Review can meet the new requirements for growth. 7.9.4 This land is not allocated for development at the present time, but subject to further assessment, which will be a matter for the Review, along with other sites for the could fulfil its purpose of meeting possible longer-term development needs. Development which would prejudice later comprehensive development will be discouraged, though temporary developments which may assist in ensuring that the land is properly looked after may be acceptable. In addition valuable landscape and wildlife features and existing access for recreation should be protected and enhanced as appropriate.

5 4. Housing Numbers

Policy number SP1 Text or Table number Summary of Objection The Response ref. Section 4 1. The starting point in the PSLP are the figures for CBC (32,000) and the unmet need from Luton (7,350). Both are derived from the SHMA2. Luton’s total unmet need was 9,3003, so CBC is absorbing 79% of that but there remains a shortfall.

2. If the simple ONS household projection number 34,587, converted to dwellings - 36,074, were to be used then the PSLP would be planning for an additional 4,074 homes in the plan period, although the surplus of allocations (2,420) reduces that to a need for an extra 1,654.

3. SHMA Fig 92 shows that “local demographic factors and long-term migration trends” are the main reasons for adjustments and these result in a 20% reduction to the CLG household projections. This Response suggests that to challenge CLG’s use of migration patterns and its demographic projections is a fundamental and universal challenge which would render the CLG figures rather worthless. It is to be expected that the CLG projections should be given additional support because of their independence and transparency.

4. Luton’s net extra housing need (additional to commitments) in its plan period up to 2031 is 17,8004 or 890 p.a. It has capacity for 8,500 extra homes within its borders, a total unmet need of 9,300 homes (up to 2031) of which 7,350 (79%) have been met in CBC. However, a further 4 years must be added to gauge the effect of Luton’s unmet need onto adjoining Districts, which totals 3,560 homes (4x890). This is based on the Luton LP and SHMA’s number rather than the ONS household projection number for Luton which is 35% higher. The previous Luton total unmet need was shared between surrounding Districts with CBC taking 79%, so an extension of Luton’s unmet need to 2035 equates to an additional 2,812 homes to be accommodated in CBC.

5. In total, therefore, the additional housing that should be accommodated in the PSLP (based on CLG/ONS figures) and the calculated increase required for Luton revises the extra homes allocation as follows: Table GPL5 revised original a) CBC Housing Need 36,074 32,000 b) Unmet Need from Luton 10,162 7,350 Total 46,236 39,350 Commitments 23,845 23,845 New allocations required 22,391 15,505 Supply from allocated sites 17,925 17,925 ‘Surplus +’ or ‘shortfall -’ -4,466 +2,420

2 Initial Strategic Housing Market Assessment for Luton and Central Bedfordshire July 2017 Central Bedfordshire Council 3 Luton Local Plan (2011-31), Adopted Nov 17 para 6.9 4 Luton Adopted Local Plan para 6.1

6 6. Thus, for adjustments to be based on the simple and transparent ONS figures, as recommended by the Planning Experts Group and proposed in the CLG Planning for Housing paper, and the addition of Luton number to match the plan period, results in a need for extra allocations of some 4,500 homes. Even then the margin justified in the PSLP, 2,420 or 16%, is not catered for so 4,500 is an absolute minimum addition.

7. This does not factor in any increases required as a result of applying the draft CLG figures. If those figures become the final version in the new NPPF (likely to be published in draft in March 2018) then the housing target for CBC would increase by some 19,000 for the District plus an extra of some 8,000 for the CBC share of Luton’s unmet need, a total of 27,000 extra homes. The impact of the growth needed for the CMKOx Corridor would be even higher: housing numbers in the Corridor should “double”5.

8. These much higher numbers, which are likely to be finalised later in 2018, provide further evidence that the PSLP/ORS figures are way too low.

Proposed Modification The Response ref. para 4.21 This Response objects to the PSLP Policy SP1 housing number of 39,350 homes and proposes a Modification that it be increased at least to an interim 46,250, noting that it will need to be very much higher when the new NPPF Government proposals for the CMKOx Corridor are published .

