Central Bedfordshire & Luton Green Belt Study

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Comment

Technical Reports

Representation ID: 574

Received: 03/08/2017

Respondent: Harlington Parish Council

Representation:

Questionable assessments which undermine both the findings and integrity of the study. See attachment for detailed comments on GB study and Harlington

Full text:

See attachment for comments from Harlington Parish Council

Attachments:

Comment

Technical Reports

Representation ID: 1253

Received: 18/08/2017

Respondent: Mr Anthony Pratt

Representation:

I am suprised by characterisation in Fig 5.1 as part of of parcel T4B as relatively weak performing and question whether an adequate field visit was undertaken. T4B is seperated from village by well defined features especially trees, is an area of particular open amenity land and borders a stream in a valley and wildlife sites (which are among trees so perhaps missed on field visit?), whereas T4A an open field probably the only site around Toddington suitable for housing development. At the very least the eastern part of T4B is an obvious candidate to be a Local Green Space.

Full text:

I am suprised by characterisation in Fig 5.1 as part of of parcel T4B as relatively weak performing and question whether an adequate field visit was undertaken. T4B is seperated from village by well defined features especially trees, is an area of particular open amenity land and borders a stream in a valley and wildlife sites (which are among trees so perhaps missed on field visit?), whereas T4A an open field probably the only site around Toddington suitable for housing development. At the very least the eastern part of T4B is an obvious candidate to be a Local Green Space.

Object

Technical Reports

Representation ID: 1457

Received: 29/08/2017

Respondent: Bedfordshire Land Promotions

Agent: JLL

Representation:

We generally support the assessment of site C4 identified in the Councils Green Belt Study and how it is then applied in the Growth Options Study. We do, however, question the "moderate contribution" assessment against Purpose 3 and consider that this should be revised to "Relatively Weak" to reflect the character of the land which includes a mix of uses (including housing) but which is clearly contained within long term boundaries.

Full text:

We generally support the assessment of site C4 identified in the Councils Green Belt Study and how it is then applied in the Growth Options Study. We do, however, question the "moderate contribution" assessment against Purpose 3 and consider that this should be revised to "Relatively Weak" to reflect the character of the land which includes a mix of uses (including housing) but which is clearly contained within long term boundaries.

Support

Technical Reports

Representation ID: 1481

Received: 22/08/2017

Respondent: Mr Gifford Box

Representation:

I agree with section 4.91 that Tilsworth should remain Greenbelt and not be suitable for future development.

Full text:

I agree with section 4.91 that Tilsworth should remain Greenbelt and not be suitable for future development.

Object

Technical Reports

Representation ID: 2188

Received: 25/08/2017

Respondent: City & County Projects

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

These representations are submitted on behalf of City and County Projects, who are promoting a site east of Chauntry Way, Flitwick (Reference NLP245) as detailed in the Call for Sites submission for it. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests, including on the Site Assessment Form for this land included in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, City and County Projects must object to the current conclusions reached in the Central Bedfordshire and Luton Green Belt Study. This is specifically in respect of how they relate to the land being promoted by them east of Chauntry Way will now be explained.

Stage 1 of the Green Belt Study involved a review of fairly wide parcels around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, these have been specifically identified and the discrete parcels considered further in isolation at Stage 2 of the Study.

Our clients' land east of Chauntry Way has not been identified separately within parcel FW1 and because this wider parcel was assessed as making a moderate contribution to assisting in the safeguarding of the countryside and a relatively strong contribution to preventing neighbouring towns from merging into one another it has not progressed beyond Stage 1e of the separate Site Assessment process.

City and County Projects object in the strongest terms to this conclusion. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which site NLP245 contributes to the purposes of including land in the Green Belt, finding as follows:

* The site does not fulfil the purposes of preventing the sprawl of a large built up area - the same conclusion was reached in the Green Belt Study on parcel FW1

* The contribution the site makes to preventing neighbouring towns from merging into each other should be 'relatively weak'. 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.

