Object

Representation ID: 9599

Received: 27/07/2022

Respondent: Andrew and Robert Tusting

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is our view, for the reasons set out below, that the Local Plan is not sufficiently justified, is not effective and is not consistent with National Policy. It therefore fails to meet the legal tests of soundness.
Policy DS2(S) Spatial Strategy
2.3 The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives or is likely to be deliverable.
Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Oxford to Cambridge Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement:
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need.
2.7 As detailed in response to Policy DS3 and DS5, there seems a reluctance by the Council to allocate further growth to the Rural Services Centres despite the acknowledged available capacity and the benefit being that proportionate growth would be delivered earlier in the Plan period, rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and withe current cost of living crisis, failure to deliver housing in settlements such as Harrold will result in more and more people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth throughout the Plan period also, to ensure they do not age and stagnate.
Land west of Odell Road, Harrold has demonstrated that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars, public transport and cycling. Moreover, due to an increased prevalence in home working and online deliveries, people are able to live more sustainably in what was traditionally considered to be a less sustainable location.
2.9 The Plan and Strategy also has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.