5. Housing Land Supply

Policy number Text or Table para 7.2 number Housing Supply Summary of Objection The Response ref. paras 4.22- 4.27 Under the heading at 7.2 ‘Housing Supply’, the basis for calculating the 5-year Housing Land Supply includes the 7,350 unmet homes figure for Luton (7.2.4) which is included in the 39,350 homes figure (although disputed elsewhere in these representations) in Policy SP1 for the 20-year plan period. There is no phasing so that 1,968 p.a. (39,350/20) is the base figure for calculating 5YHLS. This needs to be made clearer. Proposed Modification The Response ref. para 4.29 Paragraph 7.2.4 should be amended as follows: In addition to meeting Central Bedfordshire’s housing need, the plan target also includes provision for 7,350 homes to meet Luton’s identified ‘unmet need’ as outlined in paragraph 6.2.1. Policy SP1 states that the Plan will deliver 39,350 homes over the period 2015 to 2035, which is an average of 1,968 homes p.a. This is the annual figure to be used to calculate the 5-year housing land supply for the District.

5 NIC Partnering for Prosperity Nov 17 p3

7 6. Allocated Sites

Policy number SA2 Marston Vale Text or Table New Villages number Summary of Objection The Response ref. paras 5.7 - 5.8 This allocation shows a large area but amounts to 2 new villages. The plan on p53 should be more explicit. This is the wrong strategy to begin to respond to the CMKOx corridor initiative. This area is subject to many constraints and the PSLP lacks clarity on the infrastructure required. Proposed Modification The Response ref. para 5.9 Firstly, the Plan on p53 should be amended to be more specific on the area of the two villages. Secondly, the third paragraph of the Policy should be followed by: This is a modest allocation which needs to be followed in the Review, when the CMKOx Corridor strategy and housing numbers are clarified, by the allocation of a significant new settlement in the shared CBC/Bedford area of the Corridor.

Policy number Policy HA1 Text or Table number

Summary of Objection The Response ref. paras 5.15 - 5.17 The allocation of site HAS32 (Northern Chamberlains Barn) in Policy HA1 (p82) is generally supported, but the density and housing number needs amendment. The submitted planning application fully justifies the revised figures. Proposed Modification The Response ref. HAS32 Northern Chamberlains Barn (p82) - density should be ‘35’, capacity ‘253’.

9. The ‘identified’ sites

Policy number Text or Table para 7.9 number the ‘identified’ sites Summary of Objection The Response ref. para 5.19 - 5.38 The 4 ‘identified’ sites are not supported by an adequate evidence base to be included in the PSLP. However, on the information already published shows that there are significant concerns about the suitability and deliverability of each site such that there are questions about their inclusion in the PSLP. Proposed Modification The Response ref. para 5.38 The options for ‘the Review’ objection and modifications are set out in the main objection. As to the actual suitability of the 4 sites, para 7.9.4 should be amended as follows: This land is not allocated for development at the present time, and each of the sites has constraints which can only be but subject to further assessment to test suitability for

8 could fulfil its purpose of meeting possible longer-term development needs. Development which would prejudice later comprehensive development will be discouraged, though temporary developments which may assist in ensuring that the land is properly looked after may be acceptable. In addition, valuable landscape and wildlife features and existing access for recreation should be protected and enhanced as appropriate.

10. Omission Sites

Policy number Text or Table section 7.9 and number Appendix 7 Summary of Objection The Response ref. paras 6.4 - 6.50, Appendix 2 Checkley Wood Garden Village, as supported by evidence in the full Response, should be included as an ‘identified site’ in the PSLP to be assessed in the Review. Proposed Modification The Response ref. para 6.51 Add Checkley Wood Garden Village to PSLP Appendix 7 and section 7.9, with consequential amendments.

Policy number HA1 Text or Table number Summary of Objection The Response ref. para 6.54 - 6.63 and Appendices 3 and 4 The sites ‘New Trees’ and ‘Stanbridge Road’, Leighton Linslade should be added to the PSLP. Proposed Modification The Response ref. para 6.64 The Policy Table at HA1 should add the sites ‘New Trees’ and ‘Stanbridge Road’, Leighton Linslade to the list of Small and Medium Allocations

Policy number HA1 Text or Table number Summary of Objection The Response ref. para 6.67 - 6.75 and Appendices 5 and 6 The sites ‘Camel/Houghton Conquest’ and ‘Quest North’, Marston Vale should be added to the PSLP. Proposed Modification The Response ref. para 6.77 The Policy Table at HA1 should add the sites ‘Camel/Houghton Conquest’ and ‘Quest North’, Marston Vale to the list of Small and Medium Allocations

9 Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response Arnold White Estates Ltd February 2018

Appendix 2. Checkley Wood Garden Village

 Concept Diagram

 Transportation

JUNCTION 13 MILTON KEYNES

S3 M1

TRANSPORT HUB HEATH and REACH S2 CWGV

CHAMBERLAINS BARN CLIPSTONE A5 -M1 PARK A5 LEIGHTON LINSLADE Leighton ELL Link Road A4146 Buzzard S2

