Sustainability Appraisal

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Support

Technical Reports

Representation ID: 8782

Received: 20/02/2018

Respondent: Mr Richard Forsyth

Representation:

HARLINGTON

INFRASTRUCTURE-need for investment in local facilities and services

06

Full text:

The scale of the proposed development within the Parish of Harlington is significant compared to its current size. Substantial investment in local schools (from preschool upwards) will be required to ensure the growing demand for high quality school places can be met. This will necessitate additional excellent school accommodation within the village of Harlington itself to maintain the quality of education for current and future residents.

It will be necessary for investment in local schools to be delivered ahead of demand so that good quality school places can be provided at the time they are needed. Retrospective provision will disadvantage the education of those children effected significantly. Schools further up the pyramid (specifically Parkfields Middle School and Harlington Upper School) will also need investment to ensure the accommodation of additional places whilst maintaining high standards.

Investment will also be required to ensure the quality of local services more generally. Road safety and the provision of local quality health care is of significant importance.

We request please that the cost of these new facilities be passed on to developers and that any potential planning consent stipulates the provision of local investment ahead of any new residential areas being populated.

Object

Technical Reports

Representation ID: 8876

Received: 20/02/2018

Respondent: Mrs Jacqueline Collins

Representation:

SUSTAINABILITY APPRAISAL - no reference to Minerals and Waste Plan

06

Full text:

Object reference to minerals and waste p21/219. Disagree with "it is not considered that there are any significant sustainability issues within Central Bedfordshire in relation to minerals and waste................. this topic has been scoped out of the SA process for the Local Plan." The Minerals and Waste Plan identifies Rookery South as a Strategic Waste Site (pp80-82). The Local Plan Proposals Map shows the site as a CWS and it is close to the proposed development of Marston Vale new villages and reference to these conflicting uses should be made in the Local Plan and addressed in the SA.

Object

Technical Reports

Representation ID: 9518

Received: 19/02/2018

Respondent: Mr Jonathan Elwood

Representation:

SUSTAINABILITY APPRAISAL - does not address how CBC will address key sustainability issues

06

Full text:

Please see attached joint letter, please consider this letter signed by me.

Attachments:

Object

Technical Reports

Representation ID: 10042

Received: 22/02/2018

Respondent: Stondon Parish Council

Agent: Mr James Stirling

Representation:

SUSTAINABILITY APPRAISAL - no identification on mitigation measures

06

Full text:

Stondon Parish Council support the efforts of the local plan made by CBC but overall we object to the plan on the basis of a lack detail in plan, lack of consultation and the detail on the proposals to improve the infrastructure.

We are very concerned that the proposed local plan is not sound as it does seem to have any detail to support local communities and providing them with sustainable solutions such as infrastructure improvements, road and transport links at a local level. The plan seems to be aimed at an overall concept rather than the detail the community is looking for.


On a local level, one factor is that it does not recognise is the huge amount of pressure the both Upper and Lower Stondon will feel with the vast number of new homes proposed.

Growth Pressures

Stondon currently has 1023 houses recorded paying Council tax. Currently we are aware of Planning permission granted to develop an extra 190 new homes plus new applications currently proposed to add 374 homes (including 185 houses as part the Barrett development on the edge of Stondon). This would equate to doubling the size of Stondon with no definitive plans on extending the services or improvements in the road network around Stondon.

The plans that have been approved.
85 houses CB/16/05229/OUT
80 houses CB/16/02314/FULL
25 houses CB/16/03105/OUT

Currently proposed (including one on NHDC/CBC boarder).
40 CB/18/00223/OUT
149 CB/18/00181/FULL (this part of HAS46 244 dwellings)
185 NHDC 17/02175

(The above figures do not include any potential redevelopment of RAF Henlow once it closes in 2020, see Policy SE4 below)

Traffic and Infrastructure

For Stondon we have a number of concerns these include

1) Volume of traffic passing MDBA and its impact on its licence to operate as this is one of the few local sites that provide sustained employment opportunities.
2) Supporting improvements for the Doctors surgery
3) The challenges encompassed within the A507 and A600 interface

In the plan it states

"2.2.3 The key challenge this Plan addresses is driving more sustainable growth by improving and extending the range of economic opportunities and services available locally and securing additional infrastructure, including enhancing digital connectivity, to unlock the area's full potential and to achieve more sustainable travel."

Yet it provides no information on how this is planned or can be achieved.

Mitigation

In the plan in the appendices "sa_appendix_4_-_areas_a_to_d.pdf" it states on page 3 that the developments deliver mitigation appropriate to the development but this has not been detailed under what policies this will delivered and the how local communities will gain access to these mitigation measures.

Lack of proposed infrastructure improvements for the locality. The plan does not take into account how it will deliver services to the local community in a sustainable way.

4) Ensure the service is local to the residents and provides the appropriate level of care
5) Ensure that sustainable transport links are provided to larger service centres
6) Schools - local schools are UNABLE to access any funding to manage the expansions proposed yet CBC have vast amounts of monies they are sitting on and not willing to let the village school access it.
7) NHS England - need to involve themselves with proposed developments.
8) Water and Sewerage services are under strain in Stondon, yet the local plan fails to show how this is being delivered
9) Broadband services in Stondon are under strain and no plans on how to improve tem with all the proposals.

