Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5925

Received: 08/09/2021

Respondent: Mr Tom Tagg

Representation Summary:

While I understand the approach adopted to compare the many sustainability aspects of each proposed development option and generally support the 15 sustainability objectives (para 1.4), their application in practice is severely limited for the following reasons:
• Referring to the Summary table at the end of Appendix 5 that compares all development options.
• Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include: 2. Protect, maintain and enhance biodiversity and habitats; 8. Protect and enhance landscape character and townscape character…; 11. Minimise flood risk; .
• Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport.
• So in reality, of the 15 criteria only 6 criteria make a difference.
• I do not consider this to be reasonable or sufficient.
In the emerging preferred development options 2a to 2d, I believe that BBC have failed to properly consider the true impact of new settlements (especially including Dennybrook) on:
• 6. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
• 8. Landscape character – all options score the same and the words fail to fully recognise the impact and destruction of new settlements on the existing landscape.
• 9. Maximise development on brownfield/avoid loss of agricultural land – despite the massive loss of high quality agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that BBC happily accept this and have made no effort to maximise use of their stock of brownfield land – contrary to the NPPF.
THE ABOVE LIMITATIONS IN THE PROCESS CAST SERIOUS DOUBT ON THE VALIDITY OF THE EMERGING PREFERRED OPTIONS 2B, 2C AND 2D, especially for the Dennybrook site.