Housing Implementation Strategy (HIS)

Showing comments and forms 1 to 11 of 11

Object

Technical Reports

Representation ID: 8702

Received: 22/02/2018

Respondent: WK & CK Parrish

Agent: hd planning ltd

Representation:

MEPPERSHALL REASONABLE ALTERNATIVE

REASONABLE ALTERNATIVES - site is a reasonable alternative
METHODOLOGY - Dispute HIS outcomes

05

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We object to the lack of justification and explanation to support the allocation of some sites in settlements over and above the other alternatives. Site ALP210 in Meppershall was considered acceptable for development through the site assessment process (as shown at Appendix VIId of the SA and Appendix A of the SHLAA) but no further evidence has been presented to explain why this land has not been designated for allocation.
We believe this is unjustified and the alternative sites have not been adequately assessed.

Attachments:

Object

Technical Reports

Representation ID: 9145

Received: 21/02/2018

Respondent: Hunterhill Estates Ltd

Agent: Hunterhill Estates Ltd

Representation:

ALTERNATIVE SITE - ARLESEY (ALP279)
METHODOLOGY - Dispute HIS outcome

06

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Site ALP 279 - Land at the rear of 44 London Row, Arlesey, SG15 6RX was "Passed but not allocated" in the Pre-Submission Local Plan
The site is enclosed by existing dwellings on two sides and on the other two sides is the proposed allocation of land under Policy SA3.

It makes no sense not to allocate this for housing as it has passed all the necessary criteria imposed by the Local Plan process and would be an small island of undeveloped land.

Object

Technical Reports

Representation ID: 9983

Received: 22/02/2018

Respondent: IPE Orchestra Land

Agent: Tennyson Land

Representation:

DELIVERY - No evidence why there will be an increase in windfall delivery, settlement envelope policy should lead to decrease in windfall over time annual delivery rates are too high (should be 50pa)

08

Full text:

Housing Implementation Strategy Paper
Within the 5 year land supply period 2017/18-2022/23 it is projected that there will be a significant increase in the number of small windfall sites coming forward. There is no clear evidence as to why it is anticipated that there will be an increase in these sites. Based on the Settlement Envelope policy of the Plan it should be anticipated that the supply of small windfall sites should decrease overtime as infilling takes place.
Average build out rates are 50 units per housebuilder per site. Despite this the trajectory which the Council has in Appendix B of the HIS indicates site delivering well in excess of this number. It is therefore considered that this is too optimistic and that delivery rates will be lower than the Council projects. For example, the site at Warren Farm HT001a is projected to delivery 80 units in 2018/29, 80 units in 2019/20. This is considered to be overly optimistic.
Sites such as Houghton Regis Site 2- Land West of Bidwell are scheduled to deliver units within 2018/19 despite not having house builders on board, or detailed planning consents. For example, Houghton Regis Site 2 is projected to deliver 90 units in 2018/2019 despite it not being clear that contracts have been completed with housebuilders (it is noted that three have been 'identified'). Moreover s38/s278 approvals are outstanding and reserved matters applications have yet to be submitted.
This, again, risks the effectiveness of the Local Plan strategy and therefore it is unsound. It also risks the Council being unable to demonstrate a 5-year land supply.

Object

Technical Reports

Representation ID: 10811

Received: 22/02/2018

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

TARGETS - Housing target should be increased
DELIVERY - More realistic start dates and delivery rates should be applied, more evidence needed to demonstrate capacity of windfall, question capacity and deliverability of a number of sites, SA3 should be deleted due to non delivery of existing allocation, unrealistic start date for Wixams, additional new land needs to be identified.

05

Full text:

