Central Bedfordshire Stage 3 Green Belt Study (1/2)

Showing comments and forms 1 to 14 of 14

Object

Technical Reports

Representation ID: 8611

Received: 19/02/2018

Respondent: Mrs Annabel Steaggles

Representation:

METHODOLOGY - Land-use info for ALP082 inaccurate

04

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The information recorded about site ALP082 is inaccurate. This is not scrub land. It is an Orchard which has been allowed to become uncared for and overgrown. In the document drawn up in the early 1990's describing the Barton-le-clay conservation area this was highlighted as being of significant value and should,like all fruit orchards, be preserved. barton-le-Clay is a village not a town. The clause about spatial options refers to steppingly. This is another village some 5 miles away!

Object

Technical Reports

Representation ID: 8862

Received: 20/02/2018

Respondent: Mrs Elinor Brown

Representation:

GENERAL - No specific comments on Study
GREEN BELT No 'exceptional circumstances' have been shown that require development on the green belt around Barton-Le-Clay
METHODOLOGY - no evidence given for assertion that development here will not impact on openness of GB or adversely affect the sustainability of services

04

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No 'exceptional circumstances' have been shown that require development on the green belt around Barton-Le-Clay to go ahead. Presumably the justification for development on green belt land is as 'a more modest Green Belt release around Large Villages that are inset in the Green Belt, have a good level of local services and where sites are available that did not impact on the openness of the Green Belt'. The council gives no evidence for the assertion that development here will not impact on the openness of the green belt nor adversely affect the sustainability of services; which it will.

Object

Technical Reports

Representation ID: 8983

Received: 22/02/2018

Respondent: Hockliffe Parish Council

Representation:

GENERAL - No specific comments on Study, but concern that wrong sites have been selected.
GREEN BELT - fails to recognise good practice in terms of establishing long term defensible boundaries to the Green Belt

04

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This analysis was prepared in isolation from other key parts of the Development Plan, namely the emerging Hockliffe Neighbourhood Plan. Consequently, the proposed locations for new development fail to take proper account of local factors and come to inconsistent conclusions on future Green Belt boundaries. The problem is, again, one of ignorance and timing in that the HNP consultation pre-dated the completion of the CBC Stage 3 Green Belt Study (published Jan. 2018), but it was seemingly, not taken into account. In addition, CBC was aware of the preferred locations for development in the HNP at the time of the Sites Assessment work between July and September 2017. The HNP was prepared with a specific purpose of influencing the emerging CBLP. The issuing of the HNP (Reg. 14 Consultation) was delayed so that it could take account of the consultation on the CBLP in Summer 2017. There was liaison with CBC at all stages.
There is a great concern that the wrong sites have now been selected based on this flawed analysis and that those proposed will result in greater harm to the Green Belt as explained in detail under our Objection to Policy HA1. In addition, the approach fails to recognise good practice in terms of establishing long term defensible boundaries to the Green Belt. Consequently, this part of the Local Plan will fail two of the tests of "Soundness": Is the Plan positively prepared and Is the Plan consistent with national policy and legal requirements.

Object

Technical Reports

Representation ID: 8984

Received: 22/02/2018

Respondent: Hillersdon Charity

Representation:

GENERAL - No specific comments on Study, but concern that wrong sites have been selected.
GREEN BELT - fails to recognise good practice in terms of establishing long term defensible boundaries to the Green Belt

04

Full text:

