8 Policy HA1: Small and Medium Allocations - Allocation Ref: HAS07 – Caddington Park

Policy HA1: Small and Medium Allocations

Allocation Ref: HAS07 – Caddington Park Introduction

1. This representation has been made on behalf of Abbey Land Developments Limited to the Regulation 19 pre-submission draft of the Central Bedfordshire Council (CBC) Local Plan 2015 – 2035.

Summary of Representation

2. This representation supports the allocation of Caddington Park (Site Ref: HAS07). However, we object to the extent of the allocation which should include the land to the south of Hatters Way. The amended allocation presents a unique opportunity to deliver a high density, mixed use development comprising of private and affordable apartments for key workers and hospital-related uses to directly assist the smooth and efficient running of the Luton-Dunstable Hospital which is located just 7 minutes walk from the site.

3. We therefore consider that the site can accommodate more than the 66 dwellings as currently proposed in the draft Plan and this capacity should be increased to around 270 dwellings, the final capacity being determined through the planning application process.

Policy HA1: Small and Medium Allocations and Allocation Ref: HAS07 – Caddington Park

4. The proposed allocation of land north of Hatters Way (Allocation Ref: HAS07) is located on the southern edges of Luton, adjacent to the Luton and Dunstable Guided Busway and near to the M1. The site is also about a 7 minute walk of the Luton and Dunstable University Hospital. Given its unique nature, the site has a significant potential to accommodate more substantial mixed use development of high density residential integrated with hospital-related uses.

5. CSA Environmental have assessed the potential of the extended Hatters Way allocation to accommodate high density development in landscape, AONB and Green Belt impacts and conclude that such impacts are limited. Their landscape commentary is at Appendix 8.1 to this representation

6. To achieve the full potential of this location next to the Luton-Dunstable Guided Busway which is public transport hub we consider that the allocation site should be extended to include land south of Hatters Way creating the opportunity for a gateway development. A key component of the development would be the construction of a direct connection to the Luton-Dunstable Guided Busway that would link to the wider West of Luton proposed allocation, creating the opportunity to deliver sustainable public transport links from the western expansion of Luton (see separate representations) to Dunstable and Luton Town Centres.

Central Bedfordshire Local Plan Submission Draft (Regulation 19) 91 Representations on behalf of Abbey Land Developments Ltd 7. We are therefore proposing that the proposed allocation site is extended in accordance with the plan at Appendix 8.2 and the capacity of the extended allocation to be in the region of 270 dwellings together with hospital-related uses comprising car parking and a Step-Down Facility for on-going care, freeing up vital beds at the main hospital site.

8. The proposed use of part of the site for car parking would be for hospital staff if located on the western part of the site on the north side of Hatters Way would be 800m and a 7-minute walk to/from the Hospital. This would provide a significant benefit to the Hospital in alleviating severe parking issues at the existing site.

9. The proposed additional land to the south of Hatters Way, as identified on the plan in Appendix 8.2, provides the opportunity to deliver a new Step- Down Facility accommodating around 90-100 beds. This would enable beds that are being occupied in the Hospital by patients that no longer require the full complement of medical facilities offered by the Hospital to be relocated to convalesce until they are ready to return to their home. This type of facility would provide a significant benefit to the local communities in both Central Bedfordshire and also Luton.

10. The amended allocation would deliver key worker housing, meeting a local need for affordable accommodation and again would provide the potential for accommodation for hospital staff within walking distance of the Hospital.

11. We consider that a higher-density development at Hatters Way will provide an attractive gateway into Luton from the west and into Dunstable from the east. An increased housing provision figure would support the overall viability and be essential in delivering the hospital-related uses outline above.

12. Mott Macdonald have considered the highway impact of development at Hatters Way which is included in their Transport Strategy (see Appendix 4.4 of our representation in respect of Policy SP1 and section 7.9). Their evidence is that the proposed development is intended to be an extension of Luton with strong bus services with a new connection to the Luton Dunstable busway and walking and cycling links to established areas. This will help contain the number of car movements associated with the development, particularly at peak times.

