Plan for submission evidence base

Object

Representation ID: 9598

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

In the Summary of Comments document (on the Issues and Options stage) the need for effective cross boundary planning is not properly addressed, despite our representation and others in a similar vein.
The Duty to Co-operate Submission Statements (amongst the supporting documents to the Submission Plan) provide no further reassurance, in fact they serve to highlight the inadequacy of the co-operation. It is stated that the discussion with neighbouring authorities has proceeded without any disclosure of potential allocations, so it is difficult to see how it might have yielded effective outcomes. There is no evidence of engagement with South Cambridgeshire, which would seem to be vital given the implications for the A421. Furthermore, the statements identify a long list of cross boundary considerations noting potential significant impacts arising from what is proposed. These are precisely the matters that should have been subject to detailed discussion and resolution, to inform policy formulation, particularly the approach to the delivery and the timing of development relative to cross boundary infrastructure. Instead, these critical considerations are identified as ‘requiring further co-operation’ and the relevant strategic policies fail to address delivery issues entirely. The Statement records no progress on the relevant matters and as such is not in the spirit of or reflective of the approach required by the NPPF (paragraphs 24-27). On this basis, the Plan is at risk of being found not to be effective in the terms of the NPPF: the allocations reliant on cross boundary infrastructure ‘are not deliverable over the plan period, 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.’ The stated position in the DtC Submission Statements is that all major issues are deferred.


U&C are used to working in circumstances where there is an absence of clarity on infrastructure timing and delivery. Bedford Borough Council must be applauded for wanting to get on with the job, even though so much contextual information and infrastructure commitment is lagging. It is not, however, appropriate to simply ignore the very significant burden that uncertain infrastructure requirements place upon development and make allocations without constraint or regard for the potential implications. Where allocations are dependent upon significant, future infrastructure investment, policy should be clear that the development must either deliver that infrastructure (identify developer contributions) or cannot proceed until there is a clear commitment to delivery. The lack of clarity in the Policies, contingent upon investment in East West Rail or other significant infrastructure, risks delivery of the Plan allocations and potentially compromises the proper planning and delivery of growth elsewhere within the Central Area.
It appears to be possible to shape allocations for the earlier part of the Plan period, which can be justified by the evidence base, as it stands (it appears comprehensive in respect of localised need and impacts) and then to shape more broadly scoped policies for longer-term growth locations. While the NPPF/PPG provides limited guidance on the form of such policies, it does point to them shaping a process as a way forward, including further work required. In our experience as a master developer, it is helpful if such policies:
• are explicit about the limitations of the evidence base at the point the Plan is prepared.
• identify the issues and inter-dependencies that are relevant to determining the future scale and location of growth within the broad parameters identified;
• are clear about the pre-requisite infrastructure requirements and associated triggers (or addresses the need to resolve this at a later date, when there is further clarity);
• scope the further work and the cross-boundary collaboration which is necessary to safeguard comprehensive and co-ordinated development.