In our representations to Policy SP1 and Table 6.1 we request that the housing target should be increased to meet a more robust assessment of objectively assessed housing needs. In our representations to Table 6.2 and Table 7.1 we request that more realistic assessments of start dates and delivery rates at the existing and proposed strategic allocations should be applied. In our representations to Table 6.3 we request that more evidence is provided to demonstrate that capacity exists at potential windfall sites to meet future supply from this source. In our representations to Policy SA3, we request that land East of Arlesey is deleted because limited progress has been made on the existing allocations in Arlesey and there are concerns about viability. In these representations we comment on housing delivery at the proposed Wixams South Extension (Ref. HAS27), the proposed allocations at Green Belt sites in the South Area which make a strong contribution to purposes and in some instances may be larger than necessary, and the assumptions about capacity at some of the sites (HAS07 - Caddington Park and HAS08 - Land on the South East of Greenway) which might be difficult to achieve taking into account appropriate densities and site characteristics. An assessment of the main constraints at the sites is provided in the Site Allocation Assessment submitted with these representations. In light of the above, we conclude that additional land will need to be identified to meet the proposed and higher housing target, and request that additional land is allocated at North of Biggleswade (Ref. HAS06) and that new allocations are made at Land between Crawley Road and Bourne End Road, Cranfield (Ref. NLP266) and Land north of Sandy Road, Potton (Ref. NLP186). We comment on each of these sites below.
We note that more dwellings would be delivered from current Green Belt sites than non-Green Belt sites in Policy HA1; 3037 dwellings on Green Belt sites and 2087 dwellings on non-Green Belt sites. This outcome would be inconsistent with national policy that seeks to protect the Green Belt unless exceptional circumstances can be demonstrated. As set out in our representations on the South Area Green Belt sites below, it is land which is not in the Green Belt or makes a limited contribution that should be selected in preference to Green Belt sites that make a high contribution to Green Belt purposes.

HAS27 - Wixams Southern Expansion
The proposed Wixams Southern Extension is allocated for 650 dwellings, and it is predicted in the Housing Implementation Strategy that development will commence in 2018/19 and that 60 dwellings per year would be delivered from this site. The assumptions about start dates are unrealistic, and the assumptions about delivery rates take no account of delivery taking place at other parcels of land within the Wixams at the same time. If outline planning permission is granted in 2018 it will still take time to discharge conditions, market the site and complete agreements with housebuilders, obtain reserved matters approval, and deliver infrastructure before development can commence. Therefore, it is highly unlikely that development would be ready to commence at the Wixams Southern Extension during 2018/19. We note that it is already predicted that 250 dwellings would be delivered from other parcels of land at the Wixams within Central Bedfordshire, and development would also continue on parcels within Bedford Borough; the Wixams new settlement is currently delivering an average of 123 dwellings per year within Bedford Borough. The Wixams should be treated as a single development, and as such realistic assumptions about housing delivery rates should be applied to reflect comparable housing delivery rates at new settlements and urban extensions elsewhere and with reference to the Nathaniel Litchfield & Partners 'Start to Finish' Report. We consider that it should be assumed that no more than 250 dwellings would be delivered at the Wixams across all sites, and the housing trajectory should be adjusted accordingly.
The experience of development at the Wixams should provide a reminder to the Council of the problems associated with overly optimistic delivery assumptions at new settlements.

South Area Green Belt Sites
All of the proposed urban extensions to the settlements within the South Area make a strong contribution to Green Belt purposes. We note that large scale releases from the Green Belt are already committed and proposed on the edge of Luton and Houghton Regis, on the basis that exceptional circumstances related to housing need exist. The exceptional circumstances to release land at other settlements is not stated. If exceptional circumstances do exist, then land which is not in the Green Belt or makes a limited contribution should be preferred. We note that some of the sites to be released from the Green Belt are quite large and appear excessive (e.g. at Barton-le-Clay, Harlington and Westoning) but the option of a smaller releases has not been considered. We also note that other sites in the South Area and Central Area are subject to flood risk. Paragraph 100 of the NPPF provides guidance on the relationship between flood risk and development, and states: "Local Plans should apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change, by: applying the Sequential Test;...". There will be other land available in Central Bedfordshire which is not subject to the same level of flood risk, which should be preferred.
We request that the following sites are reassessed in terms of their contribution to the Green Belt or flood risk to determine whether they are suitable locations for development, and whether other sites that are less constrained are available and should be preferred:
* HAS05: Land East of Barton le Clay, Barton le Clay - strong contribution to Green Belt
* HAS09: Chapel Farm, Chalton - strong contribution to Green Belt
* HAS14: Land off Eaton Park, Eaton Bay - strong contribution to Green Belt
* HAS17: Steppingley Road, Flitwick - strong contribution to Green Belt
* HAS21: Land West of Sundon Road, Harlington - strong contribution to Green Belt
* HAS25: Land at Leighton Road, Hockcliffe - part of site subject to flood risk
* HAS26: A5 Watling Street, Hockcliffe - strong contribution to Green Belt and part of site subject to flood risk
* HAS33: Land North of Soulbury Road, Leighton Linslade - strong contribution to Green Belt
* HAS38: Land Fronting Silsoe Road, Maulden - part of site subject to flood risk
* HAS46: Land rear of Station Road, Stondon - part of site subject to flood risk
* HAS51: Land off Flitwick Road, Westoning - strong contribution to Green Belt

