1. Introduction

Showing comments and forms 1 to 17 of 17

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14320

Received: 08/07/2020

Respondent: Mr Andrew Tyrtania

Representation:

A01
P07 - Unsustainable development

Full text:

As if I needed any further incentive to leave the area!
How any educated adult can still be using the words ‘growth’ and sustainable’ in the same sentence beggars belief.

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14321

Received: 08/07/2020

Respondent: Mr Angus McJannet

Representation:

A01
P07
Removal of allocation, HAS33 due to impact on green belt and previous planning history.

Full text:

Inclusion of designated Green Belt Land on Soulbury Road as building land in Local Plan
I wrote to you on 11/2/18 about this. I note from the latest Plan Consultation documents that I receive, HAS33 still remains in the plan.
I will repeat what I wrote in Feb 2018.

This is a most hypocritical, perverse & provocative proposal. And if Central Bedfordshire Council has an ounce of integrity it will remove this site (HAS33) from the Plan. For, but not limited to the following reasons:
1. The proposal was rejected in 2013/2015/2017 on the grounds (and I quote): “it would erode the openness of this Green Belt location and fail to safeguard the countryside from encroachment. It would be outside the natural limits of Leighton-Linslade’s urban boundaries and would be an intrusion into the countryside, detrimental to its appearance and character. As such it was regarded as being contrary to national planning policy.”
2. It borders on the Valley Farm site where Aylesbury Vale District Council have been successfully resisting applications by Paul Newman. To now propose this neighbouring site on Soulbury Road can be classified as building land will be very provocative. Undermining AVDC efforts & no doubt leading to further applications from Paul Newman. Central Bedfordshire Council hardly demonstrates long term strategic thinking therefore.

3. Central Bedfordshire Council had on numerous occasions designated the land as Green Belt. Suddenly external consultants determine the classification isn’t justified and propose downgrading to building land. That’s hypocrisy on behalf of Central Bedfordshire Council and clearly demonstrates the Council adds no value whatsoever and. You pay yourselves on numerous occasions to determine the land is Green Belt. Then in addition to your salaries, pay external consultants to make other decisions for you. Your function is obsolete therefore.
4. Objections have been frequent, numerous & ongoing. Central Bedfordshire Council clearly doesn’t intend listening to the views of the people it purports to represent! Hardly reassuring.
Doubtless Central Bedfordshire Council is considering national building requirements or quotas. Your ongoing priorities though are to the residents, environment & quality of life in the area you allege to represent. By capitulating and doing a total U Turn on this & including this site in the Plan shows how little you really care.
I trust common sense will prevail and this site HAS33 will be reclassified as Green Belt (for all the reasons Central Bedfordshire Council supported before). And that it cannot be used for building now, nor in the future.

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14324

Received: 21/06/2020

Respondent: Miss Kathy Keeley

Representation:

A01
P10
Impressed by and support the vast amounts of work the Council has completed to provide a Local Plan. Only concern regarding the residential development between Shenley Hill Road and Vandyke Road in Leighton Buzzard and how it should remain agricultural land.

Full text:

I have scanned a lot of very lengthy documents on this subject and would like to express how impressed I am that:
• Serious mapping has been done
• Land use has been categorized
• Agricultural land has been classified
• Listed buildings have been noted
• Parks and open spaces are protected
• There is a statement of identification of common land in association with the Highways Agency
• Geology has been considered
• Leisure is taken seriously
• Alternative energy is considered
• Town centres are delineated
However I am concerned about:
• The accuracy of population statistics as many live in the region temporarily and have other homes
• Employment statistics when many work part time and there is a tendency toward overproduction
• Lack of consideration of market forces
• Lack of consultation at a local level through schools, churches, libraries and voluntary organisations (there was some literature in Leighton Buzzard a few years back but nothing has been heard of since)
• Generation of large amount of computerised information which it is difficult for an individual to take in unless summarised concisely in a single page
• Revision of green belt boundaries unnecessarily
• The importance of renovation of existing buildings
• Community development provision in partnership with businesses and community interest companies and statutory providers
• The small number of people putting their names to these documents
• The geographical scale of consultation only being possible by those with access to a small private aircraft
• Variations of age, culture and length of residence should be actively consulted through trusted organizations and individuals to prevent cliques with vested interests dominating consulations.
I feel an organized team of reviewers should scrutinize each document in paper form and check references.
As a user of public transport with no car I can't really comment on road and rail provision except to say what is in place currently seems adequate.
I personally feel that residential development between Shenley Hill Road and Vandyke Road in Leighton Buzzard is not a good idea and this should remain agricultural land.

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14325

Received: 25/06/2020

Respondent: Mr Simon Denchfield

Representation:

A01
P05
Objection to HAS06, North of Biggleswade, on grounds of unsafe access and network capacity.

Full text:

So CBC Local Plan officers, CBC Highways, CBC Planning, Hallam Land Management and their Transport submission don’t think that the inadequate local road network and Potton Road are a problem and that permitting up to 800 additional vehicles to access it is ok.