92 Central Bedfordshire Local Plan Submission Draft (Regulation 19) Representations on behalf of Abbey Land Developments Ltd 13. At its northern end, the development connects with Hatters Way, which is a key artery between the centre of Luton and the eastern access to Dunstable. In turn, Hatters Way connects to the A505 and the M1 at Junction 11. For car journeys that originate in the development area, there are a number of route options which enable these journeys to be dispersed effectively. From the south of the site, the local road network links to M1 Junction 10 and to the southern employment areas of Luton and the airport; the impacts will be reduced if a frequent bus service can be created linking the development with key destinations in the area including Capability Green and London Luton Airport Parkway Railway Station for fast trains to Bedford and London (from where the new people mover will connect to the airport). Similarly, the potential number of car movements will be reduced by the availability of busway services to Luton station. The design of the development will support sustainable modes rather than prioritising vehicles.

14. Where necessary, junction alterations will be undertaken to alleviate delays associated with the development traffic. These will be identified when modelling is completed to test the impacts of additional demand. In quantifying the impacts, it is expected that traffic levels will not return to the highs experienced in the past even with additional traffic generated by the development.

15. Policy HA1 states that in addition to the general policy requirements of the Local Plan, development of small and medium sized sites must take full account of the site-specific issues which are identified and set out on a site by site basis where relevant. In certain instances, the table accompanying the policy lists one or two additional policy requirements. However, we consider that a more detailed stand-alone policy allocation should be made in respect of Caddington Park, given the unique opportunity that this location presents.

Test of Soundness

16. In view of the above considerations, we believe that the Local Plan is not sound, because it has not been ‘positively prepared’, nor is it ‘justified’, ‘effective’ or ‘consistent with national policy, as it fails to maximise the development potential of land to both the north and south of Hatters Way. Consequently, it does not represent the most appropriate strategy, when considered against the reasonable alternatives.

Central Bedfordshire Local Plan Submission Draft (Regulation 19) 93 Representations on behalf of Abbey Land Developments Ltd Proposed Amendments

17. We propose the following amendments: i) The Table accompanying Policy HA1 and the Policies Map should be amended to identify a revised housing capacity figure of 270 dwellings in respect of proposed housing allocation HAS07, together with revised site allocation boundaries to include land to the south of Hatters Way, in accordance with the plan at Appendix 8.2 of this representation ii) A NEW POLICY be added:

Caddington Park will deliver a sustainable, high quality, mixed-use development which will make provision for:

●● A gateway feature into Dunstable and Luton;

●● Higher-density residential accommodation of around 270 dwellings (including key worker housing);

●● Car parking aimed at alleviating parking issues at the L&D Hospital

●● Other hospital-related uses including a Step-Down facility

●● A strategic transport hub providing:

●● a new link to the Luton-Dunstable Guided Busway;

●● dedicated bus lanes either side of Hatters Way

●● new signalised junctions along Hatters Way;

●● a new cycle route crossing across Hatters Way; and

The proposed amended allocation also shows the revised Green Belt boundary.

Examination Appearance

18. In accordance with CBC’s Statement of Representations procedure, we hereby confirm that we wish to attend the Local Plan Examination in order to provide oral evidence with regard to the Caddington Park proposed allocation, and Land West of Luton, part of which has been identified as an ‘Area for Future Development’.

94 Central Bedfordshire Local Plan Submission Draft (Regulation 19) Representations on behalf of Abbey Land Developments Ltd Appendix 8.1 Landscape Commentary on Land at Hatters Way - Caddington Park HAS07 (CSA)

Landscape Commentary on Land at Hatters Way, Luton Allocation Reference HAS07 – Caddington Park

Introduction This Landscape Commentary has been prepared by CSA Environmental on behalf of Abbey Land Developments Ltd in relation to land at Hatters Way, Luton (the ‘Site’). The Commentary forms part of representations to the emerging Local Plan. The Site is divided into two parcels by Hatters Way and will be referred to in this Commentary as the northern parcel and southern parcel as shown on the accompanying Plan. The Site was visited on a number of occasions by suitably qualified and experienced Landscape Architects, but most recently in July 2017. The Site is not covered by any statutory or non-statutory designations for character or quality. The north eastern extent of part of the Chilterns Area of Outstanding Natural Beauty (‘AONB’) lies on the southern side of Hatters Way opposite the western edge of the northern parcel of the Site, and to the west of Chaul End Road. This Commentary will therefore consider the effect on the setting of the AONB as a result of the proposed development. The Site currently lies within the Green Belt and the impact of its release from the Green Belt will be briefly considered.

