Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Support

Representation ID: 7366

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

Pegasus Group are instructed by Lone Star Land Ltd ("Lone Star") to submit representations to the Regulation 18 consultation Bedford Local Plan 2040 (the "draft Plan").
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 ID915.
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 2020. 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 representations, having previously made representations to the now adopted Core Strategy and also having made submissions through the Council's Call for Sites.
The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework (NPPF), paragraph 35:
• 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
August 2021 | KF | P19-0021 Page | 2
is 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.

Object

Representation ID: 7370

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

Lone Star have concerns regarding the potential reliance within the draft Local Plan of use of a stepped trajectory, as set out at para 3.5. The use of stepped trajectories does not address the need to meet the existing requirement (i.e. the known level of people in housing need year on year), but simply defers this to another day. There is also concern that the emerging strategy does not seek to address directly how housing provision for older people may be delivered, and/or if the locational implications of that may differ from general market or affordable housing.
If the Council decide that the provision of large strategic sites is an important part of site delivery in the Borough, then the changes in the National Planning Policy Framework (“NPPF”) published in July 2021, now provide a sound policy context for Local Plans to include such proposals within the context of a 30-year Vision to recognise their longer lead in times, and prolonged delivery (NPPF para 22). The delivery of larger sites, therefore, is not a sound reason for failing to meet the aspirations of those in housing need now.
The Local Plan should be based on a strategy which delivers a sufficient supply and mix of deliverable sites to meet the requirement of years 1 to 5 of the plan, and sites or areas for years 6 – 10. The NPPF does not support the deferral of meeting the known housing requirement to beyond year 10. The PPG (68-021) confirms that stepped requirements should not be used to unnecessarily delay meeting needs. Where stepped trajectories have been allowed elsewhere, such as Leeds and Thanet (in Thanet based on similar arguments that large sites would deliver later in the Plan period), those authorities have been unable to demonstrate an uplift in deliverability at the time the 'step' kicked in.
The Council's strategy, therefore, should be one of meeting current requirement levels today, not deferring a substantial part of delivery to the post 2030 period. A stepped housing requirement also gives rise to substantial social and economic harm by not meeting the needs of households in the early part of the plan period.
is simply being deferred to later in the Plan period without justification.
Lone Star Land would encourage a strategy which does not seek to delay meeting housing need through a stepped trajectory. In order to achieve the Standard Methodology (“SM”) figure, as a minimum, the strategy should allow for a greater number of small and medium sized sites to be delivered, which are capable of being brought forward within the first 10 years of the Plan period, to meet the current need, now.
Such a strategy should necessarily look to reliance on the delivery of sites at those settlements that are consistent with the locational strategy of the emerging plan (i.e. those sites which lie, inter alia, on the A421 corridor) and settlements which have been assessed and been found by the Council to be highly sustainable in their own right, i.e. the Key Service Centres, including Great Barford.
That Great Barford only appears in one of the four Option 2 scenarios, is without any sense of evidential support or justification. As aforementioned, the Settlement Hierarchy background paper concludes that it is a highly sustainable settlement with a full range of local services to meet day to day community needs, it is close to and well connected to Bedford, with frequent public transport service provision, and is able to support further growth demonstrably without causing environmental, landscape or heritage harm, through the delivery of sites such as that promoted by Lone Star Land.
August 2021 | KF | P19-0021 Page | 8
The Council are therefore invited to review the trajectory of delivery for their Reg 19 Local Plan, to provide a recognition of the prolonged delivery rates and timetable of larger strategic scale sites, establish a vision beyond 2040 to delivery of those sites, and look to commit to providing that which is required by the NPPF, i.e. a supply of deliverable sites for the first 10 years of the plan period, which meets as a minimum, the Standard Methodology identified requirement.
With regard to the provision of housing for older people, the emerging housing strategy is silent on the role that Key Service centres, such as great Barford, may play in meeting that specific tenure. NPPF para 62 makes clear that the housing needs of older people are to be specifically addressed in planning policies. The Council's spatial strategy may reflect that Key Service Centres have a particular role (being defined as the most locally sustainable settlements beyond the Bedford/Kempston Urban Area) and which would be well placed to accommodate and meet the housing needs of an aging population.