Central Bedfordshire & Luton Green Belt Study

See attachment for comments from Harlington Parish Council

I am suprised by characterisation in Fig 5.1 as part of of parcel T4B as relatively weak performing and question whether an adequate field visit was undertaken. T4B is seperated from village by well defined features especially trees, is an area of particular open amenity land and borders a stream in a valley and wildlife sites (which are among trees so perhaps missed on field visit?), whereas T4A an open field probably the only site around Toddington suitable for housing development. At the very least the eastern part of T4B is an obvious candidate to be a Local Green Space.

We generally support the assessment of site C4 identified in the Councils Green Belt Study and how it is then applied in the Growth Options Study. We do, however, question the "moderate contribution" assessment against Purpose 3 and consider that this should be revised to "Relatively Weak" to reflect the character of the land which includes a mix of uses (including housing) but which is clearly contained within long term boundaries.

I agree with section 4.91 that Tilsworth should remain Greenbelt and not be suitable for future development.

These representations are submitted on behalf of City and County Projects, who are promoting a site east of Chauntry Way, Flitwick (Reference NLP245) as detailed in the Call for Sites submission for it. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests, including on the Site Assessment Form for this land included in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, City and County Projects must object to the current conclusions reached in the Central Bedfordshire and Luton Green Belt Study. This is specifically in respect of how they relate to the land being promoted by them east of Chauntry Way will now be explained.

Stage 1 of the Green Belt Study involved a review of fairly wide parcels around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, these have been specifically identified and the discrete parcels considered further in isolation at Stage 2 of the Study.

Our clients' land east of Chauntry Way has not been identified separately within parcel FW1 and because this wider parcel was assessed as making a moderate contribution to assisting in the safeguarding of the countryside and a relatively strong contribution to preventing neighbouring towns from merging into one another it has not progressed beyond Stage 1e of the separate Site Assessment process.

City and County Projects object in the strongest terms to this conclusion. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which site NLP245 contributes to the purposes of including land in the Green Belt, finding as follows:

* The site does not fulfil the purposes of preventing the sprawl of a large built up area - the same conclusion was reached in the Green Belt Study on parcel FW1

* The contribution the site makes to preventing neighbouring towns from merging into each other should be 'relatively weak'. This is due to the strong visual barrier already created by existing trees along the A507 corridor and as development of the site would not make the existing gap any smaller.

* The Green Belt Study assessed the whole of land parcel FW1 as making a 'relatively weak' contribution to preserving the setting of Ampthill. This is also true of site NLP245 in isolation.

* The contribution site NLP245 makes to safeguarding the countryside from encroachment is considered to be relatively weak, compared to the moderate contribution the wider parcel FW1 makes. This is because site NLP245 is visually more closely associated with the urban area of Flitwick than it is with the rural Green Belt. It is visually separated from the open countryside by the belt of trees that runs along a small watercourse on the western boundary. Furthermore, development of the site would extend the village envelope little further to the east than the extent of the built up area to the immediate south (made up of the dwellings on Admiral Row and roads off it) and the football club facilities to the immediate north.

The Green Belt Statement demonstrates that there are very strong arguments that the site should be removed from the Green Belt and allocated for new housing. It illustrates that a robust new Green Belt boundary could be created at the eastern edge of the site utilising the existing physical feature of the water course and associated tree belt, which would provide an enduring new boundary.

As has been argued separately in the representations on the Local Plan itself, this is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP245 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

I fully support this policy on behalf of the owners of site ALP207

These representations are submitted on behalf of ours clients, Messrs Olney, Willis and Butterworth, who are promoting land south of Rectory Road, Steppingley (Site reference NLP085). Separate comments are submitted on the Draft Local Plan and other Technical Documents published with it that are relevant to our clients' interests, particularly the Site Assessments Technical Document and the conclusion reach on site NLP085.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. However, our clients object to the decision to effectively limit the Green Belt review to around Large Villages and towns and to exclude Small Villages such as Steppingley through the criteria utilised in the Site Assessment Technical Document, upon which separate representations are submitted.

