Strategic Housing Land Availability Assessment (SHLAA)

Showing comments and forms 1 to 30 of 142

Object

Technical Reports

Representation ID: 7843

Received: 22/02/2018

Respondent: Bedfordshire Land Promotions

Agent: JLL

Representation:

ALTERNATIVE SITE - Caddington
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

Land at Caddington Brickfields should be included in the allocation of small and medium sites. The case for inclusion is set out in the attached documents.
1. Caddington Brickfields Masterplan. The document summarises the characteristics and credentials of the land at Dunstable Road, summarising initial assessments of the site and surroundings. It concludes with a masterplan layout which demonstrates how the site can be developed without significant harm to material considerations, notably the adjacent AONB.

2. Ecological Technical note. The document includes the Phase 1 Habitat Survey which has been carried out and which confirms the lack of significant constraint on the site. This responds to a key concern of the Council as expressed on the Technical Assessments 2017.

3. Response to assessment. The document reviews the Council's Pre-Submission Local Plan and the associated evidence base (specifically the Council's assessment of the Caddington Brickfields site). The document provides a response to the Council's assessment, drawing on the positive assessment of the land in the Growth Options Study 2017.
In combination these documents demonstrate that the land at Caddington Brickfields is a sustainable location for development and can make a positive contribution to the settlement. The evidence demonstrates that it can be delivered without significant harm to the natural or built environment. Caddington itself is a sustainable settlement with a good range of services and facilities, well located to meet needs arising from Luton.

Object

Technical Reports

Representation ID: 7885

Received: 07/02/2018

Respondent: Mrs Julianne Wright

Representation:

FLITTON GREENFIELD

METHODOLOGY - dispute site assessment process/ results

08

Full text:

see attached

Attachments:

Object

Technical Reports

Representation ID: 7886

Received: 07/02/2018

Respondent: Mr Graeme Wright

Representation:

FLITTON & GREENFIELD

METHODOLOGY - object to the assessment of NLP127 as suitable, achievable and available
FLOODING - land prone to flooding, risk of increased run off to surrounding housing
TRANSPORT - existing issues with traffic and speeding through village, concern over access
SETTLEMENTS - impact on character of village if development proceeded here

05

Full text:

see attached

Attachments:

Object

Technical Reports

Representation ID: 7887

Received: 07/02/2018

Respondent: Miss Hannah Wright

Representation:

FLITTON & GREENFIELD

METHODOLOGY - object to the assessment of NLP127 as suitable, achievable and available
FLOODING - land prone to flooding, risk of increased run off to surrounding housing
TRANSPORT - existing issues with traffic and speeding through village, concern over access
SETTLEMENTS - impact on character of village if development proceeded here

05

Full text:

See attached

Attachments:

Object

Technical Reports

Representation ID: 7888

Received: 07/02/2018

Respondent: Mr James Wright

Representation:

FLITTON GREENFIELD

METHODOLOGY - dispute site assessment process/ results

08

Full text:

see attached

Attachments:

Object

Technical Reports

Representation ID: 8162

Received: 15/02/2018

Respondent: Martin Small

Representation:

HARLINGTON

METHODOLOGY-flawed assessment of Harlington capacity

04

Full text:

The analysis o Harlington village and capacity assessment contained so many errors and omissions so as to render unsound and unjustified the proposal for the village to expand by 60%.

Attachments:

Comment

Technical Reports

Representation ID: 8403

Received: 18/02/2018

Respondent: Mrs Jen Fisher

Representation:

FLITTON GREENFIELD

METHODOLOGY - dispute site assessment process/ results

08

Full text:

NLP 272 Moat Farm Close Greenfield
I note that this site is marked as a 'reserve' site and I wish to strongly oppose this. The proposal is for up to 30 houses and considering that Greenfield (with Flitton and Wardhedges) has small village status, then the development of the land in this way is completely out of proportion. It would overwhelm the village and certainly does not conform with the 'infill' of up to two houses ascribed to small villages. I also believe the site is outside the village settlement envelope plus the land is grade 2 agricultural land, which the village does not want to lose.

In terms of landscaping, the site is visible as you enter the village from a main approach (the west). It would be back-land development in a mainly linear setting. The site forms part of the open countryside and would alter the rural feel of the village. At the moment the houses in this part of the village and this side of the road are well spaced out and this development would impact on the visual appearance and character.

In terms of traffic, the impact would also be hugely detrimental. The road through the village is already busy with high-volumes of traffic, not least because the village is used as a rat run to and from the A1/ M1. The parish council has already invested huge amounts of money in traffic calming through the village which doesn't actually appear to have had much effect - I hate to think of the impact of adding inevitable cars and car movements from this development. This is compounded by the lack of facilities and amenities in the village, which means that new arrivals would be dependent on their cars (partly because the pedestrian and cycle access to Flitwick are so dangerous).

Linked with this - lack of amenities in the village. The local lower school is already at capacity and neither Flitwick middle school nor Redborne upper school are in our catchment area. Children from F&G go to Arnold (Barton) then Harlington upper and the distance to get to these 2 schools is far greater than Flitwick and Ampthill. Also, there is currently a threat to withdraw school coaches certainly to Arnold which would totally exacerbate the problem.

There are also wildlife & environmental concerns. For example existing hedgerows / trees would be affected and should not be lost or removed, indeed should be retained and enhanced for the benefit of the environment, villagers and visitors.

I strongly believe that the constraints already identified on this site mean that, although it has not been allocated in the Local Plan (so far - at the moment seen to constitute some kind of reserve site) it should be totally rejected as unsuitable.

NLP 127 Land to rear of 58 High St Flitton
I also strongly object to the designation of this site as some kind of reserve.
Density and Settlement -
I would not wish to see development of this site especially as Flitton is a small village/settlement where the presumption would be that the scale of development should be commensurate with the scale of the small settlement. A development of this size would swamp the settlement and is far more than the presumption to limit development to 'infill' - generally defined as up to two dwellings (taken from the Draft Pre - Submission document - page 106)
I believe the site currently used for farming business and is primarily Grade 2 agricultural land which should not be lost to the Parish. There are quite often cows and sheep on this land which is preferable to more housing, particularly in this rural village setting.
Settlement is mainly linear in the High Street and this would change the pattern. In addition, the settlement envelope in the past has been carefully drawn to exclude this back land and avoid a mass of development in the centre of the village.
I have serious concerns about the landscape of this site.
The site is in open countryside, visible from all neighbouring properties in Sand Road and High Street and would be back-land development in a mainly linear setting. It is on a fairly steep hill and would seriously overlook nearly a dozen houses in the High Street and Wardhedges Rd. Whilst back land development has occurred elsewhere in the parish none of the other sites have the serious overlooking situation that would occur here.
In addition development of site is not acceptable in landscape terms as it forms part of the rural landscape setting to Wardhedges and abuts the Flitton Conservation Area with Church and Mausoleum.
I believe there may also be a serious drainage and flooding issue give the location of the site.
In terms of Point 33 Drainage and Flooding on the site assessment forms, the fact that this site is marked with a G meaning no assessment is required is totally inaccurate. The stream at the bottom of some of the gardens in Flitton High St has flooded the gardens in the past and clearly if any houses were to be built this would seriously exacerbate the situation with run off from hard standing going direct into this stream particularly as the proposed houses would be so much higher than the existing properties.
This site shares the serious traffic and infrastructure problems as I have highlighted for the Greenfield site so need to be taken on board here as well.