* The Green Belt Study assessed the whole of land parcel FW1 as making a 'relatively weak' contribution to preserving the setting of Ampthill. This is also true of site NLP245 in isolation.

* The contribution site NLP245 makes to safeguarding the countryside from encroachment is considered to be relatively weak, compared to the moderate contribution the wider parcel FW1 makes. This is because site NLP245 is visually more closely associated with the urban area of Flitwick than it is with the rural Green Belt. It is visually separated from the open countryside by the belt of trees that runs along a small watercourse on the western boundary. Furthermore, development of the site would extend the village 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.

The Green Belt Statement demonstrates that there are very strong arguments that the site should be removed from the Green Belt and allocated for new housing. It illustrates that a robust new Green Belt boundary could be created at the eastern edge of the site utilising the existing physical feature of the water course and associated tree belt, which would provide an enduring new boundary.

As has been argued separately in the representations on the Local Plan itself, this is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP245 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

Comment

Technical Reports

Representation ID: 2240

Received: 25/08/2017

Respondent: ALP207

Agent: Mr Richard Parry

Representation:

I fully support this policy on behalf of the owners of site ALP207

Full text:

I fully support this policy on behalf of the owners of site ALP207

Object

Technical Reports

Representation ID: 3075

Received: 29/08/2017

Respondent: Messers Olney, Willis & Butterworth

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

These representations are submitted on behalf of ours clients, Messrs Olney, Willis and Butterworth, who are promoting land south of Rectory Road, Steppingley (Site reference NLP085). Separate comments are submitted on the Draft Local Plan and other Technical Documents published with it that are relevant to our clients' interests, particularly the Site Assessments Technical Document and the conclusion reach on site NLP085.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. However, our clients object to the decision to effectively limit the Green Belt review to around Large Villages and towns and to exclude Small Villages such as Steppingley through the criteria utilised in the Site Assessment Technical Document, upon which separate representations are submitted.

In respect of the approach taken in Stage 1 of the Green Belt Review, our clients are concerned that this has been undertaken at too high a level and also in an inconsistent nature, leading to a failure to identify suitable parcels that contribute nothing to the purposes of the Green Belt.

For example, our clients land south of Rectory Road, Steppingley has been considered as part of Parcel FW4, to the west of Flitwick. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt (Purposes 1, 2 and 4) and a strong contribution to Purpose 3. However, unlike with other parcels considered as part of the Green Belt Review, in this instance the Review has not identified smaller parcels within FW4 that make less of or no contribution to Purpose 3 of assisting the safeguarding of the countryside from encroachment. As was demonstrated in the Call for Sites Submission for our clients' site (Parcel NLP085), it lies between existing buildings and it is of a modest scale, therefore its development would not result in any significant encroachment into the countryside.

The Call for Sites submission on behalf of Messrs Olney, Willis and Butterworth included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary between the settlement edge and the Green Belt.

Paragraph 2.18 in the methodology section of the Green Belt Review states "areas of land that make a relatively limited contribution to the overall Green Belt would be where new development would effectively be 'infill', with the land partially enclosed by development; new development would be well contained by the landscape, e.g. with rising land; new development would be of little harm to the qualities that contributed to the distinct identity of separate settlements in reality; and a strong boundary could be created with a clear distinction between 'town' and 'country'."

Our clients' land is exactly the type being described here. This highlights the inconsistent approach that has unfortunately been taken with the Green Belt review meaning its conclusions and the Draft Local Plan that has resulted cannot be considered justified as required by the NPPF.

