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Object

Plan for submission evidence base

Duty to Cooperate Position Statements

Representation ID: 9317

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate. Our review of the supporting documents, particularly the Duty to Cooperate Position Statements (April 2022) and the Sustainability Appraisal Report (April 2022), suggests that the Council has not co-operated sufficiently with its neighbouring authorities regarding the strategic cross-boundary impacts of the proposed new settlement at Little Barford. The evidence base has not considered the transportation and infrastructure requirements that may be required to support the chosen growth strategy as per the NPPF paragraph 24 and the legal Duty to Co-operate.

Full text:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate. Our review of the supporting documents, particularly the Duty to Cooperate Position Statements (April 2022) and the Sustainability Appraisal Report (April 2022), suggests that the Council has not co-operated sufficiently with its neighbouring authorities regarding the strategic cross-boundary impacts of the proposed new settlement at Little Barford. The evidence base has not considered the transportation and infrastructure requirements that may be required to support the chosen growth strategy as per the NPPF paragraph 24 and the legal Duty to Co-operate.

Object

Plan for submission evidence base

New Settlements Assessment

Representation ID: 9318

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate and fails to meet the tests of soundness. Our review of the New Settlements Assessment finds that the chosen spatial strategy is not positively prepared or justified. The Assessment contains factual errors, is inconsistent in its approach and does not represent a suitable, fair and objective assessment of the new settlement options. Further, the SA objective scorings within the Assessment are contrived to bolster the planning and sustainability case for Little Barford, impacting the chosen spatial strategy as a whole.

Full text:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate and fails to meet the tests of soundness. Our review of the New Settlements Assessment finds that the chosen spatial strategy is not positively prepared or justified. The Assessment contains factual errors, is inconsistent in its approach and does not represent a suitable, fair and objective assessment of the new settlement options. Further, the SA objective scorings within the Assessment are contrived to bolster the planning and sustainability case for Little Barford, impacting the chosen spatial strategy as a whole.

Object

Plan for submission evidence base

Bedford Borough Transport Model Assessment of Local Plan 2040 Preferred Strategy

Representation ID: 9319

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Plan is not legally complaint owing to failure to comply with the duty to co-operate and fails to meet the tests of soundness. The Council has not co-operated effectively with neighbouring authorities regarding strategic cross-boundary impacts (including transportation) of the proposed new settlement at Little Barford and the transport evidence (BBTM) is not consistent with national policy (NPPF Paragraph 73c) with serious concerns over the application of the BBTM results to the site selection process.

Full text:

The Local Plan is not legally complaint owing to failure to comply with the duty to co-operate and fails to meet the tests of soundness. The Council has not co-operated effectively with neighbouring authorities regarding strategic cross-boundary impacts (including transportation) of the proposed new settlement at Little Barford and the transport evidence (BBTM) is not consistent with national policy (NPPF Paragraph 73c) with serious concerns over the application of the BBTM results to the site selection process.

Object

Plan for submission evidence base

Sustainability Appraisal Report

Representation ID: 9321

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate and fails to meet the tests of soundness. Our review of the SA and New Settlements Assessment finds that the chosen spatial strategy is not positively prepared or justified. The assessment contains factual errors, is inconsistent and does not represent a suitable and objective assessment of the new settlement options. The Sustainability Appraisal scorings appear to be contrived to bolster the planning and sustainability case for Little Barford, and its resulting impact on the chosen spatial strategy.

Full text:

The Local Plan is not legally complaint owing to its failure to comply with the duty to co-operate and fails to meet the tests of soundness. Our review of the SA and New Settlements Assessment finds that the chosen spatial strategy is not positively prepared or justified. The assessment contains factual errors, is inconsistent and does not represent a suitable and objective assessment of the new settlement options. The Sustainability Appraisal scorings appear to be contrived to bolster the planning and sustainability case for Little Barford, and its resulting impact on the chosen spatial strategy.

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