Policy DS5(S) Distribution of growth

Object

Representation ID: 10231

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to Policy DS5(S) in so far as it identifies 3,800 dwellings to be provided at Little
Barford. Little Barford is undeliverable and undevelopable within the 2400 plan period as it is
reliant on the delivery of key rail infrastructure which does not currently exist, and is unlikely to
by 2030.
Please see attached representations…specifically section 3 paragraphs 3.1-3.28, para 5.6
bullet 4, section 6, Appendices A, B,C.

Object

Representation ID: 10237

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
The approach to rely on new settlements to deliver homes in the latter part of the plan is flawed as has been addressed, as it holds back 88% of the new allocations for the second half of the plan placing incredible burden on the first 10 years to deliver no less than might be needed.
Whilst it is noted that the distribution of growth identifies an excess of 1,274 dwellings above the requirement this does not go far enough to counter the very likely under supply from the new settlement strategy.
The distribution of growth policy reinforces the absence of any sites proposed on the edge of sustainable settlements. It also relies on the allocation of brownfield sites, some of which will be identified on the brownfield register. As indicated by the NPPF (para 23) these sites should not be allocated in the plan where they are identified in the register. Potentially this allows a redistribution of up to 1,200 units to the rural areas or the edge of the Urban Area to deliver vital homes in the first ten years of this plan.

Object

Representation ID: 10244

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
The approach to rely on new settlements to deliver homes in the latter part of the plan is flawed as has been addressed, as it holds back 88% of the new allocations for the second half of the plan placing incredible burden on the first 10 years to deliver no less than might be needed.
Whilst it is noted that the distribution of growth identifies an excess of 1,274 dwellings above the requirement this does not go far enough to counter the very likely under supply from the new settlement strategy.
The distribution of growth policy reinforces the absence of any site’s proposed on the edge of sustainable settlements. It also relies on the allocation of brownfield site’s, some of which will be identified on the brownfield register. As indicated by the NPPF (para 23) these site’s should not be allocated in the plan where they are identified in the register. Potentially this allows a redistribution of up to 1,200 units to the rural areas or the edge of the Urban Area to deliver vital homes in the first ten years of this plan.

Object

Representation ID: 10256

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
The approach to rely on new settlements to deliver homes in the latter part of the plan is flawed as has been addressed, as it holds back 88% of the new allocations for the second half of the plan placing incredible burden on the first 10 years to deliver no less than might be needed.
Whilst it is noted that the distribution of growth identifies an excess of 1,274 dwellings above the requirement this does not go far enough to counter the very likely under supply from the new settlement strategy.
The distribution of growth policy reinforces the absence of any sites proposed on the edge of sustainable settlements. It also relies on the allocation of brownfield sites, some of which will be identified on the brownfield register. As indicated by the NPPF (para 23) these sites should not be allocated in the plan where they are identified in the register. Potentially this allows a redistribution of up to 1,200 units to the rural areas or the edge of the Urban Area to deliver vital homes in the first ten years of this plan.

Object

Representation ID: 10342

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

SECTION TEN: CONCLUSION

Elstow Parish Council recognises that the A421, A6, East West Rail and Midland Mainline railway are travel corridors which would support development along part of their routes south of Bedford but would also point out that the A6, East West Rail and Midland Mainline all go north from Bedford as well, and therefore should attract a fair share of development along this part of their routes. This sharing should include some development in the communities north of Bedford and should not concentrate solely on development along the A421 corridor to the south of Bedford.

Elstow is a relatively small village with a rich history and heritage and local residents are attracted to the village by its proximity to the countryside. This rural character must not be detrimentally affected. Whether it is the threat of being urbanised or the threat of coalescence as Wixams again extends across the fields in the direction of Elstow.

There has been representation within the consultation done in a misleading way to all stakeholders in this consultation process as set out earlier in this document.

With a number of areas where the Parish Council has highlighted HOU5 and EMP5 are against existing planning policy. In addition to raising the weak planning policy wording within the draft local Plan 2040 which will not safeguard and protect the existing local communities.

Object

Representation ID: 10350

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

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.

Bedfordia has engaged at all previous consultation stages undertaken as part of plan-making for the Local Plan 2040. These representations should be read alongside the detailed Regulation 18 representations (Representation ID: 7450) submitted previously. Our client’s land has been registered under Site ID 832 (Land at Station Road, Oakley) and is considered capable of accommodating around 210 dwellings additional to those allocated within the ‘made’ Oakley Neighbourhood Plan.

