Plan for submission evidence base

Object

Representation ID: 10415

Received: 27/07/2022

Respondent: Lone Star Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Introduction

Pegasus Group are instructed by Lone Star Land Ltd ("Lone Star") to submit representations to the Regulation 19 consultation on the Bedford Local Plan 2040.

Lone Star control 1.8 hectares of land south of Roxton Road in Great Barford (the" Site", or the" Lone Star Site" - see land control plan at Appendix A). The Lone Star Site has been assessed as part of the Council's Call for Sites, under site reference 1D915.

Lone Star have been actively engaged with the local community and Great Barford Parish Council since acquiring an interest in the Site. In addition to maintaining a dialogue with Great Barford Parish Council's Neighbourhood Plan Sub - Committee, Lone Star have presented proposals for the Site to the local community via a website, the distribution of leaflets, an individual consultation event in October 2020 and participation at the "Meet the Developers" consultation event in November 20 20. The Site is not allocated for development in the Made Neighbourhood Plan but did score well in the Parish Council's own assessment for deliverability.

Lone Star welcome the opportunity to engage further in the Local Plan process through these represent at ions, having previously made representations to the now adopted Core Strategy and also having made submissions through the Council's Call for Sites and the Bedford Local Plan 2040 Regulation 18 consultation.

• Positively prepared - providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and s consistent with achieving sustainable development;
• Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective - deliverable over the Plan period, and based on effective joint working on cross­ boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in the Framework.

These tests of soundness, along with other legal and procedural requirements associated with the Plan-making process provide a contextual framework for these representations.

Representations

The Council's consultation page identifies a number of documents which sit behind the Local Plan. Key amongst these are the 'Site Assessments' and the Sustainability Appraisal.

Lone Star highlighted at Regulation 18 stage that the Council's assessment had not accurately reflected the Site's merits. In particular, the Site was identified by the Council as having possible highway capacity issues. That query, however, was not supported by the Highway Department comments identified in the Site Assessment pro-forma, which acknowledged that the Site could deliver betterment to local connectivity (i.e. widen pre-existing footpaths), and noted that there are no access constraints.

The Site was also assessed as being Best and Most Versatile ("BMV") agricultural land, whilst Lone Star's submission documents to the Call for Sites made clear that whilst it is in class 3, it is unclear if the land is Class 3a (BMV), or 3b (not BMV). In any event, the size of the Site and location of the Site do not make it critical to the viability of an agricultural unit. Finally, the Site Assessments Report queried the Site's ecological value. Detailed survey work has been undertaken on site (and was attached to the Regulation 18 submissions) and identified that whilst the habitat may be suitable for reptiles, the nature of the Site is such that it has low potential of supporting any viable population, and that standard working practice surveys can avoid any harm. The submitted ecological report also identified how a net gain in biodiversity could also be delivered at a nearby off-site location to mitigate any loss on sit e, a point which was also incorrectly referenced in the Council's assessment as being 'uncertain'.

The Council's HELAA which sits behind the Regulation 19 version of the Local Plan, however, has made no attempt to re-evaluate the Site correctly, but rather dismiss en masse, all those sites deemed not to be in accord with the selected preferred strategy. Of 307 sites excluded from consideration in the Stage One initial sift, 293 sites were dismissed for this reason alone. How a preferred strategy is identified when there are significant factual errors in the evidence base (as highlighted by my client's example site), calls into question the veracity of both the preferred spatial distribution strategy, and the site selection process.