Well, attached are photographs which demonstrate the highly unsafe and inadequate nature and the extremely dangerous situation that pedestrians, cyclists, wheelchair users and other road users are put through every day. The footpaths are less than 600 mm wide on both sides of the road, HGV vehicles break the 7.5 tonne restricted zone every day, pedestrians are forced to step into the road near a blind bend, cars speed across the bridge and its approaches, the inadequate footpaths are poorly maintained and mothers with children in pushchairs putter lives in danger every time they use this section pf Potton Road. The situation is clearly unsustainable. The current situation is worsening as more and more vehicles use this route to access the A1 north junction, Bedford and Milton Keynes.

Perhaps you can understand why residents feel that the proposed allocation and development will exacerbate the inadequacies and make the situation far far more dangerous and that the HAS06 allocation should be removed from the draft local plan and the Planning application CB/19/04301/OUT should be refused.

Attachments:

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14327

Received: 27/06/2020

Respondent: Mrs Glenys Ingrey

Representation:

A01
P10
Issues regarding different interested parties, experts and local people having no say in development

Full text:

After not having a Local Plan in place on time, CBC provide one which the Inspectors pulled apart. Is this one any different.

CBC admit to not being democratic.

Developments go ahead whatever the local people, Town Cpuncils, experts on all subjects, highways agency, Countryside Alliance say.

Meetings are held in secret and money agreed with developers, there is no reason to go through all the usual rigmarole! What is the point of us locals looking at let alone commenting on the Local Plan. CBC has its own agenda, nothing we say or do can change that..

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14328

Received: 28/06/2020

Respondent: Ms Elizabeth Watkins

Representation:

A01
P10
Believe plan should be postponed until impacts and priorities from and after Covid-19 are known.

Full text:

As a consultee for the above plan, I would suggest the process be postponed until the impact of the pandemic on the project budget and people,s values and priorities post covid-19 are known.

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14341

Received: 22/06/2020

Respondent: Miss Kathy Keeley

Representation:

A01
P07
Allocation between Shenley Hill Road and Vandyke Road should be removed from the Local Plan.

Full text:

See Attachment

Attachments:

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14373

Received: 24/07/2020

Respondent: Everton Parish Council

Representation:

A02
P02
Object to HAS15 & HAS16 (not part of consultation)

Full text:

See attachment

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14493

Received: 10/08/2020

Respondent: Vistry Group

Agent: David Barnes

Representation:

A02
P07
Object to allocation of sites in the Green Belt, propose alternative site.

Full text:

See attachment

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14516

Received: 11/08/2020

Respondent: Hertfordshire County Council

Representation:

A01
P02
HCC comment on the importance of planning for appropriate infrastructure alongside housing.

Full text:

HCC welcomes the opportunity to comment on the Central Bedfordshire Local Plan additional evidence supplied as part of the examination process.
HCC notes that the following documents are the subject of this consultation;
• EXAM 106 - Prologis Park Marston Gate Expansion Scheme Comparison Document
• EXAM 107 - Sundon Rail Freight Interchange Alternative Site Assessment
• EXAM 108 - Biggleswade Holme Farm Planning Design Delivery Analysis Report
• EXAM 109 - Employment Land Update
• EXAM 110 - North Luton LVIA Addendum
• EXAM 111 - Statement of Common Ground between Highways England & Central Bedfordshire Council
• EXAM 112 - Employment Technical Paper
• EXAM 113 - Housing Technical Paper
• EXAM 114 - Transport Technical Paper
• EXAM 115 - Sustainability Appraisal of the Central Bedfordshire Local Plan Supplementary Report
• EXAM 117 – CBC Schedule of Suggested Main Modifications arising from Additional Evidence
HCC wishes to make the following comments;
EXAM 106 through EXAM 112 – HCC has no comments to make.
EXAM 113;
At the regulation 19 stage, HCC noted the options in the plan for building new large communities comprising thousands of dwellings and that the Local Plan covers areas close to the Hertfordshire boundary. Where such new developments in Central Beds are close to the Hertfordshire boundary, residents from the increased Central Beds population may likely cross the boundary into Hertfordshire to access services or to work. This may put pressure on already busy services within Hertfordshire. HCC would therefore need to ensure that no additional strain is placed on the existing services in Hertfordshire as a result of new or increased cross boundary flows of people into Hertfordshire. If this is likely to be the case, Hertfordshire supports the introduction of new services within Central Bedfordshire. Where developments are close to the Hertfordshire border and are likely to place strain on Hertfordshire services, HCC welcomes the opportunity to continue to work with Central Bedfordshire as new developments are progressed.
EXAM 114;
Appendix 1 on Sustainable Transport, paragraph 3.2.3 mentions a transport hierarchy, but it does not mention reducing the need to travel in the first instance, followed by consideration of sustainable modes and then changing the mode of travel. The first bullet point of Policy 1 of the Hertfordshire LTP4 makes this hierarchy clear. This consideration also appears to be absent from the rest of the paper.
EXAM 115: No comments
EXAM 117: No comments
HCC made several comments on the Central Bedfordshire Regulation 19 consultation. HCC would like to reiterate those comments as HCC has no further comments to make on any of the materials presented in this consultation.
We hope the above comments are of assistance to you and we would like to continue to work with Central Bedfordshire to ensure the best outcomes surrounding cross-boundary issues

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14600

Received: 12/08/2020

Respondent: Mrs Anna Maudlin

Representation:

A02
P07
Delete HAS08, impact on character, create traffic issues

Full text:

See attachment

Attachments:

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14606

Received: 10/08/2020

Respondent: CPRE Bedfordshire

Representation:

