Object

Plan for submission evidence base

Representation ID: 10123

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

2.28 The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
2.29 As is discussed further below, whilst we have more significant concerns relating to soundness and legal compliance relating to the SA and site assessments and the application of a stepped trajectory, we also consider the proximity of the Little Barford new settlement to Huntingdonshire and the associated implications, has been given insufficient consideration in the prepared Position Statement.
2.30 The allocation of Land at Little Barford is a strategic cross boundary matter with the potential that Huntingdonshire District Council, given the closer relationship with the population and settlements of Huntingdonshire than that of Bedford, will consider that growth in this location will be capable of accommodating the needs of their population. The Position Statement sitting within the evidence base does not reflect this relationship and the impact on Huntingdonshire’s needs. Further cross-boundary engagement is considered necessary and should be reflected in an updated Position Statement that considers housing need, deliverability and engagement with infrastructure providers.
2.31 In terms of the Position Statement relied upon (signed 1 April 2022, prior to publication of details within the Plan for Submission) this simply states in relation to housing provision that further cooperation may be required ‘subject to its location’. Plainly at the time this statement was completed Bedford Borough Council was aware of the proposed allocation at Little Barford within its selected strategy. The Council would also plainly be aware of Huntingdonshire District Council’s objection to either Option 2c or 2d including new- settlement scale growth in this location, as outlined in its Preferred Options consultation response8.
2.32 We would note particularly those elements of the representations that relate to the feasibility and achievability of satisfying infrastructure requirements at the site (including new rail crossings) and the related impact on lead-in and delivery timescales as being highly relevant to our objections regarding the Council’s proposed reliance on a stepped trajectory and lack of evidential support for unprecedented completion rates in excess of 600 units per annum. For example, the objections from Hunts DC note:
“Huntingdonshire District Council acknowledge that this site is likely to benefit from being in closer proximity to a new East-West rail route where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy and thus has greater potential to incorporate sustainable modes of transport. However, there is still uncertainty on the location of an East-West railway line station and when it may be delivered. Additionally, there is also the timing and delivery of the proposed realigned A428 route which will impact the eastern edge and southern aspects of the site to consider. These may give rise to delays in effective masterplanning of the site, mix of land uses, incorporation of sustainable and accessible transport and its eventual delivery.”