Plan for submission evidence base

Object

Representation ID: 9930

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

OBJECT:
I. The supporting SA which seeks to justify the back-loaded delivery strategy / stepped trajectory is flawed. The SA simply concludes that the stepped trajectory’s implications for housing delivery will be ‘? uncertain’ (SA, Appendix 8, page 113, SA Objective 12).
II. For such a significant issue which goes to the heart of the whole plan and could hinder achievement of sustainability objectives for economic growth (SA objective 5), providing for residents’ needs (SA objective 13) and social cohesion (SA objective 14) as well as people’s quality of life, health and well-being, this lack of evidence and testing is a significant omission.
III. The SA rejects the entirely reasonable alternative (a central requirement of NPPG001 – SEA and SA) of delivering homes on non-strategic sites in otherwise sustainable locations - to Key Service Centres and Rural Service Centres - on the crude assumption that such locations will result in increased car dependency with associated negative consequences in terms of CO2 emissions and air quality. Spatial option 3c was dismissed on this basis and ‘village related growth’ considered the worst component of the strategy (SA paragraphs 7.10, 7.23 and 8.13). However, the Council have not properly assessed the capacity of the KSCs and RSCs to accommodate sustainable growth – there is no assessment of sites or individual settlements as part of the SA process.
IV. This is despite the site-specific assessments in the SA showing site options which perform as well, if not better, than the Council’s preferred strategic allocations given proximity to existing schools, facilities and high frequency public transport into Bedford (refer Appendix Ei to our main representations in response to Policy DS2(S) and DS3(S).
V. A key distinction is also that such non-strategic sites are deliverable and viable in the context of an effective plan (NPPF test of soundness 35(c)), a factor which is entirely disregard in the SA notwithstanding a cursory comment that such sites may deliver more quickly (SA paragraph 8.17, page 96, in the context of options 3b, 3c, 4 and 7 where development at KSCs and RSCs was assessed at a high level).
VI. These sites will not trigger heavy infrastructure investment in the SRN nor depend on EWR and can deliver localised improvements as necessary via the S106/CIL process. They would form part of a strategy which can meet its needs over the first 10 years of the plan, without the need for a stepped trajectory. Such non-strategic sites and locations would clearly be considered an appropriate and justified strategy under NPPF test of soundness 35(b). The adopted 2030 Local Plan directs growth to KSCs and RSCs so such a strategy would accord with BBC’s previous approach.

Object

Representation ID: 9931

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

OBJECT:
I. The ‘stepped trajectory’ against the minimum LHN of 1,355dpa is entirely unjustified. The exceptional circumstances to depart from the LHN – as required by NPPF61 – have not been demonstrated. This also goes against NPPF requirements for a positively prepared plan which helps boost the supply of homes.
II. Further detailed justification is provided in response to Policy DS2(S) and DS3(S).

Comment

Representation ID: 9934

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

760 Land South of Keeley Lane, Wootton

1. This is a deliverable site in a sustainable and accessible location, with potential for a further 20-30 homes which complements the existing Wootton Neighbourhood Plan (WNP) (made March 2022) allocation on part of the site – W6 – Land on the south side of Keeley Lane, allocated for 20 dwellings (a planning application for this allocation was submitted in May 2022 and awaits determination – ref. 22/01035/MAO). This area is already recognised as a sustainable location for development given its allocation in the made WNP, with the extension proposed simply helping to meet future needs at Wootton over the new local plan period to 2040.
2. The site’s sustainability and accessibility credentials are identified in the Council’s SA of the site, summarised at Appendix Ei of these representations. The site is in close proximity to a food store, primary school and major employment – all of which scores positively in the Council’s assessment.
3. The site is close to existing bus services at Keeley Corner, providing frequent services to the centre of Bedford and Bedford train station – just 20 minutes journey time via Services 53 and 41 (Stagecoach East).
4. The SA demonstrates that access can be achieved without constraints. With respect to the ‘uncertain’ impacts on highway capacity identified in the SA, this is clearly a scale of development where impacts will be limited and no capacity issues are identified at nearby junctions (refer to the Transport Technical Note enclosed at Appendix Eii). Even if issues were encountered the modest scale of development on this non-strategic site would be capable of localised mitigation through the S106/S278 process as required.
5. In terms of highway capacity, the Council’s SA shows that strategic-scale developments including HOU16 (Land East of Wixhams), HOU14 (Kempston Hardwick New Settlement) and HOU19 (Little Barford New Settlement) will have a negative impact on highway and junction capacity in any event with highway access also identified as constraints by the Highway Authority. Site 760 performs better in access and highway terms than strategic growth allocations preferred by the Council, and is not dependant on SRN improvements or EWR.
In terms of ecology, the Ecology Topic Paper at Appendix Eiii (EDP, July 2022) demonstrates the potential presence of breeding birds, bats, badgers and reptiles, with an off-site population of GCN following surveys undertaken between 2019 and 2022. However, the assessment concludes that “none of these species would provide an in-principle constraint to development. Any potential impacts upon these species can be mitigated for within the generous amount of open space being provided within the proposals for the Site.” In any event, the enclosed Biodiversity Net Gain calculation demonstrates how a net gain of 12.3% could be achieved. This resolves the SA’s
‘uncertain’ impacts under objectives 2b (protected species) and 2c (achieving a net gain). In the Council’s SA the site clearly performs better than the preferred strategic site allocations where negative impacts are identified in the SA – for sites HOU11, HOU13, HOU15 and HOU16 for example (refer Appendix Ei).
7. With respect to heritage it is important to note that the SA shows that all of the Council’s favoured strategic allocations (HOU11, HOU13, HOU14, HOU15, HOU16 & HOU19) score negative against this SA objective (4a) as demonstrated in Appendix Ei. Nevertheless, the conclusions of the Council’s heritage assessment for site 760 have been considered and are addressed in the topic paper enclosed at Appendix Eiv (EDP, July 2022). The assessment demonstrates that there would be harm to the significance of 35 Keeley Lane (a Grade II Listed Building c.50m to the west) and that the level of harm to 18 and 20 Keeley Lane and Pear Tree Cottage (Grade II) is minimal and did not prevent allocation of the northern part of the site in the WNP in any event. No other designated assets will be affected by development on the site.
8. With respect for the potential impacts on and loss of a small proportion of moderately preserved ridge and furrow (where the Council’s assessment identifies a level of
‘substantial harm’) the enclosed assessment explains that this represents “no more than the eroded corner of a much larger 15ha block of better-preserved ridge and furrow, in a parish that has been identified more generally as having a “high level survival of ‘good’ condition ridge and furrow” (Albion Archaeology, 2016). Therefore, the level of potential harm is low - affecting just 3.5% of the block of ridge and furrow mapped in the HER -and the earthworks within the Site are assessed as being of low or local significance.”
9. A draft masterplan is enclosed at Appendix Ev to illustrate how a well-planned community can be realised, informed by the above technical work. Rainier Developments is keen to work with the Council, Members, local community and key stakeholders to realise the opportunities and benefits associated with this deliverable site.