Support

Technical Reports

Representation ID: 3087

Received: 29/08/2017

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

Please see comments attached

Full text:

Representations on Draft Central Bedfordshire Local Plan 2035 and Technical Evidence
to support the promotion of Land at Manor Close Barton Le Clay (ALP252)
Representations on the Green Belt Review
As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt
Review is supported as is the need to release land as part of the Plan to help meet the high housing
need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton
Borough's unmet need.
Our Clients support the approach taken in Stage 1 of the Green Belt Review, and in particular, the
conclusions reached in respect of parcel BC2, to the east of Barton-Le-Clay. This parcel is identified
as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of
including land in the Green Belt - purposes 1, 2 and 4. The Review does conclude however that this
parcel makes a relatively strong contribution to purpose 3, by assisting the safeguarding of the
countryside from encroachment.
Parcel BC2 extends across a wide area of the Green Belt covering the whole of the east of Barton-Le-
Clay. In the Stage 2 assessment of the Green Belt Review the site falls within parcel BC2a which is
assessed as having relatively weak contribution to the Green Belt. The Green Belt Review notes this
area lies adjacent to the built edge of Barton Le Clay and includes Ramsey Manor Lower School and
Arnold Middle School which has the effect of making a relatively weak contribution to purpose of
including the land within the Green Belt. The assessment concludes the heavily-treed watercourse
to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong
potential alternative to the Green Belt boundary.
Our Clients are of the view that the allocation of the Land at Manor Road would be a logical
extension to Barton-Le-Clay on a contained site in an existing built up area. Development of the site
would not harm the purposes of including the land in the Green Belt as it is located between the
northern boundary of Ramsey Manor Lower School and Ivel Close, and sits directly to the west of the
tree lined watercourse which could form a new edge to the settlement limits and an appropriate
boundary between the built form and Green Belt beyond.
Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Manor Road
and states "Areas of land that make a relatively limited contribution to the overall Green Belt would
be where new development would effectively be 'infill', with the land partially enclosed by
development; new development would be well contained by the landscape, e.g. with rising land; new
development would be of little harm to the qualities that contributed to the distinct identity of
separate settlements in reality; and, a strong boundary could be created with a clear distinction
between 'town' and 'country'."

Support

Technical Reports

Representation ID: 3106

Received: 29/08/2017

Respondent: Connolly Homes

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need.

Connolly Homes supports the general approach taken in Stage 1 of the Green Belt Review, and in particular, the conclusions reached in respect of parcel WE2 to the south of Westoning. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt - purposes 1, 2 and 4. The Review also concludes that whilst it does make a relatively strong contribution to purpose 3, assisting the safeguarding of the countryside from encroachment, the field adjacent to the inset settlement, which is the land at West View Farm being promoted by Connolly Homes, is considered to be fairly well contained due to its relationship with the existing built up area of Westoning.

The conclusion that the West View Farm site should progress separately to Stage 2 of the Review as parcel WE2a is also supported, as is the assessment that it makes a relatively weak overall contribution to the Green Belt purposes, and that its outer hedgerow, together with the A5120 and railway line, would make a strong potential alternative Green Belt boundary. The Call for Sites submission on behalf of Connolly Homes included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary the Green Belt.

Given the above, it is entirely appropriate that Parcel WE2a/West View Farm should be released from the Green Belt and allocated for housing in the Submission Version of the Plan.

Object

Technical Reports

Representation ID: 3545

Received: 29/08/2017

Respondent: Toddington Mews Developments Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

These representations are submitted on behalf of Toddington Mews Developments Ltd, who are promoting a site at Luton Road, Toddington (References NLP138 and NLP264) as detailed in the Call for Sites submissions. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests. This include responses to the Site Assessment Forms for these parcels in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, Toddington Mews Developments Ltd must object to the current conclusions reached in the Green Belt Study. This is specifically in respect of the consideration of parcel T2, and particularly their land at Luton Road (Sites NLP138 and NLP264), which form a small part of the wider land parcel.

Stage 1 of the Green Belt Study involved a review of fairly large parcels of land around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. Our clients consider that this has resulted in an overly simplistic look at Green Belt boundaries for the benefit of the authors. Given the intended permanence of Green Belt boundaries and how infrequently they are review, it is of utmost importance that this Green Belt review is carried out in suitably through and considered manner. Unfortunately, this has not been the case.

