Central Bedfordshire Pre-submission Local Plan (January 2018)

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Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

1.4 Calculating Housing Need and the Plan Target

Representation ID: 8065

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

TARGET-para 1.4 fails to justify housing numbers
GREEN BELT-given threat to Green Belt essential that housing numbers are justified

06

Full text:

These paragraphs fail to adequately justify the housing numbers proposed in the Local Plan. Paragraph 1.4.1 states that the new approach proposed by the Government is not supported because there is insufficient evidence, and then paragraph 1.4.2 goes on to say that the Government approach leads to a target of 39,350. It appears that the Plan has been prepared using this figure.

It needs to be made much clearer how the Council has arrived at its figure. The text suggests that the number has been decided and will be justified later.

Given the shortage of sites and the threat to the Green Belt it is essential that housing numbers are justified by a comprehensive evidence base.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

2.3 Cross-boundary and neighbouring growth pressures and the role of the Green Belt

Representation ID: 8095

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

GREEN BELT-Object to the removal of the Green Belt around Luton no evidence to demonstrate special circumstances

04

Full text:

The Society is aware of the considerable pressure for development in the south of the District, particularly as there is a shortage of land within the Luton boundary. This puts particular pressure on the Green Belt surrounding Luton, which also forms part of the Chilterns landscape and is in the setting of the Chilterns AONB.

The Green Belt to the north and south of Luton meets the five purposes for designation and particularly the following two:

- to check the unrestricted sprawl of large built-up areas

- to assist in safeguarding the countryside from encroachment

With Luton having a clearly defined settlement edge, any development to the north of Luton would cause substantial harm to the Green Belt, clearly conflict with these purposes and permanently remove the designation.

It is clear that these purposes are still relevant and in order to meet the tests in the NPPF the Council needs to demonstrate that the benefits of development clearly outweigh the harm to the openness of the Green Belt and that very special circumstances exist to allow development.

The need for housing is an important consideration but does not, on its own, create a very special circumstance. Locations outside the Green Belt must be considered first, including sites to the north of the Council area and in neighbouring local authority areas. Impacts on the Green Belt and the Chilterns landscape need to be addressed on a more regional basis, encompassing a number of housing market areas.

In the case of the North of Luton site, it is also partially within the Chilterns AONB and also wholly within the setting of the AONB. Further comments on this will be provided in relation to Policy SA1.

If Green Belt has to be developed, the Society would expect a similar extent of new Green Belt to be created in order to reduce encroachment into the countryside and the convergence of settlements.

The Society is not convinced that there is sufficient evidence to justify that very special circumstances exist for altering the Green Belt boundaries and we therefore consider that its loss is not adequately justified and is inconsistent with national policy.

We therefore object to the loss of this key area of Green Belt.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

4.1 The Vision - Where we want to be in 2035

Representation ID: 8096

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

ENVIRONMENT- no reference to the importance of the AONB and the Green Belt

STRATEGY - more wording on the local landscape would help to give reassurance Plan is balanced

04

Full text:

The Vision for 2035 makes no reference to the to the Central Bedfordshire landscape including parts of the Chilterns, or to the importance of the AONB and the Green Belt.

Given the scale of development proposed, the inclusion of more wording on the local landscape would help to give reassurance that the plan is not only about accommodating extensive development, but also seeks to ensure developments are sustainable and impacts on the local environment would be minimised.

These changes would ensure the the Plan was more positively prepared.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

4.2 The Strategic Objectives - How we will get there

Representation ID: 8097

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

SO4

STRATEGY- Strategic Objectives are not effective in protecting the AONB and the Green Belt
ENVIRONMENT- SO4 refers to character, landscape and environment, but does not refer specifically to the importance of conserving and enhancing the AONB and the Green Belt

04

Full text:

The Society considers that the Strategic Objectives are not effective in protecting the AONB and the Green Belt.

In particular SO4 refers to character, landscape and environment, but does not refer specifically to the importance of conserving and enhancing the AONB and the Green Belt through the policies in the plan.

The text should be amended to make this Strategic Objective more effective.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

8.5 Development in the Green Belt

Representation ID: 8098

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

GREEN BELT - harm to green belt

04

Full text:

Paragraph 5.3.1 states that there is a 'strong case' for alterations to Green Belt boundaries immediately adjoining Luton to meet the unmet housing need for Luton.

The Society does not consider that this gives sufficient justification for removing Green Belt designation. Such decisions must meet the test set out in the NPPF, with the benefits of development being shown to clearly outweigh harm to the Green Belt and to demonstrate 'very special circumstances'.

