Comment

Representation ID: 10074

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Please refer to the representations contained in attached the document “195345 - LP2040 Statement of Representations DS2S_DS3S_DS5S” prepared by Phillips Planning Services Ltd.

The representation contains our clients’ responses to policies DS2(S), DS3(S) and DS5(S) in respect of their interests in Land west of the village of Great Barford south of the A421 – site ID 878.

The statement has been compiled to follow the Council’s desired format.

In our opinion, the Council’s proposed Spatial Strategy, as defined under Policy DS2(S) is undermined by the risks we have identified in the Stepped Trajectory
set out in Policy DS3(S). We wish to raise concerns that the Spatial Strategy does not sufficiently address the potential for delays in the delivery of East-West Rail,
and other key infrastructure required to support the proposed strategic allocations on the East-West Rail / A421 transport corridor. Paragraph 4.3
concisely captures the main elements of the Council’s strategy and states:
“The completion of EWR will result in the creation of highly accessible locations around new rail stations. By concentrating on accessible locations, the spatial
strategy aims to minimise the need to travel by car and therefore reduce the emission of carbon dioxide in line with the objectives of the plan. The growth locations are as follows:
A. Within the urban area
B. At strategic locations adjacent to the urban area which contribute to the delivery of key green infrastructure projects
C. At new growth locations focussed on the EWR / A421 transport corridor with the potential for rail based growth, particularly in the south of Bedford area and
at a new settlement at Little Barford.”
Given the slow progress of detailed proposals for East-West Rail between Bedford and Cambridge, and uncertainties surrounding when this piece of major
infrastructure will eventually be delivered, the reliance on the Stepped Trajectory to meet the identified housing and employment needs, set out in Policy DS3(S), appears to be highly optimistic, and does not positively plan for the potential of a slower rate of housing delivery, or a delay in the commencement of development on the identified new settlements South of Bedford and at Little Barford.
The Council’s proposed residential development trajectory in the years 2030-2040 is therefore not realistic nor deliverable. We would contend that East-West
Rail will take longer to come forward, and that the Council is likely to fall far short of achieving the requisite 1,700 dwellings per annum in the years 2030-2040.
The risks surrounding the delivery of EWR are acknowledged in the ‘Development Strategy Topic Paper’ (June 2021). In the analysis of the ‘Option 2’ sub-options i.e. Development in and around the urban area, plus A421 transport corridor with rail based growth plus one or two new settlements. In the ‘Weaknesses and delivery challenges’ assessment of the reasonable alternatives
for Option 2 the Topic Paper states:
• Viability and land assembly challenges for urban land and timing of delivery in some cases dependent on EWR delivery;
Delivery of new rail stations is proposed, but not yet confirmed.”
While we recognise that the Council is acknowledging these risks stating it will monitor the provision and delivery of infrastructure and, if necessary, bring
forward a review of the Local Plan, we would contend that for the plan to be positively prepared and effective, the plan should attempt to mitigate these known risks through an appropriate policy framework to be put forward now, in the Local Plan 2040, rather than postponed for another review.
This Spatial Strategy is therefore not effective, nor is it positively prepared to address the potential weaknesses in the strategy during the plan period. We would contend that this would make the plan, as submitted, UNSOUND.