Fairfield

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Object

Site Assessment Forms (Housing)

Representation ID: 1404

Received: 21/08/2017

Respondent: Ickleford Parish Council

Representation:

Unsustainable development which conflicts with the aims of the NPPF.

Full text:

The ministerial foreword to the NPPF states that the purpose of planning is to help achieve sustainable development, with 'Sustainable' defined as ensuring that better lives for ourselves don't mean worse lives for future generations.
The proposed developments in the draft Local Plan, taken with those already in planning will add several hundred new homes. This will inevitably lead to significant increases in car journeys, and those wishing to travel south or south-west will likely to need to drive through Ickleford. The resultant increases in traffic through are village, and the concomitant environmental impacts clearly run counter to the aims of sustainability as defined in the NPPF. There appears to be no recognition of this nor any substantive attempts to mitigate against it to alleviate the issue for those wishing to drive towards Luton and the M1 (south).
The issues which Ickleford will face will be further exacerbated by other CBC developments either within the draft Local Plan or already proposed in the towns and villages near to north Herts. There is not likely to be sufficient investment in infrastructure (e.g. public transport, increased rail network capacity) to make this sustainable, and conflicts with many aims of the NPPF.
It is on these grounds that Ickleford Parish Council objects to the CBC draft local plan relating to development in those communities adjacent to our boundary.

Object

Site Assessment Forms (Housing)

Representation ID: 2047

Received: 25/08/2017

Respondent: Linden Homes Strategic Land

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

These representations are submitted on behalf of Linden Homes Strategic Land ('Linden'), who are promoting a site on the western edge of Fairfield (Reference ALP439), but which lies within the Parish of Arlesey, as detailed in the Call for Sites submission. Separate representations have been submitted on the Draft Local Plan ('DLP') itself and also in response the Settlements Capacity Initial Study.

Linden objects to the conclusion reached by the Council in respect of this parcel of land that it was ruling it out at Stage 1B of the Assessment process due to the perception that coalescence between Fairfield and Arlesey would result from its development.

The Call for Sites Submission for Site ALP439 included a concept plan illustrating how it might be developed. This indicated that housing would be restricted to the two fields immediately adjoining Fairfield, with the additional field to the west shown as permanent open space, including allotments, for use by local residents. The existing balancing pond currently located on the southern of the two fields adjoining Fairfield was also indicated as being relocated to the western field.

A development based on this concept plan would still leave the width of two large open fields between the extended Fairfield and the existing built edge of Arlesey, a distance of approximately 500m. A substantial landscaping framework has also been indicated around the outside of the housing land to mirror the approach taken with the existing development and this would further reinforce the separation between Fairfield and Arlesey.

Linden would also highlight that the Draft Local Plan indicates support for strategic site NLP419 for approximately 2,500 dwellings on land between Arlesey and Fairfield, which rather undermines this position of concern in relation to coalescence as such a scheme would substantially reduce the gap between the two even with the provision of new landscaping.

The Settlements Capacity Initial Study concluded that Fairfield has medium capacity to support new development, thus between 50 and 500 dwellings. It also acknowledges that there are constraints to the north, east and south of the village that could restrict development, whereas the land to the west is unconstrainted and therefore more readily deliverable.

Notwithstanding these comments made refuting the suggestion of coalescence on the basis of the existing concept plan included in the Call for Sites Submission, Linden have also prepared an alternative smaller-scale scheme (Drawing no. P17-1739_001 enclosed) on part of the southern field adjoining the built up area of Fairfield that would have even less of an impact in terms of reducing the gap between it and Arlesey.

This is included with these representations and indicates around 32 dwellings with the scheme based upon the principles outlined below:

Access would be provided via an extension to Livingstone Way. As a consequence, the existing pumping station would be relocated elsewhere within the wider parcel, which would be a benefit to existing residents by moving this further away from them.

Housing is proposed to be set back from, but overlooking the Bridleway running north - south adjacent to the existing western built edge of Fairfield. This would enable it to be retained on its existing alignment with the path potentially enhanced as part of the scheme. The indicative layout of the dwellings proposed would be a logical extension of the existing built form at Fairfield. The scheme would also utilise the existing levels of the site to add interest and character.