We feel that this is not being taken to the level detail required for the community and it needs to include a holistic view on the developments. The community need help and understanding how CBC can help it maximise any potential gains.

What is absolutely paramount, given the lack of infrastructure, is some forward planning on this aspect before more housing or hand in hand with any proposals. The Local Plan seems to be weak and lacking in detail on the need for more infrastructure.

It has been suggested by NHS England that Stondon would be best served by local health care centre based in Arlesey. There are no proposals to provide relevant transport links to these suggested facilities, especially when people will need to access the healthcare service as a two-hour bus ride is not a practical proposition, especially for increasing numbers of aging population.

The plan also seems to fail to address the challenges encompassed within the A507 between Chicksands and Stotfold and overall it fails to address the challenges with the increased volume of traffic along village interconnections. We believe the assessment is shallow and does not provided the depth of detail needed to accommodate the increases, especially in Stondon.

Currently employment for those who live in Stondon is many miles away. Transport links to site of employment are either wholly by car or by car to either Arlesey or Hitchin railway stations. Public transport to such sites of employment is weak or patchy at best, and none of the bus services through Stondon connect with the Arlesey railway station and a limited service to Hitchin Station. Again, the plan makes no reference to how a doubled population will be accommodated in getting to work so one can only conclude that further strain will be put on the already congested road network.


HAS46 244 new homes and Bloor community gains

HAS46 Landscape buffering required along the northern edge. Due to the nature of neighbouring land uses, all development proposals for this site must have regard to the prevention of major accidents and limiting their consequences, including the increase of vehicular movements on the A600.

This segment of land on the local plan is suggested as one contiguous space but has three different land owners and no clear definition on how this process will be managed. There are a number of areas that the Parish Council wants to be improved. Moving the Pharmacy and Post office closer to the current Doctors could improve the traffic and parking issues in Station Road. Adding a suitable access point from Bedford Road could help with traffic volumes into the development could aid traffic flows.

Currently Bloor have made an application but this has limited community gains and does not meet with the needs of the community as it will also increase traffic on to Station Road, which is already under great strain. In previous applications some limited Healthcare provision had been proposed but we feel that NHS England is not looking at the community impact and how to provide services on a greater local level.

The Parish Council would greatly appreciate additional input from CBC and the experienced officers to help guide the Parish Council on how it can secure additional funding to ensure we can access local high quality services.

CBC's Local Plan needs to reach out and help local communities gain the most from developers.

HAS47 33 - proposal for 40 new homes

With HAS47 again, little thought to the area apart from a comment "due to the nature of neighbouring land uses, all development proposals for this site must have regard to the prevention of major accidents and limiting their consequences, including the increase of vehicular movements on the A600".

Again, no suggestion on how the issues will be addressed. This could include suggestions that mitigation will be required to improve roads on the periphery of the village or suitable alternative practical solutions.


Sites Proposed

It feels to the residents of the parish of Stondon that we have two sites proposed and Henlow Camp (which has grown significantly) and yet villages close to us have sites that could be proposed but seemingly left out of the plan. It is felt that a greater spread of sites across Central Bedfordshire was needed.

Policy SE4

Policy SE4 anticipates closure of the RAF Station in 2020 and the wider RAF Henlow site, including the airfield, has been identified in this policy as a potential strategic location for mixed use employment. Any and all redevelopment of the site will have a major impact on Stondon due to its close proximity and shared Parish boundary road network. SPC supports the principle of a mixed development on the wider Henlow site as it appears to offer good opportunity for employment on the north site and potential residential development on the south site. However, as there is only limited detail in relation to the extent of the development allocation there is a very real concern that strategic development could result in the loss of the airfield and/or facilities that support the operation of the airfield. The loss of the airfield or the prejudicing of facilities or safeguarded airspace that supports its operation would have a major adverse impact on recreational aviation and flying training in the area. We are also concerned at the potential loss of other facilities on the site that are already used by the community (or have potential to be once the RAF base closes). We therefore believe that CBC should make it clear in the Local Plan that it supports the retention of the airfield which in turn supports its objective of bringing in employment in High Performance Technologies and R&D.

The guiding document on airfield planning is NPPF13 and the CAA's CAP 168 covers Safeguarding requirements. We assume CBC is familiar with the provisions of the NPPF requiring priority being given to the retention of existing airfields. Its importance and relevance were re-emphasized in May when the Inspector adjudicating a planning refusal appeal against the local Council in relation to Manston airport cited the provisions of NPPF13 in justifying his decision to reject the appeal.

We note that references to NLP126 and 469 in the Local Plan have now been omitted. As previously mentioned any re-development of the site should be consistent with protecting the use of the airfield and space for employment and recreational facilities. Surrounding Parishes to the north and west of RAF Henlow such as Stondon, Henlow Clifton, Meppershall and Shefford have had new developments recently and are earmarked for more in the Local Plan. It should be remembered that prior to approval of CBC's Local Plan as it has to continue meeting its 5 year housing supply target, and some more of the speculative planning applications in the local Parishes could be approved ahead of the final publication and adoption of the Plan.

