Pulloxhill

Showing comments and forms 1 to 16 of 16

Comment

Site Assessment Forms (Housing)

Representation ID: 1868

Received: 29/08/2017

Respondent: Mr B. Sherry

Agent: Aragon Land & Planning Ltd

Representation:

STAGE 2 ASSESSMENT CONCLUSION for the conclusion on ALP 172 is incorrect. The land is not elevated, but well screened. It is furthermore in line with the commercial buildings adjacent and, again, well screened from the conservation area. The site offers no landscape benefit to the conservation area, this is not identified in the conservation area appraisal.

.

Full text:

STAGE 2 ASSESSMENT CONCLUSION for the conclusion on ALP 172 is incorrect. The land is not elevated, but well screened. It is furthermore in line with the commercial buildings adjacent and, again, well screened from the conservation area. The site offers no landscape benefit to the conservation area, this is not identified in the conservation area appraisal.

.

Comment

Site Assessment Forms (Housing)

Representation ID: 2155

Received: 25/08/2017

Respondent: Miss Julie Gibbons

Representation:

This site should be considered as part of Flitton and not Pulloxhill.
The development will impact Flitton, not Pulloxhill
Flitton is a small village and we wish it to remain so.
Flooding has prevented walkers using the pathway
Centenary wood will be impacted by the development affecting wildlife and local use.
Access to the site is potentially dangerous due to previous accidents and speed of traffic into the village.
Poor infrastructure to support this development
Adjoining green belt land.

Full text:

NLP353 - Hand Post Field - Sand Road
This field which is situated in Sand Road is listed as part of Pulloxhill, however it will have no impact on that village. The site can only be seen as part of Flitton and if developed will have a huge impact due the size and potential for further development. As the house owner adjoining the site we have considerable concern about this proposed development.

Flooding - there has been flooding which prevents walkers using the pathway.

Access: Adjoining Centenary Wood which is a well maintained and well used amenity, provided and maintained by local residents. Residents and local school children raised money and helped plant to the wood to commemorate the Centenary. Local people are concerned that a further development project, potentially one of considerable size, would be harmful to the environment. The woodland is used by local people for exercise and to see the wildlife and plant life therein. The woodland gives homes to many birds including birds of prey such as buzzards, there are also two ponds containing an abundance of pond life.

Access to the site is opposite the junction of Silsoe Road and Sand Road where a number of accidents have been recorded in the past. The junction is already well used particularly at the beginning and end of each working day.

Flitton Road is a long straight road linking the two villages, vehicles reach great speeds from Pulloxhill towards Flitton. We have reported such incidents to the police as we are concerned for the safety of our young family. Additional traffic would have to pass the entrance to the site for access to amenities in neighbouring towns and villages.

Infrastructure - Only one school, consistently over subscribed and no further space for expansion. All other school children have to be transported to schools in neighbouring towns and villages. There is no Post Office, shop and no surgery. All services would require improved facilities for vehicles as parking is already an issue close to surgeries. A further increase in traffic problems is also an issue.

Green Belt: adjoining

Current use - Grade 2 agricultural land use of which would be against policy DC6 as outlined in the local plan. Consistently used and maintained for agricultural until change to equestrian.

Site NLP353 should not be considered as it is part of Pulloxhill but not located in Pulloxhill. Flitton is a SMALL village and villagers urgently wish it to remain so. The potential scale and size of the proposed development is completely out of keeping with Flitton.

Support

Site Assessment Forms (Housing)

Representation ID: 2190

Received: 29/08/2017

Respondent: Anthony Catlin Will Trust

Agent: J & J Design

Representation:

We support the allocation of Land at Blackhill Lane Pulloxhill (ALP061)
as a Housing Site.

Full text:

Land at Blackhill Lane Pulloxhill (ALP061)

The site is located on the south west side of Blackhill Lane at the south west end of the village. The site extends from the junction of Blackhill Lane with Church Road in a southerly direction to a woodland belt. The site is part of a larger area of open arable farmland.

The site is outside but adjacent to the Settlement Envelope for Pulloxhill. The site abuts the boundary of the Settlement Envelope on the north and north east sides. We support the allocation of this site as a Housing Site. The potential site is situated within a field of 20ha. However, by reason of the site's location within a sensitive landscape it is proposed to limit the development to 10-15 units along the road frontage. Landscape and Visual impacts will be mitigated by structural tree and hedge planting on the proposed south west and southern boundaries and enhancing local biodiversity. This will accord with the objectives of the Mid Bedfordshire Green Infrastructure Plan (2008) for the Harlington to Pulloxhill Ridge.

In view of the statutory duty on the Council to provide sufficient serviced plots for self-build and custom housebuilding to meet local demand and the current levels of demand in Central Bedfordshire, the landowners consider that a low density self-build scheme with 10-15 serviced plots could be ideal on this proposed allocation.

The landowners have expressed support for draft LP Policy H7 and supporting text.