Object

Technical Reports

Representation ID: 8693

Received: 22/02/2018

Respondent: Red Eagle Securities

Agent: hd planning ltd

Representation:

MOGGERHANGER - object to HAS40

REASONABLE ALTERNATIVE- consider NLP305/149 more suitable
METHGODOLOGY - dispute HIS outcome

05

Full text:

We object to the allocation of site HAS40 (Bedford Road, Moggerhanger). This allocation is unjustified and is presented in a form which is different to the site which was submitted for consideration. Originally this site HAS40 was submitted as a 4.71 hectare site which was proposed to accomodate at least 85 dwellings. The Council has provided no further justification for the reduction in site area of this parcel of land or the reason for changing the details of the submitted site at this late stage. We question this as a site for 30-40 dwellings has been promoted to the south which passed all the site assessment criteria. We ask for justification as to why this site was altered rather than considering allocating the alternative site to the south (NLP305/159).

We further question the justification for this allocation which is surrounded on three sides by open countryside rather than site NLP305/149 which was for a similar scale of development and considered suitable for development through the Site Assessment process (as presented in Appendix A of the SA and Appendix VIId of the SHLAA).
This site further south of Bedford Road, is surrounded on three sides by residential land and to the north is screen by a tree belt which would prevent any visual impact on the character of the area. This site would be much more suited to residential development and would include the same benefits to that presented within site HAS40. No further justification has been provided by the Council to back up this allocation over other alternatives in the locality and we seek clarification as to why site NLP159/305 was not considered suitable for allocation where this site separate from the existing residential dwellings in Moggerhanger has received an allocation.

Object

Technical Reports

Representation ID: 8704

Received: 22/02/2018

Respondent: Messrs &Ms N, I, R, L & E Gibson & Reynolds

Agent: hd planning ltd

Representation:

BLUNHAM
ALTERNATIVE SITE
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

We object to the lack of justification for the chosen allocations within policy HA1 and more importantly the process which led to the proposed allocations.
Points were raised as part of the draft Plan consultation in August 2017 against the site assessment criteria which led to some of the sites being discounted. In particular, site ALP214 (Land east of John Donne Lower School, Blunham) was discounted for flooding reasons as it was considered that more than half the site was within zones 2/3. This calculation was disputed as part of this consultation and a full FRA was submitted to provide evidence that flooding was not a barrier to the development of the site. However, these comments have not been addressed by the Council and no response has been received.
This site, as presented previously, offers substantial benefits to the local community including an extension to the local school, additional playing fields, parking for staff members along with biodiversity and open space contributions. An up to date indicative scheme has been attached to this representation showing these benefits.
The site was submitted including areas which are potential liable to flooding; however all of this area is to be offered as open space and playing fields which is wholly acceptable. This narrow assessment criteria had led to a suitable development site with extensive benefits being discounted and we question this justification and ask for this to be reviewed at Examination.

Attachments:

Object

Technical Reports

Representation ID: 8705

Received: 22/02/2018

Respondent: K Quince & Son Limited

Agent: hd planning ltd

Representation:

BLUNHAM
ALTERNATIVE SITE - ALP216
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

We object to the decision to discount site ALP216 (north of the barns, Blunham) from the SHLAA at a late stage in the Local Plan process without any consultation with the owner or agent. This site appears to have been discounted on questions over the ability to access the site for more dwellings; however, the site already has consent for over 5 dwellings and a suitable access to adoptable standards has been agreed through this planning permission.
We seek further justification for this decision to not progress site ALP216 further through the site allocation process.

Attachments:

Object

Technical Reports

Representation ID: 8736

Received: 22/02/2018

Respondent: K Parrish & Son

Agent: hd planning ltd

Representation:

STONDON REASONABLE ALTERNATIVE

REASONABLE ALTERNATIVES-have not been considered. Additional land available close to HAS46
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

We question the justification for the allocation of HAS46 without considering the additional land to the north (ALP304). This site was submitted via the call for sites process and passed all the site assessment criteria (as set out in the Site Assessment Forms (Housing) (Technical Paper). As part of the update to the SHLAA this site was discounted due to landscape reasons. We question this as the site would abut the proposed allocation HAS46 and will therefore be surrounded on three sides by residential development. Views from Bedford Road towards Upper Stondon are possible but these views are of modern agricultural buildings at Manor Farm in the distance and are not thought to be of landscape value.
This area of land would form a logical extension to Lower Stondon and we believe should form part of allocation HAS46 to form a larger allocation.

Object

Technical Reports

Representation ID: 8811

Received: 21/02/2018

Respondent: Greene King

Agent: David Russell

Representation:

STOTFOLD

ALTERNATIVE SITE - Stotfold (NLP154)
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

At the Draft Plan stage, we strongly supported the principle of bringing forward development through the identification of small and medium size sites to ensure a continuity of housing land supply before the larger strategic sites come on stream. Our concern is with timing. We were involved with the previous Central Bedfordshire Local Development Plan that was adopted in 2011 in relation to a strategic land allocation for around 1000 dwellings. Seven years on, planning discussions are continuing with no starts as yet on site.

We note that Policy HA1 includes no proposals for Stotfold. In our representations on the Draft Plan, we made the case for allocating some land along the Arlesey Road, being the most logical location in relation to the village and its commercial and community infrastructure. Our client owns land in this area, referenced site NLP154 in the LPA's Site Assessment Technical Document. It could provide approximately 80 dwellings. One of the reasons given for not considering this land as a potential housing land allocation was its function as a "rural buffer". Clearly, this alleged function was not important enough for the land to be designated as an Important Countryside Gap in the Pre-Submission Document. This land, together with land to the east (LPA reference NLP160), would have a combined capacity of around 250 dwellings. This would help to reduce the size of proposed allocation SA3, that in its current form poses such a major threat to open countryside around and between Arlesey, Fairfield and Letchworth.

The Draft Plan's technical assessment said that our client's land, referenced NLP154, should not be considered as a land allocation for the following reasons:
* The site does not follow the existing residential line of development and would extend the settlement in an illogical way.
* Comments from consultees highlight issues surrounding negative impacts on existing green corridors and the site's importance as a rural buffer.
* Also the site is not within a flood zone, but may hold flooding issues from the adjacent brook.

The potential flood risk associated with Pix Brook is very small. According to the Environment Agency, the risk from the stream is almost non-existent and that from surface water is low. The site's development will include drainage measures to help restore natural habitat along the brook's northern bank.

The objections on landscape and green infrastructure grounds are mainly based on aspiration 37 of the Stotfold Green Infrastructure Plan, rather than the inherent nature of the site. This aspiration was prepared without consulting the landowner, whose intentions to promote the site as a housing land allocation have been clear since their expression of interest, submitted in response to Mid Bedfordshire's March 2007 consultation on the Mid Beds LDF Site Allocations for Housing.

Ever since that first expression of interest, we have stated the landowner's willingness to dedicate land on the site's southern edge to improving the natural habitat along Pix Brook, and include drainage measures that will assist in achieving this. Our proposals will result in a positive improvement to biodiversity along the Pix Brook corridor, reinforcing the green infrastructure corridor that runs between Stotfold and the current edge of Arlesey shown on The Mid Bedfordshire GI Plan 2008.

It is difficult to understand how the site can be described as a rural buffer. It has no functional connection with the open countryside to the north beyond Arlesey Road or to the south beyond Pix Brook. It has no features that are of landscape value.

Far from extending the settlement in an "illogical way", the site is an integral part of the last remaining strategic growth area for Stotfold, between Arlesey Road and the Pix Brook corridor, extending west to the Etonbury Middle School.