As Policy SE4 sets out CBC's objective for the RAF Henlow site and we would draw your attention to some of constraints on development of the airfield area.

- The MBDA Exclusion zone is a statutory requirement dictated by the production processes used on site.

- The Four Belfast Hangars are Grade II listed buildings, and it should be noted that MBDA's Exclusion zone extends to these hangars thereby forming a contiguous protected area to the south east of the site.

In common with many MoD properties military use has led to areas of extensive ground contamination and these would need to be cleared prior to any development. Although most of the areas affected are known the nature of the contaminate is not always known and munitions are reported to have been found in some locations. The financial cost of this work is likely to be substantial.


In summary Stondon Parish Council support the Local Plan but call into question some of the assumptions made and the lack of overall detail.

Stondon Parish Council would like to appear and speak at The "Inspection in Public" in order to provide more detailed explanations of the objections and comments we have outlined in this response.


Sent on behalf of Stondon Parish Council by James Stirling Clerk to the Council.

Comment

Technical Reports

Representation ID: 10048

Received: 22/02/2018

Respondent: WSF Ltd | UK Regeneration

Representation:

GENERAL - support

06

Full text:

The attached paper provides comments from UK Regeneration, the promoter of the site included within Policy SA4, on the whole plan as well as the specifics of Policy SA4.

The paper lists a number of supporting documents. These are being provided via a dropbox link as some are large.

Attachments:

Object

Technical Reports

Representation ID: 10062

Received: 22/02/2018

Respondent: Pigeon Investment Management

Representation:

STRATEGY - omission of Flitwick a flaw

06

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: 10070

Received: 18/02/2018

Respondent: CPRE Bedfordshire

Representation:

GENERAL - flawed as driven by high growth figures
SUSTAINABILITY APPRAISAL - negative effects not assessed in any detail

06

Full text:

We do not believe that CBC has complied with the Duty to Cooperate as described by the Government's Planning Guidance.

There is insufficient space in this box (max 100 words) to provide more detail.
Please refer to CPRE Bedfordshire's full response to the consultation which has been uploaded with this submission.
Section 2, pages 2 and 3 refer to the Duty to Cooperate

Object

Technical Reports

Representation ID: 10071

Received: 18/02/2018

Respondent: Mr Darren Brooker

Representation:

GENERAL - Appendix 2 of SA missing
SUSTAINABILITY APPRAISAL - does not address how CBC will address key sustainability issues

06

Full text:

The Central Bedfordshire Pre-submission Local Plan 2015-2035 is not a properly considered, not a sound, nor a competent plan. The timescales for the production of this Local Plan were very significantly shortened after the process had started in order to beat an imposed central government deadline, as a result many areas contained within the plan are ill-considered, inaccurate or based upon old data or incomplete assessments. The assessment of need has not been carried out correctly; several of the site assessments have not been fully completed, nor carried out correctly; there are several inaccuracies and conflicts within the Plan documents themselves. Changes and additions to the documents have been made during the consultation window, without any notification or list of changes, making it impossible to properly review the documents, consider the Plan and respond to the consultation. Final versions of several technical assessments are not available (at the time of writing) or are incomplete, still in progress or have not yet been commissioned, for example the transport assessments are incomplete (they do not include rail and other non-motorised transport), with the available technical study documents primarily referring to outdated studies, missing key documents (e.g. "Central Bedfordshire Local Plan Stage 1A Transport Modelling", "Sustainability Appraisal - Appendix 2 SA Scoping Report") or refer to previous local authority areas (from pre-April 2009) of Mid-Bedfordshire and/or South Bedfordshire. There is no specific and suitable assessment for the transport impact on the important A1 transport route north and south of the area, a key infrastructure component of this Local Plan. There is no overall environmental and wildlife impact assessment, for an area identified by Central Bedfordshire Council themselves as a "predominantly rural area".
I believe the consultation processes undertaken by Central Bedfordshire Council both in the preparation of, and consultation upon the draft and pre-submission versions, of the Central Bedfordshire Local Plan have not been carried out in an inclusive, fair and open, nor a lawful manner. Accessing most of the consultations has been impossible for some working people, some older people and some people with disabilities. The consultation sessions were restricted in timing and held at times when most young and working people were unable to attend (the photos in the Central Bedfordshire Council Local Plan (2015-2035) (January 2018) Consultation Statement document show the lack of diversity of attendees, including the absence of young and (mainly) working age people - except for the Council officers themselves). The online commenting process has been unduly time consuming, unnecessarily complex and intrusive. The consultation web site has been unavailable at times during both consultations. Central Bedfordshire Council have been adding and amending documents which form part of the consultation during the consultation window without notice and without consultees being able to identify what has been changed.
The Central Bedfordshire Pre-submission Local Plan (2015-2035) is inadequate and ill-considered in many respects; it does not contain sufficient, robust and effective safeguards to properly protect the natural environment, agricultural assets (including prime / grade 1 agricultural soils), historic assets, natural habitats, water resources, areas with dark skies, areas of tranquillity, scheduled ancient monuments, conservation areas, as well as local communities and community cohesion. Little or no reference is made to important non-economic matters such as the environment, air quality and CO2 emissions, with only a weak link made to trees as countermeasure to the latter. The Plan as it stands proposes the destruction of both old and new woodlands and tree plantations. Whilst specific concerns are expressed about air quality in named urban areas, the plan proposes to develop large new urban areas which will exacerbate the problem of air quality, whilst a larger number of small and medium sized dispersed developments would more likely alleviate it. Scant references are made to agricultural needs and soil which has been and still is an important basis of Bedfordshire's employment since Roman times. With population growth, climate change, the weakening of trade links with Europe and the associated financial uncertainties, it is quite feasible that the UK may struggle to feed its population within the timescales covered by this Plan. Once prime agricultural land is built over it cannot easily be returned to food production. Central Bedfordshire is rich in both top grade soils and water resources, where these come together as they do in two areas near Biggleswade and the village of Sutton, covering them in brick and concrete would not only contravene national planning policy, but would amount to reckless environmental vandalism.
Whilst The Central Bedfordshire Pre-submission Local Plan (2015-2035) does propose some new local infrastructure will be built with the proposed new developments, the Plan does not include provision of sufficient or wider infrastructure required to support the scale of development proposed in the area around Biggleswade and the A1 corridor, in particular the land to the east of Baden Powell Way (Policy SA4) and the 'Identified Area for Future Growth' east of Biggleswade (Appendix 7, 'Land East of Biggleswade (East of the allocated new village, South of Sutton and West of Dunton)). Massive additional development of thousands of houses and businesses has, and is, already taking place to the south and east of Biggleswade and around Potton, with limited and inadequate infrastructure and service provision. The transport (rail and road) infrastructure to Cambridge and London is already well beyond capacity. The east coast mainline railway line (the main rail route north-south and into London) is severely restricted by the tunnels and viaduct at Welwyn, with no current plans or proposals to provide increased capacity. Health, water, education and leisure facilities are already extremely overstretched in the area. Central Bedfordshire Council are proposing that Integrated health and care hubs will 'support the local ambition for access to modern, high quality and locality-based health and care services' and as a result will improve local healthcare services. These healthcare proposals are not currently planned, nor funded. Central Bedfordshire Council has not proposed locations for these hubs, has not identified the costs, nor how funding and associated budget for this will be obtained. No credible provision or plans have been included in the Plan for this essential infrastructure.
The Central Bedfordshire Pre-submission Local Plan (2015-2035) is not a balanced plan, insufficient consideration and priority has been given to environmental matters, and non-financial/commercial considerations. Insufficient regard and priority has been given to important non-financial resources such as high quality agricultural land, water catchment areas, wildlife, environmental assets and quality of life.
The Central Bedfordshire Pre-submission Local Plan (2015-2035) is inadequate in respect of sustainability, it is not a sustainable plan and does not sufficiently address how Central Bedfordshire Council plans to meet the sustainability objectives or to address the key sustainability issues identified within the Sustainability Appraisal report. Table 4.2 of the Sustainability Appraisal details the objectives and yet the Plan has no reference to the objectives, nor does it state how the Plan will address these. Section 2.2.2 of the Plan states that 'Travel patterns within Central Bedfordshire are less sustainable with a high reliance on car commuting, together with increasing pressure on interchanges and the rural road network.' Central Bedfordshire Council has overseen one of the worst declines in bus journeys in England over the past four years, this Plan does nothing to change that trajectory and will only exacerbate the problems of car usage and pollution.
The developments documented within the Plan are mainly in areas where public transport has been reduced in recent years and where residents are expected to travel out of the area to important facilities such as hospitals. This Plan does not acknowledge the need for improvements in public transport, nor commits to a sustainable transport plan in order to support the proposed developments. Section 2.2.2 of the Plan identifies that 'Connectivity east to west will improve with the duelling [SIC] of the A421 in the northern part of Central Bedfordshire, and will continue with the opening of the A5-M1 link road in the south', however these (road transport) developments are already in place and will neither provide the new capacity required to meet the proposed developments within the Plan, nor address the issues of sustainability and public transport. Furthermore, the distribution of houses within the Plan does not reflect these known and planned infrastructure improvements; the Plan would be more sustainable if it had proposed most of the development where the infrastructure has already or will be provided within the medium term; given the increased capacity provided on the A421 to the east of the M1 junction 13, the A5-M1 link road and relief of rail capacity which will be given by HS2, development in the west of the area, along the A5 and north of Aspley Guise would make more sense and be more sustainable than the proposals in the current version of the Plan.
The Central Bedfordshire Pre-submission Local Plan (2015-2035) contains no overall environmental and wildlife impact assessment of the developments proposed within it. It neither considers, nor makes provision the overall impact upon nature and wildlife across the area; no competent nor strategic provision has been made for either protecting or improving strategic wildlife corridors; the Central Bedfordshire Environmental Framework document refers to an area '2. Ivel River Valley' which contains both the strategic allocation SA4, and the 'Identified Area for Future Growth' east of Biggleswade & south of Sutton [blue area] to the east of Biggleswade, and the A1 to the west of Biggleswade, and which, with the exception of an inadequate and very narrow 'Green Wheel' corridor (used primarily by dog walkers, and therefore unsuitable as a broad nature corridor) would break up the identified 'strategic green infrastructure corridor' in the Ivel River Valley area. A competent, thorough and objective assessment of the environmental and wildlife impact of development, in what is a predominantly rural county, must be made which must then inform appropriate provision, protections and policies to create an environmentally sound Local Plan.