A01
P06
Raises general issues relating to the democratic process, Appendix 7 sites and justification for loss of Green Belt

Full text:

CPRE Bedfordshire would like to appear and speak at any further “Hearings in Public” should they be deemed necessary by the Inspectors in order to provide more detailed explanations of the comments we have outlined in this response.
1. Introduction
The following are CPRE Bedfordshire’s comments on Central Bedfordshire Council’s Consultation regarding their response to the questions laid out in the Inspector’s Letter to them dated 20 September 2019.
For the sake of completeness we have kept this as a single document but identified within it the relevant EXAM Documents to which our comments and objections relate.
CPRE supports a plan led system and Local Plans which provide a clear framework for sustainable housing growth and employment whilst at the same time protecting and enhancing our countryside.
Good land-use planning is the unsung hero of environmental protection. It can help slow the growth in road traffic, encourage urban regeneration, curb urban sprawl, protect the beauty and tranquillity of the countryside, and safeguard wildlife habitats.
We believe in the benefits of the Green Belt and the intrinsic value of the countryside.
Central Bedfordshire has some beautiful countryside including the northern edge of the London Metropolitan Green Belt, The Chilterns AONB and the Greensand Ridge.
It is our countryside and the “Quality of Life” enabled by it that attracts businesses and people to Central Bedfordshire and Bedfordshire as a whole.
Poorly planned and excessive development can rapidly destroy the very things that make Central Bedfordshire such a great place to live, work and do businesses.
We want the right type of development, which we can all be proud of, in the most appropriate locations which will enhance the very special character of Bedfordshire.
We have made extensive representations to CBC’s previous Local Plan 2035 Consultations on the issues detailed below and would wish to speak at any further Public Hearings should the Inspectors find them necessary.
In our previous response to the Consultation on the Pre-Submission version of the CBC Local Plan 2035 we have indicated the reasons why we consider the Local Plan 2035 to be unsound.
These reasons have not changed due to CBC’s response to the Inspector’s letter.

2. General Comments regarding CBC’s response to the Inspector’s Letter dated 20 Sept 2019 (EXAM 69)
In our view, CBC has, both in its actions since the Hearings ended, and in its response to the Inspector's letter, completely ignored and dismissed the Local Plan democratic process.
This democratic process, enables local residents of Central Bedfordshire, Town and Parish Councils, Environmental Groups, Developers, Land Owners etc. etc. to submit their views at various public consultations during the period of the Local Plan development and then finally at Public Hearings in front of Inspectors.
After hearing all the evidence from all parties, the Inspectors letter to CBC, which is the reason for this current consultation, raised serious concerns regarding many of the key strategic elements of CBC's Local Plan e.g. the need for the A6 - M1 link Road and the chosen route which is entirely in the Green Belt and which slices through the Bedfordshire Chilterns AONB, the need for SA1 North Of Luton, the huge range of development proposed for the Green Belt, the Employment Strategy and many others.
Instead of taking on board the Inspectors concerns, which in many cases reflected those of residents and other stakeholders, CBC just ploughed on regardless - effectively giving themselves planning permission for the A6 - M1 Link Road, despite widespread objections and providing planning permission for development East of Biggleswade, to give just 2 examples. We understand that there are more controversial applications in the pipeline which will be approved before the Inspectors provide their final assessment of the Local Plan.
In effect, CBC has completely ignored the democratic process which residents and other stakeholders have engaged with in good faith, relying on the process to have their cases heard fairly and independently.
What CBC has done is the complete antithesis of local democracy.
In their responses to the Inspectors letter, rather than offering change or compromise, it seems to us that CBC has simply tried to provide justification for almost every area of concern expressed by the Inspectors.

Partial Plan Review (Appendix 7)
Following the Public Hearings and the Inspector’s letter we are still unclear as whether or not the Partial Plan Review which proposed a further 20,000 new homes, has been removed from the Local Plan 2035, as we understood CBC agreed to at the Hearings in Public or, whether it remains as a Policy?
Partial Plan Review
Land West of Luton: 2,000
Land at Tempsford: 10,000+
Land East of Biggleswade: 5,000
Aspley Guise North of railway line: 3,000
Total - Partial Plan Review: 20,000 new homes
We look forward to clarity on this matter.

3. Comments on Additional Evidence (EXAM) Documents
3.1 Exam 112 Employment Technical Paper and Exam 109 Employment Land update
General
These papers reinforce our previously expressed concerns that CBC’s employment strategy is based around the easy option of attracting footloose demand from the logistics and distributions sector.
This strategy is not well founded as: -
(i) The majority of the jobs created by the sector are often low skilled and low paid.
(ii) The trend in warehousing is towards ever higher levels of automation with a subsequently reduced need for labour. So, it may be very difficult if not impossible, to achieve the employment numbers predicted.
(iii) Warehousing is an extremely inefficient user of land.
(iv) Development land within the District is scarce due to the national environmental designations such as Green Belt AOB etc. Additional and unnecessary development pressure should not be placed on these areas of the District
(v) Logistics activity will increase the level of HGV freight movements by road into and out of the sites placing further pressure on the primary road network which is already at or above maximum capacity levels
(vi) Increasing traffic will increase air pollution.
Exam 112 and 109 reinforce these concerns.
In response to (ii) and (iii) above paras 3.2.18 – 3.2.21 of Exam 109 highlight that the employment and site densities previously used when assessing these types of use are now out of date. Employment densities are much lower – the new Lidl warehouse in Central Bedfordshire is expected to provide a ratio of 1 worker per 125sq m (the previous HCA guidance was 1:77sq m).
The use of land is also becoming even less efficient – often with 30% site coverage as opposed to the previous 40% norm.
The documents highlight that CBC are now facing a shortage of true employment land as they have allowed this footloose demand to locate on what was previously proposed non warehousing employment sites.
Rather than try and address this balance and encourage new innovative employment opportunities to thrive and locate to Central Beds, CBC’s proposals are to further remove employment opportunities such as RAF Henlow and allocate more land for strategic warehousing including more land within the Green Belt at North Luton.
This is not strategic long-term planning but a knee jerk reaction to short term market demand.