Site reference NLP154 remains in our opinion as an ideal residential site for the following main reasons:
* It is in a sustainable location with all local services and facilities in easy walking distance;
* It is readily available for development, with a short development period from start to final completion;
* There are no ownership constraints;
* There are no legal constraints;
* There are no constraints on access;
* There are no local infrastructure constraints;
* The ground is not known to be contaminated;
* The level site abuts existing residential development;
* The site has well planted, defensible boundaries;
* The site is not isolated; its development will serve to round off this part of the village;
* A well designed scheme will have little or no environmental impact.

Therefore, as Site NLP154 is readily available with no constraints, it should be seriously considered, as the intention is to provide small market and affordable dwellings together with self-build plots.

Attachments:

Object

Technical Reports

Representation ID: 8828

Received: 21/02/2018

Respondent: J Gudgin

Agent: Woods Hardwick Planning Ltd

Representation:


METHODOLOGY - Dispute site assessment
REASONABLE ALTERNATIVES - not been considered (NLP155/NLP389)
INFRASTRUCTURE - lack of services and facilities
METHODOLOGY - dispute SHLAA assessment

06

Full text:

J Gudgin object to Policy HA1 on the basis that their site has not been allocated, retaining the view that it is a suitable site for further development in Shefford. They submitted the site ref: NLP155/NLP389 in response to the 'Call for Sites' for consideration as a suitable housing allocation within the Local Plan. The site did not pass the first stage assessment, the results of which were published as part of the evidence base in the Regulation 18 consultation on the Draft Local Plan. The site assessment were largely positive but the site did not pass, with the conclusion stating that the site is not considered for further assessment on the basis that:

'On balance due to the location of the site and the identified flood risk concerns and impact upon settlement character, the site is not considered for further assessment'.

In response to the Regulation 18 consultation, detailed representations were made rebutting these conclusions. For ease of reference these are appended to this submission rather than repeated. This current consultation now sets out a list of small to medium scale sites that are to be allocated under Policy HA1. For the plan to be found sound, it is submitted that there should be a robust evidence base to justify the decision-making process for allocating the listed sites. The evidence base is clearly lacking in this regard.

The evidence base includes a Sustainability Appraisal (SA) and a Strategic Housing Land Availability Assessment (SHLAA). The SA assesses all of the sites that passed the first stage assessment against a set of criteria. However, having carried out the assessment there does not appear to be a comprehensive further assessment or justification as to why sites have or have not been allocated. Appendix 7D purports to set out this information as this section is titled 'Pre-Submission CBLP SA Report: Appendix VIId Small-Medium Site Options - Outline Reasons for Selection or Rejection'.

Appendix 7D provides justification in part. Some sites are subject to quite detailed comments as to why they have not been allocated but other sites simply state that they passed the assessment but have not been allocated. Furthermore, there is no robust justification for the selection of the allocated sites. It simply states that the site has been 'Progressed as HASxx'.

Furthermore, the SHLAA only provides little if any information to justify the sites that have been selected. These representations do not wish to isolate and comment on any one specific site. However, it is important to highlight the fact that there are a number of sites that have been proposed for allocation that did in fact not pass the first stage assessment. There is no explanation for this.

We have submitted representations elsewhere with regard to the overall housing growth figure and the need to both raise this figure and allocate further sites to meet the clear and substantial housing need. Furthermore, the over reliance on strategic sites to deliver a substantial amount of housing is not an effective strategy to deliver the required housing growth. This site is submitted as being a suitable allocation to assist with that delivery.

We also wish to express concerns with regard to infrastructure provision in Shefford. The Regulation 18 consultation was accompanied by an assessment of development capacity in Shefford. One of the key issues identified within that assessment and an issue that is widely known, is pressure on education provision and in particular the availability of lower school places. The Council has stated that

'Shefford Lower School is close to capacity and a rise in students is predicted in the pupil forecast, however the school site cannot accommodate expansion.'

A further allocation is proposed in Shefford on the extreme edge of the town, which is proposed to deliver a further 72 units. J Gudgin previously submitted an application on their site and the main area of concern that was raised was the lack of capacity in the lower school, with the Council effectively placing a moratorium on any significant further development in the town. Since then several windfall sites have come forward. This further allocation is proposed with no apparent solution to this key infrastructure issue. J Gudgin is of the view that this renders the plan unsound. It has not been positively prepared to meet the clear and obvious infrastructure issue in Shefford. Further development, including this site, should be brought forward to provide a site for a new lower school. This should include this site, which is submitted as being a suitable site in all respects. J Gudgin has a strong track record of delivery having brought forward two sites in a very timely manner following their allocation within the 2011 Site Allocations DPD.

Object

Technical Reports

Representation ID: 8838

Received: 21/02/2018

Respondent: Canton Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

SHILLINGTON

ALTERNATIVE SITE - NLP395 is suitable
METHODOLOGY - Dispute site assessment

06

Full text:

Canton Ltd object to Policy HA1 on the basis that their site has not been allocated, retaining the view that it is a suitable site for further development in Shillington. They submitted the site ref: NLP395 in response to the 'Call for Sites' for consideration as a suitable housing allocation within the Local Plan. The site did not pass the first stage assessment, the results of which were published as part of the evidence base in the Regulation 18 consultation on the Draft Local Plan.

Canton Ltd object specifically to the findings and conclusions expressed in response to their site submission for 'Land at Hillfoot Road' (Ref: NLP395). The conclusions stated are that the site is within the conservation area and open countryside and that the development of this site would adversely impact the conservation area. This reason for rejection essentially follows the reason for refusal on a previous planning application for this site. It should be noted that the application was recommended for approval by officers but was subsequently refused by the committee.

The application was supported by a comprehensive set of supporting documents addressing all relevant planning considerations. As stated, the site assessment conclusion follows the reason for refusal. This is helpful in so far as it clarifies that this is the only issue of concern with regard to taking the site forward for further consideration.

Before addressing this issue further, Canton Ltd wish to reinforce the observation in the assessment that the site is well related to the existing built form of Shillington. It is adjoined by development on three sides and contained by existing landscaping to the north. Canton Ltd therefore do not believe that the site should be regarded as open countryside. This is a classification based on the fact that the site is outside of the current defined Settlement Envelope and is not reflective of the particular context of the site.

Following the decision to refuse the previous application, Canton Ltd carefully reviewed the reason for refusal and sought further specialist heritage advice regarding the preparation of a revised planning application for 35 dwellings. The revised application was unfortunately refused for the same reasons as the previous application despite being supported by a very comprehensive Heritage Impact Assessment. The key observations and conclusions of that assessment, which we wish to specifically highlight are as follows (the full report is attached):
* The main reason stated for the designation of the conservation area (stated in the current Conservation Area Appraisal (CAA)) was to enable development control to determine whether proposals preserve or enhance the conservation area or its setting i.e. it was more of a development control tool than a recognition that the settlement included buildings and land of special interest.
* The adopted CAA notes the architectural and historic interest of the conservation areas as largely deriving from the surviving historic fabric embodied with the built heritage
* The land does not make a positive contribution to architectural or historic interest of the conservation area as its value has been eroded over time and cannot be experienced in relation to the historic core of Shillington;
* The site does not play a key role om the separation of Shillington from its 'Ends' in view of the extent of intervening modern development. The experience of that separation is no longer apparent or relevant in relation to this site;
* Whilst the proposal would cause a change through the loss of one field within the conservation area, the development proposals for the site are designed to provide an area of open space within the scheme that fronts Hillfoot Road and provides a liner corridor focusing views towards the church along the existing footpath;
* This reflects the local conditions of the site and its surroundings and the resultant loss of a single, former agricultural field within the conservation area will only result in very limited impact upon its special interest;
* In respect of the Grade I listed church, it has been assessed that the proposals would cause no harm to its significance and its special architectural and historic interest would remain undiminished.