Object

Technical Reports

Representation ID: 10075

Received: 18/02/2018

Respondent: Mr Darren Brooker

Representation:

GENERAL - Appendix 2 of SA missing
SUSTAINABILITY - issues identified in SA not addressed in Local Plan

06

Full text:

The community have not been sufficiently involved in the process and Central Bedfordshire Council have not complied with their Statement of Community Involvement (October 2012):
o This document is out of date and references groups, items and publications (such as Central Bedfordshire News Central) that no longer exist;
o The Central Bedfordshire Together www.centraltogether.org.uk) web site includes reference to the Draft Local Plan, but no reference to the changes in timescales, nor to the Pre-submission Local Plan;
o The 'Policies Map' covering the whole of the Central Bedfordshire Area (dated 11 January 2018) was not available and not published at the start of the consultation period;
o Certain sections of the community have found it difficult or impossible to engage with the consultation process, in particular many of the community involvement events and public exhibitions have taken place at times, and in locations, which make it very difficult or impossible for certain groups to attend, this has especially applied during this consultation to rural areas (where public transport services have been severely cut back over the past four years in the Central Bedfordshire area), to working people (many of the sessions have been held at times where most working people cannot get to them), and to older and disabled people who are unable, or have difficulty, in using.
A Sustainability Appraisal (SA) was carried out, however part of the document (Appendix 2) is missing from the consultation documents.
Many of the issues identified within the Sustainability Report are not addressed by the Pre-submission Local Plan.

Object

Technical Reports

Representation ID: 10282

Received: 22/02/2018

Respondent: Mr Peter Sparks

Representation:

DtC - SA does not take into account adjoining LPA growth

06

Full text:

I am hereby writing to lodge my opposition to the Central Bedfordshire Local Plan as part of the January/February 2018 Consultation (Regulation 19). Below I have listed the reasons for my opposition.
Delivering this Local Plan - The level of detail and language of the policies in this plan show the inability of Central Bedfordshire Council to deliver the proposals of this plan. The residents of this council area deserve to know not the "principles of the development" but what the development must provide. The policies should be the parameters in which development and growth happen. The wording of this document suggests too much flexibility which will allow developers and land owners to subsequently manoeuvre out of agreements under the pretence of lack of viability.
For example policy SA2 is to change one parish from around 550 homes to approximately 5,000. This level of development is so extreme that the notation that more than 5,000 homes could be built is not one that the local residents would accept. This is the opportune time to explicitly state the limit of development so it is clear as the policy progresses during the term of this plan.
Third party agency reliance and infrastructure - So much of this Local Plan is reliant on other third party agencies such as improvements to roads and junctions maintained by Highways England, East-West Rail and the other mainline routes, provision of healthcare and utilities including broadband. This plan sets out 'principles' and aims but nothing that can be relied on. There is not even a policy to state that assurances and agreements will be in place with these third party agencies to deliver what is necessary for these new developments to be sustainable. This is particularly true where provisions are not meeting current need. Policy SA2 covers such an area, provision in healthcare and improvements to Junction 13 of the M1 and the East-West upgrade would need to be in place before any development begins. Furthermore given that funding and a route have not been approved for East-West Rail to go beyond Bedford to Cambridge this infrastructure should not be relied on so heavily.
Coalescence (8.8) - The Local Plan put forward at this stage continues to provide no definition or definitive policy as to how coalescence will be managed. Point 8.8.2 highlights that the Marston Vale is a location that will experience strong pressure for development and that specific protection in this location is needed. However, bar this acknowledgement the Local Plan fails to provide any specific security as to the limitation of coalescence if development is pursued. As it is recognised that this location is of particular risk then an enforceable policy is needed at this stage to give protection against the highlighted risk. Section 8 continues with Important Countryside Gaps but fails to provide any to the Marston Vale area where development is proposed.
A clear way of ensuring that coalescence of existing settlements is not permitted would surely be that sites taken forward should not have their boundaries meeting the boundary of a settlement. A defined substantial area of land should be mandated between existing settlements and sites proposed.
Policy SA2: Marston Vale New Villages - This policy area is too large to provide useful comment on and should be in smaller sections as some development could have been acceptable. To propose it as one policy only leads to a standpoint of opposition. The fact that the vast majority of the policy area falls within Lidlington Parish but Lidlington is not mentioned goes someway to reveal the future look of the place with the existing small village disappearing under the new town of Marston Valley. Detailing this policy as 4 villages misrepresents what will, in essence, be a town.
As mentioned in the coalescence section above, the boarders of this policy should have been pushed back from the existing settlements to stop coalescence from the outset.
As per the Settlement Hierarchy (Section 9) Lidlington is classified as a Small Village and the Local Plan highlights that the Greensand Ridge is designated as a Nature Improvement Area and highlights the importance of Forest of Marston Vale. To impose 5,000 houses and 40ha of industrial use is clear overdevelopment of one parish. Furthermore this is agricultural land that once lost is not substituted elsewhere.
The Forest of Marston Vale is mentioned on a number of other occasions and to list green benefits from building over it does seem somewhat at odds with showcasing its importance as a valuable landscape when that will be lost. The development will not bring any benefit to the existing settlements as they will be transformed from rural community to urban sprawl.
Cumulative impact - The cumulative impact of neighbouring councils' plans for development and growth, though included in the Sustainability Appraisal, I do not feel have been fully considered. Milton Keynes Council and Bedford Borough Council have large scale plans that will put pressure on the same infrastructure that this plan is reliant upon. The vast majority of new residents will be out-commuters in line with the current demographic of the council area and the fact that the proposed housing need is based on inward migration to the council area. Therefore the vast majority of these journeys will in part at least include a car journey either to Milton Keynes as a final destination or to the nearby mainline rail station. Therefore road infrastructure improvements need to be mandated into the plan before development starts.
Conclusion - Much more could be said on the weakness of the proposals in this Local Plan for Central Bedfordshire and I am sure will be from individuals and organisations that are more qualified in those areas. A document of this nature and consultations held in this manner do not allow for ease of access from residents.
A local plan is necessary but the option put to residents of Central Bedfordshire seems to be a bad plan or no plan, neither outcome is beneficial to anyone bar developers. A truly sustainable plan is needed that meets the needs of the current population of Central Bedfordshire not one that merely is designed to attract inward migration and increase outward commuting.

Object

Technical Reports

Representation ID: 10313

Received: 22/02/2018

Respondent: Mr John Rix

Representation:

SUSTAINABILITY APPRAISAL - does not address how CBC will address key sustainability issues

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Technical Reports

Representation ID: 10328

Received: 21/02/2018

Respondent: Nicola Jones

Representation:

SUSTAINABILITY APPRAISAL - does not address how CBC will address key sustainability issues

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Object

Technical Reports

Representation ID: 10333

Received: 21/02/2018

Respondent: Mr Rob Jones

Representation:

SUSTAINABILITY APPRAISAL - does not address how CBC will address key sustainability issues

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Comment

Technical Reports

Representation ID: 11258

Received: 22/02/2018

Respondent: Natural England

Representation:

HRA - Local Plan should take a strategic approach to water quality and air quality through WCS and Air Quality Assessment

SUSTAINABILITY APPRAISAL - concerned that evidence to inform the SA are not complete
SUSTAINABILITY APPRAISAL - need for pathways for impacts to be assessed
SUSTAINABILITY APPRAISAL - over reliance on development management policies
GENERAL- need for further evidence

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Object

Technical Reports

Representation ID: 11798

Received: 17/02/2018

Respondent: Marston Moretaine Action Group (MMAG)

Representation:

GENERAL - Plan does not sufficiently address the sustainability objectives identified in the SA

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Local Plan Objection

Marston Moreteyne Action Group (MMAG) objects to the local plan and wishes to speak at the Inspection in Public.

MMAG (formerly MMETAG) is a non-political group of volunteers who joined forces in July 2008. Our original focus was to stop plans to build a so called 'Eco-Town' in the Marston Vale area. We proved highly effective in co-ordinating opposition to those plans including getting over 700 villagers to march on the A421 (now C94). The Action Group was re-launched in 2009 to fight inappropriate development that would swamp and urbanise our individual and distinct rural communities. Over the years we successfully engaged the community in these external threats to their environment and way of life. However, on this occasion we find ourselves seeking to engage in a threat to the community driven by our very own Central Bedfordshire Council (CBC). There is therefore a justifiable sense of betrayal felt by this and nearby communities.

Planning Mania

The Marston Vale has seen no shortage in recent years of plans unrelenting in their development expectations. These included the East of England Plan and Milton Keynes South Midlands Sub Regional Strategy. Ostensibly these were all abolished to enable local authorities more freedom to plan the housing needed. The Cambridge - Milton Keynes - Oxford corridor (formerly the Oxford-Cambridge Arc) is a notional arc of agricultural and urban land at about 80 km (about 50 miles) radius of London, in south central England. It runs between the two English university cities of Oxford and Cambridge via Milton Keynes and other important settlements in Cambridgeshire, Bedfordshire, Buckinghamshire and Oxfordshire, at the northern rim of the London commuter belt. It is significant only in economic geography, with little physical geography in common. However, the 'Oxford to Cambridge Arc' is the latest manifestation of the same plan to create massive development across the same area.
In 2009 we facilitated a Conference - 'Marston Vale 2050' so the community could hear from and engage with planners about a shared vision for the Marston Vale. Central Bedfordshire Council stated at the conference that sub regional planning policy would focus on:
* Revitalisation of Bedford Town Centre;
* Reducing the need to travel by private vehicle and
* Continued environmental regeneration in the Marston Vale
There is no electoral mandate for these proposals. No one voted for housing development on this scale creating new towns by stealth.
The Scale
Residents of Central Bedfordshire are astonished at the scale of housing numbers proposed. In the introduction to the pre submission local plan Cllr Nigel Young states "we are planning for up to 20,000 homes over the next twenty years". This understates the number of homes that will be delivered in the plan period. The actual figure is 39,350 new homes comprising 32,000 + unmet need from Luton of 7,350 giving the total 39,350. Of these homes CBC have already committed to building (i.e. provided full or outline planning permissions) for 23,528 over the plan period. So the total number of additional homes that CBC needs to deliver over the plan period is 39,350 minus 23,528 = 15,822 new homes. This is 4,178 (+26%) more homes than they are required to build - the equivalent of a new town the size of Ampthill - numbers suspiciously similar to the proposed Marston Valley four villages. CBC have no requirement to deliver these houses in this location. This is excessive, surplus house building designed to connect Milton Keynes with Bedford; the very issue this community rejected decisively when previously touted as an Eco-Town.
Most of the proposed homes to be built will be for people commuting out of the area; this is evidenced by the proposed 24,000 new jobs and proposed 39,350 new houses. Why are we encouraging a large amount of people to settle in, what the plan itself calls, a 'predominantly rural' area, where they will need to commute regularly outside of the area. This is both unsustainable, environmentally damaging, and will cause the permanent loss of valuable countryside and agricultural land to meet non-local needs. It will negatively impact infrastructure and services well beyond the Central Bedfordshire area as well as within. The plan should limit itself to addressing the current and properly assessed need only; it should balance the need for homes with the need to protect rural and countryside assets and should not strive for additional development that has either not been correctly assessed and/or is not clearly identified as needed.
This is clearly not justified, or appropriate or sustainable.