6.4 Marston Gate Policy SE2
We have commented under Exam 115 that CBC’s assessment of whether to allocate land for strategic warehousing or not does not support the proposed allocation at Marston Gate. In addition, the SA ignores any negative impacts on the land at Marston Gate.
In table 4.3 and 5.3 of Exam 115 there is no recognition of the impact of Landscape (which is shown as positive) and Historic Environment (neutral) despite all the information CBC now has on this site.
It is only as a result of this inaccurate assessment that this site is deemed in para 5.67 in Exam 115 to be one of the best performing.
There is still therefore little justification for this allocation. Our previous comments and comments above highlight our strong concerns for CBC’s employment strategy which underpins this allocation on such a sensitive site.
We have also noted that rather than address the Inspectors’ concerns on this allocation themselves and commission an independent expert to assess this, CBC has continued to use the applicant’s professional team to justify overriding the serious design and landscape issues surrounding this allocation.
This is not an impartial approach.
We do not consider that the additional evidence has addressed the concerns or justified this allocation.
Para 6.3.27 – 6.3.29 A6 – M1 Link Road
CBC state in these paragraphs that:
“The Council has recently granted full permission for this road (January 2020). As such the issues raised within EXAM 69 in terms of the alignment of the road are no longer applicable. Further details on this can be found within the Transport Technical Paper (EXAM 114).”
Surely this cannot be the case? - The issue does not go away simply because CBC has granted planning permission - in this case, in effect, to themselves.
The matter of the alignment of the road is still very much a live issue.
It will slice through the southern edge of the nationally important Bedfordshire Chilterns AONB, is entirely within the Green Belt and will adversely impact 2 “ancient” woodlands (planted before 1600).
CBC has still not provided evidence that it has properly investigated alternative routes.

3.2 Exam 113 Housing Technical Paper & Exam 115 Sustainability Appraisal of the CBC Local Plan – Supplementary Report
Housing Numbers
Exam 115 continues to be fundamentally flawed, by CBC’s intention to accommodate the unnecessarily high growth figures and housing numbers. As stated in our previous evidence we believe these figures are way in excess of what CBC should be planning for in the future and therefore what needs to be accommodated within the Local Plan.
We welcome the Inspectors’ request that CBC consider the most up to date ONS household projections and the impact that this will have on the housing numbers within the Local Plan.
CBC have only just published their response on this issue, and we have not had the opportunity to review this in detail before the submission date of these representations. From an initial read of the documents CBC appear to be using technical arguments to justify the continuing use of their inflated assumptions, particularly relating to Luton’s unmet need. We assume these assertions will be tested fully by the Inspectors.
CBC’s whole rational for Green Belt Release is based on the need to accommodate these housing numbers, and the proposed allocation at Luton North is justified by the agreement to meet Luton’s unmet need. We do not consider that decisions can be made on either of these issues until an agreed position is reached with the Inspectors on housing numbers including the quantum of Luton’s unmet need.

Methodology
We note that CBC has tested further growth scenarios however a number of these Options are based on unrealistic assumptions and we would question the conclusions reached based on this Option testing. In particular the options which assume that the land North of Luton can accommodate 4,000 homes when it was quite clear from the Inquiry and admitted by CBC that this is not the case.
In addition, a wide range of housing units are adopted for Houghton Regis North, some of which are unrealistically low when again these numbers should be clear as these are already housing commitments
Surely sound Option testing should be based on realistic and achievable alternatives

