submissions on behalf of willis dawson ltd in respect …

HD Town Planning Ltd Mortimer House Mortimer Lane

Mortimer Berkshire RG7 3AJ

Tel: 07919 047588

E-mail: [email protected]

SUBMISSIONS ON BEHALF OF WILLIS DAWSON LTD

IN RESPECT OF THE DRAFT CENTRAL BEDFORDSHIRE

COUNCIL LOCAL PLAN 2015 – 35 (REGULATION 19 CONSULTATION)

PREPARED BY:

HD TOWN PLANNING LTD

DATE: 19th February, 2018

mailto:[email protected]

Willis Dawson Ltd Land West of Harlington

Ref: MED Date: February 2018

CONTENTS:

1. INTRODUCTION 1

2. VISION AND OBJECTIVES (SECTION 4.2) 1

3. SPATIAL STRATEGY (SECTION 5) 1

4. PROPOSED LOCATIONS FOR GROWTH (SECTION 6) 2

5. IMPLEMENTATION (SECTION 7) 4

6. GREEN BELT (SECTION 8) 7

7. HOUSING (SECTION 11) 7


Ref: MED Date: February 2018 1 | P a g e

1. INTRODUCTION

1.1 These representations relate to the Draft Central Bedfordshire Local Plan Regulation 19

Consultation and are submitted on behalf of Willis Dawson Ltd specifically in relation to a

major site West of Harlington where the company has a controlling interest.

1.2 As the site in question is being promoted for residential development and a major part of it

has been identified as a proposed residential allocation in the Draft Local Plan (HAS20)

reference will be limited to those parts of the Plan (including the text and policies) which are of

relevance to the provision of housing during the Plan period. Reference will also be made to

the supporting documents that provided the evidential base for the Plan which are listed on

the Council’s web site. Again reference will be primarily to the residential aspects of these

documents.

2. VISION AND OBJECTIVES (Section 4.2)

2.1 After setting out a commendably brief Vision of the Council area for 2035 this section then

goes on to set out a number of objectives which are said to form the basis of the subsequent

policies developed later in the Plan. These strategic objectives, which focus on providing

sustainable development (SO1) as well as “delivering enough homes and jobs to meet our

needs” (SO2). Whilst these first two objectives are somewhat anodyne insofar as they beg

the question as to what is “enough” and what is the area’s “needs”, they are generally

supported. However, it is noted that whereas employment is then clarified more precisely and

quantitatively in SO4 by setting a minimum number of jobs (24,000), the number of homes

and a minimum target fails to get any mention; SO8 is merely a repetition of SO2 at best and

moreover tends to focus only on affordable housing. As such the objective is imprecise and,

having regard to later comments on dwelling numbers, should be re drafted to make it sound

so that it refers to a minimum number (39,350) of dwellings in the Plan period. This would

bring it into line with the economic objectives in the Plan and reflect the fact that this Plan is to

be reviewed with the aim of incorporating potentially more housing (and employment) growth

within the Plan period if new infrastructure investment takes place before 2030 (see

comments on next section).

3. SPATIAL STRATEGY (Section 5)

3.1 Willis Dawson Ltd support the Spatial Strategy outlined in Paragraphs 5.1.1 – 5.1.5 and

particularly note the last paragraph which effectively sees the 39,350 new homes as being a

minimum figure with the prospect of potentially greater numbers being added through a

Partial Review with any increase in the Plan period being dependent on the delivery of East

West rail and improvements to the A1 and East Coast Mainline.

3.2 Paragraph 5.2 sets out the Key Spatial Objectives and these are generally supported by

Willis Dawson Ltd. The fourth bullet point reflects the advice from the Government’s White



Paper focussing growth on existing and potential transport hubs. Although not a major

settlement Harlington has a major advantage in having a rapid and frequent mainline train

service as well as being very close to Junction 12 of the M1. Moreover Harlington has not

had to accommodate much development over the last 30 years, primarily as a result of the

tight Green Belt boundary around the settlement. Whilst this highly restricted policy has been

in place the opportunities for meeting housing demand in the south of the Council area,

especially around settlements like Harlington, has been very difficult, hence our support for

the “exceptional circumstances” now identified by the Council justifying some limited

relaxation of the Green Belt boundary to meet housing needs. The only part of the Key

Spatial Objectives which we believe to be flawed is in relation to the commitment in the 6th

bullet point to strategic growth locations (Tempsford, Aspley Triangle, West of Luton and East

of Biggleswade) as the main areas of search in a future Partial Review. Not all of these

locations are necessarily dependent on the infrastructure improvements listed as being a pre

requisite for further growth. Moreover, by the time development takes place in 12 – 15 years

there is likely to have been major changes in technology such that concentrated forms of

strategic development (as opposed to more dispersed patterns of development) may no

longer have the same levels of advantage in the context of Sustainability Assessments.