These representations should be read alongside the Site-Specific Statement – Land at Station Road, Oakley and Spatial Strategy and Legal Compliance Representation Report, both of which are appended.

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.

The Sustainability Appraisal process has examined village-related growth only with the assumption 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). No testing of individual site options has been undertaken before determining that the village-related component of growth should be rejected altogether as inconsistent with the selected strategy.
This overlooks that both the Council’s own SA and 2021 Development Strategy Topic Paper anticipate scope for further refinement in the testing of site options.

The planned growth distribution does not create new demands or opportunities for rural areas; it only allows for the fulfilment of existing rural allocations. Despite this, the SA at paragraph 7.23 asserts that housing development in rural areas may significantly contribute to meeting housing needs and goes on to list specific locations that should be taken into account. Particularly emphasis is placed upon locations within or adjacent existing settlements i.e., criterion which capture our client’s Land at Sharnbrook. This appears to directly conflict with the SHLAA Table 2.2 where all village-related sites are ruled inconsistent with the chosen strategy based on the SA findings. As a result, various rural areas are suggested as possible options without more in-depth assessment or expansion allocation.

According to paragraph 66 of the NPPF2021, strategic policies should stipulate a housing requirement for designated neighbourhood areas that reflects the overall strategy for the pattern and scale of growth and any related allocations. From the 2012 iteration of the Framework, this is a significant change. However, the Council's testing of options for the Local Plan 2040 neglects to consider any identification of housing requirements for designated neighbourhood areas beyond the distribution of growth within the Local Plan 2030.

The potential benefits of village extensions across the borough 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 Council has not adequately addressed issues raised by our client during earlier consultation rounds, particularly the need to consider "hybrid" options for degrees of expansion within the settlement hierarchy. To further elaborate, a new "Option 8" that substitutes village-related development for Little Barford's "new settlement" growth has been evaluated and "rejected" in the Council's Sustainability Appraisal for the Submission version Plan. However, this result was reached without fully analysing the possibility for growth in particular settlements or site options.
The SA confirms that Oakley 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.

These issues particularly affect Oakley due to its existing classification as a Rural Service Centre and the associated distribution of growth under the Local Plan 2030. As such, the deferral of allocations to Neighbourhood Plans was a fundamentally inadequate mechanism to address strategic priorities related to school place provision at Lincroft Academy or to safeguard the longer-term requirements of this facility and opportunities for sustainable development east of Station Road. These are priorities that can only be addressed as part of site assessment and site selection for the current plan-making process.

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 Oakley 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, specifically the enhancement of services and facilities at Lincroft Academy. Concerns about the site's assessment in connection to ecology, BMV, and heritage assets have also been raised.
Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.

Support

Representation ID: 10385

Received: 29/07/2022

Respondent: Bletsoe Parish Council

The Parish Council welcomes Policy DS5(S) in so far as it outlines the distribution of growth by location and takes into account existing commitments. This factors in the growth envisaged by adopted neighbourhood plans in rural areas, and it recognises that some Parish Councils may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs.

Object

Representation ID: 10392

Received: 29/07/2022

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5 (S) Distribution of growth – This policy confirms that 50ha of employment land will be delivered within the growth locations on the A421 transport corridor and with the potential for rail based growth. This policy allows for some housing development (400 dwellings) beyond the plan period but no allowance is provided for employment land. It is unclear why the Council has adopted a different position in respect of employment and housing.

Object

Representation ID: 10418

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The current Core Strategy identifies, Great Barford as containing 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area'. The strategy alighted upon for the Regulation 19 plan however, whilst continuing to identify the role of Great Barford as a Key Service Centre, does not seek to identify a single additional home to the village, beyond that already committed through the current Core Strategy and identified via the Neighbourhood Plan.

Objection is raised to the overarching spatial strategy's reliance on a limited number of large sites to deliver the new homes required for the Borough. This is at the total exclusion of growth within sustainable settlements such as Great Barford, which are capable of accommodating additional growth on smaller sites well related to the urban fabric. These would be capable of early delivery, thereby avoiding the need for a stepped trajectory, and would meet need both when it arises, and within sustainable locations.