Green Belt Issues
Exam 115 continues to understate and underplay the fundamental purpose of the Green Belt and as such its importance is not reflected in the recommendations and conclusions. Green Belt considerations continue to only features as a subset in 1 of CBC’s 14 Strategic Objectives
The documents still provide no justification as to why CBC have ignored National Planning policy which states that the Green Belt should have been considered as a constraint when setting housing targets.
We are pleased to note that following the Inspectors clear recommendations CBC have agreed to remove 6 of the proposed allocations within the Green Belt.
This still however leaves the proposed release of over 380ha of Green Belt land for housing and over 60 ha for employment.
In removing these allocations CBC has admitted, despite having been through the various steps leading to their initial allocation, CBC were not able to demonstrate the exceptional circumstances required to remove these allocations from the Green Belt. In addition, CBC have also admitted that in some cases they had not fully researched the deliverability of certain sites.
This does not provide any confidence in CBC’s allocation process.
CBC’s explanation for the exceptional circumstances justifying their proposals to release land from the Green Belt are set out in their Green Belt Topic paper dated April 18. In this they justify Green Belt Release through a combination of requirements:
i. To satisfy the overall housing numbers,
ii. Location of sites (close to Luton to meet their unmet need) and
iii. Sustainability issues.
The Topic Paper states in respect of (iii) sustainability issues that “Development within the Green Belt will also bring its own site-specific advantages such as improved infrastructure provision such as schools, roads, healthcare etc”.
However, Exam 115 in considering the benefits of the various growth options, identified the poorest performing options were Option 3 (village extensions) and Option 4 (growth around strategic roads).
Many of the small and medium allocations within the Green Belt are these poorest performing options- village extensions. In many cases they represent significant increases in the built form of these historic settlements and there is no evidence to support the claim that this extra housing will act as a catalyst for additional physical and social infrastructure. They will just add to the pressure on what few facilities already exist.
We fail to understand how these allocations will enable the advantages outlined in CBC’s justification for Green Belt release particularly as evidenced in EXAM 115 they are the poorest performing Option of all the proposed scenarios tested by CBC.
Neither Exam 113 or Exam 115 document makes any effort to consider the various alternatives we have suggested previously to accommodate additional housing without the need to release land from the Green Belt.
In particular we have highlighted the lack of development at Houghton Regis North.
Despite planning permission being given in 2014 and the land being withdrawn from the Green Belt by order of the SoS because he was told by CBC that the new homes were "desperately needed". And, despite the investment of £200m of tax payers money in new road infrastructure completed in 2017 (A5-M1 Link Road and the Woodside Link Road). According to CBC's latest Housing Trajectory (updated Feb 2020) just 50 homes will be constructed during 2020/21 and just 110 new homes will be built in 2021/22.
Over the entire Plan period only 2,828 new homes will be delivered (at a rate of 200 a year) out of the 5,000 planned. This will have taken CBC 21 years to achieve!!
With this as background, it is completely unacceptable that CBC now seeks to withdraw even more land from the Green Belt in order to construct 3,100 new homes at SA1 North of Luton which will require an new Road (A6 - M1 Link Road) which is also entirely in the Green Belt and which will slice through the edge of the Bedfordshire Chilterns AONB.
In our view CBC should be compelled to build-out HRN1 as quickly as possible before Inspectors even consider releasing any further Green Belt land for housing development.
The Inspector of Luton's Local Plan said that HRN1 was the best site to build Luton's additional housing need.
In conclusion, CPRE Bedfordshire fails to see how CBC can justify any “exceptional circumstances” for removing land from the Green Belt. One of CBC’s key priorities within the Strategic Assessment which underpins the Local Plan is to maintain and enhance community and settlement identities.
This was the very reason the Green Belt was established and should remain.

Retention of Harlington Allocation
We are disappointed to note that CBC have not taken the Inspectors’ advice and deleted the Green Belt allocation at Harlington. Others will be making more detailed representations on this however we believe the main reasons this allocation should not remain are:-
• The site would be separated from the village by the railway line (dysfunctional as a village) and would expand towards the Toddington motorway services so reducing the existing gap. This is unsustainable development which will not be supported by services within the village. As previously identified these services were exaggerated during the site assessment process to justify this allocation and identify Harlington as a Minor Service Centre. It is worth noting that since this assessment was carried out the closure of two businesses has reduced that provision further due to the impact of Covid 19. Given the separation from the village and its position on Toddington Road, it is more likely that residents would access the far wider provision of services in either Flitwick or Toddington itself.
• The access to the site and the identified Safer Route to School cannot be made safe by the proposals put forward by the developers, as the measures are not considered deliverable or sufficient. It is not possible to widen footpaths over the railway bridge on Toddington Road or under the bridge on Westoning Road without narrowing already narrow roads (which are unlit) and this could only provide a footpath of sorts to one side of the road. No safe cycling routes are possible and proposed traffic calming measures to address the blind bends on Toddington Road would urbanise this ‘countryside’ entrance to the village Conservation Area and make it unsafe.
• The developer does not own the Green Belt land required to connect the site to Westoning Road via a footpath/cycle path which could not be lit.
• The Increase in housing density to accommodate the school within the site and the proposed number of homes, would be out of character and urbanising on this Green Belt site. It would also result of loss of green spaces within it and be inappropriate and increase the impact on the landscape.
• The site is not directly connected to Luton and therefore against Highways England’s policy to avoid hop on hop off journeys on this stretch of the M1. The M1 is already running at 120% capacity and set to increase to 150% with the addition of allocations in the Local Plan (HRN1 and 2), and not including the other proposals for Green Belt village extensions that would access the M1 at J12 via the A5120 and new allocations of land for warehousing at J11a.
• Nearby Flitwick is being developed as a Transport Hub and has funding for step free access – Harlington has no step free access. NWR were not consulted prior to the inclusion of Harlington in the allocations for the LP, it is therefore unlikely that this has been taken into consideration in forward plans. Not all trains stop at Harlington Station and given the status of nearby Flitwick Station, this is unlikely to change as it would lead to a drop in journey times.

