Object

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

Representation ID: 8830

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Representation Summary:

Emerging Preferred Growth Options - 2a, 2b, 2c, And 2d
3.17. There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in the Key Service Centres and smaller sustainable villages. None of the four emerging preferred growth options include any growth in the north of the Borough, not even in the Key Service Centres.

3.18. The north of the Borough includes several highly sustainable settlements, including the Key Service Centres of Bromham, Clapham, and Sharnbrook, and the Rural Service Centres of Carlton, Harrold, Milton Ernest, Oakley, and Turvey. There are also many other sustainable smaller villages.

3.19. The decision not to allocate further growth to the northern villages appears to be based upon the findings of the Bedford Borough Transport Model prepared by Aecom. The assessment considers a range of predetermined scenarios for growth and identifies that where a range of development is considered in the north (and across the Borough) up to 2040, there will be adverse impacts on the A6 corridor and suggests that there is no adequate mitigation available. As a result, the broad conclusion argues that development along the A6 corridor should be constrained.

3.20. While it is acknowledged that general scenarios have to be considered in order to assess the impacts of strategic growth on the highway network, this represents a very blunt tool and so its conclusions should be considered in that context. The transport modelling is clearly quite broad, particularly when considering development opportunities in the larger settlements in the north of the Borough which are primarily assessed in the “Grey scenario” (dispersed growth). In this scenario, development in the north is considered as a proportion of overall growth across the Borough and the highways impact is felt more widely. This is clearly a blanket approach which lacks the fine grain of assessment necessary to properly understand the impact of growth opportunities in key locations, and therefore too easily discounts development in the Key and Rural Service Centres in the north which are sustainable settlements with capacity for growth. We would contend that the transport modelling does not provide a conclusive position that a more targeted approach to growth in the north cannot be accommodated by the highway network. The report identifies that mitigation measures are available, and therefore a more focused assessment should be considered.

3.21. Growth in the north including in the Key Service Centres, and Rural Service Centres has been too easily discounted and this is a lost opportunity as there are several highly sustainable settlements in this location. Additional growth in the northern settlements can make a positive and meaningful contribution to the wider strategy going forward to 2040, improving the long-term vitality, and the viability of existing services and facilities. We would argue that allocations should therefore be made proportionally across the Borough in the interests of long-term sustainability.

3.22. The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process. The emerging Sharnbrook Neighbourhood Plan has carefully worked through a number of objectives to deliver an allocation of 500 dwellings under the Local Plan 2030. Sharnbrook is a highly sustainable settlement and there is an opportunity for some of the objectives to be carried forward into a further round of allocations.

3.23. Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area, and fails to address the growth agenda established by the vision for the Oxford-Cambridge Arc.