CENTRAL BEDFORDSHIRE LOCAL PLAN CONSULTATION – AUGUST 2017 On behalf of Bellcross Company (including Bellcross Homes and Kensworth Builders Ltd) 25th August 2017 INTRODUCTION 1. The following representations are made by Rapleys on behalf of the Bellcross Company (including subsidiaries, Bellcross Homes and Kensworth Builders Ltd) in respect of their land interests within Central Bedfordshire. 2. The land interests are fourfold – Land off Parkside, Houghton Regis, comprising some 13.8ha being promoted for residential development; Land off Trafalgar Drive, Flitwick, comprising some 7.3ha being promoted for residential development; Land off Dunstable Road, Caddington, comprising some 46ha, part of which is being promoted for residential development; and Land off Chalton Heights, Chalton, comprising some 14ha being promoted for mixed residential/employment/roadside development. 3. All four sites have previously been promoted through the iterations of the Local Plan and call for sites exercises. Rapleys welcomes the opportunity to participate in this consultation exercise and provide the following comments below in respect of the Councils draft Local Plan. 4. The representation commentary focusses in generic terms on the overall strategy being considered by the Council, as this is a major element of this consultation and should be read in that context. It is important to get this right rather than be too centred at this stage on the more general development control policies such as affordable housing, open space provision, etc. We reserve the right to provide further comment on these matters at the appropriate time (i.e., the next consultation). Separate comment is then provided in respect of each of the client sites. GENERAL OBSERVATIONS IN RESPECT OF HOUSING NUMBERS 5. The SHMA estimates Central Bedfordshire's housing need as 32,000 dwellings 2015 to 2035. The Draft Local Plan covers the period 2015 to 2035 and is therefore consistent with the SHMA. The publication of the initial Strategic Housing Market Assessment (SHMA) for Luton and Central Bedfordshire is welcomed as it demonstrates the Council’s intention to meet the objectively assessed development needs of the plan area. In addition, it is recognised that the Council is also fulfilling its Duty to Co-operate by joint working with Luton Borough Council in looking to meet their unmet housing needs. However, whilst the background SHMA work deals with the Duty to Co-operate with Luton in particular, it is not clear whether the Council has undertaken the Duty to Co-operate requirement with the Greater London Authorities into account as well. Essentially, if not, why not? Such consideration may affect the overall housing need. 6. The use of the latest population data through the use of the CLG 2014 based household projections is supported. 7. The SHMA identifies that the annual average OAN of 2,550 dwellings is notably higher than the recent rate of housing delivery in Luton and Central Bedfordshire over the 10 year period from 2001-11 which averaged about 1,320 dwellings each year. Therefore, there is a required step change in the delivery of housing over the forthcoming plan period. Consequently, the strategy for delivering this growth has to be sound and deliverable – see further comment on this under the ‘Strategy’ section. 8. The latest Five Year Housing Land Supply and Trajectory is dated July 2017 and is based on the latest 32,000 dwelling figure endorsed by the SHMA equating to 1,600 dwellings per annum. Over the first 2.25 years completions were 3,710 against the requirement of 3,600, i.e., a surplus of 110 dwellings. This leaves 28,290 dwellings to be found, equating to a five year requirement with 5% buffer of 8,367. RAPLEYS LLP 1 9. Supply is significant at 20,506 excluding completions and the 2,550 dwellings that are anticipated after 2035. The 5 year supply equates to 9,625 dwellings giving 5.75 years overall. 10. The housing trajectory appears unbalanced towards the first 5 years (9,625 completions) (the remaining 13 years total 10,881 dwellings). Once the April 2017 completions data is available a comparison can be made to see how realistic the trajectory is and we reserve the right to be able to do this. 11. There is a good variety and spread of sites, with the land supply not dominated by a single site. However, half of the supply is in 3 locations (4,830 at North of Houghton Regis, 2,430 east of Leighton Linslade and 3,500 at Wixams). THE PRINCIPLES OF THE DEVELOPMENT STRATEGY Strategic Options: Scenarios for Distributing Housing Growth 12. In developing the Strategy for the Local Plan the Council has divided the administrative area into four broad planning locations, A-D and considered five development scenarios. This demonstrates that the Council intend to produce a plan that addresses the objective of contributing to the achievement of sustainable development by systematically taking into account the environmental, economical and social impact of proposals, alongside the consideration of alternatives. Overall this is welcomed. 