Object

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

Representation ID: 8711

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Representation Summary:

3.9 The Council’s Preferred Options published for consultation contend that they draw heavily on the ‘pillars’ of economic development and the natural environment from the emerging Spatial Framework. The representations identify that the Council’s published consultation proposals fail to embrace the comprehensive approach to supporting sustainable development anticipated in the Spatial Framework. Paragraph 1.10 of the consultation document ignores altogether the place-making ‘pillar’ of the Framework while the Preferred Options as a whole are 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 Arc Spatial Framework, that the consultation proposals 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 consultation document ‘Creating a Vision for the Oxford- Cambridge Arc places significant emphasis on reducing the need to travel. Connectivity is not just about strategic road/rail links - it means:

“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 also states the importance of recognising the needs of an ageing population


in terms of service delivery. 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 Key Service Centres across the authority have a key role in delivering these requirements for sustainable communities and serving a wider rural hinterland – both in terms of immediate needs and their role throughout the plan period. The strategy in the Local Plan 2030 has deferred important decisions relating to these priorities in terms of placing the requirement to allocate sites upon Neighbourhood Plans. Priorities have therefore not been addressed and in any event the current strategy has only sought to address a foreshortened period to 2030.

Remedy
3.14 The Council’s Preferred Option 2d delivers scope to fulfil local requirements for effective place-making and enhancements to connectivity through support for growth in the ‘east’ corridor parishes and specifically at Great Barford. It is necessary, however, to ensure that the approach to this component of the strategy is underpinned by the Council’s site assessment and site selection process and that this seeks to specify levels of development that maximise opportunities for growth. This is particularly the case at Great Barford (the only Key Service Centre within the ‘east’ corridor) where the majority of development under this part of the strategy would be expected to take place.

3.15 The Council’s indicative figure of 750 units in the ‘east’ corridor parishes in the strategy distribution options is not based on any site-specific testing. Firstly, this represents a risk to securing the opportunities and benefits from this part of the Plan Area as part of the approach, once finalised. Secondly, the current evidence base also takes no account of those opportunities that would embrace opportunities both in the period to 2030 (to address the immediate uplift in the need for growth) and across the entire plan period. Our client’s Willoughby Park proposals comprising a self-contained scheme for 500 units accord closely with the Council’s indicative figures for distribution and incorporate a positive response to the emerging Plan’s place-making objectives (particularly in terms of provision for health and green infrastructure). It is therefore essential for soundness that our client’s site is confirmed as part of the final selected strategy subject to future consultation in order to provide a significant local contribution towards the emerging priorities of the Spatial Framework.

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