Objection is raised to the Local Plan Policies DS2(S), DS3(S) and DS5(S), on the grounds that these key policies embed an unsustainable growth strategy for the Borough, which fails to have regard to the evidence base, and which fails to follow through on the recognition of the settlement hierarchy, notably, larger villages such as Great Barford, which are identified as Key Service Centres and for which no new allocation is made for the plan period. In this case, the provision of a stepped trajectory, thereby denying the requirements of those in housing need today, is considered to be an unnecessary deferral of delivery. It also requires a significant uptick on historic delivery rates, over rates achieved in recent years. A strategy which draws on some smaller/medium sized sites, capable of faster delivery, would be more sustainable as p art of an overall balance which might still favour longer term delivery through large sites.

Lone Star have concerns regarding the reliance within the Regulation 19 Local Plan on use of a stepped trajectory, as set out in Policy DS3(S). The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.

The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6
- 10. The National Planning Policy Framework ("NPPF") does not support the deferral of meeting the known housing requirement to beyond year 10. Planning Practice Guidance (68 - 0 21) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.

The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.

To achieve this objective of national policy guidance, to meet the housing requirement with positive site allocations in years 1 to 10 of the plan or at least broad areas of growth from beyond year 5, the plan should balance away from such a heavy reliance on freestanding large new settlements. Currently, the Reg 19 plan speculates that the step might shift from 970 dw/yr up to 2030, with 1,5700 dw/yr beyond 2030, i.e. deferring 17,000 of the Plan's 27,10 0 dw requirement to later in the plan period.

The Council are therefore invited to review the trajectory of delivery for their Regulation 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.

With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as Great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy should reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.

For the above reasons the identified Policies DS2(S), DS3(S) and DS5(S), are considered unsound as they are neither Positively Prepared, Justified, Effective, nor consistent with National Policy .

Object

Representation ID: 10431

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

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.

This representation relates to a site at land to the west of Clapham which did not form part of the 2020 Call for Sites exercise but should in any event have been subject to assessment by the Council as part of a positive approach to site identification in accordance with national policy and guidance (ID: 3-010-20190722).

This representations form should be read alongside the supporting Site Specific Representation Report – Land Adjacent Milton Hill, Clapham and the Spatial Strategy and Legal Compliance Representation Report that provides full details related to the site and the Council’s evidence base relating to the assessment of site options in this location and across the wider Borough. A Site Location Plan can be found in the accompanying Site-Specific Representation.

The site at Clapham is directly adjacent to the 806 Milton Hill Neighbourhood Development Plan allocation but lies just outside of the Parish boundary. The site is therefore located within the Oakley Parish and as such could not be allocated through the Clapham Neighbourhood Plan. Given the proximity to the allocated land and location within an identified growth location, the site presents an excellent opportunity to deliver additional growth to the settlement, which is recognised for its sustainability credentials as a Key Service Centre. Were it not for the effect of the administrative parish boundary geography upon the extent of the designated neighbourhood area the site would likely have been allocated as part of 806 Milton Hill. The evidence base for the Neighbourhood Plan, including a Design Code exercise covering the entire site area, is reflective of this.

The land allocated within the Clapham Neighbourhood Plan is currently the subject of a planning application, the details of which provide for all future infrastructure and services requirements necessary to enable the additional capacity for development on our clients’ adjacent land.

In the case of Clapham, the suitable extent of the preferred direction of growth west of the village has been arbitrarily limited by the extent of the designated neighbourhood area (based on parish boundaries) precluding the most effective use of land in this area. To achieve the objectives of the upcoming Local Plan 2040 higher rates of village-related growth must be promoted from the beginning of the 2020–2040 plan period. Details of suitable, available and achievable site options such as our client’s land adjacent Milton Hill provide one such opportunity that would complement the existing spatial strategy and would not in isolation materially affect the proposed approach in the Plan for Submission.

The Council’s assessment of housing requirements and site options within designated rural settlements is unsound. Despite the requirements set forth in Policy 1 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 in respect of housing land supply, rural vitality and the application of a stepped trajectory. The adoption of a Stepped Trajectory and the deliverability of the sites included in the Council’s trajectory is considered in the Bedford Local Plan 2040 Deliverability Assessment Update appended to the Spatial Strategy and Legal Compliance Representation.

Sites within rural settlements were disregarded at the initial stage of testing, as described in the SHLAA, solely on the grounds that they ran counter to the preferred spatial approach. Due to the apparent predetermination of the preferred approach and the unjustified decision to reject all village-related growth, it appears that Council has decided against evaluating all alternative options for growth. This fundamentally restricts the assessment of this component's potential contribution to an appropriate spatial strategy.