Land North of Luton and M1 A6 link
The documents assume that because this road now has planning permission it will be delivered. This is not the case.
We have commented under EXAM 112 (see pages 4 & 5) on CBC’s assertions that now they have granted themselves planning permission the issues relating to alignment are no longer applicable which is quite clearly not the case.
Of equal concern is whether CBC can fund and deliver the road. Funding for the road is to be provided through a combination of SEMLEP Growth area Funds (£32.75m) and contributions from the developers of the proposed Luton North development and the Sundon RFI. We assume CBC will have to cashflow the project for the time between construction and receiving the developers’ contribution. This will be a significant and risky financial commitment particularly in the current uncertain climate when Local Authority’s funding is under severe pressure.
There are several issues which seriously challenge deliverability of the road and call into question whether it will be built.
Based on information provided by CBC in response to an FOI request we are aware that: -
i. CBC still need to obtain approval from Department for Transport to the Full Business Case for the project before it can be confirmed. This is due to be submitted in November of this year.
ii. A condition of SEMLEP’s Funding is that is must be spent by March 2021. Quite clearly this will not now happen, and no extension has yet been given to this deadline.
iii. The costs of the project are still not known despite CBC having issued a tender for the construction contract. CBC confirmed the construction costs were £64.6m in July 2019 however these have increased and now need to include the costs of mitigations works to J11A, and extensive additional drainage solutions which would involve cross border issues and agreement with Thames Water.
iv. There is no agreement in place with either the developers of the land North of Luton or Sundon RFI on the extent of contributions or certainty over if and when these developments will happen.
v. CBC will need to be responsible for any cost overruns and any shortfall between the cost of the road and the contributions received together with the on- going maintenance costs.
Assuming the SEMLEP funding is granted an extension (and this is not yet confirmed) CBC could therefore be left in the position of having to fund either in the medium or long term a significant cost relating to the Road which we have not seen any evidence they have either the approval or funds to do so.

Employment Strategy Options (section 4)
We note CBC have carried out an assessment of the two Options of either allocating land for footloose demand for Strategic Warehousing or making no allocation.
The conclusions from this do not support the proposed allocations at either Marston Gate or Sundon RFI.
Para 4.41 of Exam115 states:
“The effects of Option 1 on the environmental SA objectives are generally negative. Because strategic warehousing developments are usually large in scale, they can be prominent features in the landscape and any adverse effects on the landscape and cultural heritage, in particular, may be difficult to mitigate.
The nature of these developments also means that they are likely to be located close to the main roads, with many employees likely to travel to work via car with the associated impacts on air quality and greenhouse gas emissions. However, the negative effects are uncertain until the location and design of sites are known, and mitigation proposals are detailed. As the effects at this strategic level of assessment are so uncertain, it is difficult to conclude whether the social and economic benefits of warehouse sites could outweigh the potential negative effects.”
We fail to understand why having highlighted the potential strong negative impacts of strategic warehousing CBC then allocate 2 highly sensitive sites (one of which is within the Green Belt) for this use, knowing full well the impacts this will have. This is not a sound basis for future policy making.
Whilst Exam 115 does highlight the negative impacts of an allocation at Sundon Rail Freight Interchange, which along with three other sites, has the largest number of significant negative effects associated with any one site, it ignores any negative impacts on the land at Marston Gate. In table 4.3 and 5.3 there is no recognition of the impact of Landscape (which is shown as positive) and Historic Environment (neutral) despite all the information CBC now has on this site. It is only as a result of this inaccurate assessment that this site is deemed in para 5.67 to be one of the best performing.
Section 5 of EXAM 15 sets out CBC’s reason for decision making and proposes the retention of the Marston Gate, based on its performance within the SA and the completely inadequate mitigation measures which have been proposed by the applicant and not independently assessed by CBC. This is not a sound impartial decision.

Marston Vale
We remain of the opinion that this proposal is an example of excessive over development with far too many homes planned for the site.
It is entirely within the Forest of Marston Vale which was created to deliver environmentally led regeneration of the area. CBC does not appear to have taken into account material changes since the Local Plan was submitted in 2018.
The additional evidence is silent on changes the Plan should address including: the latest ONS projections of population growth which are much lower than they were in 2018; the adoption by Milton Keynes of its Local Plan which includes development east of the M1; and the Government’s decision to abandon the commitment to the East West Expressway which undermines the justification for development on the proposed scale in Marston Vale.
Marston Vale is assessed as ‘strongly positive’ on sustainable transport.
Building 5,000 houses would more than double the number of car journeys which begin and end here.
‘Sustainable’ transport means that strategic and local roads can cope with the increased traffic and moving people out of cars and onto public transport, cycling or walking. There is nothing in the additional evidence which would support that happening.
There is insufficient weight given to the designation of this site as part of the Community Forest of Marston Vale which functions effectively as a valued environmental amenity and an important contribution to managing climate change.
The Plan involves delivering 25% of the overall need for development from Marston Vale on the grounds that it is located along a strategic route despite the decision to abandon the East West Expressway and ignoring sites on the A6 – M1 – A5 strategic route which has planning permission and is committed to delivery.
It also involves the permanent loss of AONB, green belt and community forest land whilst ignoring opportunities to develop options for expanding existing towns in Area D with access to existing facilities

