Appendix 4: Existing Employment sites & land that should be considered favourably for alternative (non-employment) uses

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Support

Central Bedfordshire Pre-submission Local Plan (January 2018) Appendices

Representation ID: 7514

Received: 16/01/2018

Respondent: Cllr Roger Smith

Representation:

**SUPPORT**

EMPLOYMENT - should this also include RAF Henlow?

Full text:

But should this not also include RAF Henlow?

Support

Central Bedfordshire Pre-submission Local Plan (January 2018) Appendices

Representation ID: 8791

Received: 20/02/2018

Respondent: Mr Darren Brooker

Representation:

**SUPPORT**

I support the re-use of these existing sites; this is the sort of re-use / brownfield initiative that we should be seeing more of.

Full text:

I support the re-use of these existing sites; this is the sort of re-use / brownfield initiative that we should be seeing more of.

Object

Central Bedfordshire Pre-submission Local Plan (January 2018) Appendices

Representation ID: 12155

Received: 22/02/2018

Respondent: D Anderson

Agent: Mrs Val Coleby

Representation:

see comments below

Full text:

CENTRAL BEDFORDSHIRE LOCAL PLAN 2035: PRE-SUBMISSION CONSULTATION FEBRUARY 2018: Land at Charlton

On behalf of our client David Anderson we wish to lodge representations in respect of the following policies of the above Local Plan:
* Policy SP1: Growth Strategy;
* Policy SP7 Settlement Envelopes;
* Policy HA1 Small/Medium Site Allocations;
* Policies H6 Starter Homes;
* Policy H7 Self and Custom Build Housing; and
* Policy EMP 2 Development for Non-Employment Uses.
These objections are made with reference to the above site in Chalton, which adjoins Moggerhangar, as shown on the attached plan. The land is in our client's ownership and accommodates a haulage and agricultural business totalling 3 hectares in area, although only around 0.5 hectares adjoining the road frontage is considered appropriate for development at this time, which could comprise:
* cessation of the current lawful, un-restricted 24 hour use of the whole 3 ha site for haulage purposes, thereby removing this non-conforming use which is harmful to the appearance of the countryside, causes noise and disturbance to adjoining residents and is prejudicial to highway safety due to the generation of significant HGV movements on narrow country lanes serving the site;
* removal of all existing buildings and hardstandings and return of the majority of the site area to open countryside;
* a high quality rural housing development of approximately 10 - 15 dwellings, which could include affordable or self/custom build housing;
* substantial landscaping and the creation of a suitable new defensible boundary to the development site; and
* an attractive, locally distinctive development designed in detail to reflect the architectural qualities, character and appearance of the hamlet of Chalton and the adjoining village of Moggerhangar.
Policies SP1: Growth Strategy and SP7: Settlement Envelopes
In accordance with the NPPF, and in particular its requirements in respect of the need for sustainable development in rural areas set out in paragraphs 7, 14, 28, 55 and 159, the hierarchy of settlements should be defined such that development in the rural areas is concentrated in sustainable locations which:
* help to meet both the need and demand for additional market and affordable homes;
* allow small scale additional housing growth which can provide demonstrable economic, social and environmental gains; and
* help retain and enhance village services and facilities, thereby helping to create a thriving and mixed, sustainable community.
In this regard it should be noted that Moggerhangar has a full range of services and facilities, including a primary school, local shops, recreational provision, village hall, public transport services and local employment, all of which are located in close proximity to our client's site. The site is also easily accessible, both by car and public transport, to the nearby town of Sandy, which has further employment, retail, leisure and community service provision.
This is therefore a sustainable location, as already shown by the allocation of another site in the village for 30 dwellings.
We also submit that the land in question should be identified for residential development and/or included within the village envelope of Moggerhangar/Chalton, for the following reasons.
* cessation of the current lawful, un-restricted 24 hour use of the whole 3 ha site for haulage purposes would remove this non-conforming use which is harmful to the appearance of the countryside, causes noise and disturbance to adjoining residents and is prejudicial to highway safety due to the generation of significant HGV movements on narrow country lanes serving the site;
* A development of 10 -15 dwellings as suggested, together with the removal of all buildings and hardstandings and the return of the majority of the site to open countryside, would significantly enhance the visual qualities and character of the locality and create a suitable defensible boundary to this part of the village. It would also provide additional family sized and/or starter homes and/or self/custom build units to help address the village's population profile and aid the retention of village services and facilities, thereby assisting in the enhancement of a thriving and mixed community;