S1 Express HOUGHTON A505 REGIS S1 Express

S G BU UIDED AYLESBURY DUNSTABLE

KEY

Checkley Wood Garden Village (CWGV)

Chamberlains Barn and Clipstone Park

Public Transport Service 1 Express - Proposed exemplar service CWGV to Luton Station Interchange

Service 2 - Rapid Shuttle E-Vehicle (Transport Hub to Station using shared Narrow Gauge Railway Corridor to Pages Park, then Public Highway)

Service 3 - Proposed Service CWGV to Milton Keynes

Luton Guided Bus Transport Interchanges STUART MICHAEL Checkley Wood Public Transport Hub (Park & Change) ASSOCIATES CONSULTING ENGINEERS Leighton Leighton Buzzard Railway Station Buzzard FIGURE CWGV.sma3A Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response Arnold White Estates Ltd February 2018

Appendix 3. New Trees concept masterplan Eastern Way

Shenley Hill Country Park Shenley Hill Extension Country Park Extension

Shenley Hill Road

Arnold White Estates Ltd Residential Play space and recreation New Trees and Shenley Hill Country Park Structure planting/informal open space Concept master plan Tree planting Extended Shenley Hill Country Park 1-22_202 | 13-04-2016 | NTS

Existing woodland/hedge 0 20 60 140 Arable and pasture

built form resource

01865 261456, Oxford Centre for Innovation, New Road, Oxford OX1 1BY [email protected] www.builtformresource.com Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response Arnold White Estates Ltd February 2018

Appendix 4. Stanbridge Road concept masterplan Residential Formal recreation Informal open space Retention area

Allotments Street trees Boundary planting

Sketch concept master plan

Arnold White Estates Ltd 1-09-SK021 | 11-03-2016 | 1:5,000@A4 built form resource Stanbridge Road Site 0 100 200 Leighton Buzzard 01865 261456, Oxford Centre for Innovation, New Road, Oxford OX1 1BY [email protected] www.builtformresource.com Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response Arnold White Estates Ltd February 2018

Appendix 5. Marston Vale concept masterplan BEDFORD

ay sw res xp e E idg br il am a C R to t rd s xfo e O W - t s a E A421 A421-A6-Bedford

A421-Kempston B530

Kempston Railway station Kempston Hardwick Station Hardwic k Railway

Strategic access Kempston Wixams Station Hardwick Local access Lakes Local routes The Wixams Strategic routes 1 2 4 Water body A y Recreation a w s Broadmead New Settlement s re p Settlement x L-Field Park E A6 e Coronation- Countryside g Quest Park id r b Stewartby Station m a C Arnold Whi te Est ates Ltd o t d Quest Marston Vale concept masterplan r Wixams South Park o f Stewartby x O Stewartby Lake A421-Marston Moretaine 1- 69_006 | 23 -05 -2017 | NTS Houghton Conquest 0 25 50 1000 1500

l Wood i a e R n Camel t i s L e n i W a - M Forest t s d Centre a A421 n E a l B530 d i 01865 2614 56, Ox ford Ce ntre for Inn ova tio n, New Road, Oxford OX1 1BY

M i n f o @ b u i l t f o r m r e s o u r c e . c o m w w w . b u i l t f o r m re s o u r c e . c o m Central Bedfordshire Local Plan 2015 - 2035 Pre-Submission Plan January 2018 Consultation Response Arnold White Estates Ltd February 2018

Appendix 6. Location plan with Camel and Quest concept plans. Bedford Borough

Marsh Leys

Coronation Business Park Broadmead

The Wixams

Quest North

Stewartby

Camel Houghton Conquest

Central Bedfordshire

Sites submitted in this Call

Adjacent existing settlements and approved sites

Local Authority boundary

Marston Vale with proposed sites

Arnold White Estates Ltd 1-09_021 | 14-03-2016 | NTS built form resource Central Bedfordshire 0 500 1000 Call for Sites

01865 261456, Oxford Centre for Innovation, New Road, Oxford OX1 1BY [email protected] www.builtformresource.com

The Wixams

n T o S t a t i o Main vehicular access

36m

Main vehicular access

36m

Residential Public open space/recreation Street trees Boundary planting

Sketch concept master plan

Arnold White Estates Ltd 1-61-SK002 | 09-02-2016 | NTS built form resource Quest Pit 0 50 100 Marston Vale

Appendix 7. The CMKOx ‘Golden Arc’ The CambridgeMK Oxford Arc

‘The Golden Triangle’ as defined in the Bedford Borough Local Plan 2035, Draft Plan for Submission January 2018

Fig 1 p9