This analysis was prepared in isolation from other key parts of the Development Plan, namely the emerging Hockliffe Neighbourhood Plan. Consequently, the proposed locations for new development fail to take proper account of local factors and come to inconsistent conclusions on future Green Belt boundaries. The problem is, again, one of ignorance and timing in that the HNP consultation pre-dated the completion of the CBC Stage 3 Green Belt Study (published Jan. 2018), but it was seemingly, not taken into account. In addition, CBC was aware of the preferred locations for development in the HNP at the time of the Sites Assessment work between July and September 2017. The HNP was prepared with a specific purpose of influencing the emerging CBLP. The issuing of the HNP (Reg. 14 Consultation) was delayed so that it could take account of the consultation on the CBLP in Summer 2017. There was liaison with CBC at all stages.
There is a great concern that the wrong sites have now been selected based on this flawed analysis and that those proposed will result in greater harm to the Green Belt as explained in detail under our objection to Policy HA1. In addition, the approach fails to recognise good practice in terms of establishing long term defensible boundaries to the Green Belt. Consequently, this part of the Local Plan will fail two of the tests of "Soundness": Is the Plan positively prepared? and Is the Plan consistent with national policy and legal requirements?

Object

Technical Reports

Representation ID: 9004

Received: 21/02/2018

Respondent: Toddington Mews Developments Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

METHODOLOGY - Dispute conclusions of Study in relation to alternative sites. Alternative conclusion proposed

04

Full text:

In respect of the Green Belt, our Clients are entirely supportive of the principle of the existing Green Belt boundaries being reviewed as part of this Local Plan. This is long overdue and the exceptional circumstances required by the NPPF, such as the need to significantly boost the supply of housing, certainly apply here, as evidenced by the supporting technical work published as part of this review. Indeed, in light of the ambitious housing target adopted by the council, combined with their marginal 5 year housing land supply position, there is a pressing need to identify more land which is appropriate to accommodate the required growth in the District.

The site at Luton Road, NLP138, is identified at the Stage 3 Greenbelt review 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. The Stage 3 Green Belt Review goes on to note that although open and undeveloped, its release is unlikely to harm the Green Belt due to the strong boundary features to the east. This, combined with the fact the Medical Centre to the south and the dwelling and parking area located in the north-west give the site an overly urbanising influence means the site it considered to relate more strongly to the settlement of Toddington than the wider countryside.

Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Luton 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'."

Site NLP138 passed the Site Assessment process in the SHLAA and is considered suitable for development. However, despite this it has not been included as an allocation under Policy HA1 of the Local Plan, a matter Toddington Mews Developments Ltd is objecting to. This is despite demonstrating little to no contribution to the functions of the green belt in the Stage 3 Review. Bearing this in mind, our client wishes to draw attention to a number of sites, such as the other housing allocations in Toddington - HAS49 (NLP153a, b / NLP184) and HAS50 (NLP411) - that passed the assessment in the Site Assessment Technical Document despite displaying greater contributions to the functions of the Green Belt in the Stage 3 Green Belt Review that those displayed by NLP138.

The HAS49 allocation is made up of a number of sites identified from the Call for Sites process. Of these NLP153a and NLP184 were assessed as making low and low-moderate contributions to the Green Belt, the same as and slightly lower than those identified for NLP138. However, a large proportion of the site, the area known as NLP153b, is deemed to make a greater contribution to the Green Belt than NLP138. As a whole, NLP153 is deemed to make a moderate contribution to the Greenbelt. Likewise, HAS50 Alma Farm is outlined in the Green Belt Review as contributing moderately to the purposes of the Green Belt. The analysis for this parcel does note that, the eastern portion in isolation only makes a low-moderate contribution, however, the full site, which is included in the allocation in the Plan, is deemed to make a moderate contribution.

As has been argued separately in representations on the Plan itself, Toddington is a sustainable location for new housing and our Clients respectfully request that the Council revisits its position on NLP138 and identifies it for release from the Green Belt. On a side note, our client postulates as to whether this site has been overlooked as a result of the Council reaching their required target for housing utilising other sites and therefore this site was simply not deemed to be required. However, as has been outlined in additional reps on the Council's Growth Strategy, the adopted OAN only includes a 6% contingency margin to account for delays in delivery etc. Our client therefore submits that further appropriate sites such as NLP138 should be considered further for allocation.