A children's play area is proposed to be incorporated within the scheme, providing a benefit to both existing and proposed residents. It is understood that there is a desire from the Parish Council to see new play facilities delivered in Fairfield.

The existing attenuation basin in the north-west corner of this field would be enlarged to accommodate any additional runoff from the resulting increase in impermeable area. The remainder of the field would provide open space and landscaping, with the existing mature planting along its western boundary providing a substantial screen reinforcing the separation between Fairfield and Arlesey with the development proposed having no impact on this.

To conclude, Linden would request that this site is reconsidered for allocation in the Submission version of the Local Plan, particularly in light of the separate comments made on the Draft Local Plan itself regarding the need to reduce the reliance on new settlements and major urban extensions and allocate more deliverable small and medium scale sites as part of the growth strategy to ensure delivery of the high housing target over the Plan period.

Object

Site Assessment Forms (Housing)

Representation ID: 5003

Received: 21/08/2017

Respondent: Ickleford Parish Council

Representation:

Combined impact of proposed sites and those already submitted.
Traffic increase
Traffic increase and environmental impacts counter to sustainability aims of NPPF
No recognition of impacts or attempts to mitigate traffic towards Luton from M1
Combined impacts with proposals in towns/villages near to north Herts.

Full text:

The ministerial foreword to the NPPF states that the purpose of planning is to help achieve sustainable development, with 'Sustainable' defined as ensuring that better lives for ourselves don't mean worse lives for future generations.
The proposed developments in the draft Local Plan, taken with those already in planning will add several hundred new homes. This will inevitably lead to significant increases in car journeys, and those wishing to travel south or south-west will likely to need to drive through Ickleford. The resultant increases in traffic through are village, and the concomitant environmental impacts clearly run counter to the aims of sustainability as defined in the NPPF. There appears to be no recognition of this nor any substantive attempts to mitigate against it to alleviate the issue for those wishing to drive towards Luton and the M1 (south).
The issues which Ickleford will face will be further exacerbated by other CBC developments either within the draft Local Plan or already proposed in the towns and villages near to north Herts. There is not likely to be sufficient investment in infrastructure (e.g. public transport, increased rail network capacity) to make this sustainable, and conflicts with many aims of the NPPF.
It is on these grounds that Ickleford Parish Council objects to the CBC draft local plan relating to development in those communities adjacent to our boundary.

Comment

Site Assessment Forms (Housing)

Representation ID: 6138

Received: 29/08/2017

Respondent: North Hertfordshire District Council

Representation:

The Settlements Capacity: Initial Study (July 2017) identifies Fairfield as having medium capacity for development, however we are concerned that it is equally acknowledged in the evidence base that there is a lack of easily accessible services and facilities (particularly educational, healthcare and retail), which would place significant impacts on social infrastructure demands within our administrative area. We would therefore expect Central Bedfordshire to satisfy itself that the required facilities, services and infrastructure can be provided on-site to meet the needs of the development. Our authorities would need to work together on any outstanding cross-boundary impacts. see attachment

Full text:

see attachment

Attachments:

Comment

Site Assessment Forms (Housing)

Representation ID: 6315

Received: 25/08/2017

Respondent: Linden Homes Strategic Land

Agent: Woods Hardwick Planning Ltd

Representation:

The Submission Local Plan should include a proportionate amount of growth at Fairfield. The Settlements Capacity Initial Study, upon which separate representations have been made, indicates that Fairfield has medium capacity for growth, i.e. between for between 50 and 500 dwellings, a conclusion Linden endorses. Constraints do not exist to the west of the settlement and there is suitable land available there being promoted by Linden. This reinforces the appropriateness of allocating land at Fairfield in the Submission version of the Local Plan.

Full text:

These representations are submitted on behalf of Linden Homes Strategic Land ('Linden'), who are promoting a site on the western edge of Fairfield (Parcel ALP439) as detailed in the Call for Sites submission. They focus on the Draft Local Plan ('DLP') itself, with separate comments submitted on the Technical Documents published alongside the DLP that are relevant to our Clients' interests, particularly the Site Assessments Technical Document and the conclusion reach on Parcel ALP439.