* The land is adjoined by the following developments and physical features:
o Established, 'frontage' housing to the south, on both sides of the road; and
o Close by to the south is the village school and village hall;
* The land is suitable, viable and deliverable for limited, small scale and low density residential development to meet a local need for additional homes;
* The site also has the benefit of being on the edge of the village, closest to the facilities and services of Sandy. This is also advantageous in that most traffic to and from the site would not have to travel through the main part of the village and those living on the site could very easily walk to the school and the village hall;
* We confirm that there are no known technical constraints to prevent residential development of the land and that such development could be achieved without harm being caused to the attractive character and appearance of the village; and
* The form, mix, density and design of a residential scheme at the site would be the subject of consultation with the Council, the Parish Council and the community should the site be identified for development in the Local Plan.
Such a form of development would therefore provide social, economic and environmental benefits and constitute sustainable development in accordance with the National Planning Policy Framework (NPPF), in much the same way as new housing was provided on the site of the old station and goods yard south of the nearby village of Blunham, now called Old Station Court.
Policy HA1 Small/Medium Site Allocations
It is clear from Government statements in 2017 and again early in 2018 that the imminent consultation on a revised NPPF will propose that Councils should be allocating a greater number of smaller sites for housing development, for the following reasons:
* The Autumn 2017 Budget Statement required local planning authorities to bring forward 20% of housing supply as smaller sites, which would "speed up the building of new homes and supports the government's wider ambition to increase capacity in the housebuilding market";
* Sustainable urban extensions have not delivered housing in sufficient numbers as previously hoped and delivery rates are much slower due to complex land ownership negotiations and significant and costly infrastructure requirements; and
* It would "create particular opportunities for custom builders and smaller developers who were hit hard by the recent recession.
In February 2018 the Government suggested that a "small site" is one below 0.5 hectares, yet we note from the Council's policy SP1 that of all the site allocations considered to be "small/medium" only two are below 0.5 hectares, well below the emerging Government requirement of 20% of total housing supply.
As stated above, the allocation for housing (under policy HA1) of around 0.5 hectares at our client's site would conform fully to this emerging Government policy.
Policy H6 Starter Homes and Policy H7 Self and Custom Build Housing
If our client's site is allocated, it is also possible that it would be suitable for starter homes and/or self/custom build housing, as promoted and encouraged by policies H6 and H7.
Policy EMP 2 Development for Non-Employment Uses.
We note that Appendix 4 of the Local Plan lists employment sites which will be considered favourably for non-employment generating uses under policy EMP2. For all the reasons already described in the representations above, our client's site should be included in this list.
Conclusions and Proposed Changes
We object to the Local Plan and consider that the pre-submission version is in conflict with paragraphs 7, 14, 28, 47, 55, 157-159 and 173 of the NPPF; it is not positively prepared, justified, effective or consistent with national policy, as required by paragraph 182 of the NPPF, and it therefore fails the tests of soundness.
We consider that the Local Plan should encourage maximum flexibility in allowing for appropriate levels of housing development in villages where it is sustainable according to the NPPF, where it can help meet both need and demand for market and affordable housing and where additional housing development can also stimulate economic growth and secure social and environmental benefits. In all these respects this site is an appropriate location to accommodate modest housing growth and should be included within the settlement confines and/or identified as a site to accommodate part of the required housing growth accordingly.
In the light of the above analysis, we propose as follows:
* revision of policies SP1 and SP7 and the Settlement Hierarchy to include Moggerhangar and Chalton as a large village and confirmation that there is scope for limited development within or adjoining the village confines of these settlements where it can be shown to be sustainable in accordance with the NPPF and its location and scale duly reflect the size, pattern of development, character and appearance of the settlement;

* under policy SP7 our client's site should be included within the settlement confines of Moggerhangar and Chalton;

* under policy HA1, identification of our client's site for housing development; and

* under policy EMP2, inclusion of our client's site in the list in Appendix 4 of sites where non-employment uses will be considered favourably.