Comment

Representation ID: 10076

Received: 28/07/2022

Respondent: Countryside Partnerships Plc

Agent: Phillips Planning Services

Please refer to our representations in respect of proposed policies DS2(S) and
DS3(S) of the Local Plan 2040 – Plan for Submission. We raise objection to the soundness of the plan due to a reliance on stepped housing trajectory, reliant on
strategic settlement delivery in 2030, underpinned by the need to have
significant infrastructure in place before 2030. This is a high risk strategy and our
representations are that additional housing should be identified in the search
area, consistent with the spatial strategy, that will offer additional capacity; could
be delivered in phases in the late 2020s, or are held as strategic reserve sites to
be released for development should it become clear that delays in the delivery of
strategic infrastructure in the form of east-west Rail and improvements to the
A421 will delay or reduce the delivery of the identified new settlements on Land
South of Bedford and Little Barford.
On the basis of the above representations, Policy DS5(S) does not identify
sufficient allocations to mitigate for this scenario, nor does it take the
opportunity to identify strategic reserve sites that could be brought forward if
and when necessary to meet the shortfall in delivery rates.
Without adequate insurance through further allocations or identification of
strategic reserve sites, policy DS5(S) – Distribution of growth has not been
adequately justified by the evidence base and will not 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.