The Central Bedfordshire Council (Woodside Link Houghton Regis ...

Planning Act 2008 (as amended by the Localism Act 2011)

The Central Bedfordshire Council (Woodside Link Houghton Regis) Development Consent Order

Local Impact Report

Central Bedfordshire Council

Regulation number

Regulation 60 (3)

Pins Reference number

TR010011

Date

November 2013

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APPLICATION BY CENTRAL BEDFORDSHIRE COUNCIL FOR DEVELOPMENT CONSENT ORDER FOR THE PROPOSED WOODSIDE LINK, HOUGHTON REGIS LOCAL IMPACT REPORT PI Reference

TR010011

CONTENTS SECTION 1

INTRODUCTION

SECTION 2

SITE AND PROJECT DESCRIPTION, SURROUNDINGS AND HISTORY

SECTION 3

RELEVANT DEVELOPMENT PLAN POLICIES

SECTION 4

HIGHWAY JUSTIFICATION

SECTION 5

GEOLOGY/SOILS

SECTION 6

WATER

SECTION 7

MATERIALS

SECTION 8

CULTURAL HERITAGE

SECTION 9

ECOLOGY AND NATURE CONSERVATION

SECTION 10

LANDSCAPE

SECTION 11

COMMUNITY AND PRIVATE ASSETS

SECTION 12

AIR QUALITY

SECTION 13

NOISE AND VIBRATION

SECTION 14

EFFECTS ON ALL TRAVELLERS

SECTION 15

ECONOMIC IMPACT

SECTION 16

DEVELOPMENT CONSENT ORDER

SECTION 17

CONCLUSIONS

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1.0

INTRODUCTION

1.1

This report has been prepared by Central Bedfordshire Council (the Authority) as planning authority for the greater part of the site, in accordance with advice and requirements as set out in the Planning Act 2008, the Localism Act 2011 and Advice Note one: Local Impact Reports (version 2, April 2012, The Planning Inspectorate). Luton Borough Council (LBC) is planning authority for a small part of the site and is expected to submit a separate Local Impact Report.

1.2

The Advice Note states that a Local Impact Report is a ‘report in writing giving details of the likely impact of the proposed development on the authority’s area’.

1.3

The Advice Note states that when the Examining Authority decides to accept an application it will ask the relevant local authorities to prepare a Local Impact Report and this should be prioritised whether or not the local authority considers that the development would have a positive, negative or neutral effect on the area. The Report may include any topics that they consider to be relevant to the impact of the development on their area as a means by which their existing body of knowledge and evidence on local issues can be fully and robustly reported to the Examining Authority.

1.4

The Advice Note indicates that topics addressed in the LIR may include: • • • •

• • • • • • •

1.5

Site description and surroundings/location Details of the proposal Relevant planning history and any issues arising Relevant development plan policies, supplementary planning guidance or documents, development briefs or approved master plans and an appraisal of their relationship and relevance to the proposals. Relevant development proposals under consideration or granted permission but not commenced or completed Local area characteristics such as urban and landscape qualities and nature conservation sites Local transport patterns and issues Designated sites Socio-economic and community matters Consideration of the impact of the proposed provisions and requirements within the draft Order in respect of all of the above Development consent obligations and their impact on the local authority’s area.

The LIR may comment on the development consent obligations and the requirements and also any relevant representations.

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1.6

The LIR has been written so as to incorporate the subject areas suggested in the Advice Note (set out above), the subject areas in the Environmental Statement, and the obligations and proposed requirements submitted with the application for DCO.

1.7

The Examining Authority has issued its First Written Questions (Annex E of the R.8 letter). Where the subject matter of this LIR addresses issues raised by one of these Questions the LIR notes this by stating, in square brackets, the number of the question concerned in the form EAFQn (where n is the number of the question). The (Planning) Authority will reply separately to the Questions (see document sent with this LIR).

2.0

SITE AND PROJECT DESCRIPTION, SURROUNDINGS AND HISTORY

2.1

The proposed Woodside Link is a new highway to connect the Woodside Industrial Estate with proposed Junction 11a on the M1 motorway to the north-east. Part of it would run in a corridor between Houghton Regis and Luton built-up areas and part would initially run through arable fields but which are earmarked for development as a sustainable urban extension. At its south-western end it would connect with existing highways which serve major employment areas as well as Dunstable and Houghton Regis town centres. It would connect with other local roads serving east Dunstable and west Luton residential areas.

