Central Bedfordshire Pre‐Submission Local Plan 2035 Consultation Land east of Leighton Road, Toddington February 2018 Contents 1. Introduction 3 2. Response to Local Plan ‐ Strategy and Housing Numbers 4 3. Response to Local Plan – Site Specific 12 4. Response to Local Plan – Development Management Policies 29 5. Conclusion 40 Appendix 1: Site Location Plan 42 Appendix 2: Landscape & Visual Appraisal 43 David Wetherill Client Taylor Wimpey UK Ltd Our reference TAYR3035 February 2018 1. Introduction 1.1 These representations have been prepared by Turley on behalf of Taylor Wimpey UK Ltd in respect of the Central Bedfordshire Pre‐Submission Local Plan 2015‐2035 consultation (January 2018). 1.2 Our client has important land interests in the Local Plan area, in particular at Toddington. As such this response focuses on issues particularly affecting Toddington. 1.3 Each of our responses relates to a particular policy or paragraph and this report is structured accordingly. 1.4 We can confirm we wish to appear at the Examination in Public in due course and look forward to continuing to engage with the Local Plan process. 2. Response to Local Plan ‐ Strategy and Housing Numbers Chapter 2: Key Themes Objectively Assessed Need 2.1 The Local Plan has been informed by the Luton and Central Bedfordshire SHMA (December 2017) which calculates the full Objectively Assessed need (OAN) for housing in Central Bedfordshire to be 31,778 dwellings over the period 2015 to 2035 (1,589dpa). For Luton the OAN is calculated to be 18,810 dwellings over the Plan period (940dpa). 2.2 The Government published a draft new standardised methodology for calculating housing need in September 2017. Applying this methodology would result in a significant increase of 60% in the number of homes that would be required to be delivered (1,589dpa – 2,553dpa) to meet just Central Bedfordshire’s own housing need. The consultation documents made clear that Plans submitted before the end of March 2018, or prior to the publication of the NPPF (whichever is the later) could continue to be prepared on the basis of previous OAN assessments. Plans submitted after this time would need to be prepared in accordance with standardised methodology in its final form. 2.3 The Council’s Local Development Scheme (December 2017) confirms the Council’s intention to submit the Plan in March 2018 and in this scenario the calculation of housing need will fall under the old methodology (1,589dpa). Whilst the timetable for the publication of the NPPF has been delayed, with this now scheduled for summer 2018 with the ‘cut off’ point for submission of Plan’s under the old OAN methodology delayed accordingly, it is understood that the Council intend to continue with its current stated programme. 2.4 In light of the above, the Council have proceeded with the preparation of the Local Plan on the basis of the OAN proposed in the SHMA of 31,778 dwellings over the plan period to 2035. The overall housing target proposed by the Local Plan is 39,350 dwellings, including 23,528 homes that are already planned for or built and a proportion of ‘unmet housing need’ from Luton. 2.5 In respect of the new standardised methodology, the Local Plan at paragraph 1.4.1 states that: “The Council consider that while the OAN is likely to rise over time further work is needed on factors specific to Central Bedfordshire before a new approach can be supported and is looking to commission additional studies for the relevant Housing Market Area, together with neighbouring authorities.” 2.6 There is an apparent reliance on an early review by Central Bedfordshire as part of the Local Plan preparation to account for a number of changing circumstances that are already anticipated towards the start of the plan period. 2.7 The background to these ‘changing circumstances’ relates to planned infrastructure improvements, including East West Rail/Expressway. Paragraph 5.5.4 of the Local Plan states: “The Partial Review is proposed to start within six months of adoption of this Plan and complete as soon as decisions on routeing and financial commitment to strategic infrastructure are in place.” 2.8 Whilst we have no objection to the principle of a commitment to an early review of the Local Plan, an approach which has now been accepted in a number of Local Plans, it is important that where decisions can be reached under the current Local Plan process they are not artificially pushed‐back to a future review. We recognise the challenges, and significant opportunities, represented by the Cambridge‐Milton Keynes‐Oxford Arc and support the recognition that the Council needs to respond positively to this. In considering the Arc it is important that Central Bedfordshire also considers the opportunities and challenges faced by both neighbouring authorities and those located in the wider Arc. At this time it is unclear what form any strategic governance arrangement for the Arc would take, although it is noted that the Oxfordshire authorities have secured a growth deal and will be preparing a Joint Spatial Plan which will inform the separate Local Plans for each authority. It is important that the Council therefore consider the wider relationships. 