‘Objection’ representations by Sundon Parish Council
This representation considers the soundness of the Council’s Local Plan and its compliance with the National Planning Policy Framework. Objections to aspects of the plan following this summary are discussed holistically, and cover together with supporting evidence and reasoning; plan making, housing, employment, transport, environment, and sustainability. The following are the key points of this representation:
- The reasoning underpinning the choice of the Council’s priorities is not included in the Local Plan.
- Plan making does not involve Luton Council in the co production of the Local Plan in a manner the National Planning Policy Framework says it should.
- The Local Plan’s declared priority is “Maximising employment opportunities and delivering housing growth to meet the needs of our community.” The Local Plan says 50% of new homes are for migrants and is therefore contrary to this priority.
- The Local Plan exacerbates the problem of long term vacant homes.
- The Local Plan delivers at least 5% less affordable housing than Luton residents’ need and makes it less likely the affordable housing needs of Central Bedfordshire residents will be met.
- The Local Plan does not account for changing preferences for rented tenure. Currently 86% of new households are private or social renters.
- The Local Plan does not propose a contingent employment use for Sundon Rail Freight Interchange on the imminent approval of competing provision near St Albans putting 2 300 jobs at risk.
- The Local Plan is misleading because most alternative road transport options are included for the sake of having options rather than because they are likely to be delivered.
- The Local Plan increases road congestion to unstable levels and does not account for the effect on traffic in South Central Bedfordshire because of the proposed expansion of London Luton Airport.
- The Local Plan does not fulfil a National Planning Policy Framework criterion for the removal of land from the Green Belt and negatively impacts the Chilterns Area of Outstanding Natural Beauty.
- The authenticity of the Local Plan’s Sustainability Appraisal is questionable. There is no evidence that anyone independent of the Council was involved with the appraisal of options to counter inevitable bias when scoring options. The ‘Do Nothing’ option is entirely unrealistic.
The Council’s chosen planning option is unsustainable because it uses Green Belt needlessly and negatively impacts on an Area of Outstanding Natural Beauty, increases commuting outside the area to work, increases journey times by 40% and congestion to unstable levels, increases carbon emissions and pollutants, and reduces quality of life. It does not comply with National Planning Policy Framework sustainability requirements.
The Council’s Local Plan explains the need for a core strategy by referring to the work of a Local Strategic Partnership called Bedfordshire Together. The work of the partnership results in two documents published in July 2010; a Sustainable Community Strategy and its evidence base. The strategy contains priorities for Sustainable Communities and the evidence base underpins the choice of priorities. These documents were not included in this consultation or consultation on the draft Local Plan. This is a significant omission as they explain why the Local Plan is needed. Section 2.0 of the Local Plan gives clues to why it is needed by setting out undesirable characteristics of Central Bedfordshire’s current profile. These are deprivation, unemployment, and excessive commuting outside the area to work. However, neither Section 2.0 nor the Sustainable Community Strategy explains why the Council is planning to encourage excessive migration into Central Bedfordshire. As well the Council give no explanation of how the plan will reduce deprivation, commuting, and unemployment specifically amongst Central Bedfordshire residents.
The Localism Act places an obligation on Local Authorities to work together. Paragraphs 178-181 of the National Planning Policy Framework give further guidance on ‘planning strategically across local boundaries’, and highlight the importance of joint working to meet development requirements that cannot be wholly met within a single local planning area. A priority of the Local Plan is the delivery of homes for Luton residents. The Local Plan presents no evidence that the Council has worked with Luton to produce the Local Plan. Local Plan documents relating to housing show the Council have considered statistical data pertinent to Luton’s population but it has not included significant future Luton development in its transport impact assessment. Because the Local Plan has not been co produced as the National Planning Policy Framework intends it should, it does not comply with it. The production of Local Plan does not comply with usual public consultation processes because Luton residents have not had the opportunity to comment on the effects the Local Plan will have on them.