Furthermore, the approach taken has been inconsistent. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, or did so to a lesser extent, the latter have been specifically identified and these discrete parcels then considered further in isolation from the larger parcels they originated from at Stage 2 of the Study.

Our clients' land at Luton Road, Toddington (Sites NLP138 and NL264) has not been identified separately within parcel T2 and because this wider parcel was assessed as making a strong contribution to assisting in the safeguarding of the countryside it has not progressed beyond Stage 1e of the separate Site Assessment process.

Toddington Mews Developments Ltd wish to object to this conclusion in the strongest terms. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which sites NLP138 and NL264 contribute to the purposes of including land in the Green Belt. In respect of the Green Belt purpose of safeguarding the countryside from encroachment it concludes:

"5.2.7 The site relates much more closely to the urban area of Toddington than it does to the open countryside to the east. It is screened from views from the open countryside by a large block of woodland on the eastern boundary and tree and scrub belts along the northern and southern boundaries (which form permanent boundary features). To its immediate north and south are features that already form urbanising influences on the Green Belt. As a consequence, this particular site within the parcel only makes a relatively weak contribution to this Green Belt purpose.

5.2.8 The site scores very highly in terms of sustainability, being an extension to a Minor Service Centre with good transport links.

5.2.9 A new Green Belt boundary for the land east of Luton Road, Toddington is proposed, which meets the need for permanence expressed in the National Planning Policy Framework."

The Green Belt Statement demonstrates that there are very strong arguments that the site should be released from the Green Belt and allocated for new housing. It also illustrates that a robust new Green Belt boundary can be created utilising existing physical features, which would provide an enduring boundary.

As has been argued separately in the representations on the Local Plan itself, Toddington is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP138 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

Support

Technical Reports

Representation ID: 3557

Received: 29/08/2017

Respondent: Eaton Bray Parish Council

Representation:

Agree that the Green Belt is unchanged around and within Eaton Bray

Full text:

Agree that the Green Belt is unchanged around and within Eaton Bray

Object

Technical Reports

Representation ID: 3774

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached representations.

Full text:

Please see attached representations.

Object

Technical Reports

Representation ID: 3803

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached

Full text:

Please see attached

Comment

Technical Reports

Representation ID: 3814

Received: 29/08/2017

Respondent: Mr Rawdon Crozier

Agent: mr james mcmurdo

Representation:

please refer to document attached

Full text:

please refer to document attached

Attachments:

Object

Technical Reports

Representation ID: 3861

Received: 29/08/2017

Respondent: Mr Spencer Taylor

Representation:

I object to the proposed development. It is contrary to the slip End and Caddington neighbourhood plan, it is on green belt land, there is insufficient space for road improvements and current roads do not have the capacity to support existing or proposed developments and water supply and sewerage are at capacity already.

Full text:

I object to the proposed development. It is contrary to the slip End and Caddington neighbourhood plan, it is on green belt land, there is insufficient space for road improvements and current roads do not have the capacity to support existing or proposed developments and water supply and sewerage are at capacity already.

Object

Technical Reports

Representation ID: 3863

Received: 29/08/2017

Respondent: Miss Sam Roberts

Representation:

I object to the development because it is contrary to the Slip End and Caddington neighbourhood plan, it is on green belt land and roads and water and sewerage are already at capacity.

Full text:

I object to the development because it is contrary to the Slip End and Caddington neighbourhood plan, it is on green belt land and roads and water and sewerage are already at capacity.

Support

Technical Reports

Representation ID: 5074

Received: 29/08/2017

Respondent: GPS Estates Ltd

Agent: Woods Hardwick Planning Ltd

Representation:

Support ALP252
Support approach taken in stage 1 of Green Belt Review, in particular consultation on parcel BC2
Development of site would not harm the purposes of including the land in the Green Belt as it is located between the northern boundary of Ramsey Manor School and Ivel Close, and sits directly to the west of the tree-lined watercourse which could form a new edge to the settlement limits.