The site is located in the centre of Shillington and is therefore the most sustainable location for new development in the settlement. The benefits arising from the proposal in this regard, including the provision of publicly accessible open space (the existing site is private land), outweigh the very limited impact to the conservation area. The circumstances have changed on the second application, where the LPA were able to demonstrate a 5-year housing land supply against their own housing need. However, with the Council now committing to meeting a substantial amount of unmet need arising from Luton, additional land is required. Canton believes that this site is entirely suitable and is well located, being relatively close to Luton, where the unmet need is arising.

The evidence base supporting the Pre-Submission Local Plan includes a Sustainability Appraisal (SA) and a Strategic Housing Land Availability Assessment (SHLAA). The SA assesses all of the sites that passed the first stage assessment against a set of criteria. However, having carried out the assessment there does not appear to be a comprehensive further assessment or justification as to why sites have or have not been allocated. Appendix 7D purports to set out this information as this section is titled 'Pre-Submission CBLP SA Report: Appendix VIId Small-Medium Site Options - Outline Reasons for Selection or Rejection'.

Appendix 7D provides justification in part. Some sites are subject to quite detailed comments as to why they have not been allocated but other sites simply state that they passed the assessment but have not been allocated. Furthermore, there is no robust justification for the selection of the allocated sites. It simply states that the site has been 'Progressed as HASxx'.

Furthermore, the SHLAA only provides little if any information to justify the sites that have been selected. It is important to highlight the fact that there are a number of sites that have been proposed for allocation that did in fact not pass the first stage assessment. There is no explanation for this.

Canton Ltd do however wish to comment on Site Allocation HAS45: Land to the south and east of High Road, Shillington comprising 2.33ha and allocated for around 42 homes. The allocation is a combination of parcels ALP167 & NLP188, put forward through the Call for Sites. Allocation HAS45 is summarised in Appendix A of the SHLAA as being suitable, available, achievable and deliverable within the first five years of the plan.

In the 1st Stage of the Site Assessments, while both sites passed the various stages of the assessment, significant concerns were raised by the Council's Landscape Officer in terms of the loss of the rural edge to the settlement and harm to the settlement pattern and character, as well as exposure of development to window views from the open countryside. While these concerns were noted, the conclusion of the assessment for site NLP188 goes on to say:

"It is considered that the site if fully developed would not form a logical extension to the settlement with development appearing as an incursion of built development into the open countryside, causing harm to the character and appearance of the area, including the intrinsic character and beauty of the Countryside. However it is considered that a portion of the site could be acceptable".

As noted above, the SHLAA only provides little information to justify why the sites that have been selected as an allocation have been chosen. HAS45 covers an area of 2.33ha, this is just 0.47ha smaller that the area put forward as NLP188. The concluding sentence of the site assessments suggests only portion of the site area could be acceptable and while the site has been reduced in scale by 0.47ha this small area is barely of consequence. The allocation of HAS45 is not supported by any robust evidence therefore Canton Ltd question it's suitability.

We have submitted representations elsewhere with regard to the overall housing growth figure and the need to both raise this figure and allocate further sites to meet the clear and substantial housing need. Furthermore, the over reliance on strategic sites to deliver a substantial amount of housing is not an effective strategy to deliver the required housing growth. The site at Hillfoot Road (Ref: NLP395) is submitted as being a suitable allocation to assist with that delivery.

Object

Technical Reports

Representation ID: 8892

Received: 22/02/2018

Respondent: S&R Developments

Agent: hd planning ltd

Representation:

HENLOW

ALTERNATIVE SITE - Henlow (NLP234)
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

We object to the justification for the allocation of some sites within policy HA1 over other more reasonable alternatives which have been submitted for consideration.
Reasons for dismissing some sites within the SHLAA are unjustified given the information presented within the call for sites submission and additional information submitted in 2017 as part of the draft consultation.
In particular, when considering site NLP234 in Henlow the Council considered the land suitable for development in 2017 within the site assessment technical documentfor the area. The update to the SHLAA, which now accompanies this proposed submission plan states that a "Portion of site in keeping with settlement pattern and buffering A507 not able to accommodate 10+ dwellings, narrow gap to A507."
We strongly dispute this. In 2017, as part of the consultation process, additional information was submitted to support the development of this site. This included a layout plan which clearly showed that the portion of the site which was remaining (following planning permission being granted on the front of the land) could accommodate more than 10 dwellings whilst maintaining a buffer between this land and the A507. This information has clearly not been considered and has not been referred to when producing the SHLAA document in December 2017. We therefore submit this information once again and ask that the justification for the dismissal of this site be reviewed.

Attachments:

Object

Technical Reports

Representation ID: 9031

Received: 22/02/2018

Respondent: Mr Rodger Newman

Agent: Bletsoes

Representation:

CLIFTON

ALTERNATIVE SITE
METHODOLOGY - Dispute HIS outcome

05

Full text:

See attached document.

Attachments:

Object

Technical Reports

Representation ID: 9037

Received: 21/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

ALTERNATIVE SITE - BARTON (ALP252)
IDENTIFIED SITES - sites are not suitable, need evidence
METHODOLOGY - Dispute site assessment

05

Full text:

Policy HA1 of the Plan makes provision for Small and Medium Allocations totalling 5,005 dwellings. In Barton Le Clay two sites are allocated in the Plan, HAS04 Land at Luton Road for approximately 168 dwellings and HAS05 Land East of Barton Le Clay for approximately 498 dwellings. Both are outside the existing settlement boundary and within the Green Belt. These sites, particularly HAS05 which because if it's scale requires the approval of a Development Brief, are likely take much longer to reach the stage of occupation and while they would assist in meeting housing need over the plan period they would not make a worthwhile contribution towards the immediate housing need in the District. Appendix A: List of new sites which pass assessment of the SHLAA which includes a summary of the sites, the sites are assessed as 'not deliverable' within the 5 year period.

To assist with the pressing need for housing the allocation of smaller sites in Barton Le Clay is essential. GPS Estates Ltd agree with the conclusion reached in the initial Site Allocations Technical Document (SATD) prepared as part of the evidence base to support the Draft Local Plan, that parcel ALP252 Land at Manor Road should be considered further as part of the Local Plan. The parcel clearly passed all of the initial stages of the Site Assessments however no further detailed assessments providing justification and evidence as to why the site should not be allocated are published with the supporting evidence. The Sustainability Appraisal to accompany the Pre-Submission Local Plan notes the site as being unsuitable as it would not accommodate 10 dwellings along with the retention of mature trees. No evidence has been published that supports this claim.

The Call for Sites submission, submitted by GPs Estates Ltd suggests a development of 15-20 dwellings could be provided on the site which will make an important and contribute to local housing need in Barton-le-Clay in the early part of the plan period. It is also suggested the development of the site would enable the provision of additional parking spaces to serve the neighbouring school which would be an added benefit of the scheme should the site be allocated for development.

The eastern tree lined boundary would create a strong new boundary between the settlement edge and the Green Belt as suggested on the Stage 2 Assessment of the Green Belt review. The site would effectively infill the space between existing settlement uses and would be contained by the tree lined boundary to the east such that it would not extend away from the settlement boundary itself.

We note there are a number of sites that did not pass the initial site assessment stage but have gone on to be allocated in the Pre-Submission Local Plan. The January 2018 Sustainability Appraisal and the January 2018 SHLAA published alongside the Pre-Submission Plan lack sufficient evidence as to why specific sites have been selected and others discounted. Concern is therefore raised regarding the undue dismissal of sites and unjustified allocations.

