Object

Representation ID: 9988

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.

Aligned to our representation of the spatial strategy (Policy DS2(S), the 'village-related' growth component relating to settlements both inside and outside the 'east' and 'south' corridors would only be thoroughly tested if a 'hybrid' approach were applied to the spatial strategy informing the distribution of growth and used to inform site assessment and site selection under Policy DS5(S). This has not been undertaken, meaning that the distribution of growth identified in Policy DS5(S) is not justified, not effective and not consistent with national policy.

When village-related growth has been tested under the Sustainability Appraisal process, it has been done so with the presumption that all settlements at the same level of the hierarchy will have "flat" development quanta (500 units in Category 1 villages and 35 units in Category 2 villages).

Furthermore, the Council has not attempted to discriminate between settlements that are included in the A421 "transport corridor" as indicated by its own strategy choices (including, for example, Great Barford).It is not evident from the Council's assessment whether it genuinely feels these locations perform any differently against the objectives of the Local Plan or inform any differences in capacity for growth across the settlement hierarchy when considered in the context of the spatial strategy.

The SA for the Submission version Plan which appears to contradict the Council’s view that all village sites in all settlements should be treated in the same way and viewed as inconsistent with the spatial strategy (see Table at Para 9.13). In this table, ‘excluded’ ‘village’ sites do not include those in settlements such as Great Barford (where these form part of the identified transport corridors). It is not, however, clear from the Council whether it genuinely considers these perform any differently for the purposes of the spatial strategy or settlement hierarchy and the conclusion in the SHLAA is that sites in any village are ‘inconsistent’ with the strategy.

As a result, the spatial strategy and assessment of effects under the SA may in fact have distinct relationships with village-related growth in various settlements. Policy DS5(S) should therefore also reflect the distinction between ‘east’ and ‘south’ corridor parishes in terms of the distribution of growth.

The planned growth distribution only permits the completion of existing rural allocations; it does not place additional demands or opportunities on rural settings. In spite of this, the SA at paragraph 7.23 claims that housing development in rural regions might significantly contribute to satisfying housing needs and goes on to specify specific locations recommended for consideration, which seems to directly contradict the SHLAA Table 2.2 where all village-related sites are ruled inconsistent with the selected strategy based on the SA findings. As a result, specific rural locations are mentioned as viable choices without further detailed testing or allocation of growth.

Strategic policies should provide a housing requirement for designated neighbourhood areas that reflects the overall strategy for the pattern and size of growth and any applicable allocations, according to paragraph 66 of the NPPF2021. This is a significant change from the Framework's 2012 iteration. The testing of options by the Council for the Local Plan 2040, however, advances an arbitrary distribution of anticipated levels of growth in Key Service Centres and Rural Service Centres and fails to provide a housing requirement for specific rural settlements.

The potential benefits of village extensions in the east and south corridor parishes should be considered within this context as specifically complementing the distribution of growth within the selected strategy rather than restricting any opportunities outright. Despite this, options in these locations have not been subject to any further iterative testing prior to completion of the Plan for Submission.

The necessary iterative methodology is not evident in the Council's SA. Concerns highlighted by our client during earlier consultation rounds, particularly the requirement to evaluate "hybrid" possibilities for levels of expansion within the settlement hierarchy, have not been satisfactorily addressed by the Council. To expand further, a new "Option 8" that swaps Little Barford's "new settlement" growth for village-related development has been assessed and "rejected" in the Council's Sustainability Appraisal for the Submission version Plan. This conclusion, however, was made without thoroughly examining the potential for growth in specific settlements or individual site options.

The SA confirms that Great Barford and specific site options within village locations have only been the subject of early testing against a number of SA indicators. There has been no attempt to apply the identified combination of effects to any revised strategy option or against conclusions of the potential suitability (including provision of specific benefits) from individual site options.

We also have a number of concerns about the site assessment procedure, as is detailed in our Regulation 18 representations. In particular, we have previously raised serious concerns about the Council's assessment of our client’s land at Great Barford after submission as part of the Summer 2020 Call for Sites exercise. The site assessment pro-forma neglects to document or acknowledge the advantages connected with site development, such as the provision of green infrastructure. Concerns about the site's assessment in connection to ecology, BMV, and heritage assets have also been raised in the past.
Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.