‘Objection’ representations by Sundon Parish Council

Summary

We are concerned about the effects of the strategy. The strategy will result in inward population migration up to 2031 in excess of the population migration accounted for in the Department of Communities and Local Government’s Household Projections. The planned magnitude of inward population migration is not supported by a commensurate quantum and variety of new jobs. This will result in a level of commuting, to and from where new houses are located and where their occupants work, which can not be supported by existing and planned transport infrastructure. Inward population migration from places within the defined Strategic Housing Market Area and beyond will adversely affect the affordability of new housing in Central Bedfordshire and Luton. This will prevent people who can not afford this housing’s costs from having a home of their own.

Duty to Cooperate

The Development strategy is unsound because Central Bedfordshire Council has not fulfilled its ‘Duty to Cooperate’ obligation in the way the National Planning Policy Framework and the Department of Communities and Local Government Planning Practice Guidance intends it should. This is for the following reasons:

  • Central Bedfordshire Council has so far been unable to substantiate it has complied properly with its ‘Duty to Cooperate’ obligation. It appears it intends to provide a quantum of Luton Borough Council’s housing need. Central Bedfordshire Council has not justified with any objective evidence this quantum of housing need can not be met by Luton Borough Council. Central Bedfordshire Council has not produced an objective assessment of this housing’s impact on its transport and other infrastructure. There is no evidence these Councils have agreed to share financial responsibility for the provision of this housing’s supporting infrastructure.
  • Central Bedfordshire Council say they have Memoranda of Understanding with other Councils in the area. We are concerned these are not effective tools for reducing the pressure for more inward population migration above the level already planned unless the Councils within the Strategic Housing Market Area cooperate and plan for ‘net nil migration’ across this area.
  • Planning Practice Guidance says these Memoranda of Understanding must be in place prior to submitting the Development Strategy to the Planning Inspectorate. We hope Central Bedfordshire Council has fulfilled this aspect of its ‘Duty to Cooperate’ obligation otherwise its Development Strategy is not legally compliant.

Policy 2 Growth Strategy

We consider the Strategy’s objectives of 31,000 net new homes and 27,000 net new jobs between 2011 and 2031 are unsound as these objectives are:

  • not consistent with National Planning Policy Framework ‘Sustainable Development’ objectives as they will impose unsustainable social and environmental impacts on the area due to growth in commuting, congestion, petrol and diesel vehicle emissions, and countryside loss. These consequences of housing growth are contrary to the vision of sustainable growth set out in Central Bedfordshire’s ‘Sustainable Communities Strategy’ 2010.
  • not justified by a robust and credible evidence base.

Policy 3 Green Belt

We consider the proposals for creating Strategic Urban Extensions and Employment Zones within the Southern Bedfordshire Green Belt are on a scale which is unsound because they are:

  • not justified and not consistent with national policy, being based on housing and employment objectives which are themselves considered by us to be unsound. The proposals do not form a sufficient case of ‘exceptional circumstances’ as required by the National Planning Policy Framework for removal of the quantum of Green Belt proposed.

Employment and Economy Paragraphs

We consider Central Bedfordshire Council’s objective to provide 27,000 new jobs by 2031 is unsound because:

  • the number of new jobs is not justified, being a figure which though claimed to be ‘robustly evidenced’ is at the same time described at Paragraph 6.19 as ‘ambitious’ and at Paragraph 6.20 as ‘stretching’. We note the figure of 27,000 is almost 7,000 higher than that suggested by recent economic forecasts and modelling (see Paragraph 6. 14), and 3,000 higher than that based on historic trends (see Paragraph 2.30 of the Council’s Employment Technical Paper, January 2013). We also think new jobs growth in the Central Bedfordshire area associated with the expansion of Luton Airport will not make more than a modest contribution towards closing this gap.
  •  the objective is not effective as it is unlikely to be deliverable.

Policy 29 Housing Provision

We consider the objective of 31,000 net new homes, of which approximately 11,325 are identified with new strategic sites located within the Green Belt, is unsound because the new homes are:

  • not justified by local need, being the outcome of a housing strategy which encourages inwards population migration, with insufficient regard to the impact this will have on the Green Belt and on sustainability.
  • not consistent with national policy as it will not deliver the National Planning Policy Framework objective of sustainable development . We note the Sustainability Appraisal (June 2014) assesses the 31000 housing target against 13 Sustainability Objectives, and judges the level of impact will only be adverse in 2 of them, and then only at a ‘Minor Negative’ level. This complacent conclusion can have no credibility. The Transport Modelling Report, Stage 2 (December 2012), which has not been updated, points to huge increases in traffic congestion across the Central Bedfordshire and Luton area by 2031 arising from the level of housing growth proposed at that time (28,700), with many key roads experiencing Volume to Capacity Ratios of over 95%. This is before any consideration of the uplift to 31000 homes, or the doubling of passenger throughput at Luton Airport which has recently been approved.

Policy 61 North of Luton Strategic Site Allocation    

We consider the North of Luton Strategic Site Allocation is unsound because:

  • the policy is not effective as the function, alignment and deliverability of the proposed M1 – A6 Link Road which would service this Strategic Site Allocation has not yet been properly identified. Unless these fundamental issues relating to this ‘critical’ link road have been properly established, we consider the policy is flawed.
  • its development is not consistent with Landscape Policy 58, which reflects National Planning Policy Framework content by requiring ‘exceptional circumstances’ for development within and abutting an Area of Outstanding Natural Beauty. This Strategic Allocation will impact adversely on the Chilterns Area of Outstanding Natural Beauty due to its visual intrusion and noise and light pollution. The Sustainability Appraisal of the site confirms this landscape is of ‘High Sensitivity’. This requires a commensurate level of ‘exceptional circumstances’ to justify overriding national and local Area of Outstanding Natural Beauty policy.
  • the Sustainability Appraisal also places this site in the ‘Red’ category in relation to Green Belt and Coalescence issues. This as well would require a commensurate level of ‘exceptional circumstances’ to override National Planning Policy Framework content concerning the removal of land from Green Belt status; we think the development of this site is not consistent with national policy.
  • the Transport Modelling Report, Stage 2, shows quite clearly the level of traffic movement that would be generated by this Strategic Site Allocation, even with provision of an M1 – A6 Link, and before any factoring in of the implications of Luton Airport expansion, will create unsustainable impacts on the surrounding road network. As such it is clearly not a proposal which accords with the principles of sustainable development as laid down in the National Planning Policy Framework, and is therefore is not consistent with national policy.

Policy 64 Sundon Rail Freight Interchange

We consider this proposal is unsound because:

  • given the uncertainties surrounding both the practicality and the commercial viability of the site as a Rail Freight Interchange the proposal is not justified by a credible and robust evidence base sufficient to establish the ‘exceptional circumstances’ required by the National Planning Policy Framework to remove the area from Green Belt status.
  • noise, light and visual intrusion from the site will impact heavily on the adjoining County Wildlife Site and Site of Special Scientific Interest areas. The National Planning Policy Framework at Paragraph118 states in the case of a Site of Special Scientific Interest such impacts need to be clearly outweighed by the benefits arising from the proposed development. Given the uncertainties surrounding the practical and commercial aspects of the Sundon Rail Freight Interchange concept, and the actual number of jobs arising from the B8 nature of the operations on the site, no present clarity as to the benefits of the proposed development exists. The proposal is therefore not consistent with national policy.