Best and Most Versatile Land (BMVL) - Paragraph 112 of the Framework advises that local planning authorities should take into account the economic and other benefits of BMVL. The Agricultural Land Classification map indicates that the site is Grade 2 (good) agricultural land. The land may therefore be BMVL and the loss of such land weighs against the proposal. However, some 80.9% of the District is Grade 3 or better. The Council has accepted that in order to meet housing need it is likely that greenfield sites, including agricultural land, will need to be developed. In this case the site is typical of agricultural land around Pulloxhill as well as the wider area. It is concluded that the development of BMVL is almost inevitable due to its location within an area of high quality agricultural land. In this case the loss of 0.8ha BMVL will be modest and should be afforded only limited weight. In any event, this proposal cannot reasonably be described as 'significant development of agricultural land', as set out in paragraph 112 of the Framework.

We attach the following technical studies:
* Landscape and Visual Appraisal,
* Highways Statement,
* Drainage Strategy,
* Masterplan, and
* Preliminary Archaeological Assessment.

These will demonstrate the context of the proposed allocation as a Housing Site in the CBC Local Plan 2035.

The Landscape and Visual Appraisal concluded:

"Given the nature and character of hilltop settlement patterns in the area and taking into consideration the visual qualities and amenity of the area, it is considered that the site has capacity to accommodate change and provide a small-scale settlement extension similar in form, density and massing at the existing settlement edge, subject to a sound design approach and appropriate mitigation, including landscape proposals."

"There are a limited number of constraints or issues in landscape and visual terms that reduce the site's capacity to accommodate development. It is considered that the opportunities to provide mitigation will ensure that the impacts of any such development on the wider landscape can be minimised."

"If potential development incorporates a sensitive design approach that contributes to the existing landscape character of the site and helps contain the development from the immediately adjacent landscape, visual effects would be adequately reduced."

The Highways Statement concluded that:

"It has been adequately demonstrated that the site can be accessed in an acceptable way and is reasonably sustainable for a rural development site, thus whilst a greater level of detail will be required at any subsequent planning application there are no grounds highways or transport related grounds preventing allocation for residential development of up to 19 units in the Local Plan."

The Sustainable Drainage Strategy concluded:

"The Sustainable Drainage Strategy provided is fully in line with all current local and national policy and there are no flood risk or drainage related grounds on which to object to the proposed allocation of the site for development of 15 to 19 dwellings in the Local Plan."

The Preliminary Archaeological Assessment concluded that:

* The potential impact of groundworks on any surviving sub-surface archaeological heritage assets is assessed as ranging from slight to moderate harm.
* The potential for heritage assets to be present on the PDA has been assessed as varying from negligible to moderate, depending on the date of the remains. The significance of any potential archaeological remains could be low to moderate, depending on their exact nature. The significance of any impact upon potential heritage assets (before mitigation), therefore, ranges from insignificant to significant.
* If required by the LPA, any direct impact of the development on potential buried archaeological remains could be mitigated by measures to investigate and record the presence/absence, nature and significance of the potential buried archaeological remains.
* The PDA is screened from the Pulloxhill medieval village core, conservation area and listed buildings by adjacent modern development on Church Road and Blackhill Lane.
* The impact of the PDA on the setting of any of these heritage assets is, therefore, assessed as no change. The significance of this impact is assessed as insignificant.


The Site Assessment states the site is over 800m from a bus stop. This is not correct. The nearest bus stops are at Greenfield Road and in High Street opposite Fieldside Road about 500m east of the site. These are within reasonable walking distance from the site. Daily bus services have recently been improved and now comprise:

* Grant Palmer Service 200 Biggleswade - Flitwick Monday Friday 5 services (4 on Saturdays)
* Centrebus Service 20 Luton - Toddington - Pulloxhill Monday - Saturday 2 services.

The site is in single ownership and is capable of delivery within the early part of the Plan Period. In order to assist the Council with its duty under Section 2A of the Self-Build and Custom Housebuilding Act 2015 as amended by the Housing and Planning Act 2016 Sections 9 and 10, the landowners would be willing to commit to bring the allocation for Self-Build forward within three years.

The site is close to the local facilities offered by The Chequers PH and within convenient walking distance from the local bus services to Biggleswade, Luton and Flitwick.

Comment

Site Assessment Forms (Housing)

Representation ID: 2191

Received: 29/08/2017

Respondent: Anthony Catlin Will Trust

Agent: J & J Design

Representation:

A Landscape and Visual Appraisal is attached in support of the proposed allocation site at Blackhill Lane Pulloxhill (ALP061)

Full text:

Land at Blackhill Lane Pulloxhill (ALP061)
A Landscape and Visual Appraisal is attached which concludes:

"Given the nature and character of hilltop settlement patterns in the area and taking into consideration the visual qualities and amenity of the area, it is considered that the site has capacity to accommodate change and provide a small-scale settlement extension similar in form, density and massing at the existing settlement edge, subject to a sound design approach and appropriate mitigation, including landscape proposals."