HAS07 - Caddington Park and HAS08 - Land on the South East of Greenway
The Site Allocation Assessment assessed whether capacity exists at those sites to deliver the proposed number of dwellings. We are concerned about the proposed number of dwelling at the following sites, which might be difficult to achieve taking into account appropriate densities and site characteristics.
* HAS07 - Caddington Park - it is proposed that 66 dwellings would be delivered at this site. The site is 1.66Ha and the density would be 40dph. The site is currently within the Green Belt. The northern boundary of the site borders the Luton-Dunstable Busway. There may be a potential noise constraint from M1 (eastern boundary) and the A505 Hatters Way (southern boundary). It is likely that land would be required to accommodate noise buffers within the proposed development and to separate residential development from noise generating uses. It is also likely that land would be required to accommodate landscaping to address the loss of Green Belt and the close proximity of remaining areas of Green Belt and the Chilterns AONB. It is likely that the number of dwellings that can be provided at this site should be reduced.
* HAS08 - Land on the South East of Greenway: It is proposed that 66 dwellings would be delivered at this site. The site is 0.47Ha and the density would be 140dph. The density would be much higher than exists at other rural locations and small villages. The proposed developments would result in potential coalescence issues between Campton and Shefford. There are potential noise constraints from A507 (northern boundary). It is likely that the number of dwellings that can be provided at this site should be reduced significantly.
We request that the capacity of these two sites is reassessed to determine whether the proposed number of dwellings can be delivered.

Comment

Technical Reports

Representation ID: 11964

Received: 22/02/2018

Respondent: IPE Orchestra Land

Agent: Tennyson Land

Representation:

DELIVERY - No evidence why there will be an increase in windfall delivery, settlement envelope policy should lead to decrease in windfall over time annual delivery rates are too high (should be 50pa)

08

Full text:

see attachment

Attachments:

Comment

Technical Reports

Representation ID: 12190

Received: 22/02/2018

Respondent: Willis Dawson

Agent: HD Town Planning

Representation:

DELIVERY - concerns over strategic site delivery, HAS20 can deliver sooner than stated in trajectory

08

Full text:

see attachment

Attachments:

Object

Technical Reports

Representation ID: 12370

Received: 22/02/2018

Respondent: O&H Properties Ltd

Agent: David Lock Associates

Representation:

METHODOLOGY - Flawed since it relies on a housing trajectory which is demonstrably inaccurate in relation to the delivery of committed development allocated in previous Local Plans

04

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 12994

Received: 22/02/2018

Respondent: Richborough Estates

Agent: RPS Planning and Development

Representation:

METHODOLOGY - need to evidence delivery rates and lead-in times. Dispute delivery rates for North of Luton and Marston Vale, and East of Leighton Linslade. Dispute windfall allowance
08

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 13251

Received: 22/02/2018

Respondent: Diocesan Board of Finance

Agent: Bidwells

Representation:

STRATEGY - Development is front loaded, should increase housing requirement
DELIVERY - Targets are ambitious

09

Full text:

See attachment

Attachments:

Object

Technical Reports

Representation ID: 13871

Received: 22/02/2018

Respondent: Abbey Land

Agent: JB Planning

Representation:

DELIEVRY - The housing trajectory is overly optimistic, Delivery rates for North Luton and Marston Valley are optimistic, a 10% buffer should be added to the housing trajectory

05

Full text:

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: 13997

Received: 22/02/2018

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

HOUSING - dispute delivery assumptions (particularly for strategy sites)

08

Full text:

These representations are submitted on behalf of our Client, GPS Estates Ltd, who have significant concerns over the contents of the Pre-Submission Local Plan and the supporting evidence published with it. GPD Estates Ltd are of the view the plan does not currently meet the tests of soundness set out at 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 the representations attached.