This circular reasoning cannot be used to support the conclusion that site suitability assessments and detailed or iterative testing of strategy options for levels of growth in the rural area (or at specific settlements) should not be conducted beyond that undertaken prior to the Regulation 18 consultation stage. Regardless of whether the Council will unjustifiably assert that it has "run out of time" to examine the situation in more detail, the Council's position is in direct conflict with paragraph 3.10 of the 2021 Development Strategy Topic Paper, which serves as the basis for the Regulation 18 Draft Plan.

In respect of village-related growth, considered under option 3c, the Topic Paper indicates highways constraints as a reason to reject this strategy. This is considered in detail in the Technical Note appended to this submission which was prepared and submitted in respect of our client’s wider land interests in September 2021. As is detailed in the Technical Note, the AECOM report focuses primarily on the evaluation of development in Bedford being given in the form of "either" a new community at Colworth or Twinwoods, or both. The local road network's capacity to support a more varied pattern of expansion among nearby communities as opposed to just at Colworth / Twinwoods does not appear to have been evaluated.

Specific capacity analyses have not been conducted for individual settlements. The Settlement Hierarchy Addendum reaffirms this (April 2022). The Council has simply decided not to evaluate whether the settlement hierarchy outlined in the 2030 Plan needs to be changed because no new allocations or expansions were planned in the major rural service centres.

The planned growth distribution is therefore only intended to enable the fulfilment of the existing rural allocations; it does not generate new demands or opportunities for rural areas.

This is a specific issue for Clapham where our client’s land adjacent Milton Hill would complement an established direction of growth. The SA at paragraph 7.23 asserts that housing development in rural areas may nonetheless significantly contribute to meeting housing needs and goes on to list specific locations that should be taken into account, which appears to be in direct conflict with the SHLAA Table 2.2 where all village-related sites are ruled inconsistent with the chosen strategy based on the SA findings. As a result, a number of rural locations are recommended as potential choices without a more thorough analysis or allocation for expansion.

The logic of the Council’s approach is particularly flawed in relation to Clapham, where Site ID: 3234 (corresponding to land allocated in the Clapham Neighbourhood Plan) is rejected from both sources due to its perceived inconsistency with the Plan’s spatial strategy despite having been identified as a suitable, sustainable and preferred direction of growth for the settlement.

Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.

Object

Representation ID: 10436

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd

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.

These comments should be read in conjunction with our clients Regulation 18 representations (Representation ID: 8572 / Site ID: 1247) which are appended to a Site-Specific Representation and which provides detailed comments on the proposed strategy and specific details relating to our client’s land interests. In addition to the Site Specific Representations Report, which contains an updated Site Analysis Document showing how the site could deliver up to 120 dwellings, these representations should be read alongside the supporting Spatial Strategy and Legal Compliance Report.

The Site Analysis Document and Regulation 18 representations detail how the site could deliver the green infrastructure priorities set out in adopted (and proposed saved) policies AD24 and 36S. It is within the context of a site capable of delivering meaningful residential development in the Kempston Rural area, that these representations are made.

In theory, it is positive that the Council's Preferred Option includes development at the urban edge within Kempston Rural Parish, which also forms part of the ‘transport corridor’ south parishes within the selected strategy.

It is particularly encouraging to see this location recognised as being sustainably located to existing services and facilities. This is thought to illustrate the seamless connections between the parish's growth pattern—particularly at Green End—and the services and amenities found in the urban area. The sustainability of this location is presumed to be acknowledged when the Council specifies a number of 1,500 for sustainable locations adjacent to the urban area without mentioning any settlement- or site-specific distribution within the policy.
Aligned to identified concerns in respect of the stepped trajectory and approach to site assessments, set out in further Regulation 19 representations, we consider it necessary that the Council, through a Main Modification, recognise the benefits associated with our client’s land at Green End, and the ability of the site to contribute to delivering the housing requirement in the early part of the Plan period. Accordingly, we propose a modification set out below.

It is also pertinent to note in respect of the site assessment process that there appears to be considerable inconsistencies in the way sites within the same component of the spatial strategy have been tested from the very first assessment in the SHLAA. This is true of the way in which the proposed allocation at Gibraltar Corner (636) and our client’s land at Green End (1247) have been considered in the SHLAA, despite the fact that they are adjacent to each other, as demonstrated on in the appended Site Analysis Document.