"There are a limited number of constraints or issues in landscape and visual terms that reduce the site's capacity to accommodate development. It is considered that the opportunities to provide mitigation will ensure that the impacts of any such development on the wider landscape can be minimised."

"If potential development incorporates a sensitive design approach that contributes to the existing landscape character of the site and helps contain the development from the immediately adjacent landscape, visual effects would be adequately reduced."

Object

Site Assessment Forms (Housing)

Representation ID: 2810

Received: 28/08/2017

Respondent: Mr Michael Brown

Representation:

Wrong village
Should be Flitton
Inappropriate for a "small" village

Full text:

NLP353

This site though listed in Pulloxhill (which is pedantically correct)is on the boundary of Flitton and would be very much part of Flitton, not Pulloxhill cf the Woodlands estate the bulk of which is in Pulloxhill but geographically and socially is in Greenfield. It should be treated as part of Flitton, Greenfield and Wardhedges for the purposes of the local plan.
At a proposed 66 dwellings,it is a "housing estate" which would have an adverse effect on the character of Flitton (not on Pulloxhill) . It should not go forward to the next stage of assessment as being at odds with the character of a small village.

Comment

Site Assessment Forms (Housing)

Representation ID: 2818

Received: 28/08/2017

Respondent: Dr Steven Larcombe

Representation:

This site should be considered as part of Flitton and not Pulloxhill.
The development will impact Flitton, not Pulloxhill
Flitton is a small village and we wish it to remain so.
Flooding has prevented walkers using the pathways
Centenary wood will be impacted by the development affecting wildlife and local use.
Access to the site is potentially dangerous due to previous accidents and speed of traffic into the village.
Poor infrastructure to support this development
Adjoining green belt land.

Full text:

NLP353 - Hand Post Field - Sand Road
This field which is situated in Sand Road is listed as part of Pulloxhill, however it will have no impact on that village. The site can only be seen as part of Flitton and if developed will have a huge impact due the size and potential for further development. The site is situated adjacent to the last house on Sand Road, Flitton. As the house owner adjoining the site we have considerable concern about this proposed development.

Flooding - there has been flooding which prevents walkers using the pathway. There are 2 footpaths around the field border which suffer in winter months and pools appear in the field.

Access: Adjoining Centenary Wood which is a well maintained and a well used amenity, provided and maintained bylocal residents. Residents and local school children raised money and helped plant to the wood to commemorate the Centenary. Local people are concerned that a further development project, potentially one of considerable size, would be harmful to the environment. The woodland is used by local people for exercise and to see the wildlife and plant life therein. The woodland gives homes to many birds including birds of prey such as buzzards, there are also two ponds containing an abundance of pond life.

Access to the site is opposite the junction of Silsoe Road and Sand Road where a number of accidents have been recorded in the past. The junction is already well used particularly at the beginning and end of each working day.

Flitton Road is a long straight road linking the two villages, vehicles reach great speeds from Pulloxhill towards Flitton. We have reported such incidents to the police as we are concerned for the safety of our young family. Additional traffic would have to pass the entrance to the site for access to amenities in neighbouring towns and villages.

Infrastructure - Only one school, consistently over subscribed and no further space for expansion. All other school children have to be transported to schools in neighbouring towns and villages. There is no Post Office, shop and no surgery. All services would require improved facilities for vehicles as parking is already an issue close to surgeries. A further increase in traffic problems is also an issue. A development of 20 plus houses has recently been approved on Greenfield Road which will already significantly add to the population on the village and put further strain on traffic and local facilities. Other developments on Sand Road such as NLP172 have been previously rejected as this would result in significant harm to the character and appearance of the surrounding area.

Green Belt: adjoining

Current use - Grade 2 agricultural land use of which would be against policy DC6 as outlined in the local plan. Consistently used and maintained for agricultural until change to equestrian.

Site NLP353 should not be considered as it is part of Pulloxhill but not located in Pulloxhill. Flitton is a SMALL village and villagers urgently wish it to remain so. The potential scale and size of the proposed development is completely out of keeping with Flitton.

Support

Site Assessment Forms (Housing)

Representation ID: 3572

Received: 29/08/2017

Respondent: Mr Sam Franklin

Agent: Mr Sam Franklin

Representation:

A small frontage development of up to 10 houses in keeping with the linear nature of the settlement is proposed.

Full text:

ALP391
The site is only separated from the current settlement area to the East of Flitton Road by a small parcel of land. I do not consider this a barrier as there are residential dwellings on the opposite side of Flitton Road up to the edge of the proposed site.

The site offers an opportunity to provide additional housing without increasing traffic congestion and parking in the village centre.

Whilst the overall site is large it is envisaged that only a small frontage development of up to 10 houses in keeping with the linear nature of the settlement would occur at this point.

Pulloxhill is a sustainable development location and this site could meet housing need.