2.2

The proposal may be summarised as the construction of 2.9km of mainly single carriageway highway linking the C205 Poynters Road/Park Road North, where it crosses the Houghton Regis/Luton border, with the proposed Junction 11a on the M1 motorway, to be constructed between Junctions 11 and 12. The latter proposal forms a key part of the A5 to M1 link, a strategic highway programmed to be completed in 2016 (para.3.3.2 of TA). The overall plan of the principal highway would form a handed letter ‘L’ with a single carriageway (the ‘southern arm’) running east from an upgraded Porz Avenue roundabout on the C205 to a new roundabout. It would then turn 90 degrees to run due north (the ‘northern arm’) to a roundabout from which the 0.45km ‘Sundon Link’ dual carriageway would run north-west to a further roundabout on the C198. The main highway would continue north as a dual carriageway for the short distance to the western ‘dumbell’ roundabout at Jn.11a. Chalton Cross Farm would be partly demolished leaving the farmhouse and a farm building on opposite sides of the road. In addition, there would be short links from the principal highway to both Wheatfield Road, Luton and Parkside Drive, Houghton Regis, serving Lewsey Farm estate and Parkside estate respectively.

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2.3

The road would be elevated on an embankment in the central part of the southern arm and southern part of the northern arm in order to clear the Houghton Brook and cycleway and to be above flood levels. The elevated part of the southern arm would have 2m high acoustic fences along both sides but other fencing would be provided towards the western end of the southern arm. Drainage of the road would generally be to parallel swales thence to small attenuation ponds in the adjacent open space and onwards to the brook.

2.4

The boundary between Central Bedfordshire and Luton Borough is significant to the southern arm of the highway. Although the built up areas of Luton, Houghton Regis and Dunstable appear to form a single urban area there is a wedge of undeveloped land, broadening to the east, through which the southern arm runs. This wedge is mainly within Central Bedfordshire with the Luton boundary running along the southern edge with residential development extending up to this boundary. However, part of the road as it approaches the C205 Poynters Road roundabout straddles the boundary and thus part is within Luton Borough. The linear open space beside Houghton Brook, with a new foot/cycleway, also extends slightly into Luton Borough at the eastern end of Kestrel Way. Despite this open space being designated on the Local Plan for enhancements (see 3.8 below) the land itself is not used actively or maintained.

2.5

The National Cycle Network (route NCR6 from St Albans to Milton Keynes) crosses the site, taking a course through Parkside estate and crossing the site of the new road at Parkside Drive where it then assumes a route parallel with Kestrel Way before passing under the M1 towards Hockwell Ring estate. A separated track would have to be provided alongside the re-opened Parkside Drive extension before running alongside the Link which it would then cross by a toucan crossing opposite Pastures Way. An alternative foot / cycle route would be provided alongside Houghton Brook east of this crossing replacing FP8. The formal foot / cycle path from Frogmore Road to Wheatfield Road, near the surgery, would be provided with a toucan crossing. Two further links between Sandringham Drive and Wheatfield Road would be made and have two additional toucan crossing facilities. Most public footpaths near to or crossing the site are discontinuous. Discontinuous FP8 (which is usually ploughed up) could be diverted as indicated above. Discontinuous FPA17 does not exist on the ground but most of it is parallel to an informal path crossing an area of rough ground; it would be stopped up. Discontinuous FP7 tends to be parallel with farm tracks and would be ‘diverted’ to run alongside the northern arm. FP6 would be diverted to run alongside the Sundon Link but it appears that road walking would be necessary to reconnect with its onward route to the north (Environmental Statement para. 2.6.25). Farm and other tracks on the arable land are used for recreational walking and dog walking (4.3 Ecological appraisal), understandably in preference to the discontinuous designated footpaths.

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2.6

New foot / cycle routes (other than as above) would be created either side of the Link, especially those parts presently shown crossing farmland. A final toucan crossing would be located half way along the northern arm (Ch1970). However, this is referred to as an uncontrolled crossing at ES 2.6.26 because lights would not be needed until pedestrian traffic increases with adjacent development. It is assumed that developers of adjacent land would install the toucan crossing at the appropriate time. This is addressed at 14.5 below.