Appendix 7D provides justification in part. Some sites are subject to quite detailed comments as to why they have not been allocated but other sites simply state that they passed the assessment but have not been allocated. Furthermore, there is no robust justification for the selection of the allocated sites. It simply states that the site has been 'Progressed as HASxx'.

It is important to highlight the fact that there are a number of sites that have been proposed for allocation that did in fact not pass the first stage assessment. There is no explanation for this. We refer specifically to the following allocated sites:

Site allocation HAS26 - A5 Watling Street, Hockliffe 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 has been published to demonstrate this site has been properly and fairly assessed by the Council.

Site Allocation HAS03 Land off Meadow View, Aspley Guise - Allocated for 37 dwellings. This site failed the initial Stage A Site Assessments. No justification has been published to demonstrate why the site has been allocated despite failing the initial Site Assessments.

Site allocation HAS14 - Land off Eaton Park, Eaton Bray is allocated for 49 dwellings. This site failed the initial Stage A site assessments. No justification has been published to demonstrate why the site has been allocated despite failing the initial site assessment stages.

Site allocation HA25 - Land at Leighton Road, Hockliffe is allocated for 23 dwellings, however the site did not pass the initial Stage A of the Site Assessments. No justification has been published to demonstrate why the site has been allocated despite failing the initial site assessment stages.

Site allocation HAS32 - Northern Chamberlains Barn, Leighton Linslade - Allocated for 175 dwellings. The site failed the initial Stage A Site Assessments. No justification has been published to demonstrate why the site has been allocated despite failing the initial Site Assessments

Site Allocation HAS33 Land North of Soulbury Road, Leighton Linslade - Allocated for 5 dwellings. This site failed the initial Stage A Site Assessments. No justification has been put forward to demonstrate why the site has been allocated despite failing the initial Site Assessments.

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 NLP 318 in Aspley Guise, however site NLP 318 is in Arlesey.

For the reasons covered above GPS Estates Ltd are not convinced the Pre-Submission Local Plan has allocated sites that are suitable. Further evidence is requested in order to demonstrate the above sites have been fully and fairly assessed and meet the criteria set out in the SHLAA. In this respect the Plan is considered to be unsound.

Object

Technical Reports

Representation ID: 9044

Received: 21/02/2018

Respondent: All Land Investments (Stotfold 1) Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

ALTERNATIVE SITES - STOTFOLD - ALP282, NLP106, NLP160
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

These representations are submitted on behalf of our Clients, All Land Investments (Stotfold 1) Ltd, who are appointed promoters of land to the south of Arlesey Road, Stotfold (Parcels ALP282, NLP106 and NLP160) and have significant concerns over the contents of the Pre-Submission Local Plan (referred to hereafter as 'the Plan') and supporting evidence submitted with it.

All Land Investments (Stotfold 1) Ltd are of the view the plan does not currently meet the tests of soundness set out in paragraph 182 of the NPPF as it is not positively prepared, justified, effective or consistent with the NPPF as will be explained in detail in these representations. The comments made on the Plan and supporting Technical Documents focus on the areas of interest and concern to our Client.

Policy HA1 of the Plan makes provision for Small and Medium Allocation totalling 5,005 dwellings. As has been argued in the separate representations on Section 7 and Policy SP1, yield from the strategic allocations in the Plan period has been substantially overestimated and moreover, the Plan fails in any event, to provide for delivery of sufficient housing to meet the need in the HMA. For both these reasons there is a need to increase the amount of medium and small scale allocations included in the Local Plan, as such sites are generally easier and quicker to deliver.

To date, the plan has not identified any sites in Stotfold to be allocated as part of contributing towards this target, ignoring its inherent sustainability as a location for new housing.

The land south of Arlesey Road, Stotfold, being promoted by All Land Investments (Stotfold 1) Ltd is entirely suitable for allocation and should be included as an additional medium scale allocation under Policy HA1. Originally put forward as three separate parcels (ALP282, NLP106 and NLP160) by the landowners, the site is all now under the control of our Client, All Land Investments Ltd, as detailed in our letter to the Council dated 13th April 2017.

Turning to the reasons given in the SHLAA for these parcels not being allocated, in respect of parcel NLP160, which relates to land between Arlesey Road and Pix Brook, it is stated that the 'site is already allocated'. However, this in only true of 3 of the 5 fields included in the area promoted, with these being allocated under Policy HA12 of the Site Allocations DPD (2011). The two westernmost fields are excluded from the existing allocation and were the reason this site was put forward by the landowner. It is therefore suggested that this land should be included in Policy HA1 as an extension to the HA12 allocation. This has been raised separately with one of the Planning Policy Officers, but they did not seem to understand the implications.

Additionally, our Client wishes to draw attention to the fact that, in partnership with a national housebuilder, they have engaged a professional team to prepare and submit a detailed planning application for the entirety of NLP160, including the currently unallocated land. This process has progressed positively and there is a realistic prospect of this site being brought forward in the near future. Moreover, our client has outlined their intention to design the development at NLP160 in a manner which would facilitate future intentions to develop upon the ALP282 & NLP106 to the south which our Client also owns.

In respect of parcels ALP282 and NLP106, in both cases the SHLAA raises the issues of coalescence and impact on ecology. However, these reasons do not stand up under scrutiny. The same points were made in the Site Allocations Technical Document published with the previous draft of the Local Plan in July 2017 and were robustly dealt with in the submissions made on behalf of All Land Investments (Stotfold 1) Ltd.

Firstly, regarding ecology and the fact that the site abuts Etonbury Woods, Aspect Ecology, our Clients' appointed Ecological Consultants, have undertaken a walkover survey which has confirmed that there is limited habitat in this area with biodiversity impact potential and nothing in this regard should constrain future development of the promoted land. Furthermore, in respect of the potential impact on Etonbury Woods, given the size of the combined landholding being promoted there is ample opportunity to create a buffer zone between new housing and this woodland to mitigate for this and provide a sensitive transition.

In response to the argument regarding the landscape impacts and concern over coalescence between Stotfold and Arlesey, a Landscape Statement, prepared by James Blake Associates (JBA) Landscape Architects, which has been appended again, was submitted and demonstrates that the site is completely screened by trees from views from Arlesey to the west. There is currently no visual connection between the two settlements. Although the physical gap between the two settlements would be diminished as a result of the development, the visual separation will increase in scale and permanence. In landscape terms, the site is well screened from most external viewpoints and those views afforded over it that do exist could be screened effectively through mitigation planning.

It is disappointing that the submission made on the previous draft has not been given due consideration. This is especially the case when we note there are a number of sites that did not pass the initial site assessment stage that have now gone on to be proposed for allocation in the Pre-submission Local Plan. We refer specifically to the following sites:

Site allocation HAS26 - A5 Watling Street, Hockliffe 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 is allocated for 23 dwellings, however the site did not pass the initial Stage A of the site assessment process, failing at Stage 1E. No justification has been put forward to demonstrate why the site has now been allocated despite failing the initial site assessment stages.

Site allocation HAS14 - Land off Eaton Park, Eaton Bray is allocated for 49 dwellings. This site failed the initial Stage A site assessment. No justification has been put forward to demonstrate why the site has been allocated despite failing the initial site assessment stages.

Site allocation HAS32 - Northern Chamberlains Barn Leighton Linslade - Allocated for 175 dwellings. The site failed the initial Stage A site assessment. No justification has been put forward to demonstrate why the site has been allocated despite failing the initial site assessment process.

