Object

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

Representation ID: 6108

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

Representation Summary:

3.9 The draft strategy contends that the Council draws heavily on the ‘pillars’ of economic development and the natural environment drawn from the Spatial Framework. However, they fail to embrace the comprehensive approach to supporting sustainable development as anticipated by the Spatial Framework. Paragraph 1.10 ignores altogether the place-making ‘pillar’ of the Framework while the LP2040 draft strategy as a whole is overly reliant on assumptions regarding improvements in strategic-level connectivity. This fails to embrace local opportunities for sustainable development.
Reasoning
3.10 It is surprising, and inconsistent with national policy and the emerging objectives of the Ox-Cam Arc Spatial Framework, that the LP2040 draft strategy Options make no mention of the connectivity or place-making pillars of the Spatial Framework. Each should be considered of equal importance.
3.11 Specifically, paragraph 4.1 of the Ox-Cam Arc consultation places significant emphasis on connectivity, defined as:
“improving communities’ access to the services they need – like a good quality, sustainable water supply and broadband, schools, cycle lanes and healthcare, as part of a great approach to place-making.”
3.12 Paragraph 4.4 affirms the importance of recognising the needs of an ageing population in terms of service delivery and moreover, at paragraph 4.5 the document goes on to explain:
“the policies of the Framework will be used to create a clear infrastructure plan giving communities access to the public services they need – including education and health”
3.13 The settlement hierarchy in Bedford Borough means that Rural Service Centres and Key Service Centres across the authority have a key role in delivering the requirement for sustainable communities, serving a wider rural hinterland – both immediate needs and throughout the plan period. The strategy in the BLP2030 has deferred important decisions relating to these priorities both in terms of avoiding the reclassification of centres and by placing the requirement to allocate sites upon Neighbourhood Plans.
3.21 Priorities have therefore not been addressed and in any event the current strategy has only sought to address a foreshortened period to 2030.
3.22 In the case of Wootton, no provision for additional growth was identified in the strategic policies of the LP2030, by reason of plan period and the Council knowingly opting to pursue an objectively assessment of housing needs substantially below government policy as indicated by the result of the standard method. These policies (including Policy 3S) nonetheless recognise Wootton’s highly sustainable location and support for recent patterns of growth south of Bedford.
Remedy
3.14 The Council’s draft strategy consultation proposals offer limited scope to address these local requirements for place-making and connectivity as part of a comprehensive strategy with no confirmation of the levels of growth that may be supported in Wootton as part of the selected strategy option.
3.15 The Local Plan must acknowledge the continuing need for additional village-related growth within the ‘south’ transport corridor parishes. Considerable and significant growth is weighted towards the delivery of strategic new settlement growth. Such development carries substantially higher delivery risk and is dependent on strategic infrastructure. Opportunities for sustainable development in accordance with these requirements (and the objectives of the emerging Spatial Framework) must be embraced both in the period to 2030 (to address the immediate uplift in the need for growth) and across the entire plan period to sustain the role and function of the Borough’s most sustainable settlements within the context of a longer term vision.