Object

Site Assessment Forms (Housing)

Representation ID: 4720

Received: 29/08/2017

Respondent: Mr Sam Franklin

Agent: Mr Sam Franklin

Representation:

ALP391 - objects to site excluded from further assessment

Full text:

ALP391
The site is only separated from the current settlement area to the East of Flitton Road by a small parcel of land. I do not consider this a barrier as there are residential dwellings on the opposite side of Flitton Road up to the edge of the proposed site.

The site offers an opportunity to provide additional housing without increasing traffic congestion and parking in the village centre.

Whilst the overall site is large it is envisaged that only a small frontage development of up to 10 houses in keeping with the linear nature of the settlement would occur at this point.

Pulloxhill is a sustainable development location and this site could meet housing need.

Object

Site Assessment Forms (Housing)

Representation ID: 4794

Received: 25/08/2017

Respondent: Mrs Jacqueline Baron

Representation:

NLP353
No infrastructure in Flitton or Pulloxhill to support further housing,
road and traffic problems
no school capacity
negatively change character and appearance of the village

Full text:

NLP353
There is no infrastructure in Pulloxhill or Flitton to support 66 houses. The roads are already too busy and dangerous. There is no space in the schools and limited buses, no post office or doctors. There are other significant developments happening nearby(24 homes on greenfield Road) and the villages can not accept this without it changing the character and appearance of the area. The nearby Centenary wood is supposed to be a quiet amenity for villagers that has an abundance of wildlife and flora. This would destroy all the environmental work that has been completed on this site.

Object

Site Assessment Forms (Housing)

Representation ID: 5189

Received: 14/09/2017

Respondent: Mr Victor Emery

Representation:

Object to NLP172, NLP 449 and NLP 353. They would significantly alter the rural aspect of the area and that of the village. The village does not have the infrastructure, volume of traffic already too high through the village, health services and schools already at capacity, the sites would dramatically alter the village aspect and loose farmland.

Full text:

Object to NLP172, NLP 449 and NLP 353. They would significantly alter the rural aspect of the area and that of the village. The village does not have the infrastructure, volume of traffic already too high through the village, health services and schools already at capacity, the sites would dramatically alter the village aspect and loose farmland.

Attachments:

Object

Site Assessment Forms (Housing)

Representation ID: 5201

Received: 15/09/2017

Respondent: Mr and Mrs Ward

Representation:

NLP 353. The site is in Flitton and should be seen as part of Flitton not Pulloxhill. There has been flooding in the field. Problems with access. The site would join Centenary Wood, provided and maintained by local residents. Residents are concerned that further development will harm the environment. School is over subscribed. Parking issues. The site is attached to Green Belt. Site is used for agriculture.

Full text:

Object to to NLP353 Hand Post Field, Sand Road, Pulloxhill/Flitton
Object to NLP172 Land off Sand Road, Flitton
Object to NLP449 Field behind Sand Road and behind 96 Greenfield Road - 41 dwellings.

Flitton residents are overwhelmed by the large number of development proposals for the village without the infrastructure to support them. We should therefore not be considering more development. Flitton is a small village and residents urgently want it to remain so.

Attachments:

Object

Site Assessment Forms (Housing)

Representation ID: 5207

Received: 15/09/2017

Respondent: Mr Alan Hislop

Representation:

NLP353 - would have no impact on Pulloxhill as it is attached to Flitton. It adjoins Centenary Wood an amenity the village is very proud of. It is used by walkers and environmentalists as it has an abundance of wildlife and flora.

Full text:

Commenting on NLP172, NLP449, NLP353
Flitton is a small village and its current residents feel strongly that they wish it to remain a village. Were these developments to be built the character of the village would be lost forever. Flitton would become a mere dormitory for commuters.
See attachment

Attachments:

Object

Site Assessment Forms (Housing)

Representation ID: 5313

Received: 19/09/2017

Respondent: Pam Emery

Representation:

Objections to NLP353 on impact on character and appearance, infrastructure, services and facilities grounds

Full text:

See attachment

Attachments:

Comment

Site Assessment Forms (Housing)

Representation ID: 5547

Received: 29/08/2017

Respondent: Bushmead Homes

Agent: Bidwells

Representation:

The land under Bushmead's control is illustrated on the enclosed location plan. It is identified as 'NLP335' within the Council's Site Assessment.
The Draft Plan has positively assessed the site for further consideration. The site is identified for development of approximately 24 dwellings, as per the CBC methodology.
A significant amount of research and technical assessments have been undertaken on the site to ensure the deliverability of the proposed development.
Our Client wishes to make some comments in relation to specific policies within the Local Plan. These comments are provided below under the relevant Local Plan Headings.