A priority of the Council’s Sustainable Community Strategy is “Maximising employment opportunities and delivering housing growth to meet the needs of our community.” The Local Plan’s strategic objective of delivering 25 100 homes, Scenario C; Housing Technical Paper January 2013, exceeds the housing required to achieve this priority as the paper’s Scenario B says, 13 800 homes would meet the housing of needs of Central Bedfordshire residents. The Council’s chosen Scenario C, forecasts a 43 300 net change in population growth. This figure includes population growth resulting from Scenario B plus migration into Central Bedfordshire from places predominately located between North London and Luton. This additional migration accounts for 45% of the total number of homes the Council intends to provide. Another 3 600 homes are required to support the housing needs of Luton adding these to the homes required to deliver Scenario C means 50% of planned homes are intended for migrants. This level of housing growth specifically to meet the needs of migrants does not align with the above priority. The Local Plan is unsound because resources, in particular Green Belt land, will be used to provide homes not required by the people of Central Bedfordshire.
The number of homes required by a population is calculated by adding 3.8% to the number of households which in turn has been calculated from anticipated population growth. The figure of 3.8% comes from the National Census 2011 (Office for National Statistics) and is the proportion of the total number of homes that are either long term vacant homes, or transitionally vacant homes. Homes waiting to be sold or rented are an example of transitionally vacant homes. The calculation to account for these two types of vacant home results, in the case of the Council’s chosen scenario, in a requirement for an additional 4 300 homes. Because the calculation is in part based on current long term vacant property a proportion of these additional new homes will perpetuate the current number of vacant homes. The Council plans to deliver more homes than needed because some of its existing housing stock is vacant! The Local Plan is unsound because it uses resources to deliver new homes that will exacerbate the problem of long term vacant homes.
Considering the calculation required to convert increases in population to increases in households. According to the Housing Technical Paper the average household size for the population increases forecast in Scenarios A, B and C is approximately 1.8 persons per household. Recent statistics say the total number of usual Central Bedfordshire residents is 254 300 and the number of households is 104 300; National Census 2011 (Office for National Statistics). According to these statistics the average household size is 2.4 persons per household. If this figure was applied to Scenario B and the 3.8% figure to account for vacant homes were not, the number of homes required to meet the needs of Central Bedfordshire’s growing population reduces from 13 800 to 9 600. The Local Plan is unsound because the Council provide no evidence to support their figure of 1.8 persons per household. As a consequence their calculation of the number of households, irrespective of their chosen scenario, results in a requirement for more homes than people of Central Bedfordshire need.
Central Bedfordshire Council plan to supply affordable and market homes based upon the needs of residents. The Luton and Central Bedfordshire Sub-region Strategic Housing Market Assessment (SHMA) Update 2012 addresses the issue of affordable and market homes. In the case of affordable homes; Figure 42, page 38 of the assessment report shows the proportions of affordable homes required by Luton. The base proportion of affordable housing meeting Luton residents’ need over the planning period remains unchanged at 35% but could rise to 75% if houses prices rise 10% above their 2011 levels. Central Bedfordshire Council’s Affordable Housing Policy 34 page 81 of the Local Plan; says 30% of homes should be affordable. This coupled with developers’ currently asking to phase in this Section 106 agreement means meeting Luton’s need for affordable housing is jeopardised and makes it more difficult to meet Central Bedfordshire residents’ need for it. Currently there are 3 200 Central Bedfordshire households on the Council’s housing waiting list. Not considered in the Local Plan is the demand for affordable housing arising from the effect of benefits capping starting in April 2013. This will result in changes in population due to households moving to lower rent areas to ensure their total benefit claim remains within the cap. Considering market housing, the Local Plan does not account for changes in demand for market housing due to current trends in housing tenure of recent movers. Nationally in 2011, 86% of new households were private or social renters the remainder were owner occupiers; English Housing Survey Report 2010-2011 (Department for Communities and Local Government). The Local Plan is unsound because it falls 5% short of providing the affordable housing Luton residents need. It does not deliver enough social housing to accommodate Central Bedfordshire residents, or for the increasing need for affordable housing arising from benefits capping. The Local Plan does not provide a mix of tenures to cater for reducing demand for owner occupied homes.