In respect of the approach taken in Stage 1 of the Green Belt Review, our clients are concerned that this has been undertaken at too high a level and also in an inconsistent nature, leading to a failure to identify suitable parcels that contribute nothing to the purposes of the Green Belt.

For example, our clients land south of Rectory Road, Steppingley has been considered as part of Parcel FW4, to the west of Flitwick. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt (Purposes 1, 2 and 4) and a strong contribution to Purpose 3. However, unlike with other parcels considered as part of the Green Belt Review, in this instance the Review has not identified smaller parcels within FW4 that make less of or no contribution to Purpose 3 of assisting the safeguarding of the countryside from encroachment. As was demonstrated in the Call for Sites Submission for our clients' site (Parcel NLP085), it lies between existing buildings and it is of a modest scale, therefore its development would not result in any significant encroachment into the countryside.

The Call for Sites submission on behalf of Messrs Olney, Willis and Butterworth included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary between the settlement edge and the Green Belt.

Paragraph 2.18 in the methodology section of the Green Belt Review states "areas of land that make a relatively limited contribution to the overall Green Belt would be where new development would effectively be 'infill', with the land partially enclosed by development; new development would be well contained by the landscape, e.g. with rising land; new development would be of little harm to the qualities that contributed to the distinct identity of separate settlements in reality; and a strong boundary could be created with a clear distinction between 'town' and 'country'."

Our clients' land is exactly the type being described here. This highlights the inconsistent approach that has unfortunately been taken with the Green Belt review meaning its conclusions and the Draft Local Plan that has resulted cannot be considered justified as required by the NPPF.

Representations on Draft Central Bedfordshire Local Plan 2035 and Technical Evidence
to support the promotion of Land at Manor Close Barton Le Clay (ALP252)
Representations on the Green Belt Review
As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt
Review is supported as is the need to release land as part of the Plan to help meet the high housing
need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton
Borough's unmet need.
Our Clients support the approach taken in Stage 1 of the Green Belt Review, and in particular, the
conclusions reached in respect of parcel BC2, to the east of Barton-Le-Clay. This parcel is identified
as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of
including land in the Green Belt - purposes 1, 2 and 4. The Review does conclude however that this
parcel makes a relatively strong contribution to purpose 3, by assisting the safeguarding of the
countryside from encroachment.
Parcel BC2 extends across a wide area of the Green Belt covering the whole of the east of Barton-Le-
Clay. In the Stage 2 assessment of the Green Belt Review the site falls within parcel BC2a which is
assessed as having relatively weak contribution to the Green Belt. The Green Belt Review notes this
area lies adjacent to the built edge of Barton Le Clay and includes Ramsey Manor Lower School and
Arnold Middle School which has the effect of making a relatively weak contribution to purpose of
including the land within the Green Belt. The assessment concludes the heavily-treed watercourse
to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong
potential alternative to the Green Belt boundary.
Our Clients are of the view that the allocation of the Land at Manor Road would be a logical
extension to Barton-Le-Clay on a contained site in an existing built up area. Development of the site
would not harm the purposes of including the land in the Green Belt as it is located between the
northern boundary of Ramsey Manor Lower School and Ivel Close, and sits directly to the west of the
tree lined watercourse which could form a new edge to the settlement limits and an appropriate
boundary between the built form and Green Belt beyond.
Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Manor Road
and states "Areas of land that make a relatively limited contribution to the overall Green Belt would
be where new development would effectively be 'infill', with the land partially enclosed by
development; new development would be well contained by the landscape, e.g. with rising land; new
development would be of little harm to the qualities that contributed to the distinct identity of
separate settlements in reality; and, a strong boundary could be created with a clear distinction
between 'town' and 'country'."

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need.

