Cambridge Strutt & Parker LLP 66-68 Hills Road Cambridge CB2 1LA Telephone 01223 459500 Facsimile 01223 301231 [email protected] www.struttandparker.com Local Plan Team Direct Dial: 01223 459493 Central Bedfordshire Council Email: [email protected] Watling House High Street North Dunstable Bedfordshire LU6 1LF 29th August, 2017 Dear Sir or Madam, Re: Central Bedfordshire Local Plan 2035: Draft Plan Consultation July 2017 I write on behalf of my client, Beechwood Homes in relation to the Draft Local Plan for Central Bedfordshire. These representations relate to land at Middlefield Lane, Henlow, which is also the subject of a current planning application (CB/17/02915/FUL). Introduction The Local Plan provides the basis for meeting the land-use needs of the District up to 2035 in accordance with the Government's economic, environmental and social priorities set out in the National Planning Policy Framework (NPPF). The NPPF (paragraph 14) establishes a ‘presumption in favour of sustainable development’ which means that local planning authorities should positively seek opportunities to meet the development needs of the area and that: “local plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change”. Paragraph 47 challenges local planning authorities to ‘boost significantly the supply of housing’ and ensure that their local plan meets the full objectively assessed needs for market and affordable housing in the market area. It also requires local authorities to identify and update annually a supply of specific deliverable sites, sufficient to provide five years worth of housing, including the identification of key sites which are critical to the delivery of the housing strategy over the plan period. It is noted in paragraph 2.1.1 of the Central Bedfordshire Local Plan that ‘The Luton and Central Bedfordshire SHMA (May 2017) identifies population growth of 19.5% over the plan period to 2035 for Central Bedfordshire’. This is a significant uplift in the population and will require a wide range of types of site in a range of locations, and a range of sizes. Regulated by RICS Strutt & Parker LLP is a limited liability partnership and is registered in England and Wales with registration number OC334522. A list of members’ names is open to inspection at our registered office: 13 Hill Street London W1J 5LQ. …/Page 2 Central Bedfordshire Council 29th August, 2017 Spatial Strategy Approach For the purposes of plan-making, Central Bedfordshire has been divided into four spatial areas based on their geography, characteristics, and functionality. It is noted that the Growth Areas shown in Figure 3.1 (page 35) differ from those shown on the Key Diagram, Figure 8.1 (page 76) in that Henlow and RAF Henlow appeared to be located in Area D (Figure 3,1) rather than the A1 corridor (Figure 8.1). This should be clarified. Paragraph 5.1.1 and 5.1.2 of the Local Plan describes the five growth scenarios that were assessed as part of the evidence base to inform the plan. Scenario 1 proposes ‘higher levels of growth across all of Central Bedfordshire’ (the growth location options in this Plan). The implementation of the Scenario is supported on the basis that it provides the highest levels of growth of the five scenarios and is likely to deliver the most significant economic and social benefits. The Sustainability Appraisal, which underpins the Central Bedfordshire Local Plan 2035 has been used to support the strategy supports growth in Areas A, B and C as having positive effects on housing delivery and employment. It is considered that both Henlow and RAF Henlow should be included in area Area B as they both benefit from a close relationship with the A1 corridor and as such represent a sustainable location for further growth. Policy SP1 states that a minimum of 20,000 new homes will be delivered, however, paragraph 8.2.1 states that the full objectively assessed need is 32,000. Policy SP1 should be seeking to meet the Council’s full objectively assessed need for both market and affordable housing in accordance with paragraph 47 of the NPPF. The Policy then goes on to acknowledge that in addition to the existing committed sites, development will also be bought forward through neighbourhood plans, and through medium and small scale sites in areas B, C and D that will be set out in the pre-submission version of the plan. This approach to small and medium- sized sites is supported my clients site represent one such small scale site. It is considered that the inclusion of a greater number of allocations across the District, including, small and medium sized sites in the smaller settlements, will increase housing delivery, and provide more certainty for local communities and developers. It is unclear at this stage how effectively the development strategy will actually deliver a consistent level of housing growth sites, which are developable with a reasonable prospect that they are available and could be viably developed, over the plan period. The plan places a significant reliance on strategic sites which are notoriously slow to deliver and face significant challenges in terms of their ability to frontload infrastructure. Large parts of the District are also constrained by Green Belt. As such, further small and medium size allocations will be necessary to bring forward sites early in the plan period to maintain housing supply. The implementation section of the Plan (Section 8) acknowledges this and the risks associated with not maintaining a five year housing land supply. The recent Stotfold Appeal Decision (APP/P0240/W/16/3166033) goes to emphasis how quickly the five year housing land supply position can change and the need for Council’s to be ambitious and flexible in their housing allocations. …/Page 3 Central Bedfordshire Council 29th August, 2017 The Housing White Paper, published in February 2017, “Fixing our broken housing market” not only confirms that the country does not have enough homes and that the number of new homes is not keeping pace with the growing population, but has signaled the need for radical, lasting reform to get more homes built now and for years to come. One of the proposed reforms is the introduction from early 2018 of a standardised approach for the assessing 5 year housing land supply and delivery. Such standardised methodology is also likely to impact on the Council’s 5 year land supply position. Land at Middlefield Lane My client’s site is located in the middle of a cluster of existing dwellings between the two villages of Henlow to the north and Henlow Camp to the south. The site can be accessed from Middlefield Lane which connects to Hitchin Road to the north providing access to the neighbouring villages and the wider road network. The Centres of the villages of Henlow and Henlow Camp are respectively 1.2 km and 1.4 km from the application site. They can both be reached on foot by way of the existing pavement which runs along the southern side of Hitchin Road. This footway is also lit by streetlights between the site and the village of Henlow. Both villages contain an extensive range of services and facilities including; schools; shops; public houses; restaurants and cafes; doctors; employment opportunities, access to public transport and community facilities. Arlesey railway station is only 2.3 km away providing regular main line rail connections. The development of this site would see the infilling of a logical gap within the surrounding loose knit group of residential properties for a small scale residential development of 8 units. The site is naturally contained by its established boundary hedgerows and trees which will all be retained, except where it is necessary to create new pedestrian and vehicular access points. While there are agricultural fields beyond the adjoining dwellings and their gardens, the site does not actively demonstrate a countryside character but is more akin to the extended garden land which makes up much of the local character of the area. The development of this particular site would not be visually intrusive in the wider landscape. While it is acknowledged that the site is outside of any settlement envelope paragraph 55 of the NPPF acknowledges that where there are groups of smaller settlements, development in one village may support services in a village nearby. Whilst it cautions against isolated homes in the countryside, the application site is not considered to be isolated. The Housing White Paper also acknowledges the recent decline in small and medium sized builders and the important contribution that this sector can make to overall housing delivery. It sets out measure to reinvigorate this sector of the housebuilder market to help the sector develop and grow. Beechwood Homes are already part of this sector and need to maintain a supply of deliverable sites to ensure their economic prosperity. The importance of the inclusion of small and medium sized sites to housing supply should not be underestimated. For the reasons set out above it is considered that my client’s site should be included as an allocation I the pre-submission version of the plan. …/Page 4 Central Bedfordshire Council 29th August, 2017 I trust that these comments will be taken into consideration when drafting the new Local Plan. Yours faithfully, Adam Davies Associate Strutt & Parker LLP Enc Site Plan 0 10 20 30 40 50m 0 10 20 30 NORTH 40 50m 3 CLOSE 1 HENLOW 187 MIDDLEFIELD 206 - 39.6m Cedar Cottage Track MIDDLEFIELD ROAD LANE LANE HITCHIN 659 B Proposal Site 225 MIDDLEFIELD PROJECT. LAND OFF MIDDLEFIELD LANE & SCALE. 1:1250 @ A3 HITCHIN ROAD, HENLOW, DATE May 2017 CLIENT. BEECHWOOD HOMES LTD DRAWN.