2.7

Other works contained within the proposal include diverting the Houghton Brook (a headwater of the River Lea), excavating attenuation ponds, replacing agricultural accesses, landscaping, underbridges, street lighting throughout, borrow pit (94,000m3 – ES Table 2A.1) and works to adjacent connecting highways. Most of the landscaping is either side of the new highway works, but this includes the whole of the ‘wedge’ not otherwise occupied by highways and a large, approximately triangular, tract of land between the northern arm and the M1 motorway just north of Houghton Brook (centred on the borrow pit). Other tracts of land, such as that between the Link and Kestrel Way and most of the land north of the southern roundabout, would remain arable for the purposes of this application; this includes 3 small parcels surrounded by existing and proposed highways. Para 4.5.2 of the TA states that additional land would be allocated to permit widening ‘north’ of Parkside Drive.

2.8

The construction compound would be situated near Sundon Road (ES 2.7.4), close to the site of the A5-M1 road, a substantial distance from all but 2 isolated dwellings. However, Figure 10.5 of the ES also indicates a compound near the intermediate roundabout, although still several hundred metres from the nearest housing. Access to the works would be along the alignment except for the southern end where access would be taken from the adjacent highway network. It is not stated where the eastern construction compound would be for the A5 – M1 road.

2.9

The site is generally level but with a slight rise to the north away from Houghton Brook, which runs west – east. The western end of Wheatfield Road, Luton, which runs parallel with the southern arm of the proposed road and roughly marks the edge of Lewsey Farm estate, is on slightly higher land which overlooks the site. The southern arm runs through fairly dense scrub/young trees and rough grassland while the northern arm runs through an open intensively farmed agricultural landscape. However, 3 high voltage electricity lines (33, 132 and 440 kV) run through the site on steel towers, broadly parallel with the proposed road, with a fourth (132 kV) line parallel with the motorway. The southern pylons of the 132 kV line through the site would be removed and the line diverted underground, to re-appear midway along the northern arm (at least for the time being, given the roll-out of HRN1 – see 2.11 below). The 33 kV line on steel towers across arable land would be diverted underground throughout. Generally, the site is not

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near designated sites of ecological interest although it crosses the floodplain of the Houghton Brook in 2 places. The whole of the site, except for those parts within Luton Borough and the southwesternmost end west of Windsor Drive, is within the South Bedfordshire Green Belt. This designation includes proposed Junction 11a and the proposed sustainable urban extension (see below). 2.10

Under planning permissions two significant residential developments have recently been completed adjacent to the site. A development of about 200 houses and flats off Sandringham Drive, Parkside estate, abuts the proposed landscaped area towards western end of the road, and much of the remaining strip of undeveloped land between Kestrel Way, Lewsey Farm, and the LBC boundary has been developed for houses and flats.

2.11

Most significant of all recent planning application decisions is the resolution of Central Bedfordshire Council on 4th September 2013 to grant planning permission for a sustainable urban extension covering the whole area north and east of Houghton Regis but defined on its outer boundary by the route of the M1 and the proposed A5-M1 link as previously described. The application (ref: CB/12/03613/OUT) follows the approval, for development management purposes, of the ‘Houghton Regis (North) Framework Plan’. This proposal would broadly include up to 5,150 dwellings and up to 202,500 m2 gross additional development in a variety of classes. It is part of a larger sustainable urban extension extending further west and known as Houghton Regis North Strategic Allocation; this part is referenced HRN1. At the time of writing this LIR the application was about to be submitted to the Secretary of State and, if not called-in by him, planning permission will be issued subject to appropriate conditions and the completion of a S106 Agreement. Although the Woodside Link is shown in the documentation of this application, and forms an essential part of that scheme, it would not form part of that permission. A clause in the S106 Agreement would require that no more than 825 dwellings be occupied prior to the Woodside Link being completed. This would reflect the consideration that existing local roads alone could cope with the initial phases of development, after taking into account other developments coming on-stream within the local urban areas.

2.12

It should be noted that, although this planning application covers the greater part of HRN1, a substantial strip of land lies between the application site boundary and the eastern edge of Parkside estate and is thus not included in the application. This land is within the Framework Plan but is yet to be progressed to the stage of a planning application. The Framework Plan assumes that this land would be serviced from the HRN1 application site and the illustrative masterplan accompanying the application appears to provide for this likelihood. For the avoidance of doubt, the term ‘HRN1’ in this LIR will refer to the application development.

