Site Assessment Pro Formas

Support

Representation ID: 5972

Received: 08/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

These representations have been prepared on behalf of Anwyl Land in respect of a proposed development of their land interests at Kennel Hill, Sharnbrook, as illustrated on Figure 1 below, SHLAA ID 3231. Anwyl Land are a well-respected residential land promoter, part of the Anwyl Group which includes Anwyl Homes, an award-winning house builder.

See attached document.

Support

Representation ID: 8486

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

1.1 These representations have been prepared on behalf of Anwyl Land in respect of a proposed development of their land interests at Kennel Hill, Sharnbrook, as illustrated on Figure 1 below, SHLAA ID 3231. Anwyl Land are a well-respected residential land promoter, part of the Anwyl Group which includes Anwyl Homes, an award-winning house builder.
Figure 1: Site Location Plan
1.2 The site has been previously promoted through the various stages of the adopted Local Plan and was included as a preferred site as part of the Council’s 2017 consultation paper. Technical documents to support the allocation of the site were submitted, including highways and landscape, demonstrating the sites acceptability and deliverability. Despite this however, the adopted Plan opted to defer allocations to subsequent Neighbourhood Plans, which would deliver the housing targets set out in the Local Plan. For Sharnbrook, the Local Plan allocated 500 dwellings to be delivered through the Neighbourhood Plan.
1.3 Sharnbrook is designated in the Local Plan as a Key Service Centre, which are described as settlements “which contain a good range of services and are well connected to larger town centres by regular public transport. They provide a strong service role for the local community and surrounding area”.

1.4 Sharnbrook was designated as a Neighbourhood Plan area in September 2017. Delays to Neighbourhood Plans were highlighted as a potential issue with the Council’s adopted approach and would not be supported moving forward, particularly having regard for the Housing White Paper which seems to suggest Neighbourhood Plans should focus on issues such as design and design codes, and not the allocation of land.
1.5 The Sharnbrook Neighbourhood Plan Examiner’s Report was published on the 19th July 2021. This concluded that the Plan could proceed to referendum subject to modifications, despite significant concerns relating to the deliverability of the Plan’s key allocation (Hill Farm) and limited evidence to support that the housing requirement could be met having regard for the Plan’s short period up to 2030. The allocation at Hill Farm is predicated on delivery of significant improvements to the junction at the A6, with no confirmation from County Highways that the proposed Neighbourhood Plan allocation is deliverable.
1.6 For ease of reference these representations follow the order of the policies in the Consultation Document.

Support

Representation ID: 8488

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

Land on the north side of Kennell Hill, Sharnbrook, Bedfordshire (3231)
2.19 Our clients land interests north of Kennell Hill was identified as a potential housing allocation prior to the change in approach adopted by the Council in respect of housing allocations in Key Service Centre, i.e. housing allocations to be delivered through neighbourhood plans instead of by the Council. This resulted in the allocation of a new site in Sharnbrook Parish, albeit as discussed below, not in Sharnbrook. Work undertaken by Anwyl Land to date has confirmed the Council’s position that the site is deliverable and can be brought forward without undue impacts. An illustrative masterplan is included at Figure 2 below to show how the site can be sensitively delivered.

Figure 2: Illustrative Masterplan
2.20 The Council’s Site Assessment contains a number of criteria by which sites are scored. Where we have comments these are discussed in turn below. Within or adjoining UAB SPA or built form of a small settlement
2.21 Whilst we agree that the site does not adjoin the defined SPA of Sharnbrook as defined on the Council’s policies maps, when regard is had for the built form of Sharnbrook it is clear that the site would relate well to the village of Sharnbrook. Within the existing settlement form?
2.22 The site is outside of the SPA of Sharnbrook, but does adjoin existing built form on Kennell Hill which forms part of Sharnbrook. It is therefore considered to be incorrect to state that the site is not within the existing settlement form.

At risk of flooding?
2.23 Whilst the site contains areas of flood risk, as demonstrated on the illustrative masterplan the area of the site to be developed is entirely within Flood Zone 1. The land deemed to be at risk of flooding is to the west of the site is to be used as open space with tree planting proposed. Locating development in Flood Zone 1 is required by existing planning policy and could be further secured by site specific policy criteria. The Council could also seek to exclude such an area from any allocation, given it is not necessary to deliver the site.