Consequently we consider that it would be unwise and unsound to commit now to a particular

pattern of search for new development when they have yet to be tested in the context of

definitions of sustainability post 2030. As a consequence the Identified Areas for Future

Growth (see Section 5.5) should not be included in the Plan at this stage and should be re-

examined properly in the Partial Review together with other potentially sustainable options.

4. PROPOSED LOCATIONS FOR GROWTH (Section 6)

4.1 As the Willis Dawson Ltd interests are limited to the South Area comments will be confined to

Section 6.2 which deals with this area. Willis Dawson Ltd support the proposals for medium

scale growth in the major transport corridors as this provides both quick and easy public and

car based links directly to Luton and Dunstable but also northwards to Bedford. Wider rapid

public transport links are available to London (all central stations) and to other transport hubs

associated with the capital (London Heathrow, Gatwick etc.).

4.2 However, we object to the inclusion of West of Luton as an Identified Location for future

development (Paragraph 6.2.8) for the reasons outlined in the preceding section.

4.3 Willis Dawson Ltd generally support Policy SP1 but for reasons outlined above and for other

reasons set out below under Section 6.9, we believe the wording in the policies should be

altered to read:-

“”A minimum of 39,350 homes and a minimum of 24,000 jobs …..”.



4.4 This means that the wording of the policy is similar in respect of both jobs and houses. It

reflects the importance of actually achieving the total number of homes as well as the total

number of jobs. Both are equally important.

4.5 Willis Dawson Ltd support the greater emphasis now given to small and medium sized sites in

Paragraph 6.7.1 which reflects the advice given in the February 2017 Housing White Paper.

4.6 In Paragraph 6.8.5 it is noted that the Council believes Neighbourhood Plans cannot amend

the Green Belt boundaries. This may or may not be correct but in order to ensure that

housing needs within the Council area are met as close as possible to where they arise then

this makes it imperative to ensure that Green Belt boundary adjustments proposed in this

Plan incorporate some measure of flexibility to allow other sites to be released through the

NDP process if this is deemed necessary, especially given the potential delays which attach

to strategic sites (as documented by Nathaniel Lichfield & Partners and others). We comment

on this issue further below.

4.7 In Paragraph 6.9 (Table 6.2) it is noted that, as set out in the Introduction, the Council intend

to utilize its own estimate of objectively assessed need (32,000) as derived from demographic

forecasts as opposed to using the standardized assessment methodology on which central

Government are currently consulting. On top of this it is noted that the Council will

accommodate a further 7,350 of Luton Borough Council’s unmet housing need on the basis

that this cannot be met within the conurbation, giving a total of 39,350 houses or nearly 2,000

per annum. It is recognized that this represents a significant increase on completion rates

which have been achieved in the recent past and it is also noted that the Council are

committed to a review of OAN in the context of the East West rail study within 6 months of the

adoption of this Local Plan. On the face of it this stepped approach to potentially increasing

housing numbers (conditional upon the provision of the appropriate infrastructure) would

appear to be reasonable but it has to be recognized that on such a Partial Review of the Plan

the standardized OAN methodology will automatically come into play and become a highly

relevant consideration. The standardized OAN for Central Bedfordshire Council combined

with the standardized OAN for Luton which cannot be met within its borders both anticipate

further increase in the housing numbers to meet affordability targets: this presages a further

potentially large increase in the total (and annualized) housing numbers for the Borough and

for this reason alone it is important to ensure that the housing figures contained in Policy SP1

are regarded as minimum (as noted above). Any failure to meet these targets in the early

years will have significant effects in terms of rolling up unmet need in the later years of the

Plan.

4.8 We have already noted that the Local Plan identifies four potential areas of Future Growth

which will be examined in the Partial Review. Again whilst this would appear to be a prudent

approach we are not certain that this approach should be used to pre determine the outcome



of the Partial Review process for reasons which we have set out above. However, bearing in

mind that a significant proportion of this additional need may need to be met in the South of

the Borough to meet indigenous and Luton needs there may need to be some mechanism for

drawing attention to a further examination of the Green Belt boundaries at that time. We

make this comment because Paragraph 84 of the NPPF states that Green Belt boundaries

should be capable of enduring beyond the end date of the Plan. This is often done by the use

of “Safeguarded Land” but in the absence of this the Plan as it currently exists should make

reference to the possibility of a second stage Green Belt review to go with the second stage

review of the housing numbers.