Site Description and Context The Site is located either side of Hatters Way (A505), immediately west of the M1 Motorway, adjoining the western edge of Luton. The northern parcel forms a small strip of land between the Luton Dunstable Guided Busway and Hatters Way. Immediately to the west, the strip of land continues to Skimpot Road, and is occupied by a mobile home park at Caddington Park on Skimpot Lane. The southern parcel is irregular in shape, and occupies the western half of the area of open land immediately to the south of Hatters Way. Included in the southern parcel to the southwest and west is part of the woodland which bounds an open area of land, with the rest of the woodland to the south and west lying outside the Site boundary. The south western wooded edge of the parcel follows Chaul End Road and for a short distance it lies opposite the Chilterns AONB. A public footpath runs along the outside of the southern parcel’s eastern boundary, while a public bridleway travels within the woodland between Chaul End Road and the western side of the M1 Motorway to the south of the Site.

Land at Hatters Way, Luton (Rev B) 1

Beyond the Site are the built-up areas of Luton and Dunstable, with Luton reaching to the north, east and southeast. To the north of the Guided Busway, which adjoins the northern Site boundary, are the western residential areas of Luton and the Luton and Dunstable Hospital. Dunstable lies approximately 1km to the west, with Skimpot Road and its extension Pointers Road marking the boundary between the two settlements. The Chilterns AONB extends southwest from Hatters Way and Chaul End Road at the western edge of Luton, with a small outlying section to the northeast of the town. The Site falls by more than 5m to the north from approximately 150m Above Ordnance Datum (‘AOD’) in the southern parcel to 145m AOD within the northern parcel. To the north, the land continues to fall gradually into the residential area of Luton. To the south of the Site and along the edge of the AONB to the west, the chalk scarp rises steeply to approximately 195m AOD before it gradually plateaus to the southwest. The Site lies outside the Chilterns AONB, with the western edge of the Site separated from the AONB by Hatters Way. To the west of the Site, Hatters Way is cut into the scarp marking the northern extent of the AONB in this area. As the road travels east, the land falls, while the road rises in elevation as it approaches the bridge over the M1 Motorway. In the vicinity of the Site, Hatters Way is elevated above the surrounding land, with tree belts along the embankments which support it, screening the Site in the summer months. A block of woodland at the eastern corner of Chaul End Road and Hatters Way, outside the Site boundary, separates the southern parcel and the woodland on its western boundary from the AONB and the roads. The Chilterns Area of Outstanding Natural Beauty Management Plan 2014-2019 is of relevance when considering the effect of the development on the AONB. Policy L7 seeks to conserve the setting of the AONB by ensuring the impact of adjacent development is sympathetic to the character of the Chilterns. The supporting text to Policy L7 notes that the Chilterns is surrounded by many market towns and the larger settlements of Reading, Hemel Hempstead, High Wycombe, Luton, Dunstable and Aylesbury where large numbers of new houses and other development will be built. The Policy goes on to say that ‘the design and location of these buildings need to be sensitive to the AONB, for example by not having excessively high or reflective roofs. The impact of the development adjacent to the AONB will be significant in many ways including its visibility from many popular sites. It is important that appropriate landscape and visual assessments are undertaken’. Policy L8 deals with the interface between the AONB, the use of land for development immediately adjacent to it, and the need to avoid undue pressure from recreational needs on the sensitive landscape of the AONB. The policy notes that new areas of development adjacent to AONBs should ensure that natural capital, green infrastructure, character and amenity, biodiversity, and recreational opportunities are all accommodated within the new development.

Land at Hatters Way, Luton (Rev B) 2

Analysis of the effect on the AONB The land to the north of Hatters Way is allocated by the pre-submission draft Local Plan for development. The representations made by jbplanning associates make the case the proposed allocation should be extended to include land to the south to make a gateway development. A key component of the development would be the construction of a direct connection to the Luton-Dunstable Guided Busway. The extended allocation could accommodate some 270 dwellings together with hospital related uses, a car park, a Step Down facility for on-going health care, affordable and key worker housing to meet the unmet needs in Luton and Dunstable.

Northern parcel Hatters Way, which at the western edge of the parcel widens to contain a grassed central reservation, provides a strong separation between the northern parcel and the AONB. The trees along the embankment further add to this separation, and offer screening of the parcel in the summer months. A short distance beyond Hatters Way to the north is residential housing and the large sheds of Cradock Industrial Estate to the east of Skimpot Road. Given the raised level of Hatters Way, the nature of the land and the tree belt along the embankment, the parcel would be substantially screened. Development on this northern parcel would therefore have a limited effect on the setting of the AONB by virtue of the change in level and the existing planting. This could be strengthened with additional planting and other mechanisms, such as green walls. Some recreational requirements of the residents could be included within the parcel, with the new junction between the two parcels providing the opportunity for the residents to safely cross the road and make use of the network of footpaths on the edge of Luton and to the south of the Site.

Southern parcel The southern parcel is strongly separated from the AONB by an area of woodland, part of which lies within the parcel. The woodland continues along the south eastern Site boundary towards the M1 Motorway, and lies on the rising chalk scarp to the south and west of the parcel. The height and depth of the woodland would substantially screen potential development up to six storeys in height. In views from Hatters Way towards the AONB, a small, well vegetated corner of the AONB can be seen at the corner of Chaul End Road, when adjacent to the southern parcel. The tree belt along the embankment would filter potential development, and would screen lower storeys in the summer. The fall in elevation of the parcel, and potentially setting any development back from the road and down into the landscape would further reduce the presence of development along the road. This would complement the lower elevations in the northern parcel, and the existing development in the area to the north and northwest, and would further reduce the impact on the AONB.

Land at Hatters Way, Luton (Rev B) 3

There will be no direct effect on the public footpaths in the vicinity of the Site as a result of the development of the parcel. There will be indirect visual effects on the public footpath which lies along the outside of the southern parcel’s eastern boundary which could be mitigated with planting as it establishes. Development of the southern parcel of buildings of up to six storeys in height, subject to setting buildings on lower laying land and strengthening of the boundary vegetation, will therefore have a limited effect on the setting of the AONB.

Overview of Green Belt The Central Bedfordshire and Luton Green Belt Study July 2017 was undertaken by Land Use Consultants (‘LUC’) on behalf of Central Bedfordshire and Luton Borough Councils. It was commissioned as part of the evidence base for the Central Bedfordshire emerging Local Plan, to consider the performance of Green Belt in Central Bedfordshire and Luton Borough against the five purposes as set out in the National Planning Policy Framework (‘NPPF’). The Land Parcels identified in Stage 1 of the Study cover large parcels of land and the Site forms two very small areas on the edge of two of the Land Parcels. The Site’s northern parcel lies on the north eastern edge of Land Parcel D5, while the Site’s southern parcel lies on the northern edge of Land Parcel L6. In Stage 2 of the Study, sub-parcels which made a ‘weak’ or ‘relatively weak’ contribution to the Green Belt purposes were identified within the larger Land Parcels. The land between Skimpot Road and the M1 Motorway to the north of Hatters Way (Land Parcel D5b), which includes the Site’s northern parcel, was assessed as making a ‘relatively weak’ contribution to the Green Belt purposes. The Study concluded that the sub-parcel is: ‘ … too well contained to make a significant contribution to the wider countryside. Existing development within it and its strong relationship with urbanising features mean that it makes a weak contribution to Green Belt purposes. Hatters Way, the M1 and Skimpot Road would form a strong potential alternative Green Belt boundary.’ From our assessment of the Site, both parcels are strongly influenced by their urban edge location, and each is separated from the wider landscape by woodland and roads. The Site benefits from strong boundaries and adjoins existing development to the north and east, and therefore its development could not be considered to add to the sprawl of large built up areas. Hatters Way provides a definitive southern boundary to the northern parcel, while the woodland which encloses the southern parcel separates it from the rest of the landscape to the south. As a result of these boundaries, and its edge of settlement location, the Site plays no significant role in safeguarding the wider countryside from encroachment.

Land at Hatters Way, Luton (Rev B) 4

Conclusion The Site has an urban fringe character, with strong boundaries in the form of Hatters Way and the woodland on the southern boundary. The falling landform and the embanked Hatters Way, with established tree belts, provide containment to each parcel. The impact on the setting of the AONB will therefore be both limited and localised. Given its urban edge location and definitive boundaries the Site could be released from the Green Belt with minimal effect on the five purposes.

Land at Hatters Way, Luton (Rev B) 5

Appendix 8.2 Caddington Park (HAS07) Revised Proposals Plan HAS07

HAS07

N 7 © Crown Copyright and database right. 2017 Ordnance Survey 100049029. W E Proposed Allocation Central Bedfordshire Council. Cities Reealed aerial photograph copright 5 The GeoInformation Grop, 2010 S

957 Land at Caddington Park (HAS07) Version 01 Chells Manor, Chells Lane REVISED PROPOSALS PLAN N Scale: NTS STEVENAGE, SG2 7AA 19/02/2018 T 01438 312130

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