In particular we refer to the fact that against three scoring criteria, namely 5a. Likely to increase future economic and employment opportunities, 11a. At risk of flooding and 15c. Accessible on foot to a primary school, the Green End site scores better than the Gibraltar corridor site, with the scores for all other categories the same for both. It is therefore surprising to see that the Green End site did not progress for further assessment on the basis of conflict with the preferred spatial strategy alone, whilst no such outcome was referenced in respect of Gibraltar Corner.

Accordingly, we consider that the site assessment process has failed to apply a consistent approach and in line with our outlined concerns in respect of the SA, we object to the policy as drafted. Modifications to recognise our clients land, which performs better than the Gibraltar Corner site, are necessary to ensure that the Plan and proposed approach to site selection adjacent the urban edge is capable of being found sound.

Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively Prepared, Justified, Effective or Consistent with National Policy.

Object

Representation ID: 10445

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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.

Site IDs 918 (Land at School Approach) and 932 (Land east of Odell Road, Sharnbrook) detail the land interests of our clients. As part of the Council's Summer 2021 Preferred Plan Options and Draft Policies consultation, these interests were the focus of thorough statements and comments on the proposed strategy (Representation ID: 9000). The Council's Submission Plan does not address the problems raised previously, and it remains the case that our clients’ land interests have not undergone the necessary additional comprehensive or iterative assessment.

These representations should be read alongside previous submissions appended to a detailed Site-Specific Representations Report – Land at ‘Stoneyfields’, Sharnbrook and Spatial Strategy and Legal Compliance Representation Report.

Two alternative options for growth have been proposed. The first would see the land at Odell Road come forward for up to 397 dwellings, whilst the smaller parcel at School Approach is capable of accommodating a standalone c.100 dwellings. Together the two parcels provide for a comprehensively masterplanned development of around 500 dwellings known as ‘Stoneyfields’ and capable of providing substantial benefits to the wider community including delivery of a new Riverside Park, ecological enhancement and land for a new local centre.

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.

The Sustainability Appraisal process has examined village-related growth only with the assumption 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). No testing of individual site options has been undertaken before determining that the village-related component of growth should be rejected altogether as inconsistent with the selected strategy. This overlooks that both the Council’s own SA and 2021 Development Strategy Topic Paper anticipate scope for further refinement in the testing of site options.

The planned growth distribution does not create new demands or opportunities for rural areas; it only allows for the fulfilment of existing rural allocations. Despite this, the SA at paragraph 7.23 asserts that housing development in rural areas may significantly contribute to meeting housing needs and goes on to list specific locations that should be taken into account. Particularly emphasis is placed upon locations within or adjacent existing settlements i.e., criterion which capture our client’s Land at Sharnbrook. This appears to directly conflict with the SHLAA Table 2.2 where all village-related sites are ruled inconsistent with the chosen strategy based on the SA findings. As a result, various rural areas are suggested as possible options without more in-depth assessment or expansion allocation.

According to paragraph 66 of the NPPF2021, strategic policies should stipulate a housing requirement for designated neighbourhood areas that reflects the overall strategy for the pattern and scale of growth and any related allocations. From the 2012 iteration of the Framework, this is a significant change. However, the Council's testing of options for the Local Plan 2040 neglects to consider any identification of housing requirements for designated neighbourhood areas beyond the distribution of growth within the Local Plan 2030.

At Sharnbrook, the Local Plan 2040 specifically fails to recognise that the ‘made’ Neighbourhood Plan allocates growth at a location divorced from the main settlement (upon Land at Hill Farm). The Neighbourhood Plan does not support the development of land well-related to the existing village and previously identified as Preferred Options by the local planning authority, including our client’s Land at Sharnbrook. However, in terms of the requirements of national policy and guidance this does not preclude sound plan-making in terms of requiring an assessment of site options and identification of an appropriate housing requirement for the designated neighbourhood area particularly where this would provide a number of additional benefits for the local community and housing delivery.

The Council has not adequately addressed issues raised by our client during earlier consultation rounds, particularly the need to consider "hybrid" options for degrees of expansion within the settlement hierarchy. To further elaborate, a new "Option 8" that substitutes village-related development for Little Barford's "new settlement" growth has been evaluated and "rejected" in the Council's Sustainability Appraisal for the Submission version Plan. However, this result was reached without fully analysing the possibility for growth in particular settlements or site options.