Full text:

CENTRAL BEDFORDSHIRE LOCAL PLAN 2015-2035, DRAFT PLAN JULY 2017
REPRESENTATIONS IN RESEPECT OF REGULATION 18 CENTRAL BEDFORDSHIRE LOCAL
PLAN CONSULTATION ON BEHALF OF BUSHMEAD HOMES LIMITED
LAND AT GREENFIELD ROAD, PULLOXHILL
We welcome this opportunity to comment on the Central Bedfordshire Local Plan 2015-2035 (Draft Local
Plan).
Bidwells has been instructed by Bushmead Homes Limited to respond to the Draft Local Plan.
Bushmead are site promoters for the land at Greenfield Road, Pulloxhill.
Introduction
The land under Bushmead's control is illustrated on the enclosed location plan. It is identified as
'NLP335' within the Council's Site Assessment.
The Draft Plan has positively assessed the site for further consideration. The site is identified for development of approximately 24 dwellings, as per the CBC methodology.
A significant amount of research and technical assessments have been undertaken on the site to ensure the deliverability of the proposed development.
Our Client wishes to make some comments in relation to specific policies within the Local Plan. These comments are provided below under the relevant Local Plan Headings. Any comments in relation to specific policies have been highlighted for ease of reference.
Growth Strategy and Unmet Housing Need
We welcome Central Bedfordshire Council's (CBCs) desire to deliver development to meet the unmet needs of CBC. The Draft Plan indicates that between 20,000 - 30,000 new homes are likely to be required to accommodate the Councils anticipated level of growth. It is our belief that the actual requirement could be significantly higher than the upper level of development proposed by this Plan.
Significant additional research is required to fully assess the housing requirement for the Council, including a full Objectively Assessed Need (OAN) which has been independently scrutinised. This position was also found by the inspector of the Stotfold appeal (Appeal Reference:
APP/P0240/W/16/3166033) who concluded that the OAN for Central Bedfordshire was to 32,000 dwellings for the period 2015-2035 and that the SHMA is the most trusted indicator of housing need for an area. This must include the 7,400 dwellings that Luton Borough Council are unable to deliver.
Notwithstanding this, we note that Policy SP1 is subject to the findings of more detailed assessments as well as the expected government guidance on housing need calculations.
The level of housing that can be provided is therefore somewhat dependant on the amount of small -
medium sized sites outside the Greenbelt that are allocated for development at the next stage of the Local Plan as well as the treatment of windfall developments within the housing land supply.
In order to meet the growth strategy, it is vital that CBC have a range of sites that are allocated for development over the plan period. Smaller, more contained sites may help the Council achieve their short-term targets while larger sites are needed to provide a more strategic level of growth, particularly where there is a large infrastructure requirement. Small and medium sites outside of the Green Belt
should be included within the growth strategy in addition to the number of strategic sites. Correctly identifying and allocating such sites ensures that a more comprehensive and joined up approach to development can be planned for.
We are concerned that smaller and medium sized sites have not been identified in this iteration of the plan; such sites will provide an essential element of housing delivery, particularly in the early stages of the plan, these sites should be consulted on under the Regulation 18 consultation rather than left to a later stage of the Local Plan process. We appreciate the position CBC are at, noting that much of the
evidence base from the withdrawn Plan has been relied upon to inform the Draft Plan, we also note the context of the Housing White Paper and further changes that are expected. We acknowledge from the published Local Plan timetable that submission of the Plan is to be post March 2018, therefore consideration will need to be given to the standardised method of calculating objectively assessed
housing need, this will influence the housing target within the plan and CBC will then need to consider whether the Plan remains robust in regard to the updated evidence base, or whether further review will be required. We request detail of how such matters will be considered in future to ensure the plan remains robust and can continue through to Examination.
Settlement Hierarchy
Pulloxhill is identified as a small village within the settlement hierarchy, it is therefore identified as a settlement with limited facilities and services. Pulloxhill benefits from a Lower School and Public Houses and also close proximity to sources of employment provided by the industrial park to the north. Pulloxhill
is of a suitable scale to receive a proportionate amount of development and additional dwellings will assist in retention of services for the village.
Growth Area D - Limited Grown in Villages
We accept that area D consists of several villages dispersed between the two north south transport lines either side of the area, and in some cases connectivity is restricted due to existing infrastructure.
However, it must be recognised that this does not present suitable sites from coming forward for development. Indeed, the identification of appropriate sites can provide sustainable forms of development that benefit the communities and wider area.
Paragraph 7.6.15 of the plan notes there is scope for some small and medium scale sites; however, these will not be presented as allocations until the pre-submission version of the plan. This causes significant difficulty in the progression of a sound plan. Such site allocations should be identified and consulted on at this regulation 18 stage. Paragraph 7.6.18 notes that growth within the villages will be comprised of individual sites of less than 250 homes. Bushmead Homes does not object to the limiting of such sites to the scale of less than 250 homes, and notes that such a figure ensures the development are of an appropriate scale for the
settlement.
Paragraphs 7.8.1 and 7.8.2 notes that the plan only looks at key growth locations at a strategic scale except for the collective growth that is proposed through limited extensions to large villages and towns inset into the green belt (Area A), and that outside of green belt, small and medium sites have not been identified or given an indicative capacity. As small and medium sites in these locations will provide a
substantial element of housing delivery it is of concern that the capacity within these sites has not been addressed at this stage.
Housing
It is vital that a mix of housing is provided to ensure social diversity and mobility. The proposed development must meet the current requirements as well as ensuring the aspirations for the Council are met.
Bushmead supports the aspiration from CBC to ensure an appropriate and inclusive housing mix in new housing developments, and agrees that the correct mix can contribute to well-designed places and towards strong community cohesion. Paragraph 12.1.2 notes that the main evidence base underpinning
a good housing mix will be the SHMA 2015 (noted as currently being refreshed). The commentary within the plan also recognises a growth in particular in groups such as elderly and first time buyers.
Paragraph 12.1.7 notes the SHMA supports a requirement for smaller homes for people to downsize into, but also notes the need for family sized homes for growing families. The plan also recognises the needs of younger people (particularly first time buyers) and for people with specific needs and care requirements.
Policy H1, seeks to ensure development is suitably formed to address the mix of needs through housing types, and sizes. However, the policy falls substantially short of providing clear guidance on precise requirements for development proposals with regard to housing mix, and gives no indication of how
assessments will be formed to ensure the policy is met.
The policy does not clarify exactly how CBC will consider the submission of an evidence base; for example, there must be some guidance on the level of detail required to form a robust evidence base; or how matters will be considered when a conflict between evidence bases arises; such as a local assessment that demonstrates a variance to the most up to date SHMA. The policy must direct exactly what is trying to be achieved. For example, Housing Market Assessments may differ in outcome form a housing needs assessment or population projections.
The policy should be re-written with clear reference the specific needs for evidence base, depending on the scale and nature of the development and also the locality. CBC should provide a level of expectation that developments should meet and can be tested against (unless material considerations direct otherwise).
Policy H2 'Housing Standards' states that the Nationally Described Space Standards will be applied.
This is welcomed and allows developers certainty. For volume housebuilders, this allows a certain degree of standardisation in their products, which can help with viability.
The requirement for adaptable and accessible homes from all future developments needs to be based on clear evidence for both needs and viability as required by the Planning Practice Guidance. If the percentage requirement is not used, the Local Plan states that the requirement for adaptable and accessible homes will be looked at on an application basis, for which the Council will look at the evidence of need. This needs to be extended to include not only need, but the viability of each site. Furthermore, there will naturally be some locations within the Council that are more suitable to adaptable homes due to the proximity to services and facilities. The level of sustainability therefore needs considering along with the level of requirement and site specific viability.
This policy also needs to be considered in the context of the level of affordable housing required to ensure that an effective viability of the Local Plan can be undertaken as required by the NPPF. The NPPF states that Local Plans must enable predictable and efficient decision making, as such, policies that affect the potential viability of a site need to be fully understood from a viability perspective.
Bushmead Homes recognise the matters raised in paragraphs 12.3 of the daft plan, and welcomes the consideration of providing housing to meet the needs of an ageing population. Paragraph 12.3.7 notes that there is an essential need for smaller units, specifically 1 and 2 beds to cater for an older population, in the form of bungalows, mobility homes standards, flatted maisonettes and other mainstream housing and will also incorporate various housing tenure options. My client also recognises the desire for people to downsize from their existing properties, and seek properties that meet their needs, such as bungalows. An important matter that is not noted in the text within the draft plan is the desire for many people to remain within their local area. As such the draft plan should recognise the specific needs for
areas where the supply of appropriate housing is short and the demographic information for the locality confirms an elderly population.
Policy H3 seeks to address the matters noted in the proceeding text, however, fails to positively direct development to meet the needs of the older population. The policy fails to clearly define what would constitute a dwelling suitable for occupation by an older person, and neither does it demonstrate how such a property would be provided to the desired occupants. The policy is addressed to 'all new
residential development;' requiring all applications to identify opportunities to provide accommodation in suitable and sustainable locations, noting access to town centres, near transport links, services, and leisure and health facilities.
The policy continues with requirements for development to provide various tenures, a good quality standard and aimed to meet the needs of older people as they progress through their life changes.
While these are positive aims, there is no direction provided, and it will not be clear whether the policy requirements have been met when assessing developments. My client's concern is that the policy is so broadly phrased that there will be deliberation on whether a proposal complies with Policy H3. For example, the policy requires various forms of tenure, and lists those which are noted as suitable;
however, it is likely that specific forms will be more appropriate than others, depending on the needs and demographic of the area. For downsizers, shared ownership is unlikely to be feasible, as funds available from sales of current property will exceed the qualification requirements. Policy H3 in its current form
does not add anything with regards to the objectives for providing dwellings suitable for an older population over and above the objectives of Policy H1.
A further concern is that the policy has not been tested with regards to the wider viability of development proposals and fails to contain sufficient detail to direct how such matters should be taken into consideration. For example, a greater proportion of bungalows will have a greater land take on development sites and will result in an impact on the viability; we do not believe this has been considered
in the Councils evidence base to arrive at the affordable housing policy requirements.
The affordable housing requirement of 30% contained within Policy H4 could be provided on the land at Greenfield Road, Pulloxhill and is considered reasonable in most instances across the Council. In certain circumstances, this level of affordable housing provision may not be possible; in such instances, it is welcomed that viability testing will be considered on a case by case basis. Notwithstanding this, there are a number of policies outlined in these representations that provide a level
of uncertainty as to what will be expected in terms of housing standards and support for older people, it is therefore vital that all policies impacting on the viability of a site need to be considered, in particular policies H2 and H3 need to be balanced against the need for affordable housing.
Although it is supported that the level of affordable housing required is based on up-to-date information contained within the SHMA (or equivalent), we strongly suggest that an amendment to the level of affordable housing cannot be made legally without a review of the Local Plan, including the necessary consultation and robust justification for any amendments. It is therefore not appropriate to amend the
level of affordable housing required without a review of the Local Plan.
Providing the affordable units in clusters of no more than 10 units can often represent problems for the affordable housing providers and developers due to the future maintenance of the properties. It is therefore suggested that clusters can be larger than 10 units if appropriate design standards are put into place.
For sites only just meeting the affordable housing threshold of 11 or more units, the provision of onsite affordable housing may be unachievable and as such an offsite contribution may be required, Policy H4 should therefore cover this eventuality.
In some instances, sites may be more suited to older persons' accommodation, self-builds or more specialist accommodation, and as such these factors need to be considered within the policy to ensure that the most suitable locations for development are chosen.
Policy H6 'Starter Homes' states that 10% of the intermediate tenures should be available for starter homes. The Local Plan should allow flexibility in both the level of affordable housing provision as well as the tenure split between affordable rent and intermediate tenure. The requirement for starter homes may result in a shortage of intermediate tenures, as such allowances must be made to amend the tenure split should it be required.