3.3 Exam 107 Sundon RFI
The proposed RFI is not a Strategic RFI as agreed by CBC, who also admit this site is being provided for the footloose logistics sector. We would draw your attention to Exam30 letter from NWR dated June 2019 in relation to the freight capacity on this line. Given its proposed size and the sensitive nature of the site adjacent to an SSSI and Country Wildlife Site, and the fact that the small RFI itself is unlikely to take substantial freight off the road, there is no justification for GB release as the very special circumstances required have not been demonstrated. This site is also dependent on the construction of the M1 A6 Link through Green Belt, and across the Chiltern Hills AONB, and so the very special circumstances ‘bar’ should be set very high indeed.
CBC are relying on the developers themselves to justify this site as the only one suitable but, apart from the obvious lack of objectivity, this ignores the fact that this site was originally considered as an alternative to the permissioned site at Radlett St Albans, where it has been reported work has now begun. The distance between these sites is negligible in freight transport terms.
Recently what was intended to be a multi-use employment site on land removed from the Green Belt as part of HRN1, has been given planning permission for the sole use of a large Lidl warehouse creating thousands more freight journeys – 2 smaller warehouses have been added on Sundon Road and further warehousing is planned for the North of Luton Urban extension site.
The impact of this additional warehousing on the M1 and J11a and the proposed Link road to the A6, had not been considered when formulating the Local Plan and the proposals for the RFI and warehousing at Sundon Quarry.
These elements of the Local Plan had not been revisited in the lights of changes that have happened since their inception many years ago. Instead the justification has been retrofitted into the LP relying on evidence that has exceeded its sell by date.

EXAM30 Link - https://centralbedfordshire.app.box.com/s/2l2bfd3jh16882klx8vu1391m8g1f4dx/file/560430125059
3.4 Exam 108 Biggleswade Holme Farm
CPRE Bedfordshire are both disappointed with the retention of the strategic warehousing and dismayed at the suggestion that the size of the development is to increase by some 17ha in an open countryside setting with wide ranging views from the A1 travelling North.
The footprint of the proposed development is so vast it would dominate the Southern approach to Biggleswade as well as extending the Town Westwards into open countryside establishing an urban sprawl. It is difficult to understand how any form of landscaping mitigation can be deployed given the size and volume of warehousing structures. Should there be a “real” need to provide and increase warehousing off the A1 a more sensitive and lower cost impact alternative would be to extend the existing Stratton Park Industrial Zone to the East of Biggleswade thus focusing on building out in an Eastwards direction along with other major developments currently being considered. Transportation and access to the Stratton Park Zone is already established and can be extended at a lower cost than erecting a costly footbridge across the A1 to provide access to the services and facilities at Stratton Park for the employees in the proposed warehouse campus.
CPRE Bedfordshire maintain their viewpoint that Policy SE3 is not justified due to its harmful impact on the landscape character and setting of the area West and South of Biggleswade. We propose the lower cost alternative of providing Warehousing capacity if required should be fully explored.

3.5 Exam 110 North Luton LVIA
For reasons previously stated we remain opposed to this allocation. This document is yet again an example of the land promoter’s trying to increase the density of this allocation by impacting on and developing one of the most environmentally sensitive areas of the site. It is not an impartial and independent analysis of this key green belt site.

Attachments:

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14631

Received: 12/08/2020

Respondent: Biggleswade Town Council

Representation:

A02
P06
Objects to the allocation of HAS06 (North of Biggleswade) and the removal of the Appendix 7 sites from the Plan.

Full text:

Biggleswade Town Council has a mature and consistent approach to development. Recognising our town’s strategic location and position in the Oxford-Cambridge Arc, we are aware that future growth is inevitable.

As a Council, we have engaged constructively to plan that when that development comes forward, it is in sustainable locations and accompanied by sufficient infrastructure.

The Town Council’s position has been consistent during the development of the Local Plan and this response to the changes in the Emerging Local Plan, is entirely in line with our previously stated position.

Development South
The Town Council is supportive of economic development to the south of the town, with easy access to the A1. The allocation of this site would enable both Councils to plan for future high-skilled employment opportunities to benefit the town’s residents.

The proposed bridge over the A1 is also welcome – this improved connectivity between the east and west side of the dual carriageway will help to complete the Green Wheel and enhance the town’s network of public rights of way. The rights of way network becomes ever more important to the town as more houses are built. Not only must the existing network be respected but improvements should be made wherever possible. It is also important to improve connectivity to the Town Centre.

Development East
As stated in previous responses, Biggleswade Town Council is supportive of development to the east of the town and welcomes the 1,500 homes becoming a
strategic commitment” to reflect that this is a consented site.

Whilst the commitment to 1,500 homes is welcomed, the Council believes the Local Plan needs to go further and include the full allocation of a further 5,000 homes, effectively reinstating the four villages in Appendix 7. Allocating the full site will enable the town to control and influence future growth through the Local Plan period and beyond.

Whilst the Inspector raises legitimate questions over the ease with which these communities will integrate to the rest of the town, the Town Council is clear that solving this is not insurmountable. As a Council, we are prepared to work constructively with CBC and the developer to ensure that any development comes with innovative and interesting ways of connecting with the rest of the town. Two transport studies, by CBC and the developer, are already underway to understand the possibilities. Although this is a challenge, it should not prevent allocation of the site.

Development North
As should be clear from previous communications and representations at the Examination in Public, Biggleswade Town Council does not support development to the north of the town and is extremely disappointed to see that HAS06 remains part of the Emerging Local Plan.

