Object

Representation ID: 8518

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

PROPOSED APPROPRIATE STRATEGY– OPTION 2D AND A ‘HYBRID’ APPROACH
This section of our representations should be read alongside the standalone Review of the Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review support the Modifications in this part of the representations. This section also reinforces our specific comments on the Council’s Preferred Strategy Options.
Paragraph 3.17 and Option 2d – Comment
These representations endorse the inclusion of the ‘east’ corridor parishes as part of Preferred Option 2d but in practice indicate that this is illustrative of a need for a ‘hybrid’ approach to provide for an appropriate strategy in accordance with national policy and guidance (NPPF2021 paragraph 35(b)).
These representations conclude that any selected strategy option that does not include growth in the ‘east’ corridor parishes would be unsound and fail to comprise an appropriate strategy or genuine reasonable alternative for the purposes of the Sustainability Appraisal. This is due to soundness issues identified with the delivery of large-scale strategic growth comprising other components of the Council’s Preferred Options.
The benefits of Option 2d reflect the ability to promote and maximise the benefits of what is in-effect village-related growth at the Key Service Centre of Great Barford, which is very sustainably located within the A421 corridor. Growth at Key Service Centres is an approach that the Council has accepted as sustainable in the spatial strategy of the adopted LP2030, and the evidence base for the Local Plan 2040 indicates no in-principle constraint to capacity for further development at Great Barford that could not be adequately mitigated.
Endorsement of growth at Great Barford under Option 2d in the context of a ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’ growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of their capacity to contribute towards sustainable development. The benefits of ‘village-related’ development do not suddenly materialise only where Key Service Centre and Rural Service Centres are located in the A421 corridor and do not evaporate altogether outside of it.
To achieve the objectives of the emerging Local Plan 2040 it is necessary to support further village extensions to the settlement of Great Barford, incorporating our client’s Willoughby Park proposals, to secure contributions to sustainable development that are assessed favourably in the draft Sustainability Appraisal (including new green infrastructure, community facilities and opportunities for recreation). The potential to secure these benefits should be reflected within the Council’s conclusions on site selection and evidence base for the submission draft version of the Plan, once finalised, including the Infrastructure Delivery Plan and Settlement Hierarchy Review, which both remain awaited.
Draft Sustainability Appraisal – Suggested Appropriate Strategy Alternative
A ‘hybrid’ option would assign the ‘village-related’ growth component only to those settlements outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an indicative distribution, have been retained at 500 units in Key Service Centres and 35 units in Rural Service Centres albeit these are arbitrary figures and should be determined on a case-by-case basis. Wixams has been excluded from the total for Key Service Centres (reflecting its inclusion in the locations for rail-based growth). The only exception, taking account of this, is an increase of 215 units in the distribution to Oakley (based on its suggested reclassification as a Key Service Centre set out in representations on behalf of other clients submitted to this consultation).
For the A421-based components of the strategy the total distribution to the ‘east’ corridor parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d. This marginally exceeds the Council’s arbitrary figures applied for the purpose of testing Great Barford, Roxton and Willington as ‘village-related’ growth but would in our view represent a more realistic starting point taking account of the capacity for growth at Great Barford and in-particular our client’s Willoughby Park site. There is no site-specific justification or settlement-specific justification as to why this figure should be limited to 750 dwellings.
In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of large-scale strategic growth included in the strategy options. We have included the Council’s minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic timescales for development.
Including both components, if required (New Settlements and rail-based growth) would comfortably exceed the minimum 12,500 units required from additional allocations, with an appropriate buffer for flexibility and contingency (particularly in terms of the prospects for meeting increased needs before 2030). There is no reason higher quanta could not be included as part of an extended plan period. Equally, this could allow some settlements outside of the transport corridors to be excluded from further village-related growth. We would, however, not recommend this where Neighbourhood Plans being prepared have failed to address important strategic priorities (as at Oakley and Sharnbrook, for example).
The ‘hybrid’ strategy based on these components are summarised in Table 1 below:
SEE PARA 5.11 IN ATTACHMENT
We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with the standalone findings for growth components and the Council’s Options 2d and 3c, as well as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable development are enhanced.
This is as a result of recognising that the potential negative effects the Council assigns to village-related growth are incorrect and, in any event, inaccurate because it ignores the location of some Key Service Centres and Rural Service Centres within the A421 corridor. It also recognises that some the benefits of what is in reality ‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across settlements elsewhere in the hierarchy. Likewise, the assessment of positive effects for strategy options including the ‘east’ transport should be increased due to the ability to provide for sustainable village extensions at Great Barford. The results are summarised in Table 2 below:
SEE PARA 5.13 AND TABLE 2 IN ATTACHMENT