Site Allocation HAS33 Land North of Soulbury Road, Leighton Linslade - Allocated for 5 dwellings. This site failed the initial Stage A site assessments. No justification has been put forward to demonstrate why the site has been allocated despite failing the initial site assessment stage.

Site Allocation HAS03 Land off Meadow View, Aspley Guise - Allocated for 37 dwellings. This site failed the initial Stage A Site Assessments. No justification has been put forward to demonstrate why the site has been allocated despite failing the initial site assessment stage. 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 NLP 168 in Aspley Guise, however site NLP 168 is in Arlesey.

The January 2018 Sustainability Appraisal and the January 2018 SHLAA published alongside the Pre-Submission Plan do not provide any evidence of the decision-making process that has taken place or the justification why these previously rejected sites have now been selected for allocation whereas other sites, such our Clients' land at Stotfold have been rejected. All Land Investments (Stotfold 1) Ltd are extremely concerned that the evidence base to support and justify the strategy in the Local Plan is either flawed or is just not there at all and this symptomatic of the fact the Council has rushed the preparation of this Plan to avoid the consequences of the single method for calculating housing need in the "Planning for the Right Homes in the Right Places" consultation becoming the interim housing target until a Local Plan is adopted.

To assist with the pressing need for housing, our Client submits that the allocation of further sites in settlements such as Stotfold is essential. As noted in our representations on the Pre-Submission Plan and the Settlements Capacity Study, our Client does not agree with the classification of Stotfold as a Minor Service Centre and instead assert that Stotfold should be re-classified as a Major Service Centre capable of accommodating medium to High levels of growth. Bearing this in mind and with regard to ALP282 & NLP106 specifically, we feel these sites represent a fertile opportunity to contribute towards the Councils challenging housing target in a highly sustainable and appropriate location.
In light of these points and considering the challenging housing target the Council have adopted in the new plan, our Client submits that the discussed sites at Stotfold should be considered further as a viable option to allocate future growth.

Object

Technical Reports

Representation ID: 9062

Received: 21/02/2018

Respondent: Bovis Homes Limited

Agent: David Barnes

Representation:

UPPER CALDECOTE

ALTERNATIVE SITE - Promotion of site in Upper Caldecote
STRATEGY - Object to a number of allocated sites

05

Full text:

The full representation is contained in the attached document. There needs to be a realistic assessment about viability and rates of delivery (e.g. see Local Plan Table 7.1). It is also important that too much reliance is not placed upon delivery of housing on large sites as the means to meet a significant proportion of the additional and further housing requirement. A balanced portfolio of allocations spread across the District is required rather than concentrating too much growth at a limited number of strategic sites which may not deliver as expected.

Attachments:

Object

Technical Reports

Representation ID: 9067

Received: 21/02/2018

Respondent: Bovis Homes Limited

Agent: David Barnes

Representation:

UPPER CALDECOTE -DUPLICATE

ALTERNATIVE SITE - Promotion of site in Upper Caldecote
STRATEGY - Object to a number of allocated sites

05

Full text:

The full text of the representation is contained in the attached document but, in summary, Bovis Homes object to the spatial distribution of the medium and small sites allocated pursuant to Policy HA1. This objection to Policy HA1 is made irrespective of the outcome of any debate at the Examination concerning the OAN.

Attachments:

Object

Technical Reports

Representation ID: 9070

Received: 21/02/2018

Respondent: Bovis Homes Limited

Agent: David Barnes

Representation:

UPPER CALDECOTE

ALTERNATIVE SITE - Promoting site in Upper Caldecote
STRATEGY - Object to a number of allocated sites

05

Full text:

As detailed din the attached document, Bovis Homes object to some of the medium and small sites allocated pursuant to Policy HA1. This objection to Policy HA1 is made irrespective of the outcome of any debate at the Examination concerning the OAN.

Attachments:

Object

Technical Reports

Representation ID: 9127

Received: 21/02/2018

Respondent: All Land Investments (Stotfold 1) Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

ALTERNATIVE SITE - promoting site

STOTFOLD - should be allocated for growth
GENERAL - concerns over soundness

04

Full text:

These representations are submitted on behalf of our Clients, All Land Investments (Stotfold 1) Ltd, who are appointed promoters of land to the south of Arlesey Road, Stotfold (Parcels ALP282, NLP106 and NLP160) and have significant concerns over the contents of the Pre-Submission Local Plan (referred to hereafter as 'the Plan') and supporting evidence submitted with it.

All Land Investments (Stotfold 1) Ltd are of the view the plan does not currently meet the tests of soundness set out in paragraph 182 of the NPPF as it is not positively prepared, justified, effective or consistent with the NPPF as will be explained in detail in these representations. The comments made on the Plan and supporting Technical Documents focus on the areas of interest and concern to our Client.

5. The Spatial Strategy

In respect of the spatial strategy, All Land Investments (Stotfold 1) Ltd supports the aim of the first bullet point under Key Spatial objectives 5.2 to grow existing communities across Central Bedfordshire, proportionate to their scale and environmental context. However, they are of the view that the Plan currently fails to deliver on this objective by allocating insufficient growth to Stotfold to reflect the fact it is an inherently sustainable location.

Development to the south of Arlesey Road, Stotfold would also be aligned with one of the other Key Spatial Objectives and the first bullet point of the Spatial Strategy Approach, that of developing growth opportunities around existing and committed transport hubs. Stotfold has excellent connections to the strategic transport network as a result of being in close proximity to the A507, A1(M) and the railway station at Arlesey on the East Coast Mainline.

As will be discussed in greater detail in the representations on Section 6 (The Proposed Locations for Growth), Policy SP1 (Growth Strategy) and Section 7 (Implementation), All Land Investments (Stotfold 1) Ltd are concerned that what the Council purports under paragraph 5.3 to be 'a balanced strategy' in fact relies overly on large new settlements and strategic sites, with the result being that it will inevitably fail to deliver the expected level of housing.

It also objects to the housing target of 39,350 new dwellings, which is referred to in the first bullet point under the proposed Spatial Strategy Approach at paragraph 5.4. Whilst more detailed comments are made in direct responses to Policy SP1, the principal concern is that the Council are simply not allocating the sufficient housing in order to deal with the growing affordability problems in its area in direct contradiction to Government advice and the NPPF direction to "boost significantly the supply of housing".

A further concern is that insufficient headroom has been allowed in the housing target above the need for the area to provide a suitable contingency and ensure effective delivery. These concerns could be resolved through the allocation of further growth to Stotfold.

Object

Technical Reports

Representation ID: 9142

Received: 21/02/2018

Respondent: City & County Projects

Agent: Woods Hardwick Planning Ltd

Representation:

FLITWICK ALTERNATIVE SITE

ALTERNATIVE SITE - NLP245
METHODOLOGY - Dispute SHLAA assessment

05

Full text:

These representations are submitted on behalf of our Client, City & County Projects, who are appointed promoters of a site at Chauntry Way, Flitwick (Reference NLP245) and have significant concerns over the contents of the Pre-Submission Local Plan (referred to hereafter as 'the Plan') and supporting evidence submitted with it. City & County Projects are of the view the plan does not currently meet the tests of soundness set out in paragraph 182 of the NPPF as it is not positively prepared, justified, effective or consistent with the NPPF as will be explained in detail in these representations.

The comments made on the Plan and supporting Technical Documents focus on the areas of interest and concern to our Client.