The plan needs to include some evidence here to support the decision. Simply stating that there is a strong case is not sufficient.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SA1: North of Luton

Representation ID: 8189

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

*KEY ISSUE*

GREEN BELT- removal of Green Belt land
*ENVIRONMENT - The justification for development to meet unmet housing need does not form an exceptional circumstance or public interest that overrides the harm to the AONB. There is no reason why the development could not be provided in a less sensitive location within CBC or a neighbouring district
ENVIRONMENT - it is not considered that sufficient Landscape and Visual impact studies have been undertaken to assess the impact on the AONB and its setting
GREEN BELT - there needs to be clearly defensible boundary to the Green Belt

07

Full text:

The Chiltern Society objects to the allocation of the North of Luton site for 400 dwellings and 20 hectares of employment land to meet the unmet needs of Luton. The whole of the area is located within the Chilterns National Character Area and the Green Belt,part of the area is located within the Chilterns AONB and the whole area is within the setting of the AONB.

The Society prepared a position statement on the AONB and the Green Belt in 2016. This included the following:

"The Society should oppose development within, or affecting the setting of, the Area of Outstanding Natural Beauty (AONB), which fails to conserve or enhance its natural beauty.

As a consequence, to be acceptable, new development within the AONB should be small-scale and restricted to land within existing settlements or on brownfield sites (areas previously used for development).

The Society should oppose development in the existing Green Belt which fails to protect its openness, or undermines its five purposes (to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land).

The Society should also oppose changes to Green Belt boundaries, unless the land to be removed from the Green Belt clearly no longer fulfils the purposes of Green Belt.

The use of unmet housing need as a justification for amending Green Belt boundaries should be robustly challenged."

The proposed development area and the proposed link road fill the area between the settlement edge of Luton and the AONB boundary. In the area around Sundon the development appears to encroach over the AONB boundary. National policy in paragraphs 115 and 116 of the National Planning Policy Framework (NPPF) require great weight to be given to conserving landscape and scenic beauty in AONBs and for major developments to satisfy the tests in paragraph 116. Under paragraph 116 exceptional circumstances need to be demonstrated and the development must be considered to be in the pubic interest.

Whilst Luton is tightly constrained and evidence points to an unmet housing need, this is not, in our opinion, sufficient to demonstrate an exceptional circumstance or public interest. There is no reason why the development could not be provided in a less sensitive location elsewhere, either within Central Bedfordshire or a neighbouring district.

The development will clearly have detrimental impacts on the setting of the AONB, particularly in the area around Sundon where the land rises way from the settlement edge and the AONB boundary is on the ridgeline. We are not convinced that sufficient Landscape and Visual Impact studies have been undertaken for fully assess the effects on the character of the area and views to and from the AONB. Bullet 9 of the policy simply requires "no undue impact on the AONB", and our view is that this is totally unclear and is inadequate to meet the requirements of paragraph 116 of the NPPF.

Therefore, in terms of the AONB, we consider that the allocation has been insufficiently justified and is not consistent with national policy in the NPPF.


The Chiltern Society has campaigned for many years to protect areas of Green Belt within the Chilterns. Developments are being proposed in several areas, which will gradually erode the overall area and negate the purposes of the Green Belt. There is no provision for additional Green Belt to be designated as compensation for the proposed loss.

The proposed allocation North of Luton is wholly within the Green Belt and its development would conflict with the five purposes for Green Belts, as set out in paragraph 80 of the NPPF. In particular the proposed development would not check the unrestricted sprawl of large built-up areas and would not safeguard the countryside from encroachment.

Building on this scale would clearly cause critical harm to the openness of the Green Belt and could not demonstrate the "very special circumstances" required for developing in the Green Belt.

The only option available for the Council is to alter the Green Belt boundary through the Local Plan review process. In doing this, the Council is required under paragraph 83 of the NPPF to demonstrate exceptional circumstances for altering the boundary.

The Society's view is that there is currently a very clear settlement edge to Luton, which is quite well assimilated within the existing landform. The environmental and landscape impacts of moving this boundary further to the north, in association with the proposed link road, would be likely to lead to a more poorly designed settlement edge, filling the gap to the AONB boundary. This harm to the character of the landscape has to be weighed against the need for unmet housing for Luton, albeit in a reasonably sustainable location. When these factors are weighed up, we consider that there are no exceptional circumstances here for removing this land from the Green Belt. Unmet need, in itself, does not, in our view, create exceptional circumstances, and the landscape impact here would be significant.

We would ask that the Council reviews the allocation and considers providing the housing outside the Green Belt, or at least scales down the loss of Green Belt to allow space for substantial landscape enhancement.

In conclusion, the Society considers that the impact on the Green Belt is insufficiently justifed and conflicts with national policy on Green Belts within the NPPF.