The comments made here 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.

As a general observation, whilst acknowledging the document is an initial draft, the Local Plan is clearly still very much a work in progress, with a number of key decisions left open, or to be decided. As will be explained in detail below, Linden's principal concern is that the emerging draft Growth Strategy is unlikely to achieve the level of new housing required over the Plan period and needs refining as a consequence.

In respect of the emerging housing target, Linden are encouraged by the commitment in the DLP to allocate land for a minimum of 20,000 dwellings in addition to those expected to come forward from existing commitments over the Plan period. The pledge to provide 7,400 dwellings towards Luton Borough's unmet need on the back of 'duty to cooperate' discussions with neighbouring authorities is also welcomed, however, the Inspector examining the submitted Plan will also want to see evidence from the Council of the outcomes of this engagement (Paragraph: 010 Reference ID: 9-010-20140306 of the NPPG).

The Draft Plan and its evidence base is unclear as to what agreement there currently is between neighbouring authorities as to how the issue of unmet housing needs is to be addressed. It is evident from the Proposed Main Modifications to the Luton Local Plan that the scale of their unmet needs is greater (c. 9,300 dwellings over the period 2011 to 2031).

Clarity is therefore required in relation to what agreement there is as to how unmet needs up to 2031 are to be distributed between the respective local authorities within the Luton Housing Market Area.

Furthermore, as the Draft Plan intends to cover the period to 2035, it is unclear as to what provision is to be made to address for the potential for further unmet needs from Luton arising post 2031

In order to meet the high housing need for Central Bedfordshire of 32,000 houses, along with the contribution towards Luton Borough's unmet need, which is likely to be as a minimum the 7,400 dwellings currently suggested in the DLP, Linden are of the view that the Council needs to go further than Policy SP1 does currently and the total amount of housing to be allocated in the Submission version of the Local Plan should in fact be at the upper end of the range set out in Table 7.2 of the DLP; i.e 31,822 dwellings.

This is so as to provide sufficient contingency to take account of lapse rates and in acknowledgment that not every site allocated will come forward on time, or even at all. For evidence of this, one only has to look at the current adopted Plans for the north and south of Central Bedfordshire (Adopted in 2011 and 2004 respectively), from which there remain allocations that have yet to deliver any housing for various reasons.

Paragraph 7.7.2 of the DLP acknowledges this point to a certain extent by suggesting that the next version of the Plan is likely to include a certain level of growth as a contingency in case sites allocated fail to come forward. However, Linden's view is the full level of contingency indicated in Table 7.2 needs to be provided to ensure there is certainty of meeting the housing need.

This approach of allocating more land than that calculated as being required will be essential in providing a safeguard to ensure the housing numbers needed do actually come forward, and in this respect the Plan can then be considered to be positively prepared as required by paragraph 182 of the NPPF.

The Submission version of the Local Plan will also need to take into account any standardised methodology for calculating housing need introduced by the Government following the Housing White Paper (2017), which may alter the final housing target. It is understood consultation on the draft methodology is to commence in September.

Linden are also supportive of the fundamental principle underpinning the emerging spatial strategy for Central Bedfordshire of focusing as much development as possible along key transport corridors and interchanges (Paras 7.3.1 and 7.5.1). This approach is justified on sustainability grounds in the technical evidence published with the DLP, including the Sustainability Appraisal (SA). It is also considered essential if the scale of growth required over the Plan period is to be achieved, although, there are concerns around the extent of new infrastructure required as a pre-requisite to some of the growth options identified in the DLP, with further comment made on this below.

Development at Fairfield would be consistent with this strategy. It is located in close proximity to the A1, with excellent access to it via the A507. Arlesey Railway Station on the East Coast Mainline is also nearby, providing access to a range of locations, including London and Peterborough.

