Object

Representation ID: 10434

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy. The approach is not legally compliant in respect of the Sustainability Appraisal and Duty to Cooperate processes and fails all four soundness tests.

These comments should be read in conjunction with our clients Regulation 18 representations (Representation ID: 8572 / Site ID: 1247) which are appended to a Site-Specific Representation and which provides detailed comments on the proposed strategy and specific details relating to our client’s land interests. In addition to the Site Specific Reps Report, which contains an updated Site Analysis Document, showing how the site could deliver up to 120 dwellings, these representations should be read alongside the supporting Spatial Strategy and Legal Compliance Report.

The Site Analysis Document and Regulation 18 representations detail how the site could deliver the green infrastructure priorities set out in adopted (and proposed saved) policies AD24 and 36S. It is within the context of a site capable of delivering meaningful residential development, upon a sustainably-located site well-related to the principal settlement of Bedford but maintaining appropriate separation from the urban edge within Kempston Rural parish, that these representations are made.

We continue to have fundamental concerns about how opportunities for development within Kempston Rural parish, including our client’s specific site interests, relating to the ‘urban edge’ component of growth have been assessed. A clear rationale exists for development beyond that proposed for allocation within the Council’s Plan for Submission. Further reservations are made regarding the Council's strategy for the distribution of growth, which merely refers to dwellings and ignores the method necessary to meet the housing demands of various groups, including specialist housing for older people and self-build/custom-build housing, additional opportunities for which could potentially be provided through the identification of additional small and medium-scale allocations as part of the selected strategy.

The SHLAA confirms in respect of our client’s land that the site has not been subject to more detailed testing on the basis that it does not accord with the preferred spatial strategy. We consider that the site, if applying a hybrid approach that would (as is already the case in the selected strategy) support the prioritisation of development around sustainable urban edges without undermining the wider need for some growth at Key Service Centre and Rural Service Centre settlements within the Council’s settlement hierarchy. Maximising the contribution from urban edge sites could make an important contribution when it comes to delivering housing, offsetting a reliance on strategic scale growth elsewhere within the Plan for Submission which often delivers at a much slower pace than small-to medium sized sites.

Given the proximity of our client’s land to the proposed allocation HOU13 at Gibraltar Corner, the site is demonstrably located within the Council’s selected strategy and would, with minimal additional impact, help to deliver much needed housing.

The Council's trajectory for the Local Plan 2040 as proposed, with an over reliance on strategic scale development, will exacerbate existing problems with delayed and slow delivery of allocated sites, rendering ineffective even its suggested "stepped approach" to the housing requirement. The Council's position is further undermined by the simple fact that there is insufficient information to demonstrate that rail-based expansion in the A421 corridor is feasible before years 11 through 15 of the plan period, if not later. This result of this is an almost immediate supply issue which can only reasonably be addressed by the allocation of small/medium sized sustainable sites such as that at Green End, Kempston. Providing a choice of locations for growth will ensure that market saturation is avoided and will support urban and rural vitality in line with the requirements of the NPPF and NPPG.

Therefore, as draft we consider that Policy DS2(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.