If the Council still proposes to remove land from the Green Belt, there needs to be a clearly defensible boundary to the Green Belt and new areas of Green Belt should be considered in the local area to restrict further urban sprawl or encroachment into the countryside of the Chilterns.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy SE1: M1 Junction 11a - Sundon Rail Freight Interchange (RFI)

Representation ID: 8190

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

GREEN BELT- loss of green belt
ENVIRONMENT - impact on SSSI and footpathes
STRATEGY - no justification for allocation or exceptional circumstances for green belt removal

06

Full text:

The Chiltern Society objects to this policy due to the detrimental impact on the integrity of the Green Belt.

The proposal would remove 40ha of open land from the Green Belt, creating an area of employment land in the immediate setting of the SSSI at Sundon Chalk Quarry and the Chilterns Way footpath.

With the development of the new link road to Junction 11a and the close proximity of the main railway line, this would appear a sensible location for a new rail freight interchange to serve the main settlements in the south of Central Bedfordshire. The policy proposes 5 ha for this purpose and that would be located close to existing built up areas and in a lower lying part of the landscape that appears to have been previously developed. We accept that such a facility may require a small amendment to the Green Belt boundary, as long as it can be demonstrated that the area of land no longer fulfils the 5 purposes of Green Belt designation. A substantial landscaping scheme would be required to minimise impacts.

It is the other 35ha of open fields between the railway and Sundon Quarry that give us cause for concern. Much of the site is on raised land that is clearly visible from some distance. The lie of the land would not make it easy to provide adequate landscaping to reduce visual impacts, and the result would be the extension of the built up area considerably to the north of existing settlements.

The Council has not adequately justified why the development of warehousing has to be in this location and why this creates exceptional circumstances for removing land from the Green Belt, as required by paragraph 83 of the NPPF.

Such warehousing could be provided elsewhere in locations where it was not so prominent in the landscape, was associated with similar structures and did not develop open land within the Green Belt.

The Society therefore concludes that the allocation has not be sufficiently justified and is inconsistent with national policy in the NPPF.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

8.2 Green Belt and Sustainable Development - Exceptional Circumstances for small scale release of Green Belt Land

Representation ID: 8194

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

GREEN BELT - Insufficient wieght is being given to protection of the Green Belt

04

Full text:

The Chiltern Society is not satisfied with the approach taken to demonstrate exceptional circumstances for the release of land from the Green Belt. The sections refers to the release of small scale sites, but in reality the sites proposed North of Luton and long term to the West of Luton are significant areas of Green Belt land. In the case of North of Luton there is also the AONB to consider.

Section 8.2.1 appears to suggest that if a development is sustainable then this can override its location in the Green Belt. Green Belt is a statutory designation and should, therefore, take preference.

Under 8.2.5 the text suggests that sites will be chosen where they did not impact on the openness the Green Belt. By definition, any built development in the Green Belt over and above the existing level of development must be considered, by definition, to be inappropriate development that reduces the openness of the Green Belt.

The Society does not consider that unmet housing need is sufficient to justify removing land from the Green Belt as it would not clearly outweigh the harm caused to the 5 purposes of the Green Belt as a result of the development. The evidence gathered by the Council suggests that there is insufficient land outside the Green Belt to meet the housing needs. Therefore, given the impacts of the North of Luton site in particular on the nationally designated AONB as well as the Green Belt, then the number of houses in the Borough should be reduced or densities increased elsewhere by providing more smaller houses. Failing that, options could be further investigated with neighbouring authorities.

Overall the Society is concerned that too much Green Belt is being released too easily and that this is not sufficiently justified or consistent with national policy in the NPPF relating to Green Belts.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EMP4: Rural and Visitor Economy

Representation ID: 8198

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

GREEN BELT - 4th paragraph of the policy incorrectly applies the national test in paragraph 88 of the NPPF

04

Full text:

The 4th paragraph of the policy incorrectly applies the national test in paragraph 88 of the NPPF.

The requirement is to demonstrate very special circumstances and to show that harm is clearly outweighed by other considerations.

Comment

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy EE7: The Chilterns Area of Outstanding Natural Beauty

Representation ID: 8201

Received: 20/02/2018

Respondent: Chiltern Society

Representation:

POLICY - amend first paragraph to make it NPPF compliant - to refer to development also being in public interest

POLICY - Paragraph 15.8.4 includes a list of requirements which appear to be policy requirements rather than supporting text. It would be clearer if these points were added to the policy.

06

Full text:

The Chiltern Society supports the AONB policy as drafted.

The first paragraph could be amended to refer to developments also being in the public interest to be consistent with paragraph 116 of the NPPF.

Paragraph 15.8.4 includes a list of requirements which appear to be policy requirements rather than supporting text. It would be clearer if these points were added to the policy.

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