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

Representation ID: 8833

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Representation Summary:

RESPONSE TO DRAFT SUSTAINABILITY APPRIASAL REPORT

5.1 We raise objection to the contents of the Sustainability Appraisal. The framework for considering sustainability is well established, and we do not raise objection to the general scope of the appraisal. However, it is felt that there is an underlying bias towards urban centric growth, which discounts further growth in the Key Service Centres and smaller sustainable villages.

5.2 The four options in Option 2 are described in the consultation as primarily an urban centric set of options focused on growth in and around the urban area and rail connection points. We would argue this approach is far too simplistic and omits an opportunity to enhance the sustainability of Key Service Centres through the provision of additional services and employment opportunities. It also ignores the potential to build upon the community-led ambitions of the many Neighbourhood Plans that have been prepared in the Borough.

5.3 We note that at paragraph 8.10, the Council comment on the merits of growth around rail hubs and yet ignore to a large extent the value of the bus network with high frequency bus services being a far more flexible and viable option in providing an alternative to the car. The delivery of housing growth along high frequency bus networks, such as that served by the No.50 running between Bedford and Rushden, has the knock on benefit of supporting improvements to services and wider improvements to sustainability across a broader range of settlements.

5.4 An enhanced population along the bus network increases passenger numbers which enables improvements to those existing services to be more viable. By enhancing the network as a whole, you can better serve smaller settlements and improve their sustainability as a consequence.

5.5 We would also highlight that sustainable development needs to plan for the longer term. The private petrol/diesel powered motor vehicle/car is considered to have a harmful effect on the environment, contributing to rising CO2 levels and poor air quality. As a consequence, the language of sustainability talks about “reducing the reliance on the private motor vehicle”. However, as we progress forward in carbon neutral/zero emissions vehicles, this notion will be out of date. The Government has brought forward it’s ban on the sale of new petrol and diesel cars to 2030, with all new cars and vans required to deliver zero emissions from the tailpipe from 2035. The car industry has also reacted with many car manufacturers already committed to being fully electric by 2035. In addition the largest manufacturers, such as Volkswagen Group, have committed to their vehicles being carbon neutral at the point of manufacture.

5.6 With the move towards more environmentally friendly forms of private transport which are driven and supported by the ever-growing energy provision coming from renewable sources, the impact of the private motor vehicle will change, and will be part of a range of sustainable transport options.

5.7 We would also raise objection to the very narrow view that somehow sustainability can only be achieved by one model of growth, with a focus on what is new, being located in only a select few locations; and that somehow everything else is not sustainable, nor could ever be altered to become sustainable. In our view it ignores the wider objective of enhancing the sustainability of existing settlements of all sizes, and fails to support the long-term vitality and viability of those existing settlements and the services and facilities they rely upon.

5.8 It also assumes that travel patterns will continue to grow along the same trajectory, but our collective experiences through the Covid19 pandemic have accelerated the trend of home working, supported by advances in technology. As demonstrated by the pandemic, a large proportion of the economy can continue to function without the need to travel, and to some extent this has opened people up to embracing technology and minimising their need to travel to communicate. All development needs to consider, that going forward, a greater proportion of people will be working from home, or in localised hubs, without the need to travel long distances. That degree of flexibility is already coming in the form of communal work spaces, and hot desking centres. Therefore, the provision of high-speed broadband to all new developments, as well as supporting enhancements to the existing network and local services and facilities, is essential in delivering sustainable growth.

5.9 We would therefore conclude, by arguing that the sustainability credentials of the settlement of Sharnbrook should be assessed independently, and without bias, while opportunities for growth in the settlement should be fully considered in light of its sustainability credentials. It is self-evident that Sharnbrook occupies a sustainable location, served by the A6 and is supported by high frequency public transport links via the No.50 bus service running between Rushden and Bedford. The settlement is independently accessible from the major road network. We believe that the allocation of development at Sharnbrook would meet many of the sustainability objectives the Council are arguing in support of options 2a – 2d, further supporting enhancements to the public transport network serving the village, and as such, would question why further growth here has been discounted.