Notwithstanding the above, in light of the discrepancies outlined above and as no evidence has been published which justifies the reasoning for these discrepancies, one can only assume that the Council has failed to allocate land which is most appropriate to accommodate growth, and in this sense the plan is not sound nor justified in the terms required by the NPPF.

Object

Technical Reports

Representation ID: 9166

Received: 21/02/2018

Respondent: City & County Projects

Agent: Woods Hardwick Planning Ltd

Representation:

METHODOLOGY - Dispute conclusions of Study in relation to alternative site. Inconsistent approach that has been adopted in the assessment of sites through the Green Belt Study. Alternative conclusion proposed

04

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City & County Projects are entirely supportive of the principle of the existing Green Belt boundaries being reviewed as part of this Local Plan. This is necessary in the interests of sustainable development and the exceptional circumstances required by the NPPF, such as the need to significantly boost the supply of housing, certainly apply here, as evidenced by the supporting technical work published as part of this review. Indeed, the separate representations submitted on the Pre-Submission Local Plan on behalf of City & County Projects demonstrate that the housing need is even greater than is currently being proposed by the Council and it will be necessary to identify more land that is appropriate to accommodate the required growth in the area.

Our Clients are, however, very concerned with the inconsistent approach that has been adopted in the assessment of sites through the Green Belt Study and particularly the appraisal of the land they are promoting at Chauntry Way, Flitwick (NLP245). This site did not pass Stage 1 of the Green Belt Study because the wider parcel (FW1) which it was a part of was deemed to make a medium to strong contribution to the purposes of the Green Belt. Disappointingly, site NLP245 was never assessed individually, and has only been considered as part of the wider parcel FW1 in Stage 1 of the Green Belt Study, with this contributing directly to it being rejected, whereas other smaller sites within the wider parcels have been considered discretely.

Furthermore, in response to the conclusion reached at Stage A of the site assessment process and Stages 1 and 2 of the Green Belt Study published with the previous draft of the Plan, City & County Projects commissioned a Green Belt Statement, prepared by James Blake Associates, which is enclosed again with these representations for ease of refence. This Statement concluded that site NLP245 as a discrete parcel in actual fact makes only a 'relatively weak' contribution to preventing Ampthill and Flitwick from merging into each other. 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 than it already is.

In respect of the other Green Belt purposes, the James Blake Assessment Statement concluded that the site does not fulfil the purpose of preventing the sprawl of a large built up area (the same conclusions as reached in the Green Belt Study). The Green Belt Study assessed the whole of parcel FW1 as making a relatively weak contribution to preserving the setting of Ampthill and this is also true of parcel NLP245 in isolation. Finally, the contribution site NLP245 makes to safeguarding the countryside from encroachment is also considered to be relatively weak, compared to the moderate contribution of the wider parcel FW1, due to the former being more closely associated with the urban area of Flitwick. It is visually separated from the open countryside by a belt of trees that runs along a small watercourse on the western (outer) boundary. Furthermore, development of the site would extend the town 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.

Despite the submission of this robust evidence in response to the last consultation the Council has failed to consider parcel NLP245 as part of Stage 3 of the Green Belt Study and it does not appear that these representations have been given due consideration.

This is all the more disappointing when it is evident that other sites, including land currently within the Green Belt, that initially failed Stage A (Stages 1-3) of the site assessment process and Stages 1-2 of the Green Belt Study, have been assessed again or further and subsequently included as allocations in the Pre-Submission LP. These include:

