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

Representation ID: 9063

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Representation Summary:

6.1. At the heart of the NPPF is a presumption in favour of sustainable development. Plans and decision should apply a presumption in favour of sustainable development. The NPPF explains what this means for plan-making with making effective use of land in urban areas at the heart of mitigating climate change stating that (our emphasis added):
"all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects”
6.2. Section 11 of the NPPF is called ‘Making effective use of land’. There are a number of important requirements set out in this section of the NPPF for plan-makers including the following:
• “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land”20
• “give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”21
• “promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure)”22
• “Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.”
6.3. Given that the NPPF places such great weight and emphasis on the need to make the most effective use of previously developed land and land within settlements it is surprising how little the Draft Local Plan and its evidence have to say about how the Council intends to comply with the NPPF as part of its plan-making.
6.4. We note that the key point of the Issues and Options consultation was that urban based developed (along with A421 and rail-based growth) was the most strongly supported by consultees:
“The results are reported in full in the Issues & Options Consultation - summary and responses document and the key point was that the (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth.”
“The most common combination put forward by respondents was urban (brown) with A421 (yellow).”
6.5. BBC’s Development Strategy Topic Paper explains that one of the five ‘components of growth’ it has tested is ‘within the urban area (sites within the urban area boundary)’. BBC explains that the Sustainability Appraisal (SA)concluded that the ‘within the urban area’ component performed the best of all of the potential components:
“In relation to the broad components of growth, the sustainability appraisal found that the within the urban area component performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth.”
6.6. BBC explains that following the SA work more detailed work was undertaken to generate specific strategy options based on different combinations of the broad components using the remaining housing target of 12,500 dwellings and employment land target of 123 hectares. BBC states that the assumptions had to be made about the capacity of each ‘broad location for housing and employment growth’ however this phrase ‘broad location’ is not explained elsewhere which is confusing. BBC explains that the capacity assumptions are informed not by the Council’s own work but simply through the quantum of development put forward through the call for sites process and that further testing will take place following this current consultation. This is a very important point that the Council has not undertaken any assessment of its own as to the potential development capacity of sites and locations in the borough. It is neglectful of BBC to even consider it possible to assess development strategy options let alone select a number of preferred options without having properly assessed site constraints, the realistic capacity of the sites or broad areas being promoted by developers and landowners.
6.7. Regarding the ‘urban component of growth’ BBC explains that given that it performs most strongly “the assumption for the urban and adjoining areas is deliberately ambitious” explaining that: “Development at scale in some parts of the urban area will be challenging and will require comprehensively master planned proposals and may require land assembly powers and significant investment in the infrastructure necessary in order to deliver the development”
6.8. In the following section of the Development Strategy Topic Paper it summarises the development assumptions for options generation with ‘sites within urban area’ showing 1,500 dwellings. BBC has confirmed to us that this assumption is not based on actual sites in the ‘urban area’ and only based on sites submitted to the Council so this figure is entirely unreliable and seems extremely low. BBC’s options that it tests include this 1,500 dwelling figure for the ‘within urban area’ component of growth for Options 1a, 2a, 2b, 2c, 2d, 3a, 3b, 3c and then show 12,500 for Option 1b. BBC rejects Option 1b as it states that it is “Theoretically possible to meet residential growth needs but the densities required would have unacceptable significant impacts”
6.9. How can BBC possibly come to this conclusion when it has not undertaken its own assessment of previously developed land and settlement capacity for Bedford and the other settlements? In terms of the other options it holds the ‘within urban area’ and ‘adjoining urban area’ at a constant of 1,500 dwellings for each component respectively. There is clearly no logic to the housing numbers and shows a serious lack of sensitivity testing of a range of potential urban and settlement capacity assumptions for the options generated by the Council. Clearly if the ‘urban’ and ‘adjoining urban’ components had higher capacity yields then they would form a greater percentage of the overall housing targets and result in less need for housing elsewhere in the borough including the new settlement options. The performance of any option with an increased urban capacity would increase in terms of its performance in the Sustainability Appraisal given that this is the most sustainable location for BBC to plan its future growth.

INCLUDES TABLE OF OPTIONS FROM P23 OF DEVELOPMENT STRATEGY TOPIC PAPER

6.10. We have so many questions that are left unanswered regarding BBC’s approach to assessing its urban and settlement capacity (and previously developed land) which we set out below:
• What does BBC consider to be the ‘urban area’?
• Does BBC only consider the urban area of Bedford town for its previously developed land capacity?
• Does BBC not consider previously development land in the other settlements in the borough apart from Bedford for its development capacity?
• The NPPF expressly requires that authorities need to make as much use as possible of previously developed and brownfield land in the borough – how can BBC demonstrate that it has made any material steps towards fulfilling this requirement?
• How has BBC taken into consideration the potential release of some of its employment sites for potential housing development? We note that there are at least 16 existing employment sites assessed as ‘monitor and manage’ in the Council’s Employment Land Review. Have these been assumed as part of the potential supply of land that could be identified and released for housing?

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