The SA acknowledges that Sharnbrook and individual site options within village locations have only undergone preliminary testing against a number of SA parameters. No attempt has been made to compare the observed combination of effects of the selected strategy to any iterative approach that considers judgements on the suitability (including the availability of specific benefits) from different site options.

Given the identified delays with the delivery of land allocated within the Sharnbrook Neighbourhood Plan, we consider that our clients land in Sharnbrook should be considered in detail, with an acknowledgement that delivery could contribute towards housing need within the early part of the plan period and assist the Council maintain a sufficient supply of housing.
These benefits specifically relate to the parcel of our client’s Land at School Approach, which can be provided either as a standalone scheme for 100 units or as part of the comprehensive Stoneyfields Masterplan proposals.

Therefore, as drafted we consider that Policy DS5(S) is unsound as it is not Positively
Prepared, Justified, Effective or Consistent with National Policy.

Object

Representation ID: 10470

Received: 29/07/2022

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Please see accompanying Representations Report Paragraphs 3.39 – 3.52

As part of the Summer 2021 Consultation upon Preferred Strategy Options and Draft Policies (para 1.45) the Council identified that a review of the settlement hierarchy was ‘underway’.

In relation to our client’s interests at Lincroft Academy Site ID: 832 / 839 the Council’s proposed spatial strategy and distribution of growth is not supported. MAT further objects to the failure to revise Oakley’s classification as a Rural Service Centre as part of determining the spatial strategy and distribution of growth as an outcome of the plan-making process.
MAT support in principle Modifications to the distribution of growth outlined in Policy DS5(S) that would enable delivery of the Land East of Station Road and the wider benefits identified.
The delivery facilities for the school upon this land (including relocation of the sports pitches) is outside of the current (unfunded) project costs of £8m associated with the minimum requirements for expansion within the existing campus West of Station Road. This does not, however, preclude assessment of MAT’s interests East of Station Road as part of safeguarding future opportunities for expansion and improvement in-tandem with the delivery of the minimum requirements identified nor does it preclude recognition of the wider potential benefits of the additional land in terms of enhancement of the identified project costs and a potential source of additional funding.

Object

Representation ID: 10501

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam objects to the proposed distribution of growth, which is linked to concerns with the proposed spatial strategy in Policy DS2(S) and amount and timing of growth to be delivered expressed in Policy DS3(S). In this context the policy undermines the soundness of the plan.
Hallam considers that the proposed distribution is heavily skewed towards the Growth Locations on the A421 Corridor and with the potential for rail based growth. The overreliance is reflected in, and predicated upon, the stepped housing trajectory, which as a result of longer lead in times to allow for adequate infrastructure investment will result in rates of delivery well below the annual housing requirement of 1,335 dwellings until 2030/31. The primary objection is that this distribution of growth suggests a restriction in the supply of smaller sites, relying on those currently allocated to deliver housing below the average rates of delivery achieved over the last six years, which is evidenced to be at an average rate of 1,192 dwellings per annum (Bedford Borough Council Interim Housing Monitoring Report 2020-2021). Moreover it may be served to preclude the delivery of other highly sustainable options for contributing to the growth objectives of the Plan. In representations on Policy DS2(S)the clear case for the inclusion of Clapham within the Spatial and Distribution Strategy is made. Specifically, in particular the opportunity should be taken to accommodate additional numbers at the settlement or to redirect allocations from the south of the town where the overconcentration of allocations leads to the greatest impacts in terms of transport and infrastructure.
The NPPF, in paragraph 60, requires a sufficient amount and variety of land to come forward where it is needed. The NPPF later states in paragraph 68 that planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and viability. Consistent with Hallam’s rationale that underpins the requested modifications to the Policy DS2(S) Spatial strategy and Policy DS3(S).

Comment

Representation ID: 10529

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS5 (Distribution of Growth) sets out where housing and employment growth will be located, which is as follows:
(extract of table in Policy DS5)
As set out in further detail above, it is considered that in order to be ‘sound’, further housing growth should be directed to already accessible locations in urban areas other than Bedford, in order to ensure the needs of the Borough are met.
Paragraph 69 of the NPPF states that medium sized sites such as Land at Rushden Road can make an important contribution to meeting the housing requirement of an area, as they are often built out relatively quickly. The Site at Rushden Road would not rely upon the delivery of any major infrastructure in order to be considered a sustainable / suitable location for new development. The Site therefore provides the Council with the opportunity to deliver growth in accordance with the needs of Bedford relatively early on in the Plan period.