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

Representation ID: 7559

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Representation Summary:

CMAT considers that Oakley’s current status within the settlement hierarchy is not reflective of the role and importance of Lincroft Academy and the background to the immediate requirement for expansion. While there is support in principle to deliver an increase in school places within the existing campus under the existing policies of the development plan Oakley’s role as a Rural Service Centre is not consistent with an effective strategy for the long-term planning of community infrastructure in this location. The risks associated with the current strategy can be summarised as follows:
• The current issues with Station Road (although potentially not a reason for refusal in themselves) would benefit from knowledge of the ability to deliver highway improvements to be set out in the policies of the emerging Local Plan 2040; and
• Securing wider benefits associated with optimising the playing field situation, which will not be addressed by the current scheme proposals and could be a barrier to further expansion
The scale and distribution of growth to Rural Service Centres contained in Policy 4S of the LP2030 has not enabled a solution to these issues being provided through the Oakley Neighbourhood Plan albeit there is no prejudice to opportunities to resolve them in future. The Council’s testing of strategy options is based on carrying forward the lack of flexibility in providing for a long-term sustainable solution at Oakley in two ways:
• It’s Preferred Options exclude the possibility of further village-related growth north of Bedford
• In any event, testing has retained the use of arbitrary figures for Key Service Centres and Rural Service Centres (500/35 units respectively)
Within this framework there is no reasonable prospect of securing the required transformation in an approach the best addresses the provision of services and facilities at Oakley. Addressing this requires flexibility in the approach to the scale and distribution of growth that reflects the opportunities and capacity at each settlement, which for Oakley is underpinned by evidence supporting its reclassification as a Key Service Centre. This provides the starting point to potentially enable levels of growth and support other improvements and wider benefits commensurate with its existing role and function.
Reasoning
The Council’s work to justify the selected Preferred Options is at a relatively early stage with significant ‘gaps’ in the evidence presented – particularly in terms of development timescales, infrastructure delivery and viability. The Council notes, as follows:
• Infrastructure Delivery Plan – to be prepared alongside site allocations
• Settlement Hierarchy (September 2018) – review underway
• Plan-wide Viability Assessment – yet to be commissioned
The absence of these documents, and in-particular completion of the review of the Settlement Hierarchy, means that the exclusion of Oakley from the Council’s Preferred Options can be demonstrated to be unsound – not effective, not consistent with national policy and not justified.
The council’s approach to the assessment of the existing settlement hierarchy is flawed as it fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available.
Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by public transport.
Oakley includes local shopping, significant employment opportunities and has both a Primary and Secondary School. As such, Oakley serves a wider catchment area and, in this context, it is a reasonable alternative to consider a higher level of growth that the 25-50 homes band proposed under the adopted plan.
The key issue with the council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the Settlement Hierarchy.
Oakley Primary Academy and Lincroft Academy also generate significant local employment opportunities both presently and in view of the expansion required. This includes around 80 Full-time staff (including teaching and support staff) and at least 50 Part-time roles (including caterers and cleaners), with the vast majority now operating from the campus following the lifting of Coronavirus restrictions. The provision of jobs in each settlement is given no weight in the Council’s scoring of the Settlement Hierarchy and overlooks this as an important aspect of providing for sustainable communities.
As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth.
The shortcomings of this finding are exacerbated because strategic priorities relating to the requirements for social infrastructure (notably education) were deferred rather than dealt with in the Local Plan 2030. This is contrary to the requirements of national policy (NPPF2021 paragraph 20(c)).
The current development plan (including the Oakley Neighbourhood Plan) makes no provision for the expansion of Lincroft Academy that is required and is a function of the growth that the current spatial strategy supports across other Key Service Centres without Secondary School provision (including Clapham and Bromham).
Addressing these current unmet strategic priorities together with providing a positive approach towards the longer-term requirements for school infrastructure would be most effectively supported by reclassification of Oakley’s role in the settlement hierarchy to reflect its importance to the wider rural area (and strong links to the urban area).
Remedy
An appropriate remedy for this would be to complete a review of the preferred options within the Local Plan 2040, treat Oakley specifically as a Key Service Centre and recognise that the area has missed out on potential growth to meet key infrastructure requirements as part of the approach to preparation of the Local Plan 2030.