4.9 Given that Table 6.2 identifies 23,528 dwellings which are already completed, consented or

allocated, Table 6.3 proposes a further 18,203 dwellings of which approximately half will be

on new strategic allocations identified in Policy SP1 and more detailed policies, with 30%

being on small or medium sized allocations and a further 16% being on as yet unidentified

windfall sites. The Plan itself is silent on where the windfall sites might originate but

presumably they will arise from opportunity applications both inside and outside urban areas,

Neighbourhood Plans yet to be drafted and appeals. Even allowing for the fact that there are

some 4,000 unidentified completions on sites which already have planning permission a

further 2,900 over the next 15 years does not sound unreasonable. However, it should be

pointed out that whereas windfall sites might be regarded as providing some flexibility in

achieving a minimum housing policy figure, the inclusion of these sites in the overall supply

side removes any such flexibility.

5. IMPLEMENTATION (Section 7)

5.1 We note that this Section commences with an assessment of the proposed new housing

allocations with delivery from existing commitments being taken from the SHLAA so as to

produce an overall trajectory. We have reservations about the relatively early start date being

given to all these strategic allocations with Marston Vale being estimated for delivery in less

than 3 years time (50 in 2021/22), North of Luton by the following year and East of Arlesey

and Biggleswade the year after. Our experience of delivery from large strategic sites in both

CBC and elsewhere is that this is a highly challenging target. The Nathaniel Lichfield &

Partners study showed that whilst it is theoretically possible to bring forward such sites quickly

this is not very common in practice and average delivery times (to first completion) are much

longer because of the complexity of the process, landownership issues and the time taken to

secure the requisite infrastructure, not to mention external variables such as the overall state

of the economy and the cost of financing. The problems associated with delivery from large

sites has afflicted several of the so called existing strategic site commitments to the south of

the Council area including North Houghton Regis (Site 1) and East of Leighton Linslade. The

former received planning permission in 2014 and is not now likely to deliver housing until after

2020 (2023/24 according to the Housing Trajectory in Appendix B of the Housing



Implementation Strategy). This overly optimistic estimate of delivery contrast with the much

more pessimistic approach taken with some of the small/medium site allocations – see below.

5.2 We fully support the identification of a significant number of small to medium sized housing

sites in Policy HA1 as this:-

i. delivers the sort of flexibility to delivery identified in the White Paper;

ii. it encourages more SME builders

iii. it better enables demand to be met where it arises;

iv. it allows sites to come forward much more quickly than the strategic sites;

v. it bolsters the 5 Year land supply position;

vi. it underpins the service base of many smaller settlements.

5.3 In particular we support the allocation HAS20 – Land West of the Midland Railway Line at

Harlington as this is in a general search location which complies with the Council’s

sustainability requirements i.e. within the Luton Bedford transport corridor. Moreover the

identification of this location fully meets the advice set out in central Government’s latest

Housing White Paper (February 2017), which identifies the possibility of relaxing Green Belt

boundaries around transport hubs. Although it is one of the larger allocations in Policy HA1,

it is located on a site West of Harlington which has minimal direct impact on existing residents

of Harlington which is a village identified as a Minor Service Centre in the Draft Plan due to

being well provided with existing facilities (shops, rail station, upper and lower schools,

doctors surgery, village hall, church and pubs), all of which are located on the eastern side of

the mainline railway. There are however opportunities for both foot and cycle connections

from the site to the existing village centre both to the North and South of the site with

vehicular movements being able to use existing radial routes out of the village with the

improved Junction 12 of the M1 being about 1 mile away from the site. The HAS20 allocation

is very well located in relation to Harlington Railway Station (for frequent public transport),

with the station being accessed on the western side of the railway line where the site is

located.. Locally there are fast rail connections with Harlington Railway Station providing an

excellent 15 minute service to Luton and northwards to Bedford where East-West Rail is

proposed, with both being accessed in 9 minutes and 16 minutes respectively. Harlington

Railway Station also connects further South to Luton Airport and also through London via St

Pancras International (Eurostar) and Farringdon (Crossrail) and then onto London Gatwick

Airport. Again an excellent 15 minute frequency of service is provided from Harlington to

these major transport hubs.

5.4 Vehicular access away from the site can be achieved for most potential residents leaving the

site for work or social purposes without passing through the village. The site is in a single



landownership and can be readily serviced (see below). There are no constraints to its early

development. Considerable work has already been undertaken in respect of the potential

scale of development in relation to the proposed allocation and the attached Master Plan (see

Appendix 1) demonstrates how the development can fit within the site and the alleged

constraints identified by the Council.