Full text:

Representations on Draft Central Bedfordshire Local Plan 2035 and Technical Evidence
to support the promotion of Land at Manor Close Barton Le Clay (ALP252)
Representations on the Green Belt Review
As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt
Review is supported as is the need to release land as part of the Plan to help meet the high housing
need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton
Borough's unmet need.
Our Clients support the approach taken in Stage 1 of the Green Belt Review, and in particular, the
conclusions reached in respect of parcel BC2, to the east of Barton-Le-Clay. This parcel is identified
as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of
including land in the Green Belt - purposes 1, 2 and 4. The Review does conclude however that this
parcel makes a relatively strong contribution to purpose 3, by assisting the safeguarding of the
countryside from encroachment.
Parcel BC2 extends across a wide area of the Green Belt covering the whole of the east of Barton-Le-
Clay. In the Stage 2 assessment of the Green Belt Review the site falls within parcel BC2a which is
assessed as having relatively weak contribution to the Green Belt. The Green Belt Review notes this
area lies adjacent to the built edge of Barton Le Clay and includes Ramsey Manor Lower School and
Arnold Middle School which has the effect of making a relatively weak contribution to purpose of
including the land within the Green Belt. The assessment concludes the heavily-treed watercourse
to the east of the schools (and the eastern edge of the Land at Manor Road) would make a strong
potential alternative to the Green Belt boundary.
Our Clients are of the view that the allocation of the Land at Manor Road would be a logical
extension to Barton-Le-Clay on a contained site in an existing built up area. Development of the site
would not harm the purposes of including the land in the Green Belt as it is located between the
northern boundary of Ramsey Manor Lower School and Ivel Close, and sits directly to the west of the
tree lined watercourse which could form a new edge to the settlement limits and an appropriate
boundary between the built form and Green Belt beyond.
Paragraph 2.18 of the Green Belt Review supports the allocation of sites such as Land at Manor Road
and states "Areas of land that make a relatively limited contribution to the overall Green Belt would
be where new development would effectively be 'infill', with the land partially enclosed by
development; new development would be well contained by the landscape, e.g. with rising land; new
development would be of little harm to the qualities that contributed to the distinct identity of
separate settlements in reality; and, a strong boundary could be created with a clear distinction
between 'town' and 'country'."

Object

Technical Reports

Representation ID: 5075

Received: 29/08/2017

Respondent: Toddington Mews Developments Ltd

Agent: Woods Hardwick Planning Ltd

Representation:


inconsistencies on Green Belt in Toddington,
Overly simplistic look at Green Belt boundaries for the benefit of the authors,
Has not been carried out suitable,
Site in Toddington (NLP138 and NLP264) should be removed from the Green Belt.

Full text:

These representations are submitted on behalf of Toddington Mews Developments Ltd, who are promoting a site at Luton Road, Toddington (References NLP138 and NLP264) as detailed in the Call for Sites submissions. Separate representations having been submitted on the Draft Local Plan ('DLP') and other Technical Documents published with it that are relevant to our clients' interests. This include responses to the Site Assessment Forms for these parcels in the Site Assessments Technical Document.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported, as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. Unfortunately, however, Toddington Mews Developments Ltd must object to the current conclusions reached in the Green Belt Study. This is specifically in respect of the consideration of parcel T2, and particularly their land at Luton Road (Sites NLP138 and NLP264), which form a small part of the wider land parcel.

Stage 1 of the Green Belt Study involved a review of fairly large parcels of land around existing settlements to determine the extent to which they contribute to the purposes of including land in the Green Belt set out at paragraph 80 of the Framework. Our clients consider that this has resulted in an overly simplistic look at Green Belt boundaries for the benefit of the authors. Given the intended permanence of Green Belt boundaries and how infrequently they are review, it is of utmost importance that this Green Belt review is carried out in suitably through and considered manner. Unfortunately, this has not been the case.