* Site allocation HAS26 - A5 Watling Street, Hockliffe currently in the Green Belt is allocated for 41 dwellings, however, it does not appear in the Call for Sites Maps for Hockliffe, nor is it in any of the relevant Parish Site Assessment Forms. It is referred to as site NLP538 in Appendix A (List of new sites which pass assessment) of the SHLAA, which includes a summary of the sites, but no detailed evidence is available to demonstrate this site has been properly and fairly assessed by the Council.
* Site allocation HA25 - Land at Leighton Road Hockliffe currently in the Green Belt is proposed to be allocated for 23 dwellings, however, the site did not pass the initial Stage A of the site assessment process. No justification has been put forward to demonstrate why the site has now been proposed for allocation despite failing the initial site assessment stages.
* Site allocation HAS14 - Land off Eaton Park, Eaton Bray currently in the Green Belt is proposed to be allocated for 49 dwellings, however, the site failed the initial Stage A of the site assessment process. No justification has been put forward to demonstrate why the site has now been proposed for allocation despite failing the initial site assessment stages.
* Site allocation HAS32 - Northern Chamberlains Barn Leighton Linslade currently in the Green Belt is proposed to be allocated for 175 dwellings. The site failed the initial Stage A site assessment process and no justification has been put forward to demonstrate why the site has now been proposed for allocation.
* Site Allocation HAS33 Land North of Soulbury Road, Leighton Linslade currently in the Green Belt is proposed to be allocated for 55 dwellings. This site failed the initial Stage A of the site assessment process, however, no justification has been put forward to demonstrate why the site has been considered appropriate for allocation.
* Site Allocation HAS03 Land off Meadow View, Aspley Guise currently in the Green Belt is proposed to be allocated for 37 dwellings. This site failed the initial Stage A of the site assessments process, however, no justification has been put forward to demonstrate why the site has been considered appropriate for allocation. The Sustainability Appraisal Appendix V11d: Small - Medium Site Options - Outline Reasons for Selection or Rejection states the site will come forward in part to join NLP168 in Aspley Guise, however site NLP168 is in Arlesey.

City & County Projects are very alarmed over the absence of evidence to justify the selection of the sites that have been included for allocation in the Plan and the lack of transparency on the decision-making process that has led to the list of sites in Policy HA1. For this reason the Plan cannot be considered sound as it is not justified by the evidence based published.

Robust evidence has been presented in the representations on behalf of City & County Projects that the Plan needs to deliver substantially more housing that is currently proposed and will need to allocated additional small and medium sized sites to achieve this. The land east of Chauntry Way, Flitwick (NLP245) should be included as one such additional allocation in Policy HA1 and the contribution it makes in isolation to the purposes of included land in the Green Belt has been significantly overstated in the Green Belt Review.

Object

Technical Reports

Representation ID: 9677

Received: 22/02/2018

Respondent: The Crown Estate

Agent: Savills

Representation:

METHODOLOGY - Dispute conclusions of Study in relation to alternative sites. Alternative conclusion proposed

04

Full text:

3.123. The Council has prepared a number of technical reports as evidence to underpin the Local Plan policies concerning Green Belt. In response to this evidence, The Crown Estate (TCE) has commissioned The Landscape Partnership to assess that evidence as it relates to TCE's respective sites at Land East of Barton Road and Land at Whitehill Farm. The Landscape Partnership's reports upon their response to this evidence as it affects these sites, was submitted in support of our representations to the Regulation 18 Draft Plan and are re-attached to these representations at Appendices 6 and 12 respectively.

Attachments:

Object

Technical Reports

Representation ID: 9746

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

METHODOLOGY - Dispute conclusions of Study in relation to alternative site. Alternative conclusion proposed

04

Full text:

See attached representation.

Attachments:

Object

Technical Reports

Representation ID: 9791

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

METHODOLOGY - Dispute conclusions of Study in relation to alternative site in Slip End. Alternative conclusion proposed

04

Full text:

See attached representation.