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2.13

Throughout this application and LIR there is a fundamental issue to be addressed: the contrast in environmental impacts between the baseline position, the completion of the A5 – M1 road and Woodside Link, and the eventual planned filling up of the rural part of the route with development from the urban extension. Whereas it is often said in the ES that adverse impacts of the road will only last until the housing is built, the lifetime of the planning permission would be at least until 2031. Thus ‘temporary’ impacts could last up to 10 or even 15 years from completion of the road.

3.0

RELEVANT DEVELOPMENT PLAN POLICIES

3.1

The Development Plan for Central Bedfordshire in the vicinity of the site comprises saved policies of the South Bedfordshire Local Plan Review 2004 (SBLPR) and of the Bedfordshire and Luton Minerals and Waste Local Plan 2005 (MWLP). The East of England Plan, Milton Keynes and South Midland Sub Regional Strategy and the Bedfordshire Structure Plan 2011 were revoked by Order with effect from 3rd January 2013.

3.2

In line with paragraph 216 of the National Planning Policy Framework (NPPF) weight can be given to emerging documents. The Development Strategy for Central Bedfordshire – Pre Submission 2013 agreed by Full Council on 29th November and publicised for a 6-week period from January 2013. Although in the process of being further revised to take account of recent ONS information and advice, when it will be submitted to the Secretary of State, this Development Strategy is nevertheless more up to date, is consistent with the NPPF, and the policy provisions now reflect the boundary of the Local Planning Authority’s area. The document may be found on the CBC website. An assessment of its pre-amendment policies alongside the scheme is provided and a statement of the scheme’s compliance will be presented in the Written Representations; a summary appears below. The Minerals and Waste Local Plan 2005 has also been through a process of updating which is now advanced, having passed through the examination for soundness, and the inspector’s report is imminent. An update on the position will be given at the NSIP examination. [EAQ5(i)]

3.3

The Luton and South Bedfordshire Joint Core Strategy (submitted in March 2011 and withdrawn from Examination in July 2011) was endorsed for Development Management purposes by CBC’s Executive in August 2011. While this document still has some relevance, in most cases the weight that would be attached to it would be less than that which would be attached to The development Strategy. Nevertheless this document identified potential strategic housing and employment sites and its Chapter 4 (Infrastructure and Delivery) defined the types and levels of infrastructure required to accommodate planned growth. The Woodside Link was listed as being a critical transport infrastructure

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project ie. Identified as being of the highest level of land and infrastructure that must happen to enable physical development. This point was also recognised (albeit referring to the nearby Grade Separation of M1 Junction 10a Luton in the same list) in the Examining Authority Report to the Secretary of State for Transport in the recent decision to make a DCO on that scheme (PI ref: TR010009). 3.4

The only relevant SPDs within Central Bedfordshire affecting this site are Design in Central Bedfordshire SPD, currently subject to review, and Managing Waste in new developments SPD 2006, also subject to review alongside the emerging Minerals and Waste Local Plan: Strategic sites and policies. The sustainable urban extension of which the recent planning application is part (HRN1) has been guided by a Framework Plan. Town Centre Masterplans have been approved for Houghton Regis and Dunstable.

3.5

South Bedfordshire Local Plan Review 2004 – saved policies NE10 – Use of agricultural land for other purposes – criteria include loss of versatile agricultural land, Green Belt and rural landscape character; BE8 – Design considerations – a general requirement for high quality new development; R3 – Proposed areas of new urban open space in Houghton Regis – designates the wedge between Lewsey Farm estate and Parkside estate for enhancement and appropriate management of existing open area for a mix of formal and informal recreation in accordance with detailed proposals to be drawn up by the planning authority; R14, 15 – Access to informal countryside recreation and public rights of way – for walkers, horse riders, cyclists especially close to urban areas

3.6

Bedfordshire and Luton Minerals and Waste Local Plan 2005 – saved policies M8 – Borrow pits – considers convenience of site to project to be supplied, satisfactory restoration and environmental benefit; W5 – Management of wastes at source – seeks waste audit as part of application to minimise and manage waste; Appraisal of compliance in respect of Local Plans

3.7

Soils within the site are DEFRA category 2 and 3a which are good quality. The proposal would result in the irreversible loss of this land and this would be at variance with Policy NE10. Soils removed would

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be re-used on banks or would be available for other purposes. The ES associates this with slight adverse impact. Until the sustainable urban extension is underway the remaining arable land would remain in use or be returned to this use as soon as no longer required for temporary purposes in connection with this proposal. It is a highly material consideration that the whole of this landscape is, through the resolution to grant planning permission, earmarked for development with the consequential loss of quality agricultural land. 3.8

In respect of landscape impacts, these would need to be seen in the context of an engineering operation which has uncompromising physical characteristics and considerable benefits in other subject areas.