Support

Representation ID: 8489

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

Hill Farm, Mill Road, Sharnbrook (814)
2.24 The land at Hill Farm, Sharnbrook is the proposed allocation in the emerging Sharnbrook Neighbourhood Plan. Save for a failure to pass referendum or legal challenge, this site may become formally allocated. Despite this, it will be necessary for the Council to critically examine this site, particularly with regard to establishing a housing trajectory and informing the level of housing growth committed and thus the level of housing growth needed to be provided for through additional allocations and to ensure the distribution of housing is delivered in accordance with any eventual adopted spatial hierarchy.
2.25 In respect of the site, there are a number of factors which weigh against it and have not been fully addressed or considered as part of the development of the Neighbourhood Plan nor its Examination. It remains unclear as to whether the site is viable, having regard for significant abnormal costs relating to the relocation of the school, significant transport improvements necessary to facilitate the development (including the delivery of a new roundabout) and wider relocation of services. The relocation of the school is to us particularly problematic, in that it will move the school from the sustainable core of Sharnbrook beyond the railway line, some distance away from many existing residents. This will result in a significant increase in car journeys and many will not walk to the school in its new location due to the distance and nature of the routes needed to access it. In terms of highways improvements, it has been confirmed that a new roundabout is needed on the A6 to facilitate the increase of traffic using Templars Way. Whilst the principle of the junction has been apparently confirmed by the Highways Authority, we are yet to see any evidence that this is deliverable on highway land or land under the control of the applicant, not to mention aforementioned comments relating to viability.
2.26 The Council’s assessment notes that the site is disconnected from the SPA, it is separated by Sharnbrook by both a significant distance and the railway line (Figure 3 below). The proposed development is actually located east of Coffle End, which is in itself a named settlement within the small settlements tier. Having regard for this, it is our opinion that in a post development scenario this will not serve functionally as part of Sharnbrook, it will be its own small settlement, interconnected to Sharnbrook and Coffle End through shared services, but that development here would not satisfy the needs of Sharnbrook and visa versa. This approach would be entirely consistent with the Council’s historic decision making and previous appeals in similar scenarios. Your reference is drawn to appeal APP/K0235/W/16/3161915: Land Off Station Road, Turvey. In this appeal, the Inspector states “the appeal site would adjoin Turvey Station End and not Turvey. Both settlements are separated by open countryside. I acknowledge the public footpaths through the countryside and the footpath along Bedford Road which connect them. However, these routes are not short enough to lead me to any different conclusion other than Turvey Station End is a separate settlement to Turvey”. This is the exact same position as Sharnbrook and Sharnbrook Coffle End, and the conclusions therefore equally applicable, i.e any development at Hill Farm would not constitute development in Sharnbrook. Not applying this logic could severely muddy the waters across the Borough with significant confusion arising as to when development is or is not part of a settlement.
Figure 3: Bedford Policies Map Extract (showing Settlement Policy Area Boundary)
2.27 Despite the assertions within the Neighbourhood Plan, the proposed allocation will in fact be a new settlement in its own right, which it a post development scenario would logically have its own SPA boundary. As such, according to the Council’s own historical decision making considered alongside current and emerging planning policy, there remains a need of new dwellings to be distributed to the settlement of Sharnbrook. As such, it remains incumbent on the Council to ensure Sharnbrook receives an appropriate level of growth. Whilst we object to the principal of moving the school and highway improvements, we do concede that the ample space available east of Coffle End would enable a sizeable education facility which could cater for the needs of both the new settlement and Sharnbrook, including further residential growth within Sharnbrook, which may help facilitate the new settlement through pooled contributions to highways or traffic improvements.
2.28 What must absolutely not occur is the delivery of dwellings at Mill Farm without a suitable 106 agreement which ensures the delivery of all improvements and services set out in the Neighbourhood Plan (and otherwise might be required to ensure a suitable scheme is advanced). Prior to the commencement of any development, the application must demonstrate clearly how all services and improvements necessary to facilitate the development will be provided, including detailed evidence on viability and phasing. These are matters which are likely to frustrate and slow development.
2.29 As such, the Council should seek to deliver additional within Sharnbrook itself, to;
• Ensure the fair delivery of dwellings through the Spatial Hierarchy in accordance with adopted principles, i.e. delivery of units should occur in a manner logical with the settlement they are related. Both functionally in terms of connectivity and also in terms of perceived cohesion. It is clear that any development at Mill Farm will not feel as part of Sharnbrook itself. It is not fair on other settlements within any tier who have located development in a logical manner and it will encourage further development allocated within Neighbourhood Plans which are located in illogical locations beyond the settlement (your attention is drawn to Carlton Road, Turvey as another example, albeit not as egregious).
• Ensure sufficient delivery in the early years of the Plan period to ensure the Council can demonstrate a five-year land supply.
• Provide suitable accommodation for Sharnbrook residents who wish to move (downsizing, upsizing, moving out, improved stock, etc) within Sharnbrook itself, not a poor connected alternative beyond easy walk of many.
• Provision of additional 106 funds to fund any shortfalls highly likely to be attributed to the proposed growth east of the railway line.
2.30 It will not be appropriate for the Council to simply assume that the Mill Farm site will be delivered without issue. Whilst it may not form an allocation made within this Plan, its strategic scale requires critical examination as to likely build out rates and likelihood on the delivery of infrastructure and services. As this will have profound consequences on the people of Sharnbrook, but also the wider aims, objectives, policies and allocations of the emerging Plan, particularly if it fails to deliver, or does not deliver the required infrastructure improvements. Notwithstanding this, as already referenced, the proposed development does not itself constitute logical growth within Sharnbrook, and as such there is still a spatial gap in delivery in this key settlement which requires rectification through proper allocation in
accordance with the Plan’s own emerging principles and policies, or otherwise will be internally inconsistent.
2.31 The land north of Kennell Hill has already been assessed by the Council as appropriate, constitutes logical development for Sharnbrook close to services and facilities existent within the settlement, and can, if considered necessary, contribute to new services at Hill Farm, to which it will be much closer than the rest of Sharnbrook. The 500 dwellings attributed to Key Service Centres are for the period up to 2030 only, and as such there is likely to be further need within the settlement up to 2040, meaning further growth will likely be required in such sustainable settlements, particularly having regard for further increases in housing requirement in respect of the Oxford Cambridge Arc.
2.32 Having regard for the above, it is clear that the there is significant justification for allocations to be made within this Local Plan within Sharnbrook and that the land north of Kennell Hill is suitable and appropriate for allocation. It can deliver in the short-term and will assist in delivery in the early years of the Plan period during the lead in time for any development at Mill Farm. It will also assist in correcting the disparity in the Spatial Hierarchy by locating development which can be reasonably attributed to Sharnbrook, particularly given none is currently proposed. Failure to rectify these issues could lead to the Local Plan being found unsound, as it would not be justified, effective or consistent with national policy.