Object

Representation ID: 9061

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

4.1. We bring into question the validity of the methodology and the results of some of BBC’s Draft Sustainability Appraisal. We summarise our points in relation to the Sustainability Appraisal below. Please note, we make extensive representations about the ‘Urban’ component of the Sustainability Appraisal and its Reasonable Alternatives in our ‘Urban and Settlement Capacity section’ – we request that BBC please ensures that those representations are captured in response to the Sustainability Appraisal as well as urban and settlement capacity (including previously developed land) more generally.
• As we state in the Urban and Settlement Capacity section of our representations, it is not reasonable to only show in Option 1a the potential ‘urban capacity’ and ‘adjoining urban areas’ as 1,500 dwellings each giving a total of 3,000 dwellings. As BBC states, these capacity figures are not based on any robust analysis of site availability or development capacity testing therefore this option will need to be revisited once the Council has done a proper capacity study.
• The rejection of Option 1b in the SA has not been justified as the Council cannot conclude that delivering 12,500 dwellings would require ‘extreme densities’ given that the Council has not fully assessed the land available in the urban area.
• If the urban capacity figures were increased to a reasonable level based on sound evidence base, the need to deliver development in less sustainable options such as new settlements or villages would likely not be required.
The SA scores the ‘urban area’ component as ‘negative’ against the air quality objective. It states that “concentrating development of all types in the urban area will mean that remaining areas receive no growth. This will have the effect of concentrating human activity (both long term and short term construction) which is the main cause of poor air quality. Much of the borough will therefore see no worsening of air quality, however the area within the urban area is likely to see worse air quality. This can be minimised with greater use of sustainable transport, which is more likely to occur with concentrated development patterns”16. Apart from being a confusing and contradictory assessment its overall conclusion is poorly considered. Clearly developing in the urban area where facilities and sustainable infrastructure are closest to the population they serve, reduces the need to travel and reinforces important investment in sustainable infrastructure such as Bedford Station and aligns with the Council’s stated Vision and Objectives. We consider this assessment against air quality for this component needs to be revisited.
• We question the SA assessment of ‘new settlements’ component in relation to ‘protect the quantity and quality of water sources’ which scores it as ‘positive’. It states that “locating growth in a few new settlements so that more are unaffected by development is likely to make it easier to protect the quality of water resources”17. We are confused as to the meaning of this statement and how BBC has arrived at such a conclusion.
• It is entirely unclear as to how BBC has merged the 6 development locations into
5. This approach has effectively ensured that the Dennybrook is classified under both point 4 (new settlements) and 5 (rail-based growth).
• Some of the promoted new settlements contain previously developed land whereas Dennybrook does not. We seek clarification as to how this has been taken into consideration in the Sustainability Appraisal as this should be an important factor for the technical assessments undertaken. This point highlights the lack of site specific details contained within the SA about particular sites which leads to the SA amounting to a theoretical exercise in many cases where the important constraints of a site or area have not been taken into account.