3.9

The planning permission for residential development off Sandringham Drive included provision for management of part of the Policy R3 area. The instant proposal continues to offer opportunity to manage most of this area for public access with the benefit that it would now be connected to a far longer green corridor to the east.

3.10

Access for walkers and cyclists would be safeguarded and enhanced in many ways. The design has been the subject of consultation with local cycling groups to accommodate the improvements that they as users would desire. While the diverted NCR6 crosses the main highway through an underpass, in order to minimise superelevation it has been found necessary for other links to cross the proposed highway on the level using toucan crossings. While this is not optimal, it reflects a balance of issues.

3.11

The borrow pit would be located conveniently for construction and would beneficially be restored as a wildflower meadow. There is support for the principle of borrow pits provided they fulfil the criteria set out including demonstration of an overall environmental benefit. A Site Waste Management Plan would be produced. Land raising to support the new highways would benefit the proposal by reducing flood risk for the road.

3.12

It is therefore considered that the proposal is substantially in accordance with the adopted development plans in force for area covered by the proposal although there remain issues in the interim of landscape and noise.

3.13

This LIR is not required to detail the relevance of the National Planning Policy Framework, as it is not part of the development plan.

3.14

Development Strategy for Central Bedfordshire – Pre-Submission 2013 1 – Presumption in favour of sustainable development – reflecting the NPPF position;

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3 – Location of Green Belt – covers site within CB; 6 – Employment land – relates to a key benefit claimed by the proposal, access to existing and proposed employment areas; 14 – Dunstable Town Centre – relates to a key benefit claimed by the proposal, access to the retail and historic core of the town; 16 – Houghton Regis Town Centre – relates to a key benefit claimed by the proposal, access to the retail and historic core of the town; 22 – Leisure and open space provision – the proposal would include substantial areas of new open space and green infrastructure – where open space is lost (near Sandringham Drive) replacement open space of equal size and quality is proposed to the north-east; 23 – Public rights of way – restoring and re-connecting; 25 – Capacity of network – seeking to deliver strategic transport schemes in the LTP of which this is one; 29 – Housing provision – refers to the Houghton Regis sustainable urban extension within which this road would be located and which it would partly serve; 36 – Development in the Green Belt – does not mention the exception for local transport schemes found in the NPPF; 43 – High quality development – delivering the highest possible quality of new development including amenity of surrounding properties, landscape and heritage assets; 44 – Protection from environmental pollution – noise, vibration, light, water, contaminated land, airborne require measures to satisfactorily minimise impacts; 45 – Historic environment – significance of heritage assets and requiring highest quality of design with appropriate mitigation; 48 – Adaptation – ensuring development is resilient and adaptable to climate change through trees, landscaping and SUDs; 49 – Mitigating Flood risk; 50 – Development in the countryside – maintain and enhance intrinsic value having regard to biodiversity, landscape, ecology, accessibility and agricultural value;

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56 – Green infrastructure – linked open spaces, quality GI not being fragmented; 57 – Biodiversity and geodiversity – enhancing habitats, restoring fragmentation, protected species; 58 – Landscape – conserved in accordance with Landscape Character Assessments; 59 – Woodlands, trees, hedgerows – protected from loss and damage, promoting new tree cover to enhance and provide cooling effect. 60 – Houghton Regis North Strategic Allocation – part of the major section supporting the principal policy and which sets the start date for the Woodside Connection (sic) at 2016.

3.15

Minerals and Waste Local Plan: Strategic Sites and Policies, 2012 with Proposed Modifications April 2013 WSP6 – Catchment area restrictions - provides for disposal and capacity for waste which arises from within the Plan area; WSP7 – Including waste management in new built developments – a high standard of mitigation of environmental impacts including climate change and appropriate waste storage and recovery; WSP8 – Non-hazardous waste transfer and materials recovery; MSP9 – Borrow Pits – convenient and specific to site and to be restored to provide a net environmental benefit. Appraisal of compliance

3.16

This would be sustainable development and a project to be delivered through the LTP. It is within the Green Belt but the reference to local transport schemes has not been included in the description of development which may be appropriate in the Green Belt. The proposal could fairly be described as requiring a Green Belt location (NPPF par.90). However, it is more properly considered as a key part of the Houghton Regis North 1 Strategic allocation which is proposed in this Development Strategy and which would roll back the Green Belt. The impact of the road would be mitigated to a degree but insofar as it would need to provide a satisfactorily relationship with the adjacent existing and new urban areas. The impacts would need to be seen in the context of an engineering operation which has some uncompromising physical characteristics and considerable benefits in other subject areas, especially regenerating employment areas and town centres.