Object

Technical Reports

Representation ID: 10061

Received: 22/02/2018

Respondent: Pigeon Investment Management

Representation:

METHODOLOGY - Study discounts sites irrespective of the fact that it (Land East of Maulden) was the best scoring location against the purposes of the Green Belt

04

Full text:

OBJECTION - Policy HA1: Small and Medium Allocations

The Pre-Submission Local Plan omits the Land East of Maulden from its site allocations. This is as a result of errors in the evidence base. These are set out in more detail below.
Central Bedfordshire and Luton Green Belt Study
Central Bedfordshire jointly with Luton Borough Council commissioned LUC to undertake an assessment of the Green Belt within Central Bedfordshire and Luton. The aim of the Central Bedfordshire & Luton Green Belt Study (November 2016) (the Green Belt Study) was to assess the extent to which the Green Belt land within the study area contributes to the purposes of a Green Belt as set out in the Framework.
The report site was assessed as follows in relation to the purposes of a Green Belt under reference (FW2/FW2a). This is set out in Table 1 below.
There were five land parcels [FW1 (north), FW2/2a (north -east), FW3/3a (south-west), FW4 (west) & FW5 (north-west)] assessed at Stage 1 of the study which surrounded the town of Flitwick. The parcels of land that were the worst performing locations (i.e. weakest contribution to the 4 purposes of the Green Belt) against the purposes of the Green Belt were FW2/2a and FW3a. This was followed by FW5. FW1 and FW4 performed the best (i.e. strongest contribution) against this analysis.
The area of land, to which our proposal site relates FW2a made the weakest contribution towards the purposes of a Green Belt. It can safely be removed from the Green Belt without causing harm or undermining the purposes of the Green. The reasons why this has not been taken forward are not given. In stage 3 NLP039 is taken forward. Why this site has been selected is not justified.

Sustainability Appraisal

The Sustainability Appraisal, January 2018 (SAR) is a core part of the evidence base which informs the Pre-Submission Local Plan's Strategy and Policies. At a strategic level, the assessment of Growth Locations Options (Appendix 5 of the SAR) discounts Flitwick town/major service centre as a potential growth location. This is a significant omission, given Flitwick's prominent location in the settlement hierarchy. The potential for Flitwick to become a town which absorbs a larger scale of growth should have been analysed further and assessed as a reasonable alternative in the Sustainability Appraisal process.
Flitwick West is discounted in Table 5.7 of the SAR for the following reasons: Green Belt designation; concern over coalescence between Flitwick and Ampthill; potential detrimental impact on the landscape, ecology and heritage in the east of Flitwick; concentrating growth along key transport corridors (A507, M1 and Midland Main Line Rail); promoting sustainable development in areas that have seen little growth due to Green Belt restrictions. Flitwick West the only option for development in the town. The omission of other locations around the, especially those which were not deemed to meet the five purposes of the Green Belt in the stage 1 and 2 assessments should have been considered here. Furthermore, it contained FW2/2a which performed as 'weak' in the Green Belt study.
The Non-Strategic Site Options (Appendix 7 of the SAR) only assess two options. These are NLP039 Steppingley Road for 420 residential units and NLP492 Site Next to Flitwick Allotments for 24 residential units. This site 'Land East of Maulden Road' is omitted from consideration, this being despite it scoring better in respect to impacts upon the Green Belt were it to be released. Table 2 below provides a commentary id our site had been assessed in the SAR. Our site, Land East of Maulden Road fairs better against the selected site NLP039. Our site preforms particularly well against the employment and health objectives.
The Strategic Land Availability Assessment
The Strategic Housing Land Availability Assessment (January 2018) (SHLAA) determines the suitability, achievability and availability of potential housing and employment sites. The sites NLP039 Steppingley Road (Green belt) & NLP492 Site adjacent to Flitwick Garden Allotments (Not Green belt) are identified as suitable, available and achievable.
Land adjacent to Maulden Road (Ref ALP 174 - NLP321) is assessed at 10.94. This site is assessed as unsuitable. It is identified that "...the site's proximity to Flitwick Moor makes it unsuitable for development, it is inappropriate for development in terms of landscape, ecology and green infrastructure. The proximity of the site to Flitwick Moor SSSI makes it unsuitable. The site, if taken forward would be able to protect and enhance the landscape which provides the foreground to Flitwick Moor SSSI and is an important visual feature giving identity to Flit Valley. Opportunities for the creation of high quality new habitats are welcomed such as Suitable Alternative Natural Greenspace (SANG) to further enhance the setting of the SSSI.
In respect of the impact on the setting of Flitwick Mill the built form would be set back substantially from Greenfield Road to the south and additional landscaping introduced which would offer opportunities to enhance the setting of Flitwick Mill, as well as provide for an attractive gateway to the town. The existing public rights of way across the site would be retained and additional footpaths would also be provided along with areas of public open space. This will improve the permeability through the site and make it accessible to local residents.
Evidence was provided at the earlier stages of this Local Plan's preparation including the Call for Sites and Regulation 18 Draft Local Plan consultations to clarify and correct some of the above assumptions in relation to 'Land adjacent to Maulden Road'. More information is set out on this in section 4 below. The findings should have been adjusted to take the submitted evidence into account. However, it does not appear that their Pre-Submission Local Plan, SHMA, 2017 or Green Belt evidence has been informed by this.
Further to the analysis above, the Pre-Submission Policy HA1: Small and Medium Allocations is not sound as it is not justified and based on robust evidence to identify the most suitable locations for housing. This is a fundamental flaw in the Pre-Submission Local Plan. The Green Belt Study discounts sites irrespective of the fact that it was the best scoring location against the purposes of the Green Belt. This site should have been carried across to stage 3 of the Green Belt study. The site was also incorrectly excluded from the SAR as a potential alternative both in the strategic and individual site analysis. The SHLAA, 2017 discounts this our clients site on grounds which are not substantiated. This proposal if taken forward for a high quality mixed use development would offer an opportunity to enhance the setting of the SPA contributing to the habitats and species there. The site would only bring forward development on Flood Zone 1. The proposed development at this site would respect the historic context of the area. The proposed strategy would recede any build development away from any area sensitives to the west to connect to the existing settlement boundary. A draft masterplan (Appendix 2) illustrates how this could be achieved. This was submitted to the Council in July 2017. We regret to note that this has not been fully taken into account.

