Object

Representation ID: 10224

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5(S) Distribution of Growth
2.38 Emerging Policy DS5 sets out where growth is to be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040.
2.39 Emerging Policy DS5(S) sets out the following distribution of housing growth:
SEE ATTACHMENT FOR TABLE

2.40 As detailed in response to Policy DS2 it is considered that the Council’s preferred strategy is over reliant on strategic sites and new settlements and is not sound. The approach proposed risks the delivery of the Plan as it is highly vulnerable to delayed or non-delivery. If one of the strategic sites does not deliver than the Plan will fail. Further, the approach adopted by the Council does not provide for choice and competition in the housing land market, which is likely to result in land price inflation given most the new housing is under the control of a limited number of landowners. Moreover, it largely rules out developments being brought forward by SME housebuilders, instead creating a monopoly of sites which can likely only be delivered by the larger housebuilders who will benefit from the economies of scale. As a result, there will also be a limited variety of houses realising to the market concurrently, slowing market absorption which will have high consequences in the latter years of the Plan period in terms of satisfying the Housing Delivery Test or demonstrating a five-year housing land supply.
2.41 The Plan states that there will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocated growth to some Key Service Centres and Rural Service Centres however, no new/additional allocations are made in these villages in the Local Plan 2040.
2.42 The Plan instead advises that some Parish Councils may ‘choose’ to allocate further sites for development in their Neighbourhood Plan; there is no requirement for this.
2.43 This absence of small and medium growth in the rural villages, particularly Sharnbrook, misses an opportunity to deliver some of the housing requirement earlier in the Plan period, rather than relying on some 10,000 dwellings to be delivered through new settlements - which are significantly reliant on the delivery of large-scale infrastructure. As detailed in response to Policy DS3 it is not an appropriate strategy to place such a reliance on strategic infrastructure to deliver such a large proportion of a housing need.
2.44 The distribution of growth within the LP2040 is not effective. As detailed in response to Policy DS3, such a reliance on strategic sites is not deliverable over the Plan period (it is already noted in Policy DS5(S) that 400 dwellings will be delivered beyond the plan period, before accounting for any delays in site assembly, unlocking and delivering the required infrastructure, and actually delivering homes on sites included within the plan period). Moreover, the failure for Sharnbrook to deliver any new housing, with all growth being funnelled to a free-standing new settlement is entirely at odds with the adopted Local Plan and also fails to utilise a key sustainable settlement with latent capacity for growth (as demonstrated by the allocation of 500 units to Sharnbrook itself in the adopted Local Plan). As such capacity exists and should be recognised and utilised for housing growth in Sharnbrook itself.