Furthermore, the approach taken has been inconsistent. In certain instances where a wider parcel was considered to contribute to the Green Belt purposes, but smaller discrete parcels within it did not, or did so to a lesser extent, the latter have been specifically identified and these discrete parcels then considered further in isolation from the larger parcels they originated from at Stage 2 of the Study.

Our clients' land at Luton Road, Toddington (Sites NLP138 and NL264) has not been identified separately within parcel T2 and because this wider parcel was assessed as making a strong contribution to assisting in the safeguarding of the countryside it has not progressed beyond Stage 1e of the separate Site Assessment process.

Toddington Mews Developments Ltd wish to object to this conclusion in the strongest terms. The attached Green Belt Statement prepared by James Blake Associates (JBA) provides a robust and objective assessment of the extent to which sites NLP138 and NL264 contribute to the purposes of including land in the Green Belt. In respect of the Green Belt purpose of safeguarding the countryside from encroachment it concludes:

"5.2.7 The site relates much more closely to the urban area of Toddington than it does to the open countryside to the east. It is screened from views from the open countryside by a large block of woodland on the eastern boundary and tree and scrub belts along the northern and southern boundaries (which form permanent boundary features). To its immediate north and south are features that already form urbanising influences on the Green Belt. As a consequence, this particular site within the parcel only makes a relatively weak contribution to this Green Belt purpose.

5.2.8 The site scores very highly in terms of sustainability, being an extension to a Minor Service Centre with good transport links.

5.2.9 A new Green Belt boundary for the land east of Luton Road, Toddington is proposed, which meets the need for permanence expressed in the National Planning Policy Framework."

The Green Belt Statement demonstrates that there are very strong arguments that the site should be released from the Green Belt and allocated for new housing. It also illustrates that a robust new Green Belt boundary can be created utilising existing physical features, which would provide an enduring boundary.

As has been argued separately in the representations on the Local Plan itself, Toddington is a sustainable location for new housing and our clients respectfully request that the Council revisits its position on parcel NLP138 and identifies it for release from the Green Belt and allocation for housing in the Submission version of the Local Plan. Failure to do so could lead to the Local Plan being considered unsound as it would not be justified in the terms required by the Framework.

Object

Technical Reports

Representation ID: 5077

Received: 29/08/2017

Respondent: Connolly Homes

Agent: Woods Hardwick Planning Ltd

Representation:

West View Farm Westoning,

Parcel of land should pass Green Belt Review to Stage 2.

Full text:

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need.

Connolly Homes supports the general approach taken in Stage 1 of the Green Belt Review, and in particular, the conclusions reached in respect of parcel WE2 to the south of Westoning. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt - purposes 1, 2 and 4. The Review also concludes that whilst it does make a relatively strong contribution to purpose 3, assisting the safeguarding of the countryside from encroachment, the field adjacent to the inset settlement, which is the land at West View Farm being promoted by Connolly Homes, is considered to be fairly well contained due to its relationship with the existing built up area of Westoning.

The conclusion that the West View Farm site should progress separately to Stage 2 of the Review as parcel WE2a is also supported, as is the assessment that it makes a relatively weak overall contribution to the Green Belt purposes, and that its outer hedgerow, together with the A5120 and railway line, would make a strong potential alternative Green Belt boundary. The Call for Sites submission on behalf of Connolly Homes included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary the Green Belt.

Given the above, it is entirely appropriate that Parcel WE2a/West View Farm should be released from the Green Belt and allocated for housing in the Submission Version of the Plan.

Object

Technical Reports

Representation ID: 5079

Received: 29/08/2017

Respondent: Messers Olney, Willis & Butterworth

Agent: Woods Hardwick Planning Ltd

Representation:

Flitwick

Smaller parcels need to be identified within parcel FW4 in regard to site NLP085, that show weakly scoring Green Belt,
can be considered infill development

Full text:

These representations are submitted on behalf of ours clients, Messrs Olney, Willis and Butterworth, who are promoting land south of Rectory Road, Steppingley (Site reference NLP085). Separate comments are submitted on the Draft Local Plan and other Technical Documents published with it that are relevant to our clients' interests, particularly the Site Assessments Technical Document and the conclusion reach on site NLP085.