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3.17

Local cycling and foot traffic linkages would be adequately accommodated. Cultural heritage and water management are considered satisfied subject to the ‘Requirements’.

3.18 Protection from environmental pollution is satisfactory. The Requirements would accommodate ecological mitigation. 3.19

In respect of the borrow pit there would be an overall environmental benefit after restoration and preparation for its new use. The provision for amendment of the agreed restoration plan should the original quantity of excavated material not be needed would ensure that this emerging policy is complied with.

4.0

HIGHWAY JUSTIFICATION

4.1

The Woodside Link has as its primary aim providing a convenient route from the primary road network to the industrial and commercial development around Woodside Industrial Estate, Dunstable and to provide traffic relief for Houghton Regis and Dunstable town centres. Its secondary aim is to provide the critical infrastructure to support the urban extension north and east of Houghton Regis (TA 1.1).

4.2

Its delivery is related to the completion of the proposed A5 to M1 road and the new Junction 11a to the M1 motorway to which it is linked at the northern end. Although it would be theoretically feasible to construct parts of the Woodside Link in its entirety without the A5 to M1 road, there would be no Jn.11a to connect to and it would be quite unacceptable to off-load traffic onto C-class Sundon Road. Furthermore, the Link would then be incapable of properly serving new development at Houghton Regis North 1. Its consideration alongside a delivered A5-M1 link is therefore essential.

4.3

The existing road network is anchored by the M1 motorway and the A5 trunk road, the latter passing through the centre of Dunstable and carrying a proportion of traffic which cannot use or simply prefers to avoid the M1. When there is congestion on the M1 the A5 is an official and often unofficial diversionary route, including the A505 through east Dunstable connecting with Junction 11. Recently completed widening of the M1 south of Jn10 and hard-shoulder running works north of that junction are expected to improve the capacity and flow of the motorway and reduce the frequency of diversions. The A505 is a fragmented west-east route which takes a direct course west of the A5 and again east of Luton; but in between it appears in part as the inter-urban road between Dunstable and Luton. These towns are well known for their traffic congestion, not only at peak hours, and Houghton Regis was often choked with Luton traffic trying to avoid Dunstable conflicting with Dunstable traffic trying to avoid Luton. Recent traffic calming works at

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Houghton Regis are now settling down but revealing traffic surveys are yet to be conducted. In consequence, commercial, retail and domestic journeys in the urban areas are frustrated by congestion well beyond peak periods. Commercial traffic contributes significantly to this situation. 4.4

Roads in Dunstable and Houghton Regis which are most congested at peak times are: • High Street / The Green HR (A5120/C198) • Bedford Road HR (A5120) • Park Road North HR (C205) • Watling Street / High Street North / High Street South D (A5) • Church Street and Luton Road gyratory D (A505) (although this is a new system which is yet to be surveyed) • West Street D (B489) • Poynters Road and junction with Luton Road D (C205/A505) • Sundon Road / Toddington Road junctions (C198/B579).

4.5

Following review of options the final route proposed for the Woodside Link would now offer a relatively direct limited access road from the M1 to the main commercial core of Dunstable (the Woodside and Woodside Park Estates) and the town centre, with traffic transferring from the Link to the relatively high capacity highway layout through Woodside Estate. Access could also be gained to Houghton Regis town centre and the western part of Luton. Such traffic would presently pass from Jn12 through the centres of Houghton Regis or from Jn11 along A505 Luton Road, which is subject to a 30mph speed limit. With the completion of the A5-M1 link and the de-trunking of the A5 (with associated calming works) commercial traffic especially, travelling south along the A5, would be diverted to the M1 or, if destined for central Dunstable, then take the Woodside Link, also relieving Houghton Regis (The proposed weight restrictions in para.9.2.1 of the TA enforce this). The ‘Sundon Link’ (3.3.15 TA) would also remove some local traffic from Houghton Regis town centre.

