Plan for submission evidence base

Comment

Representation ID: 10219

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

1. Introduction
1.1 This representation has been prepared on behalf of Anwyl Land in respect of their land interests at Kennel Hill, Sharnbrook as illustrated on Figure 1 below – the site is edged red. This site is an omission site in the emerging Bedford Local Plan 2040. The site is considered suitable for
allocation in the scenario that further housing sites are required to enable the Local Plan to be found sound (as we consider to be the case as set out within these representations).
SEE ATTACHMENT

1.2 The site has been previously promoted through the various stages of the adopted Local Plan, Neighbourhood Plan and was included as a preferred site as part of the Council’s 2017 consultation paper. Technical documents to support the allocation of the site were submitted, including highways and landscape, demonstrating the sites acceptability and deliverability.
Despite this however, the adopted Plan opted to defer allocations to subsequent Neighbourhood Plans, which would deliver the housing targets set out in the Local Plan. For Sharnbrook, the Local Plan allocated 500 dwellings to be delivered through the Neighbourhood Plan.
1.3 Sharnbrook is designated in the Local Plan as a Key Service Centre, which are described as settlements “which contain a good range of services and are well connected to larger town centres by regular public transport. They provide a strong service role for the local community and surrounding area”.
1.4 The Sharnbrook Neighbourhood Plan Examiner’s Report was published on the 19th July 2021. This concluded that the Plan could proceed to referendum subject to modifications, despite significant concerns relating to the deliverability of the Plan’s key allocation (Hill Farm) and limited evidence to support that the housing requirement could be met having regard for the Plan’s short period up to 2030. The allocation at Hill Farm is predicated on delivery of significant improvements to the junction at the A6, with no confirmation from County Highways that the proposed Neighbourhood Plan allocation is deliverable.
1.5 A referendum on the Neighbourhood Plan was held in October 2021. The Plan passed the referendum with 457 votes in favour and 80 against, with a 30% turnout. Following this result, the Plan was formally made by Bedford Borough Council in November 2021.
1.6 A planning application has been submitted on the Plan’s primary allocation, a strategic scale development isolated from Sharnbrook to the east, for up to 500 dwellings and other community infrastructure (ref: 22/01037/MAO). Key consultation responses are yet to be received for this application at time of writing, including highways.
1.7 This representation follows policies in the order that they appear in the consultation document.

Object

Representation ID: 10226

Received: 29/07/2022

Respondent: Anwyl Land

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

3 Land at Kennel Hill, Sharnbrook – Site Assessment
3.1 The Housing and Employment Land Availability Assessment and Site Assessment Topic Paper (May 2022) includes the Council’s assessments of the sites submitted for consideration throughout this Local Plan process.
3.2 A copy of the assessment for Land at Kennel Hill, Sharnbrook is provided below, with our suggested amended assessment where relevant which is based on technical assessment that have been carried out. As set out previously the site has historically been accepted by the Council as suitable for allocation, and would likely have been allocated had the Neighbourhood Plan approach correctly been rejected through its examination.
SEE ATTACHMENT FOR TABLE

3.3 With the above in mind, it is clear that Land at Kennel Hill, Sharnbrook is better suited to come forward for residential development than actually assessed by the Council, despite the historic draft allocation. The site can come forward early and can be used to replace lost supply in Sharnbrook in the initial years of the Plan period (when a sensible trajectory for the delivery of the new settlement is adopted), enabling a sensible lead in time for the new settlement, which will then in turn provide local growth later in the Plan period, closer to 2040 (albeit concerns relating to freestanding nature of the settlement remain).

4 Conclusions
4.1 This representation has been prepared on behalf of Anwyl Land in respect of their land interests at Land at Kennel Hill, Sharnbrook.
4.2 To conclude:
- The LP2040 is not consistent with national policy because it does not plan for sufficient housing to meet future needs and does not proactively plan for any uplift as a result of the Arc Framework.
- The distribution of growth within the LP2040 is not effective or justified as the level of growth expected on the strategic sites, particularly the new settlements are not reflective of historic delivery within Bedford or nationally when compared to other similar sites. The Council has assumed delivery rates of up 600 dwellings per annum on the Kempston Hardwick and Little Barford allocations (1,200 per annum in total), equating to an average annual deliver of 380 dwellings per annum on strategic allocations (760 dwellings per annum in total), wherein evidence suggests average delivery closer to 160 per annum per site is likely to be deliverable (320 per annum in total), having a significant impact on the deliverability of the proposed stepped trajectory.
- The Spatial Strategy is not justified because it has not fully taken account of all the reasonable alternatives. There is also no justification for not including a requirement for neighbourhood plans to make allocations beyond those already committed to 2030. Role of Sharnbrook underutilised given all local development directed to independent new settlement meaning non of the 500 dwellings will be delivered within Sharnbrook itself. Opportunity for Sharnbrook to actually receive housing allocations as part of updated strategy.
It is considered unlikely that the Council can demonstrate a robust five-year housing land supply at adoption, nor throughout much of the Plan period, even if the hyper ambitious assumptions made by the Council are realised. Opportunity for growth at Sharnbrook to mitigate early shortfalls (particularly when sensible and deliverable build rates are adopted in respect of the Sharnbrook NDP allocation).
- Land at Kennel Hill, Sharnbrook is a suitable site for development and should be included in an uplift of housing growth beyond that already proposed in the LP2040 and to realise the spatial role of Sharnbrook itself within the adopted and emerging hierarchy. This uplift should comprise of sustainable growth to allow housing to be delivered earlier in the plan period, balancing growth throughout the Plan instead of the back loaded approach advocated by the Council.
4.3 We politely request that we are kept informed of the progress on the LP2040 including the need to attend any relevant Hearing sessions for the Examination of the Plan.