Transport
The region is well served by major radial routes from London (the M40, M1, A1(M) and M11 motorways, and the West Coast Main Line, the Midland Main Line and the East Coast Main Line railways). In November 2017, in its report on the Corridor, the National Infrastructure Commission called for the railway line between Bicester and Bedford to be reopened by 2023 and Bedford/Cambridge by 2030, and for the development and construction of a new grade separated dual carriageway between the M1 and Oxford by 2030, as part of the proposed Oxford-Cambridge Expressway. These are plans on paper with no certainty they will be delivered. However, the present day reality is that routes around the arc are poor, with a disjointed and overloaded road network (A428, A421/A422 and A43) and a fragmentary railway line (remnants of the former Varsity Line). A twice-hourly express bus service, route X5, is operated by Stagecoach UK Buses between Cambridge and Oxford, serving the more important of the settlements on route; but taking 3 hours and 40 minutes to travel the 85 miles (137 km).
The Local Plan does not sufficiently address how CBC will meet the sustainability objectives identified within the Sustainability Appraisal report. Section 2.2.2 of the report states that; 'Travel patterns within Central Bedfordshire are less sustainable with a high reliance on car commuting, together with increasing pressure on interchanges and the rural road network.' The developments documented within the Local Plan are, in the majority of cases, in areas where public transport has been reduced in recent years, compelling residents to access car travel to hospitals, local amenities and other services. The plan does not account for how improvements in public transport will be funded, provided or made sustainable.
Environmental
The Local Plan policies does not contain sufficient, robust and effective safeguards to properly protect the natural environment, agricultural assets and the benefits of small rural villages and rural communities, including areas with dark skies and tranquillity. The Plan as it stands proposes the destruction of existing woodland and farmland; land once built over cannot easily be returned to food production. Central Bedfordshire is rich in both top grade soils and water resources and covering them in brick and concrete would not only contravene national planning policy, but would amount to reckless environmental vandalism.

Four New Villages in the Marston Vale
The proposal is misleading as it is actually four new villages and an expansion of the village of Marston Moretyene. Marston Moretyene has already contributed to housing growth with the major expansions of Marston Park and Moreteyne Farm increasing the village by easily over a third. Significant development has been continuous for almost a decade. Residents were assured by local Councillors that there would be a respite from further development.
The proximity of the four new villages is in effect creation of a new town consisting of six suburbs, four new and two existing villages. This is an enforced urbanisation of the existing community. All of the development uses precious agricultural land despite a government commitment for house building focused on brownfield sites. In addition, the CPRE states there are enough brownfields sites for 1 million homes across the UK.

There is already approved expansion of Milton Keynes to Junction 13 of the M1 / Brogborough and Bedford Borough development plans for Stewartby and Wootton. The proposed four village urbanisation will lead to coalescence of Milton Keynes and Bedford.

The former Mid Beds District Council objected to the then proposed Eco Town encompassing the same area as the now proposed four villages. In addition the then Core Strategy and Development Management Policies (driven by the East of England and South East Plans and Milton Keynes & South Midlands Sub Regional Strategy); acknowledged the Northern Marston Vale as a rural area and, in isolation, it would not be a priority location for growth.

