Object

Representation ID: 10445

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Site IDs 918 (Land at School Approach) and 932 (Land east of Odell Road, Sharnbrook) detail the land interests of our clients. As part of the Council's Summer 2021 Preferred Plan Options and Draft Policies consultation, these interests were the focus of thorough statements and comments on the proposed strategy (Representation ID: 9000). The Council's Submission Plan does not address the problems raised previously, and it remains the case that our clients’ land interests have not undergone the necessary additional comprehensive or iterative assessment.

These representations should be read alongside previous submissions appended to a detailed Site-Specific Representations Report – Land at ‘Stoneyfields’, Sharnbrook and Spatial Strategy and Legal Compliance Representation Report.

Two alternative options for growth have been proposed. The first would see the land at Odell Road come forward for up to 397 dwellings, whilst the smaller parcel at School Approach is capable of accommodating a standalone c.100 dwellings. Together the two parcels provide for a comprehensively masterplanned development of around 500 dwellings known as ‘Stoneyfields’ and capable of providing substantial benefits to the wider community including delivery of a new Riverside Park, ecological enhancement and land for a new local centre.

Aligned to our representation of the spatial strategy (Policy DS2(S)), the 'village-related' growth component relating to settlements both inside and outside the 'east' and 'south' corridors would only be thoroughly tested if a 'hybrid' approach were applied to the spatial strategy informing the distribution of growth and used to inform site assessment and site selection under Policy DS5(S). This has not been undertaken, meaning that the distribution of growth identified in Policy DS5(S) is not justified, not effective and not consistent with national policy.

The Sustainability Appraisal process has examined village-related growth only with the assumption that all settlements at the same level of the hierarchy will have "flat" development quanta (500 units in Category 1 villages and 35 units in Category 2 villages). No testing of individual site options has been undertaken before determining that the village-related component of growth should be rejected altogether as inconsistent with the selected strategy. This overlooks that both the Council’s own SA and 2021 Development Strategy Topic Paper anticipate scope for further refinement in the testing of site options.

The planned growth distribution does not create new demands or opportunities for rural areas; it only allows for the fulfilment of existing rural allocations. Despite this, the SA at paragraph 7.23 asserts that housing development in rural areas may significantly contribute to meeting housing needs and goes on to list specific locations that should be taken into account. Particularly emphasis is placed upon locations within or adjacent existing settlements i.e., criterion which capture our client’s Land at Sharnbrook. This appears to directly conflict with the SHLAA Table 2.2 where all village-related sites are ruled inconsistent with the chosen strategy based on the SA findings. As a result, various rural areas are suggested as possible options without more in-depth assessment or expansion allocation.

According to paragraph 66 of the NPPF2021, strategic policies should stipulate a housing requirement for designated neighbourhood areas that reflects the overall strategy for the pattern and scale of growth and any related allocations. From the 2012 iteration of the Framework, this is a significant change. However, the Council's testing of options for the Local Plan 2040 neglects to consider any identification of housing requirements for designated neighbourhood areas beyond the distribution of growth within the Local Plan 2030.

At Sharnbrook, the Local Plan 2040 specifically fails to recognise that the ‘made’ Neighbourhood Plan allocates growth at a location divorced from the main settlement (upon Land at Hill Farm). The Neighbourhood Plan does not support the development of land well-related to the existing village and previously identified as Preferred Options by the local planning authority, including our client’s Land at Sharnbrook. However, in terms of the requirements of national policy and guidance this does not preclude sound plan-making in terms of requiring an assessment of site options and identification of an appropriate housing requirement for the designated neighbourhood area particularly where this would provide a number of additional benefits for the local community and housing delivery.

The Council has not adequately addressed issues raised by our client during earlier consultation rounds, particularly the need to consider "hybrid" options for degrees of expansion within the settlement hierarchy. To further elaborate, a new "Option 8" that substitutes village-related development for Little Barford's "new settlement" growth has been evaluated and "rejected" in the Council's Sustainability Appraisal for the Submission version Plan. However, this result was reached without fully analysing the possibility for growth in particular settlements or site options.

The SA acknowledges that Sharnbrook and individual site options within village locations have only undergone preliminary testing against a number of SA parameters. No attempt has been made to compare the observed combination of effects of the selected strategy to any iterative approach that considers judgements on the suitability (including the availability of specific benefits) from different site options.

Given the identified delays with the delivery of land allocated within the Sharnbrook Neighbourhood Plan, we consider that our clients land in Sharnbrook should be considered in detail, with an acknowledgement that delivery could contribute towards housing need within the early part of the plan period and assist the Council maintain a sufficient supply of housing.
These benefits specifically relate to the parcel of our client’s Land at School Approach, which can be provided either as a standalone scheme for 100 units or as part of the comprehensive Stoneyfields Masterplan proposals.

Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.