Policy HA1 of the Plan makes provision for Small and Medium Allocations totalling 5,005 dwellings. As has been argued above, yield from strategic allocations in the Plan period has been substantially overestimated and, moreover, the Plan fails in any event to provide for delivery of sufficient housing to meet the need of the HMA. For both of these reasons there is a need to increase the amount of medium and small-scale allocations included in the Local Plan, as such sites are generally easier and quicker to deliver.

The site at Chauntry Way, Flitwick (NLP245) being promoted by City & County Projects should be included as an additional allocation for residential development. Arguments have been made on the spatial strategy demonstrating that more land needs to be allocated at Flitwick commensurate with its sustainability as Major Service Settlement and to ensure that the new Green Belt boundary is enduring. The reason parcel NLP245 failed the site assessments process does not stand up under scrutiny.

The SHLAA published alongside the Pre-Submission Local Plan advises that this was because it 'would cause coalescence in Green Belt between Ampthill and Flitwick'. Separate representations are submitted on the Green Belt Review, however, City & County Projects Ltd objects in the strongest terms to this conclusion and are very concerned that site NLP245 has not been assessed discretely by the Council as part of the Review, and that it has only been assessed as part of the wider parcel FW1 in Stage 1 of the Green Belt Study, which has directly resulted in the verdict regarding coalescence. It is very disappointing that in some cases where the wider parcels were concluded to be making a contribution to the purposes of the Green Belt, smaller parcels were then assessed discretely to gauge their individual contribution to the Green Belt, but not in others, and the approach taken in the Green Belt Review is generally inconsistent and cannot therefore be deemed to be either fair or sound.

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 and enclosed again with these representations for ease of refence. This Statement concluded that site NLP245 as a discrete parcel in 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 Associates 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.

Comment

Technical Reports

Representation ID: 9157

Received: 21/02/2018

Respondent: Central Bedfordshire Council Assets

Agent: Woods Hardwick Planning Ltd

Representation:

ALTERNATIVE SITE - Slip end (NLP167)
METHODOLOGY - Dispute HIS outcome

05

Full text:

Central Bedfordshire Council (CBC) Assets wishes to take this opportunity to promote their site at Markyate Road for allocation within the Local Plan.

The site was submitted in response to the 'Call for Sites' process and has been assessed by the Council during the course of the plan making process. The preparation of the plan is supported by a comprehensive evidence base to demonstrate that it is a 'sound' document. Those considered directly relevant to this site include the Green Belt Study and the Site Assessment process.

The site is designated Green Belt in the current development plan, the 2004 South Bedfordshire Local Plan. The Green Belt Study supporting the new local plan was commissioned to identify defined parcels within Central Bedfordshire's Green Belt and assess them against the purposes of designating Green Belt Land. This site is identified within Parcel SE1, which was assessed as making a weak to moderate contribution towards Green belt purposes. The Stage 1 assessment has been used to identify and isolate areas of Green Belt which perform relatively weak against Green Belt purposes and are therefore likely to cause less harm if released for development. Those sites move forward to Stage 2.

The Stage 2 assessment took forward the assessment of 29 weekly performing areas with field visits undertaken. The final Stage 3 assessment is concerned with identifying harm to the Green Belt that could result from the release of any of the 87 specific sites identified through the 'call for sites' submission or from strategic sites identified by the Council. This assessment forms part of the evidence for determining any redefinition of Green Belt boundaries if exceptional circumstances exist to making alterations to the boundaries.

The 'call for sites' reference for this site is NLP167. The Stage 3 study sets out a comprehensive and clear set of criteria for assessing the contribution towards each of the Green Belt purposes. The assessment found that this site would result in low-moderate harm. The site ranks well in regard to how low its impact is upon the Green Belt, supporting the supposition that it should be allocated.

As part of the Regulation 18 consultation on the Draft Local Plan, the Council published their assessment of the submissions to the 'call for sites'. This was a sifting process to identify a 'shortlist' of sites for consideration as an allocation. This site passed the first stage assessment.
The Regulation 19 consultation is now accompanied by a further assessment which includes a list of the shortlisted site and a summary as to whether they have been allocated, not allocated and in some cases a reason as to why a site is not allocated.

The only reason stated for not considering this site for allocation is that there are concerns with regard to the proximity of the site to Luton Airport and its associated flightpath. As a matter of fact, the site is located on the western edge of Slip End, which is categorised as a Large Village, and there are a large number of existing properties that are closer to the airport. A noise survey has been commissioned to demonstrate that prospective occupiers of the site will not be unacceptably affected. The survey is appended to this submission.

In summary, the report states that noise levels within the dwellings can be mitigated through standard construction techniques on sites where noise is a relevant issue. External noise levels are slightly above recommended daytime levels but not at a level where planning permission should be prevented. The report therefore demonstrates that the amenities of future occupiers can be addressed based on the known current situation and reasonable assumptions on the future noise environment. There is therefore no noise constraint which should preclude the allocation of this site.

CBC Assets would also reiterate the additional community benefits that the site can deliver. The site is adjacent to the school and as part of the release of this land for development, land would be transferred to the school to allow further expansion. The previous site assessment forms identified that full contributions would be required to create additional school places. Furthermore, the Settlement Capacity Study that forms part of the evidence base for the local plan states that Slip End Village School is close to capacity, that there is an increase in numbers predicted in the pupil forecast and the school is unable to accommodate any further expansion. This site is perfectly placed to facilitate that expansion.

The site also benefits from strong local support for its development. Caddington & Slip End Parish Councils have been working together to prepare a joint Neighbourhood Plan since 2011 and it has progressed to a point where it has been submitted to the Secretary of State for examination and a public hearing is to be held on 15th March 2018.

This site is proposed for allocation within the Neighbourhood Plan, comprising one of only two sites proposed for development. The allocation within the Neighbourhood Plan is predicated on the release of the site from Green Belt, which can only be formally agreed via the local plan process. The proposed allocation within the Neighbourhood Plan is under Policy CASE14, which states that the site will be supported for residential development of approximately 120-150 dwellings. The policy also states development is to meet the needs of older people and make provision of land to allow for the future expansion of Slip End School.

The Neighbourhood Plan has been subject to a comprehensive consultation process with the local community, with strong support expressed for new housing in Slip End. The evidence base that supports the Plan also demonstrates that a robust assessment has been made of all site submitted for allocation and supports the conclusions that this site should be brought forward as a residential allocation. As noted, the site would deliver wider community benefits in addition to housing which would support local services and amenities.

The site, if allocated, could be brought forward for development within a short timeframe. These is an existing agricultural tenancy which can be terminated under the normal notice provisions. Otherwise the site is in single ownership and there are no other known constraints that prevent an application coming forward at the earliest opportunity. As part of the 'Call for Sites' process, an illustrative site layout was developed following an assessment of the site and any constraints. This could form the basis for progressing a planning application.

The Local Plan is to deliver substantial housing growth over the plan period to meet both the needs of Central Bedfordshire and unmet need arising from Luton. This site is well placed to make a valuable contribution towards that. A substantial amount of housing is proposed through strategic allocations, which take a number of years to deliver and therefore the allocation of smaller to medium sized sites play an important role in delivery. This has been recognised by the Council. The allocation of this site would bolster the housing supply. It is well rehearsed that housing targets in plans are minimums and not maximums and therefore additional housing to provide a wider choice and competition in the market for land. This is advocated by the National Planning Policy Framework.

Central Bedfordshire is making a significant contribution towards Luton's unmet need and it is widely acknowledged that this should be provided as close to Luton as possible and this site is perfectly located to meet that objective.