On the 7 September 2017 both Bedford Borough and CBC wrote to the Environment Agency asking that the Environment Agency refuse Covanta a permit to operate an incinerator in Rookery Pit. Their concerns focused on:
* A lack of confidence in the dispersion model used (re matter from the incinerator stack) to address the temperature inversion arising from the topography of the Marston Vale
* Health impacts of particulate matter on local residents
* Health impacts of Diesel emission from 594 HGV movements a day on local residents
Yet the very same Council are now promoting large scale housing development in the same area and much of it very close to the incinerator.
There is concern over the impact of lack of infrastructure and the potential burden on existing facilities within Marston Moreteyne. Whilst new health facilities are identified within the plan, there are no guarantees that these will be actively delivered by the NHS. This would leave existing health facilities in Marston Moreteyne and Cranfield further overloaded and heading towards the point of collapse. Similarly there are concerns expressed over education facilities. Marston Moretyene's new lower school (Forest End) is currently being extended to accommodate additional pupils because of permissioned development in the parish. Further substantial education requirements will also be challenging with regard staffing and ongoing funding beyond creation of the buildings.
There is grave concern regarding the impact that this level of development will have on the newly downgraded C94. Any traffic accessing/leaving the proposed development will have to do so though one of the four surrounding villages: Marston Moreteyne, Brogborough, Lidlington or Millbrook. The belief is that the majority of traffic will use the C94 resulting in Marston Moreteyne and Brogborough being the worst affected. The new development of housing at Moreteyne Farm borders the C94. The road at this point has been narrowed and has a 30mph speed restriction. The scale of the proposed development would therefore have a significant, detrimental effect on the existing community of Marston Moretyene.

CBC should be exploring a more radical solution to lorry traffic to and from Millbrook Proving Ground. The proposed Cross Vale Link road simply shifts lorry traffic affecting one part of Marston Moreteyne to another part of the same village.
Conclusion
In summary, the local plan provides too many houses, in the wrong places, depending on massive infrastructure investment which is far from guaranteed, involves destruction of the countryside and wildlife habitats. Once that is gone it is lost forever.

Comment

Technical Reports

Representation ID: 11852

Received: 22/02/2018

Respondent: Homes England

Agent: AECOM

Representation:

SUSTAINABILITY APPRAISAL - document does not present required information on reasonable alternatives
SUSTAINABILITY APPRAISAL - little information on 'reasons for selecting alternatives dealt with'
STRATEGY - concern that CBC not sufficiently developed and appraised reasonable spatial alternative

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Comment

Technical Reports

Representation ID: 12067

Received: 22/02/2018

Respondent: O&H Properties Ltd

Agent: David Lock Associates

Representation:

SUSTAINABILITY APPRAISAL - support

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Comment

Technical Reports

Representation ID: 12295

Received: 22/02/2018

Respondent: Gladman Developments Limited

Representation:

SUSTAINABILITY APPRAISAL - not clear as to why alternatives chosen
SUSTAINABILITY APPRAISAL - SA has failed to identify and assess all reasonable
alternatives using the information that was made available to the Council


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Comment

Technical Reports

Representation ID: 12356

Received: 22/02/2018

Respondent: Denison Investments

Agent: Arrow Planning

Representation:

SUSTAINABILITY APPRAISAL - should be revised to include an assessment of sites on urban edge of centres
GENERAL - LP unsound

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Comment

Technical Reports

Representation ID: 13879

Received: 22/02/2018

Respondent: Catesby Estates Plc

Agent: Mr Simon Atha

Representation:

TARGETS - figures are not an accurate representation of level of growth planned for
METHODOLOGY - unclear as to how the local plan has arrived at the preferred approach, no defined conclusion, housing with the new methodology not tested in the SA as an alternative
POLICY - SP1 not tested through the SA, reason for rejection not justified

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Object

Technical Reports

Representation ID: 13898

Received: 22/02/2018

Respondent: Abbey Land

Agent: JB Planning

Representation:

METHODOLOGY - include findings on WoL, Only site to score positively
ALTERNATIVE SITE - Strong attributes, larger capacity
GREEN BELT - Less of an impact
SUSTAINABILITY - sustainable location
METHODOLOGY - must recognise evidence for WoL, consider WoL in alternative scenarios, why West of Luton is suggested for 2,000 homes, unclear how SA came to figures, scenarios incorrect, lower targets tested than at Reg. 18
Environment - Impacts on AONB can be avoided
STRATEGY -Identify WoL for housing, strategy in SP1 not tested
TARGETS - housing figures wrong in SA, not delivering higher levels, aiming for lower housing targets

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See attachments and appendices 4.1-4.5 attached to the Representation on Policy SP1

Representations created for the following documents:
Legal Soundness/Duty to Co-operate - Ch. 1.7, 1.10, 6,2
Vision and Objectives - Ch. 4.2
Spatial Strategy/Policy SP1 - Ch. 1.4, 1.5, 1.7, 5.2, 5.4, 6.0, SP1, 12.8
Monitoring - Ch. 7.3
Key Diagram - Ch. 7.4
Policy SA1 - Ch. 7.7, SA1
Policy HA1 - Ch. 7.8, HA1
Green Belt/Policy SP4 - Ch. 8.0, SP4
Sustainability Appraisal

Object

Technical Reports

Representation ID: 13947

Received: 21/02/2018

Respondent: Mr Simon Denchfield

Representation:

GENERAL - no reference to SA objectives in the Plan

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Object

Technical Reports

Representation ID: 14144

Received: 22/02/2018

Respondent: Hayfield Consortium

Agent: Savills

Representation:

GENERAL - LP not consistent with the findings of the SA in particular Area C
GENERAL - inclusion of the smaller part of the site should be appraised as an alternative for the small and medium sites
GENERAL - SA does not test the full level of housing as required by the standard methodology as a scenario

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