Plan for submission evidence base

Object

Representation ID: 10110

Received: 29/07/2022

Respondent: Rainier Developments Limited - Roxton

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: 10111

Received: 29/07/2022

Respondent: Rainier Developments Limited - Roxton

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).