As a council, we continue to argue that this site is unsuitable for housing, in large part because of the residual impact on the road network in the north of the town – an impact which is very difficult to mitigate, on roads which are already over capacity. The Town Council has engaged transport consultants who have given strong technical support to our arguments – see the submission to CBC re the Development Brief for HAS06.

Countryside Gaps
The Town Council very much regrets the suggestion to remove countryside gaps Land South of Sutton (CG2), Land North West of Dunton (CG3) and Land North of Biggleswade (CG18).

Whilst the council is supportive of development to the east, such development must respect existing settlements and ensure that there is no coalescence with our neighbouring villages. The inclusion of these countryside gaps is important for preserving the identities of Dunton and Sutton.

If the allocation of HAS06 goes ahead against the Town’s wishes, a countryside gap is vital to protect Biggleswade Common and ensure no coalescence with Sandy.

Conclusion
Biggleswade Town Council is not resisting further development – the Council’s approach has always been to engage constructively to ensure that the inevitable future growth is located sustainably, accompanied by sufficient infrastructure and managed sensibly through the period covered by the Local Plan and beyond.

Whilst a number of changes to the Local Plan are welcomed, the retention of HAS06, the removal of Appendix 7 and the removal of the countryside gaps fall far short of the Town Council’s ambitions for Biggleswade and what our residents want for our town.

Attachments:

Comment

Housing Technical Paper [EXAM 113]

Representation ID: 14653

Received: 12/08/2020

Respondent: Luton Borough Council

Representation:

A02
P07
No update on removal of Small & Medium allocations and how this affects Luton's Unmet Need. West of Luton should be an allocation.

Full text:

See attachments

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14690

Received: 12/08/2020

Respondent: Dr Clive Palmer

Representation:

A02
P02
Objection to HAS33

Full text:

You will, I am sure, be aware of the immense controversy and local opposition which has been created by Central Bedfordshire’s seemingly precipitate decision to include what is now known as site HAS33 in proposed small and medium allocations for development under the emerging Local Plan. This matter has come to the fore again in relation to the latest round of consultation on new evidence. As a Leighton-Linslade Town Councillor for the ward in which this parcel of land is situated, I would welcome your response to the following questions:
1. It appears from a response by a CBC spokesman to a local paper (the Leighton Buzzard Observer) that it is regarded that HAS33 is excluded from the round of consultation which ended on 12 August and during which, I know, several representations were made to CBC on this matter. I find it difficult to understand how such representations can be dismissed in this way when a new Housing Technical Paper has been produced making changes to earlier allocations – surely comments on omissions (ie matters within the scope of housing which are left unchanged) are as valid as comments on alterations. Separately, I would welcome your specific assurance that the comments you have received on this matter will be passed to the Inspector.
2. Throughout this whole process, to my knowledge there has been no clear indication of the evidence which led to the 2017 Green Belt analysis conclusion that “parcel has a sense of separation from both countryside and settlement and so makes a moderate contribution to Green Belt purposes” and that it should, therefore be excluded from the Local Plan process, being overturned. Of course, it may be that there is something amongst the vast array of material accumulated during the Local Plan preparation (and here, at least, I would agree with the comments about ease of access to relevant information set out on page 26 of the Government’s recent White Paper about Planning for the Future!) of which I am unaware. It would therefore be helpful to know precisely what this further evidence consists of, by whom it was prepared, and when.
3. In the comments to the local press, it was also stated by the CBC spokesman that there was a full consideration given to the impact on the surrounding area including the environment in assessing the site’s suitability for development. Again, I am not aware of the relevant evidence and would welcome sight of it specifically in relation to this site, and especially in relation to the relevant national and international legislation concerning the protection of bats.
4. A major bone of contention in relation to the allocation of this site for development is the fact that an application to build 49 houses on the site in 2012 (CB/12/02307/OUT) was comprehensively rejected. I am not aware that there has been any relevant change in the planning framework or local environment since then that would have any material impact on the detailed analysis done at that time and the conclusion reached. I would find it helpful to know what the reason now is for an apparent U-turn against this background.
I am sorry that I feel bound to raise these matters and would very much welcome your response, if only to better understand the present position as there continues to be bewilderment and indeed outrage in Linslade over this matter.
I should add that I intend to follow up this matter in more detail also through a Freedom of Information Act request for relevant material relating to points 2 and 3 above.

Object

Housing Technical Paper [EXAM 113]

Representation ID: 14747

Received: 12/08/2020

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

A01

Full text:

This is one of multiple submissions. The attachment letter covers all submissions. The documents are submitted against each consultation document as a separate submission SEE ATTACHMENTS
A01

Support

Housing Technical Paper [EXAM 113]

Representation ID: 14757

Received: 12/08/2020

Respondent: Catalyst Housing Ltd

Agent: RPS Planning and Development

Representation:

A02
P10
The Housing Technical Paper (EXAM 113) is considered to be sound with regard to proposed Site Allocation HAS33 (Land North of Soulbury Road), which is deliverable within the first five years of the plan period.

Change suggested by respondent:

Catalyst agree that proposed allocation HAS 33 (Land south of Soulbury Road) can deliver at least 55 dwellings, in support of the April 2019 revised target supply of housing within the Plan Period for Small and Medium Site Allocations.

Please see accompanying representation letter for further detail.

Full text:

See attachment