13. All four client sites identified above lie within Area A. Area A lies entirely within the Green Belt and is focussed in the south-west part of the district around Luton/Dunstable/Houghton Regis and Leighton Linslade. Specifically, in terms of settlement hierarchy, Houghton Regis and Flitwick are Major Service Centres (and settlements inset from the Green Belt), Caddington is a Minor Service Centre (inset from the Green Belt) and Chalton is a Small Village (washed over by the Green Belt with infill only boundaries). 14. Four of the five development strategy scenarios looked at by the Council propose growth within Area A. It is noted that one scenario avoided growth in the Green Belt altogether. However, this has been discounted, notably because it would not assist in meeting the considerable unmet need for Luton, which CBC is bound to do under the Duty to Co-operate. It makes logical planning sense to seek to provide for Luton’s unmet needs (purported to be around 7,350 dwellings over the plan period) as close to Luton as possible – this inevitably means development within the Green Belt within area A. Consequently, a strategy which includes development in area A is supported. 15. Furthermore, the Sustainability Appraisal which sits behind the Local Plan assesses growth in area A as having a major positive effect on the housing objective which seeks ‘to ensure that the housing needs of all residents and communities are met’ (Table 5.1). This conclusion is supported, as whilst the area A is located within the Green Belt, it does have the potential to deliver sustainable housing growth close to existing infrastructure at the main town locations of Luton, Houghton Regis/Dunstable and Leighton Linslade, as well as the rail corridor between Luton and Flitwick as identified at Local Plan paragraph 5.1.6. 16. The importance of the sustainability of area A cannot be over-emphasised, particularly in the context of the level of growth that has been identified as necessary through the SHMA and Objectively Assessed Needs (OAN), and the proposed development strategy being considered. Strategic Growth Locations 17. The growth strategy is identified in Policy SP1, setting a minimum requirement of 20,000 dwellings to be delivered over the plan period, in addition to the 23,000 commitments already in the pipeline. 18. The strategy, which reflects the scenario where there is higher levels of growth across the whole of the district, essentially consists of: North of Luton - 4,000 dwellings (Area A); RAPLEYS LLP 2 Limited extensions to towns and villages within the Green Belt - 2,000 dwellings collectively (Area A); West of Luton- 2,000 dwellings (Area A); 7,000 houses in a new town at Tempsford (Area B); 3,000 houses east of Biggleswade in new villages (Area B); 2,000 houses east of Arseley (Area B); Some 8,000 houses in ‘new villages’ within the Marston Vale/Aspley Guise rail corridor (Area C); 500 houses at Wixams (Area C) and Mixed use (Upto 250 houses) at RAF Henlow (Area D). 19. It is noted that the policy states that ‘subject to further assessment of sustainability and deliverability, new development will be planned for at a selection of these locations’. In other words, not all of the identified locations will be taken forward in the Local Plan. The following observations are offered up on this: (i) On one level, this raises questions about the robustness of the Sustainability Assessment already carried out to identify these locational options. It also raises questions about the findings of the assessment, particularly in relation to sites that are not being progressed, or options that have been overlooked, notably in the Green Belt, where, despite the conclusion of the Sustainability Appraisal overall that development should take place within the Green Belt, all options to identify strategic growth on the edge of Green Belt Towns and Villages appear to have been discounted at this stage; (ii) The locations selected for what is major growth do not follow the settlement hierarchy identified in section 10 of the Plan. For example, eight settlements are ‘Major Service Centres’ including five in the Green Belt (Area A). However, only two (both outside the Green Belt), Biggleswade and Wixams, are singled out for specific strategic development – a potential total of 3,500 dwellings. (It is acknowledged that Houghton Regis/Dunstable and Leighton Linslade already have a large number of committed dwellings in the pipeline and further development here beyond their defined physical extent at this stage would be inappropriate – time is needed to deliver these houses and for associated communities to be formed). A disproportionate number of dwellings are potentially identified to come forward in larger villages – some 8,000 as new villages in the Marston Vale/Apsley Guise area between the Green Belt and Bedford.