Object

Technical Reports

Representation ID: 11005

Received: 24/01/2018

Respondent: Barbara Bansback

Representation:

GREEN BELT - Oppose loss of Green Belt; no specific comment on Study
AMENITY - impact on quality of life

04

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Central Bedfordshire Stage 3 Green Belt Study - NLP049 - Land to North of Soulbury Road

I am writing to object to the inclusion of this land in the proposed Local Plan.

I wish to point out that this has not been circulated in the local press and, to the best of my knowledge, local Councillors were not made aware of the proposal. In addition, Central Bedfordshire Council objected itself and refused an application by Mr Compton to build on the land as recently as three or so years ago!

This land was given Green Belt status for a good reason and no case appears to have been made for any exceptional circumstance for changing this.

Arguments against the expansion of building in West Linslade were accepted twice in the applications by Paul Newman Homes in respect of the land at Valley Farm. This particular area is by the county boundary and Aylesbury Vale District Council, as well as Central Bedfordshire Council, have been working towards gaining Green Belt status for the whole area.

In addition, other parts of Leighton Buzzard have been identified for expansion. Inclusion of the land to the north of Soulbury Road could open the way for future applications which would be detrimental not only to the habitats etc provided by Linslade Wood, but to the quality of life of local residents: traffic flows into town are at near or over-capacity at peak hours, with only one road giving access to the town centre. Meeting the needs of the residents in any additional housing would also put unsustainable pressures on already over-stretched local services, in particular health and education.

I would therefore urge you to remove this parcel of land from the Plan that you are required to submit to the Secretary of State.