Linden's principal concern with the emerging approach to the Growth Strategy outlined in Policy SP1 and the supporting text is the potential reliance being placed on the delivery of housing from a small number of new settlements (both towns and villages) and significant urbans extensions, which could lead to a failure to meet the housing target for the area, particularly during the early years of the Plan. Such schemes inevitably have lengthy lead-in times with greater risk of delays in delivery due to complicated landownership arrangements and the requirement for substantial new infrastructure to facilitate them. One only has to look at the time it took from inception for The Wixams new settlement to start delivering housing as evidence of this (Approximately 30 years).

From a review of the of potential strategic scale housing growth locations provided in section 8.5 of the DLP it is evident that all of these will be dependent on the provision of substantial new infrastructure, and in some cases this infrastructure would need to be funded and/or delivered by third parties and not the Council or the promoters of the site, meaning delivery timescales are out of their control and even less certain.

The table below highlights this point and the supporting text to Policy SP1 even acknowledges that delivery from some of these sites may extend beyond the Plan period.

Site Major Infrastructure Required
North of Luton Dependent on delivery of the M1 - A6 link road, which is partly being funded by the Government through SEMLEP
Tempsford South and Tempsford Airfield Requires a new train station to form an interchange between East-West Rail and the East Coast Main Line. This is dependent on the Government and Network Rail
New junctions on the A1 and A428 will be required, along with improvements to the A1
New Villages to the East of Bigglsewade A comprehensive scheme of highways works is required to mitigate the impact of increased traffic on the A1
Marston Vale New Villages A comprehensive scheme of highway measures is required to mitigate the impact of increase traffic on M1 J13 and the A421
Aspley Triangle A comprehensive scheme of highway measures is required to mitigate the impact of increase traffic on M1 J13 and the A421

In addition, there is also a limit to the amount of housing completions achievable from a single site in a year even in a prosperous economic climate. Were the final version of the Plan to rely on too small a number of allocation sites to meet the high housing requirement it would increase the likelihood of shortfalls in the 5 year housing supply occurring during the Plan period, meaning the Council would again be open to planning applications for unallocated sites.

Linden therefore strongly encourage the Council to develop a final growth strategy that relies less on these new settlements and significant urban extensions and instead allocates more small and medium scale sites, which are generally less complicated and quicker to deliver, in order to ensure that the substantial housing need is met throughout the Plan period. This would also help ensure the Local Plan is in accordance with the approach advocated in the Housing White Paper (2017) in terms of seeking to allocate a proportion of the housing target to be delivered on small scale sites, with this likely to be made a requirement in the next update of the NPPF.

There is no reason why the Submission Local Plan should not identify longer term growth locations as part of the strategy for encouraging their delivery, but it should avoid being reliant upon such sites to provide any significant housing numbers during this Plan period for the reasons outlined above in order to ensure the Growth Strategy and as a consequence, the Plan, are considered to be positively prepared, justified and effective in the sense required by the NPPF.

To be considered the most appropriate strategy, when considered against the reasonable alternatives, the Submission Local Plan should include a proportionate amount of growth at Fairfield. The NPPF encourages the promotion of sustainable development in rural areas where it will enhance or maintain the vitality of rural communities. Furthermore, the Settlements Capacity Initial Study, upon which separate representations have been made, indicates that Fairfield has medium capacity for growth, i.e. between for between 50 and 500 dwellings, a conclusion Linden endorses.

The Settlements Capacity Initial Study also highlights potential constraints to the north (heritage), east (air quality) and south (biodiversity) of Fairfield. Such constraints, do not exist to the west of the settlement and there is suitable land available there being promoted by Linden, as set out in greater detail in the response to the Site Allocations Technical Document. This reinforces the appropriateness of allocating land at Fairfield in the Submission version of the Local Plan.

In respect of the proposed re-drawing of Green Belt boundaries in Central Bedfordshire, Linden are of the view that this cannot be considered 'sound' in terms of the requirements in the Framework if it has not been demonstrated that growth at Fairfield would not represent sustainable development in accordance with the Framework. As has already been covered above, growth at Fairfield is considered sustainable, a position backed up by the evidence based published with the DLP and thus must be included in the Submission Version of the Local Plan if the Green Belt boundary change is to be considered sound.