4.6

The Framework Plan for North Houghton Regis 1 shows that, not only would the Woodside Link provide more direct access to Parkside estate and Wheatfield Road but form the essential access to the extensive employment and retail area of the proposed urban extension as well as approximately a thousand dwellings. It would also provide the final link between the remaining 4000 dwellings and this employment area. Finally, it would connect most of the urban extension with the M1 (see also 15.4 below).

4.7

Trip generation has taken into account the HRN1 assessment to provide an agreed basis (2.3.4 TA) and a full development scenario assumes completion of HRN1. An opening year of 2016 has been adopted (to coincide with the A5-M1 link) and the Design Year is 2031. The scheme has been modelled both with and without the road serving

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Parkside Drive as the TA acknowledges that this is controversial (3.3.9). 4.8

Summary tables 2 and 3 of the TA indicates that, with full development at HRN1, Park Road North and Sundon Road into Houghton Regis are the main beneficiaries, with High Street and Poynters Road also benefitting markedly. It should be noted that the ‘adverse’ labels in Table 4 are inevitable on the completion of HRN1. Traffic on the first two roads presently adds to the congestion in Houghton Regis town centre. Sandringham Drive also benefits as it is presently a ‘rat-run’ from Sundon Road to Poynters Road / Porz Avenue despite being a residential distributor road. There is relatively little change to traffic volumes on central Dunstable roads. It will be important to appropriately sign the new road to direct heavy traffic from the NE destined for Houghton Regis town centre along the full length of the new road rather than taking a short cut up Sundon Link and along Sundon Road. It is not known if a heavy lorry ban has been considered on Sundon Road. The Town Council have rightly noted this as well.

4.9

Roads which would experience increased volumes in 2016 with the Link (ie. before development of HRN1) would be the eastern approaches to Jn.11a viz. B579 and Sundon Road Chalton. The latter road will experience greater volumes as it provides a better link with the M1 for traffic from Barton and the north Luton industrial estates than the existing junctions 11 and 12. It is a rather winding lane but already in popular use as a link between Houghton Regis, Sundon Park estate and the A6 at Barton. The impact of extra traffic, especially HGVs, will need to be assessed on the very tight ‘S’ bend to the east of the railway bridge and the performance of the junction with Sundon Park Road. There would be adverse impact on the performance of this road if alterations were left until a future M1 to A6 link is provided (4.8.4, 5.6.5 TA). (Incidentally, the first sentence on 5.6.6 only makes sense if it reads “…blocks eastbound traffic on Sundon Park Road,…”). While it is recognised that it would not be desirable for other reasons to make the route from Sundon Park estate to Jn.11a more attractive than the route to Jn.11, further consideration should be given to the ‘S’ bend as it has the potential to cause significant conflict between larger vehicles. This does not appear to have the same attention as the Sundon Park Road junction (TA 9.2.3 and 4). It is agreed that the junction itself should be reviewed in due course. [EAQ12(iii)]

4.10

No figures are provided of the existing traffic flows along Parkside Drive with which to compare figures in Table 9 of the TA. It is clear that increased traffic on this road as a consequence of the new connection with the Link would pass through a residential area, impacting on the dwellings nearest Parkside Drive although this could be balanced by a greater number of travel options for residents of the estate.

4.11

The Authority has not received ‘internal’ technical advice on the subject of highway design.

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5.0

GEOLOGY / SOILS

5.1

A phase II intrusive investigation has yet to be done at Chalton Cross Farm, where there could be contamination (ES 5.3.18). This would not be expected to be unremediable.

5.2

Excavations would be checked for geological exposures of scientific interest. Otherwise no adverse impacts are likely.

5.3

There would be a loss of agricultural production on high quality soils (Grade 2 at the northern end of the site and 3A at the middle part of the site) although this would be partly remediated by local re-use of soil. The borrow pit is not given a grade in the Agricultural Land Quality and Farming Circumstances document (technical appendix 11.1) but appears to be on Grade 3A land. It would be useful to know if the recovered topsoil here would be re-used in the restoration. A new Requirement is suggested. The context of planning proposals for major urban development on similar land locally is significant.

6.0

WATER

6.1

Figure 6.1 of the ES indicates that the Houghton Brook is a designated surface water course which flows through two areas of Floodzone 2 (