Object

Technical Reports

Representation ID: 11540

Received: 21/02/2018

Respondent: London Green Belt Council

Representation:

GREEN BELT - oppose GB release. No specific comment of Stage 3 study

04

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London Green Belt Council response to Central Bedfordshire Council's Draft Local Plan: 2035

Thank you for the opportunity to respond to this important consultation.

The London Green Belt Council is a grouping of 100 organisations representing over 50,000 people who are concerned for the future of the London Green Belt including CPRE Bedfordshire, Chalgrave Parish Council, the Chiltern Society and the Leighton Buzzard Society.

We consider that the policies within section 8 of Central Bedfordshire Council's Draft Local Plan are not "sound" as they are not "positively prepared, justified, effective or consistent" with National Policy.

We strongly object to proposals to release Green Belt land on the following grounds:

* The Green Belt sites proposed for development still meet the requirements as set out in the paragraphs on Green Belt purposes in the National Planning Policy Framework (NPPF). The removal of these important sites would compromise the integrity of the London Metropolitan Green Belt.
* Proposals to release large areas of Green Belt for development are inconsistent with the NPPF and with stated Government policy, as confirmed by the Secretary of State for Communities and Local Government.
* Proposals to release large areas of Green Belt land for housing are based on unrealistically housing need projections.

The reasons why we consider the Draft Local Plan to be unsound are as follows:

1. The plan is inconsistent with the NPPF.

1.1 Central Bedfordshire Council has failed to prove that the benefit of releasing land within the Metropolitan Green Belt area outweighs the harm.

It is quite clear that the harm of removing Green Belt land which meets Green Belt criteria in paragraph 80 of the NPPF, considerably outweighs any benefits. Central Bedfordshire Council has failed to take account of the significant harm of releasing Green Belt for development, despite there being a clear environmental and social impact for both the residents of Central Bedfordshire Council and neighbouring authorities.

Paragraph 44 of The Planning Practice Guidance states that:

'The Framework is clear that local planning authorities should, through their Local Plans, meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole, or specific policies ... Such policies include ... land designated as Green Belt'.
http://planningguidance.communities.gov.uk/blog/guidance/housing-and-economic-land-availability-assessment/stage-5-final-evidence-base/


1.2 Proposed Green Belt development undermines the Green Belt's purpose, in particular, the prevention of the merging of neighbouring towns and assisting urban regeneration, without demonstrating any exceptional circumstances, as required by the NPPF.

Central Bedfordshire Council's Draft Local Plan identifies over 400 ha of land which, it is suggested, could be removed from the Green Belt to provide housing.

The government has repeatedly made it clear that demand for housing is unlikely to be accepted as the exceptional circumstances needed to justify changing Green Belt boundaries. Brandon Lewis MP, the then Housing Minister, in a letter to MPs in June 2016, when referring directly to the Local Plan preparation process, stated that "we have been repeatedly clear that demand for housing alone will not change green belt boundaries".

Central Bedfordshire Council is, in its draft Local Plan, clearly justifying the release of Green Belt by arguing it is needed for housing. However as mentioned in 2.1 below, this is unsustainable for providing the housing needed and thus cannot warrant exceptional circumstances.

By Central Bedfordshire Council's own admission, development North of Luton risks the merging of Luton with Lower Sundon. This would contravene one of the main purposes of the Green Belt - being a barrier against the merging of settlements and towns. The mitigation suggestions will certainly not be a substitute for Green Belt land which currently more than adequately fulfils this function.

2. The Draft Local Plan is unsustainable

2.1. Focusing housing development on Green Belt land makes the Local Plan's affordable Housing Policy unachievable.
Policy H4 Affordable Homes which indicates an unambitious affordable housing target of 30% does not go far enough to address affordable or social housing need. Recent research by CPRE and planning consultants Glenigan, 'Green Belt Under siege: 2017' demonstrates that Green Belt developments fail to produce significant numbers of genuinely affordable homes - only 16 % of homes built on Green Belt since 2009 have been affordable. By concentrating housing development on Green Belt, the Draft Local Plan puts at risk the 30% affordable target stated in the Local Plan's Affordable Homes Policy .


