CENTRAL BEDFORDSHIRE LOCAL PLAN 2035 PRE-SUBMISSION CONSULTATION REPRESENTATIONS ON BEHALF OF MR & MRS R KNOX AND MR & MRS M RICHARDS IN RESPECT OF PROPOSED ALLOCATION HAS26 – A5 WATLING STREET HOCKLIFFE 1. INTRODUCTION 1.1 J & J Design have been engaged by the representors to challenge the draft allocation HAS26 at A5 Watling Street Hockliffe for residential development. 1.2 The proposed allocation is for approximately 41 dwellings on 1.74ha of greenfield land currently designated as Green Belt, on the north-west fringe of Hockliffe. 1.3 The representations raise issues including: a. The soundness of the spatial strategy and the ongoing role of the Green Belt; b. Whether ‘exceptional circumstances’ have been demonstrated to justify alterations to Green Belt boundaries; c. Whether Hockliffe has the capacity for sustainable growth within the A5 transport corridor, and if so to what extent; d. Whether the proposed allocation site is appropriate having due regard to Green Belt, environmental and historical considerations; e. Whether there is justification for Hockliffe to be designated as a Large Village in the Settlement Hierarchy. 1.4 It is concluded that the draft allocation fails the soundness tests at paragraph 182 of the Framework, being unjustified and inconsistent with national policy. Accordingly, the proposed allocation should be deleted from the Local Plan. 1.5 Furthermore, it is concluded that there is inadequate justification for Hockliffe to be designated as a Large Village. Accordingly, Hockliffe should be re-designated as a Small Village. 1 2. THE PROPOSED ALLOCATION 2.1 The proposed allocation site reference HAS26 is identified as part of draft Policy HA1 : Small and Medium Allocations, as follows: Site Area Parish Approx Approx Site Additional Name density capacity Area Policy (ha) requirements (where applicable) A5 South Hockliffe 30 41 1.74 Landscaping will Watling need to be Street sensitive to nearby listed buildings and the setting of the Scheduled Monument 2.2 The proposed allocation arises from Representation 6833 and the associated letter of Savills dated 29 August 2017, on behalf of Bedford Estates, promoting a larger landholding of 6.35 ha extending along the north- west frontage to Woburn Road (B5704). 2.3 The proposed allocation site is bounded by Hockliffe Lower School and Clipstone Brook to the south-east, A5 Watling Street and residential development to the south-west and open countryside to the north. There is no existing northern boundary. 2.4 The proposed allocation site is permanent grassland meadow normally utilised as open grazing. 2.5 The proposed allocation site has no previous planning history. 3. PLANNING POLICY HISTORY 3.1 Hockliffe lies in the former area of South Bedfordshire, where the extant adopted development plan is the Saved Policies of the South Bedfordshire Local Plan Review (2004). 3.2 In 2005, prior to local government reorganisation. Luton Borough Council, South Bedfordshire District Council and Bedfordshire County Council promoted a Joint Luton and South Bedfordshire LDF to cover the whole of Luton and South Bedfordshire. The Joint Core Strategy (JCS) was submitted for examination in March 2011 but withdrawn in July. 2 3.3 Subsequent upon the local government reorganisation in April 2009 when the former Mid Bedfordshire District Council merged with South Bedfordshire District Council to form the unitary authority Central Bedfordshire, the Council promoted a draft Development Strategy for Central Bedfordshire 2014. Following initial hearing sessions in 2015, the Inspector concluded that the Council had failed to comply with the Duty to Co-operate. After litigation, the submitted Development Strategy was formally withdrawn in November 2015. South Bedfordshire Green Belt 3.4 The history of the South Bedfordshire Green Belt is set out in Section 2 of the South Bedfordshire Local Plan Review (2004) at paragraphs 2.1-2.10. Salient points include: 1960 – Bedfordshire CC submitted a sketch plan for the proposed Green Belt to the Minister of Housing and Local Government. 1976 – Bedfordshire CC published the consultation draft County Structure Plan including Policy 12 – Green Belt. 1987 – Beds CC amended the Structure Plan policy to exclude five villages of Barton, Toddington, Eaton Bray, Caddington and Slip End from the Green Belt. Heath and Reach was subsequently excluded from the Green Belt on the adoption of the Leighton-Linslade and Heath and Reach Local Plan 1987. 3.5 A Green Belt boundary was proposed around Hockliffe for the first time in the extant Local Plan Review (2004). The Green Belt boundary was drawn tightly around the urban form and terminated at the Clipstone Brook on the north-west of the settlement. Two previously developed sites were allocated for housing development within the excluded area. Both have been implemented. 3.6 The adopted South Bedfordshire Local Plan Review (2004) did not include a formal settlement hierarchy but Policy GB3 set out a village categorisation in terms of the Green Belt. Hockliffe Neighbourhood Plan 3.7 The Hockliffe Neighbourhood Plan 2017-2035 Consultation Draft (NP) was published in September 2017 for a six week consultation period. Hockliffe Parish Council are currently considering the consultation responses, prior to formal submission to Central Bedfordshire Council. 3.8 The draft NP recognises that Hockliffe is an appropriate location for some new housing, subject to investment in essential community infrastructure. In the absence of the local referendum, it is unclear whether this is supported by a majority of local village residents. The representors suggest that the local residents may not concur with the NP in this respect. 3 3.9 The NP accepts that the scale of new development, the allocation of housing sites and the related consideration of Green Belt boundaries will be undertaken through the emerging Local Plan. Subject to these criteria the NP concludes that Hockliffe can accommodate up to 170 homes. 3.10 The NP identifies five preferred locations for future new housing development for a total of 170 new dwellings.1 These sites do not include the proposed allocation HAS26. Central Bedfordshire Local Transport Plan (LTP) 3.11 The LTP for Central Bedfordshire covers the period April 2011 to March 2026. The overall LTP is broken down into 10 Local Area Transport Plans (LATP) which set out the key transport issues and concerns of local people. 3.12 The LATP for Heath and Reach, Toddington and Barton-le-Clay includes Hockliffe. The plan is based on three Areas of Delivery. The relevant Area of Delivery is Heath and Reach, Hockliffe and Stanbridge, which include the parishes of Egginton and Tilsworth. 3.13 The LATP describes Hockliffe as a linear village dominated by the A5 trunk road running through its heart. Whilst the village does have its own Lower School on Woburn Road (B5704), residents rely on nearby Service Centres such as Leighton Buzzard and Dunstable for all main services. 3.14 The A5 Watling Street is the major transport link in Hockliffe, and is a strategic link of national importance, providing direct links to Milton Keynes and Dunstable. These links are supplemented by A4012/B5704 which provide a north-east to west link to places such as Woburn, M1 junction 13 and Leighton Buzzard. 3.15 Within the LATP area, travel-to-work modes are dominated by the private car (85%). Levels of out-commuting are also high with 51% of journeys to work outside the local area. Commuting destinations include Leighton Buzzard, Hertfordshire, London and Milton Keynes. 3.16 The LATP confirms that Hockliffe is completely dominated by vehicular traffic, resulting in an environment which is hostile towards pedestrians. The A5 is a heavily-trafficked route with a local 40mph speed limit. Whilst pelican crossings are provided and footways are of adequate width, traffic volumes, speed and congestion discourage pedestrian use. The A4012 also brings similar issues, particularly accessing Hockliffe Lower School. Whilst Woburn Road (now B5704) has a lower speed limit (30mph), traffic volumes, congestion and narrow pavements combine to provide a hostile pedestrian environment. 3.17 Despite its location on a strategic transport corridor, public transport services in Hockliffe are poor. Centrebus X31 provided a two hourly service between Central Milton Keynes and Dunstable but the service was withdrawn in December 2017.2 Service 169 Leighton Buzzard – Toddington – Houghton Regis provides two services daily each way on College days only. Service 74 provides five services daily between Hockliffe and 1 Hockliffe Neighbourhood Plan – Policy DP2 2 CBC website – Public Transport – bus timetable changes January 2018 4 Dunstable. Service 47 provides two services on Monday, Wednesday and Fridays on the route Woburn to Leighton Buzzard via Tilsworth and Egginton. Marshalls Coaches provide two outbound morning and three return evening journeys between Leighton Buzzard – Hockliffe – Dunstable – Markyate – London. The nearest railway station is at Leighton Buzzard, some 8km to the west, which offers four trains per hour on the Euston – Watford – Milton Keynes route, with reduced service onwards to Northampton and Birmingham. Plusbus rail-bus integration is available from Leighton Buzzard but does not extend to Hockliffe. 3.18 In 2008, the Highways Agency (now Highways England) estimated that the A5 in Hockliffe was operating at between 110% and 130% of capacity, leading to delays when entering Dunstable and in Hockliffe at peak periods. By 2026, it is estimated that the A5 will be operating at 150% of capacity as a result of increasing travel demands. This includes the impact of the A5 to M1 (Junction 11a) link road. 3.19 The LATP has identified the following priorities for action in Hockliffe: - Congestion at A5/A4012 junction creates air quality issues and poor pedestrian crossings - Narrow pavements and on-street parking in Woburn Road creates poor pedestrian environment - Volume/speed of traffic resulting in poor pedestrian and cycling environment - Poor pedestrian permeability across A5 to the south of the village - Poor sightlines at junction between Chalgrave Road [Tebworth Road] and A5 resulting in road safety hazard 4.