The Employment and Economic Study – Stage 2 Final Report August 2012, identifies future increases in warehousing capacity as making a significant contribution to the Council achieving its aspiration of 27 000 jobs for Central Bedfordshire. Although the report on the study says the delivery of 20 000 jobs is more realistic as this level of employment has been derived from economic modelling undertaken for the study. Along with locations in Central Bedfordshire the report identifies areas surrounding St Albans and Milton Keynes where warehousing would create employment. There are other possible land allocations in Central Bedfordshire with similar employment potential however those with the highest potential identified using ‘suitability scores’, are those allocations where developers have expressed their interest in providing warehousing. This convergence of availability of employment land and developer interest in it has led the Council to allocate land North of Luton for the development of Sundon Rail Freight Interchange. Given the significant weight, 25% when applying ‘suitability scores’, developer interest plays in aiding the selection of sites, the employment potential of Sundon Rail Freight Interchange is probably in jeopardy upon granting planning permission for a Rail Freight Interchange near St Albans because the selection of a competing location reduces the development potential of sites like Sundon. The Local Plan is unsound because it does not propose a contingent employment use for the Rail Freight Interchange site that has similar employment potential, currently estimated as 2 300 jobs, in the likely event Radlett is approved during February 2013.
The report on the impact of the Local Plan on transport called; The Assessment and Analysis of Development Plan Options – Stage 2 December 2012, assesses the effects of changes on the road network due to increasing housing and employment. The report considers 5 alternative transport scenarios against a base scenario to help the selection of the scenario with the least impact. The report is complex and therefore potentially misleading as 4 of the 5 alternative scenarios are not realistic because the Local Plan is based on the delivery of housing and employment pertinent to Transport Scenario 1. So although Scenario 1 is judged as the best scenario relative to Transport Scenarios 2, 3, 4 and 5 it is clearly worse than Scenario 0. Analysis of the forecast data for 2031 indicates Volume/Capacity (VC) ratios for Scenario 1 road schemes relative to Scenario 0. These show significant increases in congestion (VC ratio ≥ 0.95) on more roads than Scenario 0. All the proposed new roads, in particular the M1 A6 Link, will be critically congested and journey times will increase by 40%. The study explains the effects of South Central Bedfordshire development on Luton roads but does not report on the effects of future development in Luton, for example, London Luton Airport, Barnfield and Butely Road. The Local Plan is unsound because its outcomes significantly increase congestion and journey times, and because it does not account for increases in traffic due to future developments in Luton.
The development at North Luton is on Green Belt land and will have a negative impact on the Chilterns Area of Outstanding Natural Beauty. The circumstances requiring removal of land from the Green Belt are qualified in Section 83 of the National Planning Policy Framework; it says ‘Green Belt boundaries should only be altered in exceptional circumstances through the preparation or review of the Local Plan’. In the document Green Belt Technical Note January 2013 the declared circumstances necessary for altering the boundary of Green Belt land are unexceptional. The Council’s reasoning is housing and employment can not be located anywhere else other than in North Luton. The Council’s reason for co locating employment and housing is sustainability. If this claim was entirely true a further advantage of co locating these developments would be that they could be placed anywhere in Central Bedfordshire without impairing their sustainable qualities. Nationally the vast majority of employment and housing developments are not on land previously designated as Green Belt. The Council have chosen to locate unneeded development on Green Belt land and to adversely impact the Chilterns Area of Outstanding Natural Beauty when it could have located it at other places in Central Bedfordshire. The Local Plan does not comply with the National Planning Policy Framework nor does it maintain the Green Belt, as the Coalition Agreement for Government 2010 and its in 2012 update says it should.
A commonly shared notion of sustainability is resources should be used sparingly. Any planned use of resources should be commensurate with need otherwise capital, materials, environmental assets and our health will diminish at an unsustainable rate. The Local Plan allocates large swathes of Green Belt land for the delivery of 50% more homes than Central Bedfordshire residents’ need. This use of Central Bedfordshire Green Belt land is unsustainable. As 70% of planned new homes will be for owner occupiers only those households with unsupported job incomes can afford them. As the vast majority of owner occupiers will have jobs these households will be commuting to where their jobs are located and not to the employment areas the Council allocates in the Local Plan. This level of commuting and other traffic movements is forecast to increase journey times by 40%. This will result in much of the current and proposed new road infrastructure, particularly new link roads North of Houghton Regis and Luton, being filled beyond their capacity and causing congestion to rise to unstable levels. This increasing traffic and associated increases in carbon emissions and pollutants will reduce the quality of life for residents. The Local Plan does not comply with sustainable criteria set out in the National Planning Policy Framework.