Comment

Representation ID: 10075

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Following on from our representation in respect of Policy DS2(S), the proposed
Stepped Trajectory under Policy DS3(S) is optimistic and carries with it a high risk
of failure, with no mechanism evident to mitigate that risk. The Council is
adopting a stepped approach to housing delivery, where the current Local Plan
2030 provides for 970 dwellings per annum to 2024/25, then a marginal uplift is
planned for 2025/26 to 2029/30 (following adoption of the Local Plan 2040), and
then the expectation of a significant increase to 1700 dwellings per annum, from 2030/31 through to 2039/40.
The Council’s strategy for increased delivery in the years 2030-40 is a risky one
because the majority of the additional circa 12,000 new dwellings, that are
needed, are coming from the two new settlements in the plan, i.e. South of
Bedford and Little Barford. Both sites are allocated to provide at least 4,000
homes and each to a large extent are underpinned in transport terms by the
delivery of the new East-West Rail route.
The stepped trajectory assumes a sudden and immediate increase in housing
delivery in the year 2030/31. This assumption is based on a further assumption
that the identified infrastructure to support this growth is in place prior to 2030,
however, in terms of East-West Rail, the plan states at paragraph 4.23:
“The potential of EWR to offer improved connectivity and create economic growth
will be a critical catalyst for delivery and pivotal to achieving the plan’s vision. The
new links and stations however will not be operational until 2030 and other
essential infrastructure (principally improvements to the A421) are expected to be
delivered on similar timescales.”
In respect of the two new settlements the plan states that in respect of “South of
Bedford”, accessibility to the new settlement relies on the East-West Rail station
but delivery is unlikely before 2030 (see the South of Bedford Area Topic Paper
(April 2022)); and in respect of Little Barford the supporting technical note states
that it is proposed to increase public transport frequency considerably to meet
demand, and that a public transport hub is necessary with the new station at the
heart of this new settlement. The Little Barford settlement appears to be highly
reliant upon significant changes to the wider infrastructure network to
accommodate the projected growth, without such improvements it is unclear that
the existing highway network could accommodate the projected growth without
significant adverse impacts in the area immediately south of St Neots.
In our opinion, there are contradictions within the plan, where it assumes a massively increased development trajectory from 2030 onwards but at the same
time states that the new East-West Rail and other key road infrastructure will not
be ready before 2030. It does not therefore appear to plan for the possibility that
the critical supporting infrastructure, that this approach relies upon, will not be
ready until into the 2030s, either on current evidence or more so if there is a
delay.
Given that the trajectory may well slip the Council should take account of this risk
and seek to mitigate through the improved use of existing identified sites, such as
Great Barford West allocation of additional sites, or the identification of strategic
reserve sites, that remain inline with the adopted strategy, and could come
forward in the late 2020s should this strategic infrastructure be delayed.
The NPPG states the following in respect of reserve sites (emphasis added):
“Where strategic policy-making authorities are unable to address past shortfalls
over a 5 year period due to their scale, they may need to reconsider their
approach to bringing land forward and the assumptions which they make. For
example, by considering developers’ past performance on delivery; reducing the
length of time a permission is valid; re-prioritising reserve sites which are ‘ready
to go’; delivering development directly or through arms’ length organisations; or
sub-dividing major sites where appropriate, and where it can be demonstrated
that this would not be detrimental to the quality or deliverability of a scheme.”
The identification of reserve sites is therefore recognised as an appropriate part
of the plan-making process. Identifying reserve sites would provide the Council
with an insurance against a fall in housing supply and will give the Council more
time to undertake a Local Plan review in the late 2020s should East-West Rail and
the improvements to the A421 be delayed. Without adequate insurance through
further allocations or the identification of strategic reserve sites, policy DS3(S) –
Amount of housing and timing of housing growth, has not been adequately
justified by the evidence base and will note be effective in meeting the Borough’s
housing needs. The stepped change in delivery is a high-risk strategy and inadequate mitigation is provided should that strategy fail to deliver due to delays
in the delivery of strategic infrastructure. On this basis the adoption of this policy
is considered to render the plan UNSOUND.