As suggested in the representations on the Draft Local Plan itself, the principle of a Green Belt Review is supported as is the need to release land as part of the Plan to help meet the high housing need in Central Bedfordshire and the commitment to deliver 7,400 dwellings towards Luton Borough's unmet need. However, our clients object to the decision to effectively limit the Green Belt review to around Large Villages and towns and to exclude Small Villages such as Steppingley through the criteria utilised in the Site Assessment Technical Document, upon which separate representations are submitted.

In respect of the approach taken in Stage 1 of the Green Belt Review, our clients are concerned that this has been undertaken at too high a level and also in an inconsistent nature, leading to a failure to identify suitable parcels that contribute nothing to the purposes of the Green Belt.

For example, our clients land south of Rectory Road, Steppingley has been considered as part of Parcel FW4, to the west of Flitwick. This parcel is identified as making a weak/no contribution or a relatively weak contribution to 3 of the 4 purposes of including land in the Green Belt (Purposes 1, 2 and 4) and a strong contribution to Purpose 3. However, unlike with other parcels considered as part of the Green Belt Review, in this instance the Review has not identified smaller parcels within FW4 that make less of or no contribution to Purpose 3 of assisting the safeguarding of the countryside from encroachment. As was demonstrated in the Call for Sites Submission for our clients' site (Parcel NLP085), it lies between existing buildings and it is of a modest scale, therefore its development would not result in any significant encroachment into the countryside.

The Call for Sites submission on behalf of Messrs Olney, Willis and Butterworth included a concept plan to illustrate how the site might be developed and which demonstrated how the southern boundary could be augmented to create a strong new boundary between the settlement edge and the Green Belt.

Paragraph 2.18 in the methodology section of the Green Belt Review states "areas of land that make a relatively limited contribution to the overall Green Belt would be where new development would effectively be 'infill', with the land partially enclosed by development; new development would be well contained by the landscape, e.g. with rising land; new development would be of little harm to the qualities that contributed to the distinct identity of separate settlements in reality; and a strong boundary could be created with a clear distinction between 'town' and 'country'."

Our clients' land is exactly the type being described here. This highlights the inconsistent approach that has unfortunately been taken with the Green Belt review meaning its conclusions and the Draft Local Plan that has resulted cannot be considered justified as required by the NPPF.

Object

Technical Reports

Representation ID: 5086

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached covering letter that references different Technical Reports in regards to Slip End.

Green Belt Study - Area around Slip End constitutes as scoring relatively weakly or weak in their Green Belt Study, site is suitable for release against the Green Belt.

Full text:

Please see attached

Attachments:

Object

Technical Reports

Representation ID: 5089

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Any parcel assessed as making a 'moderate' or stronger contribution towards any purposes not given an overall classification of 'weak' or 'relatively weak' even though its contributions in other respects were weak.
Rather than rely on a policy, CBC should allocate additional sites now and review the plan to address longer term needs.
In addition to 'exceptional circumstances', consider that the J10a site does not make a significant contribution towards the Green Belt south of Luton.
GBS assesses large parcels, not considering the potential of smaller parcels or specific sites.

Full text:

Please see attached representations.

Object

Technical Reports

Representation ID: 5095

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attachment on Green Belt Review for further details,

The CBC assessment of the site included within Parcel SE1 of making a 'moderate' contribution (moderate risk of
harm from release) to Purpose 3 is not agreed. The L&G land is considered to make
a 'relatively weak' contribution (low risk of harm from release) to Purpose 3.
Site's layout and provisions can limit any harm to the Green Belt.