APPENDIX 1 – MASTER PLAN

5.5 We note that the Council appear to be much more cautious on the delivery from some of the

smaller/medium sized sites, including the proposed Harlington allocation (HAS20). We have

already pointed out that in the Housing Implementation Strategy this site is listed as

“developable” only i.e. delivering outside the 5 Year period on the basis that there are

potential problems with noise, surface water drainage and powerlines. We have pointed out

that we have investigated all these issues and none can be regarded as a constraint to

development. The site is a long distance away and above the floodplain and surface water

can be attenuated. Any noise issues from the railway line can easily be mitigated within the

site and it can also be “set off” from the powerlines by the appropriate distance. Given that

the site is in a single ownership and can easily be serviced by access and utilities there are

no grounds at all for suggesting that it will be delayed more than 3 years for delivery

purposes. This is similar to the delivery date anticipated by the Council for the much larger

Marston Vale proposal and for other small to medium sized allocations.

5.6 Therefore so far a housing delivery is concerned our worries about the over optimistic

assumptions with regard to the strategic allocations are partially offset by the potentially

pessimistic assessment of some of the small to medium sized allocations.

5.7 On the question of deliverability it is as well to point out that as the Housing Implementation

Strategy only shows a 5.09 yrs supply (see Appendix A). This includes 200 dwellings from

the proposed strategic allocations at North of Luton and Marston Vale in Years 4 and 5 of the

period. If as we strongly suspect these are delayed then the loss of 200 units will mean that

the Council will not be able to demonstrate a 5 Year supply of housing land at the

Examination. This is a serious position and undermines the soundness of the Plan. We

would add that this is aside from any questions which others may wish to raise about the OAN

figure, the size of the unmet demand being met from Luton or whether a 5% buffer is

appropriate. Whatever the situation the Council are dangerously close to the NPPF minimum

5 Year requirement in the early years of the Plan and this is an issue which goes to the heart

of soundness.

5.8 We do not wish to comment on the individual policies dealing with the strategic allocations

other than to point out that in combination with Policy SP3 applicants will be required to

provide a large amount of information before gaining planning permission in addition to

committing to significant amounts of associated infrastructure in a phased package. All these



requirements will tend to hinder their early release and make the NLP study evidence more

and more likely with regard to a timescale for delivery.

6. GREEN BELT (Section 8)

6.1 We have noted that exceptional circumstances required to amend Green Belt boundaries are

not set out in this section but are included within an earlier section of the Plan.

Notwithstanding this Section 8.3 refers to the release of Green Belt land both in general and

specifically and it would seem appropriate to list the factors regarded as exceptional

circumstances to ensure that readers are fully aware that the requirements of the NPPF in

respect of the Green Belt and potential releases have been fully met.

6.2 In Paragraph 8.3.3 reference is made to the fact that the Council expects Green Belt

boundaries to endure beyond the end of the Plan period. However, the Council is

immediately reviewing the Plan with a view to seeing whether higher housing numbers can be

accommodated. Some but not all of these Future Growth points lie outside the Green Belt

and are connected with East West rail provision. However, the Council itself admits that

some additional housing may be required in the south of the area to meet needs where they

arise. Whilst we do not believe that the Council needs to identify those locations now (unless

it proposes to identify Safeguarded Land), it is unwise to make a commitment to no change to

Green Belt boundaries. Instead we would propose the omission of this last sentence and, as

with the two stage approach to establishing and meeting housing need, the same two stage

approach should apply to the Green Belt. The Plan should make reference to the fact that if

“exceptional circumstances” exists then the Partial Review may need to make a further

adjustment to the Green Belt boundary.

7. HOUSING (Section 11)

7.1 Policy H2 Housing Standards indicate that the Council will require all new developments not

only to have 5% as wheelchair accessible but also a further 35% to be “adaptable” homes.

Whilst we acknowledge that with an aging population provision needs to be made for infirmity

generally, but 40% of all new housing in this category for general housing seems excessive

especially given that there will in addition be specialist housing schemes for the elderly which

provide 100% provision to meet these standards. Applying an “across the board” standard of

40% is an unnecessary additional cost of construction on general housing.

7.2 Policy H7 (Self & Custom Build Housing) is an area which central Government wish to see

encouraged. However, with the difficulties of both planning for such dwellings, and securing

the necessary finance by individuals, it is difficult to see how this can be increased to 20%

from a very low base. Given that when this is combined with affordable housing (30%)

exactly one half of a site will not be available for the developer wanting to construct open

market housing. This is likely to impose a significant burden on developers and delay sites



from being brought forward. This is especially the case with strategic sites where the number

of self-build sites generated will be huge and at 20% is likely to far exceed demand.


Ref: MED Date: February 2018

APPENDIX ONE

HARLINGTON MASTER PLAN

submissions on behalf of willis dawson ltd in respect …

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