Connolly Homes supports the general approach taken in Stage 1 of the Green Belt Review, and in particular, the conclusions reached in respect of parcel WE2 to the south of Westoning. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt - purposes 1, 2 and 4. The Review also concludes that whilst it does make a relatively strong contribution to purpose 3, assisting the safeguarding of the countryside from encroachment, the field adjacent to the inset settlement, which is the land at West View Farm being promoted by Connolly Homes, is considered to be fairly well contained due to its relationship with the existing built up area of Westoning.

The conclusion that the West View Farm site should progress separately to Stage 2 of the Review as parcel WE2a is also supported, as is the assessment that it makes a relatively weak overall contribution to the Green Belt purposes, and that its outer hedgerow, together with the A5120 and railway line, would make a strong potential alternative Green Belt boundary. The Call for Sites submission on behalf of Connolly Homes included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary the Green Belt.

Given the above, it is entirely appropriate that Parcel WE2a/West View Farm should be released from the Green Belt and allocated for housing in the Submission Version of the Plan.

These representations are submitted on behalf of Toddington Mews Developments Ltd, who are promoting a site at Luton Road, Toddington (References NLP138 and NLP264) as detailed in the Call for Sites submissions. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests. This include responses to the Site Assessment Forms for these parcels in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, Toddington Mews Developments Ltd must object to the current conclusions reached in the Green Belt Study. This is specifically in respect of the consideration of parcel T2, and particularly their land at Luton Road (Sites NLP138 and NLP264), which form a small part of the wider land parcel.

Stage 1 of the Green Belt Study involved a review of fairly large parcels of land around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. Our clients consider that this has resulted in an overly simplistic look at Green Belt boundaries for the benefit of the authors. Given the intended permanence of Green Belt boundaries and how infrequently they are review, it is of utmost importance that this Green Belt review is carried out in suitably through and considered manner. Unfortunately, this has not been the case.

Furthermore, the approach taken has been inconsistent. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, or did so to a lesser extent, the latter have been specifically identified and these discrete parcels then considered further in isolation from the larger parcels they originated from at Stage 2 of the Study.

Our clients' land at Luton Road, Toddington (Sites NLP138 and NL264) has not been identified separately within parcel T2 and because this wider parcel was assessed as making a strong contribution to assisting in the safeguarding of the countryside it has not progressed beyond Stage 1e of the separate Site Assessment process.

Toddington Mews Developments Ltd wish to object to this conclusion in the strongest terms. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which sites NLP138 and NL264 contribute to the purposes of including land in the Green Belt. In respect of the Green Belt purpose of safeguarding the countryside from encroachment it concludes:

"5.2.7 The site relates much more closely to the urban area of Toddington than it does to the open countryside to the east. It is screened from views from the open countryside by a large block of woodland on the eastern boundary and tree and scrub belts along the northern and southern boundaries (which form permanent boundary features). To its immediate north and south are features that already form urbanising influences on the Green Belt. As a consequence, this particular site within the parcel only makes a relatively weak contribution to this Green Belt purpose.

5.2.8 The site scores very highly in terms of sustainability, being an extension to a Minor Service Centre with good transport links.

5.2.9 A new Green Belt boundary for the land east of Luton Road, Toddington is proposed, which meets the need for permanence expressed in the National Planning Policy Framework."

The Green Belt Statement demonstrates that there are very strong arguments that the site should be released from the Green Belt and allocated for new housing. It also illustrates that a robust new Green Belt boundary can be created utilising existing physical features, which would provide an enduring boundary.

As has been argued separately in the representations on the Local Plan itself, Toddington is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP138 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

Agree that the Green Belt is unchanged around and within Eaton Bray

Please see attached representations.

Please see attached

please refer to document attached

I object to the proposed development. It is contrary to the slip End and Caddington neighbourhood plan, it is on green belt land, there is insufficient space for road improvements and current roads do not have the capacity to support existing or proposed developments and water supply and sewerage are at capacity already.

I object to the development because it is contrary to the Slip End and Caddington neighbourhood plan, it is on green belt land and roads and water and sewerage are already at capacity.