The inclusion of self and custom build housing is greatly welcomed and there is clearly demand within the Council for serviced land plots. Policy H7 'Self and Custom Build Housing' must ensure that the plots for self and custom builders are available in suitable locations, and as such a range of opportunities needs to be considered rather than a blanket approach. In some instances, whole sites would be more suitable, whereas smaller sites or sites where there is a clear site-wide design approach may not be suitable for self and custom build plots. Notwithstanding this, the viability of providing serviced land plots must be considered.
Transport
The requirements within Policy T2: Mitigation of Transport Impacts on the Network' are particularly onerous and may be unachievable in some instances. Sustainable transport methods must be seen in the whole, with access to a variety of modes of transport. The 400 meters' proximity to a bus route or 800 metres to a rail link need to be considered as guides, with allowances made depending on the sitespecific
issues such as topography and ease of walking and cycling.
Where financial contributions are required towards sustainable travel infrastructure, these need to be fully justified and in accordance with the Community Infrastructure Levy Regulations 2010 as well as the National Planning Policy Framework.
The large infrastructure projects planned for the area including the: East West Rail (and supporting infrastructure), the Oxford to Cambridge Expressway, A1 Route Enhancements; and the A6 to M1 link road need to be carefully considered and planned for. These large infrastructure projects take a significant amount of planning and resources; however, they also offer potential delays to development in certain areas where land is safeguarded. It is vital that the Council continues to plan for the strategic infrastructure whilst seeking to minimise any delays or uncertainty.
Climate Change and Sustainability
The need to reduce carbon dioxide emissions and maximise energy efficiency and conservation is vital, and we welcome the measures that the Local Plan has included to promote sustainable development.
Notwithstanding this, it is important to consider the financial cost of some mitigation measures. These must be balanced against other policy requirements where necessary. A 'design first' approach seeks to reduce the need for energy through design features and as such this approach to reduce energy requirements first should be maximised.
Large sites are required to generate 10% of their energy demand from renewable and low carbon sources. This is over and above the National Policy requirements and no justification has been provided within the Local Plan document for such a divergence from national policy.
In some instances, a more creative and comprehensive approach to energy generation may be more sustainable, and as such, developers must be given the opportunity to provide off site energy should it be considered appropriate.
Site Specific Considerations
The following section specifically considers the technical assessment of the land at Greenfield Road, Pulloxhill, site reference NLP335:
Site Deliverability
The land outlined in red on the enclosed location plan is within the ownership of a single landowner.
There is a promotion agreement between the landowners and Bushmead Homes Limited and as such a clear willingness from all the landowners to develop the land.
Site Assessment Technical Document
Appendix D: Preliminary Assessment Results of the Site Assessment Technical Document identifies the
land at Greenfield Road, Pulloxhill reference: NLP335.
The Site Assessment for NLP335
Review of Site Assessment
Bushmead welcome the comment by the CBC that the site is well related to the settlement, recognising the street frontage opposite existing development. We would also highlight the wider context of the site where the site sits within an existing parcel of land enclosed by the urban area of Pulloxhill on 2 sides
and forms a logical infill within the existing urban pattern of the settlement. The allocation of the site would not give rise to any concerns of coalescence and this is confirmed in the CBC assessment.
Community Consultation Bushmead have conducted engagement with local stakeholders, including two meetings with the Parish
Council (September 2015 and September 2016).
The meetings held with the Parish Council were very useful and the public exhibition was well attended, and again useful commentary was provided by attendees. The key messages understood noted the following:
● Sufficient parking spaces to be provided
● Need for smaller 2/3 bedroomed downsizing/starter homes
● Design of houses to fit in with existing 'traditional' style
● Lack of amenities no post office/shop/youth facilities/buses
Following this feedback Bushmead have been reviewing the proposals and will look to feed the comments received into the revised plans. Bushmead will look to continue the positive community engagement in future stages.
Cumulative Development
A reasonable level of growth is noted at Pulloxhill since 2006, comprising 14.73%. despite this some
services within Pulloxhill have closed.
Pulloxhill is noted in the settlement hierarchy as a small village: however the inclusion of a lower school and access to employment does give Pulloxhill positive advantage over other villages in the same category of the settlement hierarchy. Further, sustainable development at Pulloxhill will help retain and develop services within the village.
Agricultural Land Quality
The site is note currently used for arable agriculture, and was previously used for grazing cattle. This is no longer taking place, so at present there is no agricultural use of the site. The scale of the site is limited so the loss of the site from agricultural use will not be detrimental to wider agricultural operations.
School Capacity
The accessibility to education services is noted with a lower school provided within the settlement and middle and upper schools at adjoining settlements. School capacity will not be a constraint to development of the site.
Environmental Constraints
The CBC assessment notes concern from a Landscape aspect, sighting an open pastoral site on gently rising ground, increasing visibility and forming part of the landscape setting of the village.
This is not accurate; Bushmead have commissioned a landscape appraisal of the site (while formed on
the previous layout) the document examines the strong landscape screening of the site, particularly at the unit, north and to some extent eastern boundaries of the site.
The open boundary is the aspect that faces into the village, emphasising the local context, of inclusion of the site as part of the village structure, and separation from the wider landscape context, where the site is separated from the wider, open pastoral areas to the north.
Development of the site would form the most logical area within the village and other identified sites would have a far greater impact on the wider setting of the village.
With regards to ecological matters, the presence of a pond at the northern boundary is noted as is the vegetated boundaries and grassland. Surveys have been completed that confirm there is no evidence of badgers, great crested newts or reptiles. There was however, evidence of potential for foraging bats and
nesting for breeding birds; the pond also provided evidence of water shrew. Appropriate mitigation would be provided to suitable account for such matters.
Conclusion
On behalf of Bushmead Homes Ltd, we greatly welcome this opportunity to comment on the emerging Local Plan. Bushmead support the positive comments made with regard to site NLP335; initial assessments have been undertaken which support the principle of development in this area.
We would be grateful if CBC could confirm receipt of this representation and continue to keep us informed as to the subsequent stages of the Local Plan.