To conclude, the site has previously been assessed by the Council and the only concern raised was noise associated with Luton Airport. To address this, a noise assessment has been undertaken and this demonstrates that acceptable levels of amenity can be achieved.

The site is supported by the local community and is proposed for allocation within the Caddington & Slip End Neighbourhood Plan. Within the planning system, great importance is placed on the localism agenda with emphasis on development being determined at local level. The allocation of this site will fully embrace that objective. The site will not only deliver additional residential growth (which the community supports in Slip End) but also land will be allocated to allow the future expansion of the school. The school cannot currently accommodate the increase in pupil numbers resulting from current growth.

Attachments:

Object

Technical Reports

Representation ID: 9276

Received: 21/02/2018

Respondent: Mr Michael Murphy

Representation:

HOUGHTON REGIS

METHODOLOGY - dispute site assessment process/ results

08

Full text:

Appendix A List of New Site That Pass Assessment.

The assessment for NLP546 (Land to the East of Houghton Regis) is clearly incomplete as the fact that the site falls with the Green Belt and that is there is an overlapping submission (SA5 Hughton Regis North Strategic Allocation) have been omitted. NLP546 does not pass assessment.

Object

Technical Reports

Representation ID: 9488

Received: 22/02/2018

Respondent: Planning Prospects

Agent: Planning Prospects

Representation:

POTTON

SITES - Promoting alternative site

08

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The NPPF is clear that Local Plans should ensure there is a wide range of sites allocated for housing development to ensure delivery of required housing, in both urban and rural areas. The Local Plan should promote sustainable development in and adjacent to existing sustainable settlements to maintain and enhance their vitality and viability and to deliver the housing required in the District. Potton is a sustainable settlement (town) identified as a Minor Service Centre and should look to deliver additional housing to meet the District's needs. There is however just one small or medium housing site allocation in Potton (for just 12 new homes) to be delivered over the Plan period 2015 to 2035 which is disproportionately low for a sustainable settlement like Potton and further sites should be allocated. This is particularly so in Central Bedfordshire where a review of the District's Green Belt is required to identify future development land (which should itself be a last resort).
See attached document promoting residential allocation of land to the south of Sandy Road, Potton.

Object

Technical Reports

Representation ID: 9507

Received: 22/02/2018

Respondent: Linden Homes Strategic Land

Agent: Woods Hardwick Planning Ltd

Representation:

REASONABLE ALTERNATIVE - Land off Eliot Way, Fairfield

04

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These representations are submitted on behalf of Linden Homes Strategic Land ('Linden'), who are promoting Land off Eliot Way on the western edge of Fairfield (Parcel ALP439). They focus on the Pre-Submission Local Plan ('LP') and the concerns Linden has over its soundness as currently drafted.

The comments made are intended to be constructive in nature, with the aim of seeking to ensure that the final version of the Local Plan can be considered 'sound' when it reaches examination.

Section 6 of the Pre-Submission Local Plan describes the potential for growth in each of the four sub-areas into which Central Bedfordshire is divided. Linden objects to the approach set out in respect of the A1 Corridor Area (Sub-Section 6.3) due to the failure to allocate any development at Fairfield.

Given the fundamental principles set out in the spatial strategy in Section 5 of the Plan, including to allocate land commensurate with the scale of existing settlements, the failure to allocate land at Fairfield means the Plan cannot be considered the most appropriate of the reasonable alternatives as required by paragraph 182 of the NPPF in order for it to be considered sound.

Paragraph 6.6.1 of the Pre-Submission LP suggests that allocations have been selected having regard to their overall sustainability. Despite this and the fact that the Settlements Capacity Initial Study (July 2017), which has informed the LP, determined that there is medium capacity for growth at Fairfield (50 - 500 dwellings), it has been overlooked for new growth in the Plan, with allocations instead proposed at numerous less sustainable locations under Policy HA1. This demonstrates the Plan is not currently the most appropriate strategy of the reasonable alternatives available.

Separate representations on the strategy for delivering the housing target in Section 7 (Implementation) have been made on behalf of Linden arguing that, in any event, insufficient housing is being allocated in the Plan to meet the need in the area and further small - medium sized sites need to be included in the Plan if it is to be found to be effective and therefore sound.

In order to be considered sound, the Plan should be amended to include the allocation of Linden's Land off Eliot Way, Fairfield. This is considered in more detail in the representation on Policy HA1.

Comment

Technical Reports

Representation ID: 9516

Received: 22/02/2018

Respondent: Linden Homes Strategic Land

Agent: Marrons Planning

Representation:

CRANFIELD

REASONABLE ALTERNATIVES - site is a reasonable alternative

05

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If, as a result of the Local Plan Examination, it is deemed that further land is required within Central Bedfordshire, Linden Homes control additional land immediately adjacent to HAS11. The Council has assessed part of this land as site NLP104 in its Site Assessments for Cranfield. Whilst the Council's evidence assessed suitability based on the development of the entire site, a smaller sub-parcel closer to the urban edge is considered suitable with good design and appropriate landscape mitigation, in a similar fashion to that proposed for the allocated site as part of Policy HAS11. As an additional small and medium site in an existing sustainable settlement, this could achieve further housing units and help deliver housing in the early years of the plan period.

Object

Technical Reports

Representation ID: 9533

Received: 22/02/2018

Respondent: Linden Homes Strategic Land

Agent: Woods Hardwick Planning Ltd

Representation:

FAIRFIELD

ALTERNATIVE SITE -land off Eliot Way Fairfield
METHODOLOGY - Dispute SHLAA assessment

05

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Although Linden does not object to the principle of the allocation of land East of Arlesey, Linden does object to the boundary of the allocation as currently proposed on the basis it includes all of the land between Arlesey and Fairfield, but wraps around (and excludes) the site they are promoting identified by the red line on the attached plan. As a result, illogically it is the only parcel of land specifically excluded between the two settlements. Whilst separate representations are being submitted on Policy HA1 (Small and Medium Allocations) arguing that Linden's land should be included as an additional allocation in any case, if it is not ultimately allocated, it should be included within the Policy SA3 Strategic Land Allocation to ensure the comprehensive planning of the whole of the area between Arlesey and Fairfield. There is no justifiable reason for the site being left out and the allocation plan included in the LP illustrates how illogical that would be.

Comment

Technical Reports

Representation ID: 9541

Received: 22/02/2018

Respondent: WSPA

Agent: WSPA

Representation:

EATON BRAY

ALTERNATIVE SITE
METHODOLOGY - sites have been incorrectly assessed

05

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WS Planning & Architecture support the principle of the Council's small and medium sites allocations, however, we consider that the assessment undertaken to identify which sites are suitable for development has not been positively prepared. In particular, site NLP204 was discounted by the Council under the Site Assessment Technical Document Appendix D Preliminary Site Assessment Results July 2017 as it was concluded that "the site impacts on the landscaping setting, its locality in regard to a scheduled monument and the sites potential drainage and flooding issues, the site is also a considerable distance from both a train station and a bus Stop" However, it was subsequently demonstrated that the site is not within flood zones 2 & 3, nor the AONB, SSSI or within a Nature Reserve. In regard to the scheduled monument it was demonstrated that given the location of the scheduled monument coupled with size of site NLP204 any development on the site could be sensitively designed to take into account any impact on the Scheduled Monument. Moreover, there is a bus stop that is located within easy walking distance and provides links to the wider area. Furthermore under the Central Bedfordshire and Luton Green Belt study Appendix 1 July 2007 site NLP204 was included in the assessment of land parcel EB1, the conclusion of which stated that the majority of the land had a "weak/no contribution" and some parts "relatively week contribution".