2.9 As a justification for ‘changing circumstances’, whilst the Council refer to planned infrastructure improvements in paragraph 5.5.4, no reference is made to the further implications of the new standardised methodology. Assuming the methodology as originally consulted upon is implemented, the new methodology would lead to a 60% increase in the number of homes that would be required to be delivered per annum for Central Bedfordshire ‐ in addition to any unmet housing needs from the neighbouring authorities such as Luton (set to increase from 890 to 1,417dpa) which it agreed to accommodate. This is a significant increase for both authorities over the plan period, and one which both authorities should be alive to as part of this Local Plan preparation process. 2.10 At present the Council are adopting a cautionary approach to need. It is important that there is flexibility for the towns and villages to accommodate additional development where needed and appropriate, in order to ensure the “continuous delivery of homes in the short to medium term and enable the Council to maintain a rolling 5 year housing land supply” (paragraph 5.3.1). Whilst the Council considers that it is proposing to allocate sufficient sites in the Local Plan to meet the OAN as identified in the SHMA, given the inevitability that the Council’s housing requirement will increase, where sites are shown to be suitable and deliverable, there is no justification as to why these sites should not be allocated through the current Local Plan process. Indeed, given the scale of some of the proposed allocations, with their associated longer lead‐in times, it is important that a range of sites are proposed to ensure delivery across the Plan period. 2.11 Whilst we support the Council’s commitment to undertaking a Green Belt review as part of its new Local Plan, it is important to recognise the requirements of paragraph 85 of the NPPF. As such, in reviewing the Green Belt boundaries the Council must consider not only the current proposed Local Plan requirements but also the need to meet longer‐term development needs stretching well beyond the plan period. 2.12 On the basis of the current draft Local Plan, concern is raised that adequate assessment has not taken place to assess the potential of sites to meet longer term needs. As such it is anticipated that further Green Belt release will be required under the Local Plan partial review and the boundaries subject to further review and amendment, contrary to the requirements of the NPPF. Where sites are shown to be appropriate for Green Belt release, suitable and achievable, the Local Plan should be looking to allocate these sites at this stage either as full allocations for development or safeguarded sites to meet future needs. 2.13 Clearly, the implications of the new standardised methodology will be significant. For example a 60% increase in the number of homes that would be required to be delivered per annum for Central Bedfordshire ‐ in addition to any unmet housing needs from the neighbouring authorities such as Luton (set to increase from 890 to 1,417dpa). The draft Local Plan rightly focuses the “delivery...of some unmet need from Luton close to where it arises”. No provision has been made as to how future needs could be met, particularly in the “South Area” closest to Luton, which is contrary to the requirements of the Framework. Duty to Cooperate and Unmet Needs 2.14 There is an acknowledgement of the relationship the authority has with the wider area and the need to both meet the requirements of the Duty to Cooperate, and to fully address the challenges and opportunities which the area faces, particularly in light of its strategic position at the heart of the Cambridge‐Milton Keynes‐Oxford Arc as discussed above. 2.15 Whilst the SHMA itself covers the authority areas of Luton and Central Bedfordshire, it is important to note that Central Bedfordshire is in fact split across four functional Housing Market Areas (HMA). The largest number of Central Bedfordshire residents live in the Luton functional HMA. Almost 99% of the resident population currently living in the Luton housing market area were identified to live in either Luton Borough or Central Bedfordshire. 2.16 The SHMA (December 2017) apportions the joint OAN across the four HMAs as identified on the diagram below. 2.17 Clearly Central Bedfordshire has a strong functional relationship with Luton Borough in particular.