Attachments:

Comment

Site Assessment Forms (Housing)

Representation ID: 5691

Received: 29/08/2017

Respondent: St Albans Diocesan Board of Finance

Agent: Bidwells

Representation:

The land under the Diocese's ownership is illustrated on the enclosed location plan. It is identified as 'ALP060' within the Council's Site Assessment.
The Draft Plan has positively assessed the site for further consideration. The site is identified for development of approximately 14 dwellings, as per the CBC methodology. see attachments

Full text:

see attachment

Attachments:

Object

Site Assessment Forms (Housing)

Representation ID: 6298

Received: 28/08/2017

Respondent: Mr Mark Richards

Representation:

We object to NLP353.There's no infrastructure to support these developments (local school already oversubscribed).There will be no viable public transport or other services made available or would be viable regardless of promises and the local roads are unsuitable due to present volumes of traffic. These plans will destroy the village community/character, encroach on wildlife and all they will do is create an enhanced dormitory environment whereby people will commute several miles to work, to school, to shop etc impacting on local environment by increasing pollution. Flitton is totally unsuitable for further development of this kind.

Full text:

We object to Sites Ref NLP172, NLP449 and NLP353.There's no infrastructure to support these developments (local school already oversubscribed).There will be no viable public transport or other services made available or would be viable regardless of promises and the local roads are unsuitable due to present volumes of traffic. These plans will destroy the village community/character, encroach on wildlife and all they will do is create an enhanced dormitory environment whereby people will commute several miles to work, to school, to shop etc impacting on local environment by increasing polution. Flitton is totally unsuitable for further development of this kind.