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Representation ID: 8494

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.10 Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.
2.11 In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.
2.12 The issue with the other options (rail-based, east-west rail northern station and new settlement) is that they place significant an emphasis on delivery on limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further emphasis on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain
a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
2.13 Dispersed growth should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established at this point the significant harm such an approach has caused in recent years nationally, as reflected in matters such as declining public transport routes, closure of village pubs and shops and the decline in vitality of village life, generally where development has been withheld. Whilst the current Plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result in a 10-year period with no proposed growth which would be unacceptable and as such some provision must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.
Site Allocations and Call for Sites
2.16 The Council have previously evidenced that settlements such as Sharnbrook can deliver up to 500 dwellings in the period up to 2030. The emerging Neighbourhood Plan seeks to allocate 500 dwellings beyond the settlement of Sharnbrook, at Coffle End, another settlement within the Local Plan settlement hierarchy. As such it is considered that no growth has been directed to Sharnbrook itself over the adopted Plan period to 2030. Furthermore, the emerging Local Plan looks beyond 2030 to 2040, and thus commensurate additional further growth in the sustainable rural settlements must be delivered during this extended time period., The 500 dwellings allocated at Coffle End in the emerging Neighbourhood Plan will not be sufficient to meet the housing needs in Sharnbrook up to 2030, or 2040. It is considered that sustainable growth in settlements such as Sharnbrook, up to 2040, should be in the region of a minimum 100 dwellings (additional dwellings beyond the 500 allocated in emerging Neighbourhood Plan). This is consistent with the Councils previous evidence base, current housing targets, and commensurate to their sustainability and spatial role. As previously set out, we would object to any attempt to stifle appropriate rural growth.
2.17 In that regard, we consider the emerging Local Plan must make allocations in the Rural Service Centres to ensure a suitable distribution of deliverable development sites up to 2040. Within Sharnbrook it is clear through both the evidence supporting the Neighbourhood Plan and the previous assessments supporting the adopted Local Plan (whereby the Council’s 2017 Local Plan consultation paper sought to identify preferred sites for allocation, which included land at Kennell Hill), that the most suitable and deliverable site beyond those allocated in the Neighbourhood Plan is land at Kennell Hill, Sharnbrook. A range of evidence documents have been produced by Anwyl Land which demonstrate the deliverability of the site.
2.18 The Council have assessed the Kennell Hill, Sharnbrook site under ID reference 3231. We have a number of concerns with the scoring of this site. We also have a number of comments in respect of the emerging Neighbourhood Plan allocation, which whilst being allocated through a separate process is considered as part of this SHLAA assessment and will be a matter for the Council to consider. These are discussed in turn, followed by more general comments in respect of the settlement generally.