Representations on Draft Central Bedfordshire Local Plan 2035 and Technical Evidence
to support the promotion of Land at Manor Close Barton Le Clay (ALP252)
Representations on the Green Belt Review
As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt
Review is supported as is the need to release land as part of the Plan to help meet the high housing
need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton
Borough's unmet need.
Our Clients support the approach taken in Stage 1 of the Green Belt Review, and in particular, the
conclusions reached in respect of parcel BC2, to the east of Barton-Le-Clay. This parcel is identified
as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of
including land in the Green Belt - purposes 1, 2 and 4. The Review does conclude however that this
parcel makes a relatively strong contribution to purpose 3, by assisting the safeguarding of the
countryside from encroachment.
Parcel BC2 extends across a wide area of the Green Belt covering the whole of the east of Barton-Le-
Clay. In the Stage 2 assessment of the Green Belt Review the site falls within parcel BC2a which is
assessed as having relatively weak contribution to the Green Belt. The Green Belt Review notes this
area lies adjacent to the built edge of Barton Le Clay and includes Ramsey Manor Lower School and
Arnold Middle School which has the effect of making a relatively weak contribution to purpose of
including the land within the Green Belt. The assessment concludes the heavily-treed watercourse
to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong
potential alternative to the Green Belt boundary.
Our Clients are of the view that the allocation of the Land at Manor Road would be a logical
extension to Barton-Le-Clay on a contained site in an existing built up area. Development of the site
would not harm the purposes of including the land in the Green Belt as it is located between the
northern boundary of Ramsey Manor Lower School and Ivel Close, and sits directly to the west of the
tree lined watercourse which could form a new edge to the settlement limits and an appropriate
boundary between the built form and Green Belt beyond.
Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Manor Road
and states "Areas of land that make a relatively limited contribution to the overall Green Belt would
be where new development would effectively be 'infill', with the land partially enclosed by
development; new development would be well contained by the landscape, e.g. with rising land; new
development would be of little harm to the qualities that contributed to the distinct identity of
separate settlements in reality; and, a strong boundary could be created with a clear distinction
between 'town' and 'country'."

These representations are submitted on behalf of Toddington Mews Developments Ltd, who are promoting a site at Luton Road, Toddington (References NLP138 and NLP264) as detailed in the Call for Sites submissions. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests. This include responses to the Site Assessment Forms for these parcels in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, Toddington Mews Developments Ltd must object to the current conclusions reached in the Green Belt Study. This is specifically in respect of the consideration of parcel T2, and particularly their land at Luton Road (Sites NLP138 and NLP264), which form a small part of the wider land parcel.

Stage 1 of the Green Belt Study involved a review of fairly large parcels of land around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. Our clients consider that this has resulted in an overly simplistic look at Green Belt boundaries for the benefit of the authors. Given the intended permanence of Green Belt boundaries and how infrequently they are review, it is of utmost importance that this Green Belt review is carried out in suitably through and considered manner. Unfortunately, this has not been the case.

Furthermore, the approach taken has been inconsistent. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, or did so to a lesser extent, the latter have been specifically identified and these discrete parcels then considered further in isolation from the larger parcels they originated from at Stage 2 of the Study.

Our clients' land at Luton Road, Toddington (Sites NLP138 and NL264) has not been identified separately within parcel T2 and because this wider parcel was assessed as making a strong contribution to assisting in the safeguarding of the countryside it has not progressed beyond Stage 1e of the separate Site Assessment process.

Toddington Mews Developments Ltd wish to object to this conclusion in the strongest terms. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which sites NLP138 and NL264 contribute to the purposes of including land in the Green Belt. In respect of the Green Belt purpose of safeguarding the countryside from encroachment it concludes:

"5.2.7 The site relates much more closely to the urban area of Toddington than it does to the open countryside to the east. It is screened from views from the open countryside by a large block of woodland on the eastern boundary and tree and scrub belts along the northern and southern boundaries (which form permanent boundary features). To its immediate north and south are features that already form urbanising influences on the Green Belt. As a consequence, this particular site within the parcel only makes a relatively weak contribution to this Green Belt purpose.