Full text:

Please see attached

Comment

Technical Reports

Representation ID: 5163

Received: 24/08/2017

Respondent: Greensand Properties LLP

Agent: Kirkby Diamond

Representation:

Concerned re: limitations of GB study. Performance of GB should be considered on site specific basis not on basis of arbitrary parcelisation where there are wide variations. The parcel in which NLP090/090 fall covers 7550+HA extending between MK and Luton and from Ampthill to Woburn - taking in numerous villages - including several sustainable medium-sized villages that are suitable development locations. Hopelessly broad-brush approach of GB performance across this area as one - without distrinction - is a very serious flaw in the assessment. Considerable development could be accommodated in this area without compromising the purposes in NPPF para 80

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 5403

Received: 24/08/2017

Respondent: D & E Buckingham

Agent: Kirkby Diamond

Representation:

Fig 4.5 identifies a swathe of land north of Houghton Regis (area 3) as homogenous 'permitted urban extension in green belt'. This is correct for the majority of the land, however certain parcels (e.g. ALP259 / NLP132) are not permitted for development in the green belt, therefore plan is inaccurate
Plan should make provision for the release of any areas of land in this broad location that do not benefit from planning permission to be released from the Green belt
Important that this anomaly is corrected so remaining land parcels in this location can be brought forward for development

Full text:

See attachment

Comment

Technical Reports

Representation ID: 6106

Received: 29/08/2017

Respondent: Taylor Wimpey

Representation:

The Study (November 2016) has tested the performance of the Central Bedfordshire
and Luton Borough Green Belt. The site has been assessed as part of a wider land
parcel (AH1) as shown on the plan below. see attachment

Full text:

see attachment

Attachments:

Object

Technical Reports

Representation ID: 6186

Received: 29/08/2017

Respondent: St Albans District Council

Representation:

SADC objects to some of the detail of the analysis of the area north of Harpenden
GB reviews must be read taking account of specific local issues and interpretations of purposes and related terms

See attachment for detailed comments on the Green Belt assessment regarding parcels of land and approach to assessment and for excerpts of SADC GB Review

Full text:

See attachment for detailed comments from St Albans District Council

Attachments:

Comment

Technical Reports

Representation ID: 6574

Received: 29/08/2017

Respondent: Willis Dawson

Agent: HD Town Planning

Representation:

On behalf of Willis Dawson this document has been examined in some detail as it provides
the requisite background for establishing whether or not "exceptional circumstances" exists
for the release of some Green Belt land for development purposes in order to achieve a
sustainable pattern for development. We fully appreciate that undertaking such an exercise is
not a simple task and is potentially subject to criticism from a number of sources, not least
from local residents who wish to see no change in the current situation, (notwithstanding
severe pressures on the housing market in the area). see attachment

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 6629

Received: 29/08/2017

Respondent: Willis Dawson

Agent: Pegasus Group

Representation:

The Green Belt Study considered large parcels of land around the edges of
settlements, including towns and large villages, with regard to their contribution
to the five purposes of the Green Belt as defined by the NPPF at paragraph 80 to;
* check the unrestricted sprawl of large built up areas
* prevent neighbouring towns merging into one another
* assist in safeguarding the countryside from encroachment
* preserve the setting and special character of historic towns, and;
* assist in urban regeneration, by encouraging the recycling of derelict and other
urban land. see attachment

Full text:

see attachment

Attachments:

Comment

Technical Reports

Representation ID: 6723

Received: 29/08/2017

Respondent: - Wingfield, Jerram, & Monckton

Number of people: 3

Agent: Strutt & Parker

Representation:

Central Bedfordshire and Luton Green Belt Study Appendix 1 (July 2017)
The area between Ampthill and Maulden has been assessed as Land Parcel ref.: AH1. This notes that 'The parcel is mainly comprised of open arable and pasture fields defined by tree belts and small linear woodland copses.' It acknowledges that the Green Belt does not notably contribute to the purposes of the Green Belt in terms of preventing urban sprawl or coalescence. It has relatively strong contributions to preventing encroachment into the countryside and to preserve the setting and special character of historic towns. see attachment

Full text:

see attachments

Attachments: