Transport Economy Environment Buckinghamshire County Council County Hall, Walton Street Stephen Walford Aylesbury, Buckinghamshire HP20 1UA Director Growth & Strategy
Miss Sally Sharp 01296 387434 [email protected] David Carter Strategic Planning Telephone 0845 3708090 Luton Borough Council www.buckscc.gov.uk Town Hall Luton Date: 7 December 2015 LU1 2BR
Dear David
Pre-submission Luton Local Plan (2011-2031) Regulation 19 Consultation
Thank you for consulting Buckinghamshire County Council (BCC). BCC welcomes the opportunity to comment on the Pre-submission Luton Local Plan (2011-2031) Regulation 19.
BCC acknowledges that the consultation draft local plan has a housing requirement of 17,800 dwellings between 2011 and 2031, based on ‘Luton and Central Bedfordshire Strategic Housing Market Assessment (SHMA) 2015, with the SHMA being led by a steering group which included Aylesbury Vale District Council (AVDC). The SHMA found that the eastern tip of Aylesbury Vale (area extending towards Northall, Ivinghoe Aston, Edlesborough and Dagnall) is within the Luton SHMA. As confirmed in the pre- submission draft, the Strategic Housing Land Availability (SHLAA) (2015) and viability evidence demonstrated that Luton only has sufficient land for 6,700 dwellings; this leaves an unmet need of 11,100 dwellings. BCC understands that the full extent of unmet need across the SHMA cannot be determined at this time, however Luton Borough Council must begin to consider the identification of land in the Aylesbury Vale Housing and Economic Land Availability Assessment: Draft Final Report (October 2015). This report has identified land for 61 dwellings in Edlesborough, and nothing in the Northall, Ivinghoe Aston and Dagnall area.
Luton is a significant neighbour for BCC in terms of duty to co-operate, particularly from a perspective of unmet housing need and Luton’s recent inclusion into the Strategic Alliance with Buckinghamshire, Oxfordshire, Northamptonshire and Milton Keynes. Through this strategic alliance Buckinghamshire is influenced by growth in neighbouring areas and the pressures and benefits this provides. BCC would therefore expect Luton Borough Council to continue working with BCC and AVDC as part of duty to co-operate, particularly on the issue of addressing unmet housing need and on matters relating to Luton’s Green Belt. At this time, Buckinghamshire County Council cannot see a justification for not undertaking a phase 2 Green Belt review, particularly with so much unmet housing need. The key housing issues in the pre-submission plan highlights that the council will work with neighbouring local authorities to prepare a Growth Options Study to provide the
evidence necessary to determine the most suitable growth strategy for meeting the needs of the SHMA, including Luton’s unmet need. BCC understands that the Growth Option Study is not currently available; however we request that we are consulted as part of this study. Further cross boundary co-operation will be required to build on the policies developed in the local plan, for example the production of joint planning policies, infrastructure plans where appropriate to accommodate anticipated population growth from Luton within Buckinghamshire, Hertfordshire, Oxfordshire, Northamptonshire and Milton Keynes. The NPPF states that planning policies should balance land uses for employment, shopping, leisure and education, to reduce the need to travel, therefore the Local Plan should carefully consider how it would successfully implement this in light of Luton’s housing delivery constraints. Evidence of how this would be achieved is not obvious within the plan, particularly with regard to education provision and community facilities.
The new Local Plan needs to strengthen its position on identifying strategic infrastructure requirements which cross administrative boundaries into Buckinghamshire. Future growth scenarios need to take into account strategic infrastructure improvements which may include the new route proposals for the A418 from Aylesbury to north of Wing which aims to secure journey time reliability and the A5-M1 link road scheme which aims to reduce congestion in Luton/Dunstable/Houghton Regis conurbation. BCC suggests that the Luton Local Plan endeavours to successfully deliver on policy LP31 which aims to improve local road improvements to address cross boundary growth while promoting sustainable modes of transport. As highlighted in the pre-submission plan, it will be important to ensure that such improvements are well coordinated with neighbouring authorities to allow for changes in traffic movements.
The impact of Luton Airport’s expansion is also key when considering transport connectivity on highway routes between administrative boundaries. As a strategic allocation, the expansion creates an opportunity for Buckinghamshire to be part of the airports sub-regional economy and the potential economic improvements it will generate. Well maintained transport links will be essential in this case, including improvements to Luton and Luton airport via public transport.
In terms of educational infrastructure, the plan highlights that additional capacity is needed for the equivalent of a 900 place Secondary School and 500 place primary school over the next 5 years and further high school places over the plan period in central and southern Luton. As further discussions take place and more evidence is available on how educational infrastructure would be achieved, particularly where unmet housing is included within Aylesbury Vale, BCC requests that our education department is consulted as part of these discussions.
Thank you for this opportunity to comment, we look forward to further opportunities to engage with you.
Yours sincerely
Stephen Walford Director Growth & Strategy 01296 382104 [email protected]