5.2.8 The site scores very highly in terms of sustainability, being an extension to a Minor Service Centre with good transport links.

5.2.9 A new Green Belt boundary for the land east of Luton Road, Toddington is proposed, which meets the need for permanence expressed in the National Planning Policy Framework."

The Green Belt Statement demonstrates that there are very strong arguments that the site should be released from the Green Belt and allocated for new housing. It also illustrates that a robust new Green Belt boundary can be created utilising existing physical features, which would provide an enduring boundary.

As has been argued separately in the representations on the Local Plan itself, Toddington is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP138 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need.

Connolly Homes supports the general approach taken in Stage 1 of the Green Belt Review, and in particular, the conclusions reached in respect of parcel WE2 to the south of Westoning. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt - purposes 1, 2 and 4. The Review also concludes that whilst it does make a relatively strong contribution to purpose 3, assisting the safeguarding of the countryside from encroachment, the field adjacent to the inset settlement, which is the land at West View Farm being promoted by Connolly Homes, is considered to be fairly well contained due to its relationship with the existing built up area of Westoning.

The conclusion that the West View Farm site should progress separately to Stage 2 of the Review as parcel WE2a is also supported, as is the assessment that it makes a relatively weak overall contribution to the Green Belt purposes, and that its outer hedgerow, together with the A5120 and railway line, would make a strong potential alternative Green Belt boundary. The Call for Sites submission on behalf of Connolly Homes included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary the Green Belt.

Given the above, it is entirely appropriate that Parcel WE2a/West View Farm should be released from the Green Belt and allocated for housing in the Submission Version of the Plan.

These representations are submitted on behalf of ours clients, Messrs Olney, Willis and Butterworth, who are promoting land south of Rectory Road, Steppingley (Site reference NLP085). Separate comments are submitted on the Draft Local Plan and other Technical Documents published with it that are relevant to our clients' interests, particularly the Site Assessments Technical Document and the conclusion reach on site NLP085.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. However, our clients object to the decision to effectively limit the Green Belt review to around Large Villages and towns and to exclude Small Villages such as Steppingley through the criteria utilised in the Site Assessment Technical Document, upon which separate representations are submitted.

In respect of the approach taken in Stage 1 of the Green Belt Review, our clients are concerned that this has been undertaken at too high a level and also in an inconsistent nature, leading to a failure to identify suitable parcels that contribute nothing to the purposes of the Green Belt.

For example, our clients land south of Rectory Road, Steppingley has been considered as part of Parcel FW4, to the west of Flitwick. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt (Purposes 1, 2 and 4) and a strong contribution to Purpose 3. However, unlike with other parcels considered as part of the Green Belt Review, in this instance the Review has not identified smaller parcels within FW4 that make less of or no contribution to Purpose 3 of assisting the safeguarding of the countryside from encroachment. As was demonstrated in the Call for Sites Submission for our clients' site (Parcel NLP085), it lies between existing buildings and it is of a modest scale, therefore its development would not result in any significant encroachment into the countryside.

The Call for Sites submission on behalf of Messrs Olney, Willis and Butterworth included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary between the settlement edge and the Green Belt.

Paragraph 2.18 in the methodology section of the Green Belt Review states "areas of land that make a relatively limited contribution to the overall Green Belt would be where new development would effectively be 'infill', with the land partially enclosed by development; new development would be well contained by the landscape, e.g. with rising land; new development would be of little harm to the qualities that contributed to the distinct identity of separate settlements in reality; and a strong boundary could be created with a clear distinction between 'town' and 'country'."

Our clients' land is exactly the type being described here. This highlights the inconsistent approach that has unfortunately been taken with the Green Belt review meaning its conclusions and the Draft Local Plan that has resulted cannot be considered justified as required by the NPPF.

Please see attached

Please see attached representations.

Please see attached

See attachment

See attachment

see attachment

See attachment for detailed comments from St Albans District Council

See attachment

see attachment

see attachments