2.2 Green Belt release recommended in the Local Plan undermines the integrity of the London Metropolitan Green Belt as a whole.

In the plan, there is a recommendation for the inclusion of a 20-hectare employment site near the new M1 Junction 11a which underlines how building on Green Belt is unsustainable through the ripple effect of development - a recently completed road-building scheme on the Green Belt is clearly being used to justify the further release of Green Belt land. The allocation of over 20 further Green Belt sites for future housing and employment use only serves to underline the unsustainability of Central Bedfordshire Council's approach.

3. The Draft Local Plan is unjustified.

3.1. Green Belt should have been considered as a constraint when setting housing targets but this has not taken place.

The Draft Local Plan is not compliant with national policy as it does not take sufficient account of Green Belt constraints on development. This is in direct contrast to the Secretary of State's 2016 statement that Green Belt should be 'absolutely sacrosanct'.

Paragraph 45 of the Planning Practice Guidance clearly states that councils should take account of policies such as the Green Belt which indicate development should be restricted.

"Once need has been assessed, the local planning authority should prepare a Strategic Housing Land Availability Assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as Green Belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need."

This guidance has been ignored in the draft Local Plan.

3.2. Central Bedfordshire Council's housing targets are over-inflated

The housing targets in the Draft Local Plan are unjustifiable and unsustainable. They contain levels of contingencies which are completely unacceptable leading to substantial areas of land being allocated for development that need not be. Moreover, the target considerably exceeds that required from the job delivery target of a minimum of 24,000, running the risk of creating dormitory towns of out commuters to London, Milton Keynes and Bedford which because of poor transport links will again be unsustainable.

3.3 The Local Plan recommends Green Belt land for development which the Central Bedfordshire and Luton Strategic Green Belt Review found to be fulfilling the functions set out in paragraph 80 of the National Planning Policy Framework

The above made it clear that the purpose of the Green Belt Review was not to identify possible sites for development. It further reported that the clear majority of sites still performed its Green Belt functions. Notwithstanding the lack of exceptional circumstances demonstrated by Central Bedfordshire Council for releasing Green Belt land for development, the removal of well-performing Green Belt is unjustifiable.

4. Proposed modifications.

a. Revise housing targets to a more realistic and credible level, taking into account the Green Belt as a constraint to development. A figure of approximately 25,000 is more realistic and achievable and would still meet a significant proportion of Luton's 7800 unmet need, thus complying with the Duty to Co-operate.
b. Following the direction of travel set out in the Housing White Paper, work with Luton Borough Council to instigate a more sustainable alternative to meeting housing need by following government policy to develop on previously developed sites (brownfield) in the urban area and increasing density levels.
c. Include a higher affordable housing target, as acknowledged by central government to meet the need for young families and young people in Central Bedfordshire urgently seeking homes where they are urgently needed in an area of better transport opportunities.

Object

Technical Reports

Representation ID: 11921

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

METHODOLOGY - alternative GB assessment undertaken for alternative site which demonstrates land performs more weakly in terms re contribution to Green Belt purposes than Council's study

04

Full text:

See attached representation.
[Appendix 1 to the representation contains three documents that are not attached to this submission because the limit on the number of attachments has been reached - Regulation 18 representations on the Site Assessment Technical Document and the Settlement Capacity Initial Study and the Vision for Slip End East document. These have been submitted separately via email]

Comment

Technical Reports

Representation ID: 11986

Received: 22/02/2018

Respondent: Mr C Burke

Agent: Aragon Land & Planning Ltd

Representation:

TODDINGTON

METHODOLOGY - suggest alternative assessment of Green Belt surrounding Toddington, and further revisions

04

Full text:

see attachments

Attachments: