Object

Representation ID: 9984

Received: 29/07/2022

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to this policy. The approach is not legally compliant in respect of the Sustainability Appraisal and Duty to Cooperate processes and fails all four soundness tests.

Old Road Securities (ORS) has engaged at all previous consultation stages undertaken as part of plan-making for the Local Plan 2040. Details of our client’s land interests are registered under Site IDs 604 (Land off Roxton Road (c.100 units) and 645 (500 units known and ‘Willoughby Park’). Indicative Masterplans for both options are provided as Appendix 1 and 2 to this form. These interests were the subject of detailed representations and comments on the proposed strategy as part of the Council’s Summer 2021 Preferred Strategy Options and Draft Policies consultation. Issues identified with the proposed approach have not been addressed as part of the Council’s Plan for Submission nor have our client’s site interests been subject to any further detailed or iterative testing, as required. As such, these representations should in conjunction with our client’s previous submissions, full details of which are contained at Appendix 3.

The Development Strategy Topic Paper contains the rationale used by the
Council to justify its approach to spatial strategy. It sets out an approach which will focus development on the urban areas, strategic opportunities adjacent to the Bedford urban area and growth locations on the East West Rail / A421 transport corridor.

In regard to development in the rural areas, the policies of the Plan seek to limit growth to the completion of strategic Key Service Centre and more limited Rural Service Centre residential development identified in Local Plan 2030.

Despite the fact that the Local Plan 2030's growth distribution was derived under the former NPPF2012 and only extends through 2030, there is no method within the plan or supporting evidence base to identify housing needs for designated rural areas. By presenting an either/or choice between expansion in the A421 and the identified rail-based development corridor or alternatively within the ‘rural areas’, the Council has effectively excluded growth connected to villages as a component of its chosen strategy.

It is fundamentally unsound that Policy DS2(S) seeks to provide for a far more limited scope for development to meet identified priorities for the rural area than Policy 3S of the Local Plan 2030 that it is proposed to replace. Policy 3S provides in principle for the recognition of growth in Key Service Centres delivering enhancement to services and facilities, whereas Policy DS2(S) and the spatial strategy as proposed does not make any such commitment either as part of meeting additional housing needs prior to 2030 or over the full plan period to 2040.

This is compounded by the failure to consider specific capacity analysis for individual settlements. The Settlement Hierarchy Addendum reaffirms this (April 2022). The Council has simply decided not to evaluate whether the settlement hierarchy or capacity of individual locations such as Great Barford, as outlined in the 2030 Plan, needs to be changed. The Council has failed to assess in detail either the suitability of individual site options against existing and emerging policy or the relationship of site options to the characteristics and services of individual settlements in order to inform this view. This is not consistent with NPPF2021 paragraphs 20, 66, 68 and 79 nor PPG IDs ID: 41-101-20190509 and 3-018-20190722. The Council simply states that it has not looked at amendments to the settlement hierarchy or a more flexible approach to the distribution of growth because no new allocations or expansions were planned at Rural Key Service Centres under the selected strategy (see Supporting Document ID: 24 Addendum paras 5 and 4).

Although the growth distribution of the Local Plan 2030 was generated under the former NPPF2012 and only goes through 2030, there is no mechanism within the plan or associated evidence base to evaluate housing needs for designated rural centres. By presenting an either/or choice between large-scale strategic growth or extension of the urban area in the selected A421 and rail-based development corridors and development in rural areas, the Council has practically eliminated growth related to villages as a component of its preferred strategy. There is absolutely no evaluation of the degree to which these elements of an appropriate strategy could work in harmony rather than opposition to one another.

The reason the Council is unable to complete this assessment is that, as part of its site assessment process, it did not produce enough evidence to identify potentially suitable levels of growth from individual site options at specific settlements within the hierarchy before selecting or rejecting the potential contribution to growth from the rural areas in its entirety.

We specifically take issue with the district's evaluation of rural settlements. Despite the requirements set forth in Policy 1 of the Local Plan 2030 (necessitating immediate review) and modifications to national policy and guidance, the Council has not altered the method used to evaluate reasonable alternatives in this component of the settlement hierarchy from that used to evaluate the adopted Local Plan 2030. This is the cause of the issues that have been identified. The Council has simply refused to decide whether or not any potential site option is suitable before beginning its assessment of strategy options that exclude the village-related component of growth.

Aligned to this, but more broadly, the Development Strategy Topic Paper confirms that there hasn't been any attempt at a more thorough testing of all feasible alternatives, including development in rural areas; with only the preferred approach having been assessed robustly, and even then, only specific aspects of the transport corridor strategy have been thoroughly tested.

The Council's proposed trajectory for the Local Plan 2040, demonstrating an over reliance on strategic scale development, will exacerbate existing problems with delayed and slow delivery of allocated sites, rendering ineffective even its suggested "stepped approach" to housing requirements.

The Council's position is further undermined by the simple fact that there is insufficient information to demonstrate that rail-based expansion in the A421 corridor is feasible before years 11 through 15 of the plan period, if not later. This result of this is an almost immediate supply issue which can only reasonably be addressed by the allocation of small/medium sized sustainable sites across the rural area. Providing a choice of locations for growth will ensure that market saturation is avoided and will support rural vitality in line with the requirements of the NPPF and NPPG.

As set out in our client’s previous representations the scope for development in the "east" and "south" corridor parishes and support for expansion at Great Barford under Option 2d of the Council’s Strategy Options, under the framework of a "hybrid" approach, would be supported in principle. This acknowledges that rural areas can contribute to sustainable development, particularly in early stages of the plan period.

The Council has simply not progressed its evidence base sufficiently in order to assess individual site options or to assess the potential positive effects of growth at settlements within the A421 transport corridor (and to counter dis-benefits of likely delays to delivery of the selected strategy) in a manner that would justify it excluding further village-related growth from this aspect of the spatial strategy

To achieve the objectives of the emerging Local Plan 2040 we consider it necessary to support further village extensions, including at Great Barford, with our client’s land available at two different scales (100 and 500 dwellings), suitable, and with development achievable that would secure contributions to sustainable development as assessed favourably in the initial Sustainability Appraisal indicators (including new green infrastructure, community facilities and opportunities for recreation).
Therefore, as draft we consider that Policy DS2(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.