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

Object

Representation ID: 8827

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Vision And Objectives
3.2. The Vision sets out general planning aims, and we support the Borough becoming more sustainable, the delivery of good design, and improved transport options etc. However, it is surprising that the Vision does not make any stronger statements on growth, where it will be located, or make a commitment to delivering the required number of new dwellings, and employment land, as identified in the remainder of the Draft Plan.

3.3. Given the emerging focus on the delivery of the Oxford - Cambridge Arc, as identified in the document and the current consultation on priorities for the Spatial Framework, it seems a missed opportunity for the plan not to take a lead in setting out how it could play an important role in delivering the Vision. The statement at paragraph 1.11 appears to read as “we will do what we have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

3.4. In particular it would seem sensible for the plan to make some provision for the possibility of an uplift in housing and employment growth that may emerge through the preparation of the Arc’s Spatial Framework. Paragraph 5.5 of the Government’s current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states:

“concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”
(Our emphasis underlined)

3.5. At paragraph 5.8 of the consultation, it adds:

“In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself.
(Our emphasis underlined)


3.6. While it is acknowledged that the Local Plan review and the Spatial Framework will be prepared in parallel, it is clear that the emerging vision is targeting a more advanced and robust form of growth. Therefore, we would contend that the Local Plan Review should allow for some uplift whether that be 10 or even 20%. If the Spatial Framework is adopted at the same time as the plan, there is likely to be the added pressure to consider another urgent Local Plan review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and provide flexibility, helping towards reducing the burden going forward.

Object

Representation ID: 8828

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Neighbourhood Planning – Paragraphs 1.46 to 1.51
3.7. Neighbourhood Planning has been very successful in Bedford Borough, and has been embraced by many Parish Councils. On several sites we have seen Parish Councils being proactive in their engagement with developers and making informed decisions in bringing forward proposals for development in line with the requirements of the Bedford Local Plan 2030; or indeed providing development for their community in line with Local Housing Needs Survey.

3.8. This has been the case with our client’s site at Hill Farm, Sharnbrook, and on this basis, could continue to be a useful tool in delivering growth in the villages.

3.9. However, it is also important to ensure that, where strategic growth is considered, this growth is ideally identified and allocated in the Local Plan 2040. Alternatively as with the previous Local Plan 2030, growth identified in the Local Plan could be secured through the site allocation process delegated to local communities through the creation of a Neighbourhood Plan, or indeed the review, of an existing one.

3.10. We recognise that some Parish Council’s and the communities they represent, who have, or are in the process of delivering large scale growth, may be reluctant to consider enlarged allocations, going forward to 2040. However, we would encourage the Borough Council to continue to review the potential of growth of the Key Service Centres, and to consider the opportunity to build upon the infrastructure that existing allocations will deliver.

3.11. Our clients are strongly advocating that further development can be delivered in Sharnbrook, and that the remaining capacity of approximately 250 dwellings could make a meaningful contribution towards housing delivery in the next plan period.

3.12. The site at Hill Farm, Mill Road has been independently assessed as part of the Neighbourhood Plan process, and the site has been considered as sustainable and suitable to accommodate the expansion of the village; avoiding the constraints found within or to the west of the village. In her report, the Examiner noted that the site at Hill Farm had performed strongly in respect of the effect of development on ‘Biodiversity’, the ‘Historic Environment’, ‘Landscape’ and ‘Transport’. The conclusion was that the site’s allocation was soundly based.

Object

Representation ID: 8829

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Growth And Spatial Options – Paragraphs 3.4 and 3.5
3.13. The current housing need requirement of 970 dwellings per annum was based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

3.14. It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology. The Council must therefore address the shortfall in this Review. If this is not adequately addressed through the earliest stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing.

3.15. It has long been stated that there is a need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the Standard Methodology. This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040.

3.16. Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West Rail section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 8830

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Emerging Preferred Growth Options - 2a, 2b, 2c, And 2d
3.17. There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in the Key Service Centres and smaller sustainable villages. None of the four emerging preferred growth options include any growth in the north of the Borough, not even in the Key Service Centres.

3.18. The north of the Borough includes several highly sustainable settlements, including the Key Service Centres of Bromham, Clapham, and Sharnbrook, and the Rural Service Centres of Carlton, Harrold, Milton Ernest, Oakley, and Turvey. There are also many other sustainable smaller villages.

3.19. The decision not to allocate further growth to the northern villages appears to be based upon the findings of the Bedford Borough Transport Model prepared by Aecom. The assessment considers a range of predetermined scenarios for growth and identifies that where a range of development is considered in the north (and across the Borough) up to 2040, there will be adverse impacts on the A6 corridor and suggests that there is no adequate mitigation available. As a result, the broad conclusion argues that development along the A6 corridor should be constrained.

3.20. While it is acknowledged that general scenarios have to be considered in order to assess the impacts of strategic growth on the highway network, this represents a very blunt tool and so its conclusions should be considered in that context. The transport modelling is clearly quite broad, particularly when considering development opportunities in the larger settlements in the north of the Borough which are primarily assessed in the “Grey scenario” (dispersed growth). In this scenario, development in the north is considered as a proportion of overall growth across the Borough and the highways impact is felt more widely. This is clearly a blanket approach which lacks the fine grain of assessment necessary to properly understand the impact of growth opportunities in key locations, and therefore too easily discounts development in the Key and Rural Service Centres in the north which are sustainable settlements with capacity for growth. We would contend that the transport modelling does not provide a conclusive position that a more targeted approach to growth in the north cannot be accommodated by the highway network. The report identifies that mitigation measures are available, and therefore a more focused assessment should be considered.

3.21. Growth in the north including in the Key Service Centres, and Rural Service Centres has been too easily discounted and this is a lost opportunity as there are several highly sustainable settlements in this location. Additional growth in the northern settlements can make a positive and meaningful contribution to the wider strategy going forward to 2040, improving the long-term vitality, and the viability of existing services and facilities. We would argue that allocations should therefore be made proportionally across the Borough in the interests of long-term sustainability.

3.22. The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process. The emerging Sharnbrook Neighbourhood Plan has carefully worked through a number of objectives to deliver an allocation of 500 dwellings under the Local Plan 2030. Sharnbrook is a highly sustainable settlement and there is an opportunity for some of the objectives to be carried forward into a further round of allocations.

3.23. Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area, and fails to address the growth agenda established by the vision for the Oxford-Cambridge Arc.

Object

Representation ID: 8831

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Policy SB1 – Self Buid And Custom Housebuilding
3.32. The objective of this policy can only be delivered if there is a reasonable and proportionate distribution of growth in places where a need is identified on the Self Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of self build plots in and around the urban area. The Government’s objective in bringing forward the self-build requirement was for that untapped part of the sector to start making a contribution towards housing delivery.

3.33. This means that self-build plots should be provided where they are wanted, and as the register shows a broad range of desirable locations, if the objectives of SB1 are to be realised, then a commensurate range of sites should be provided. The residual land at Hill Farm could make a contribution towards meeting this Government objective.

Object

Representation ID: 8832

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

RESPONSE TO DEVELOPMENT STRATEGY TOPIC PAPER
4.1 The settlement of Sharnbrook was included in many of the options in the Issues And Options Consultation June 2020 – options 3b, 3c, 4, 6, and 7. All of these options allocated 500 dwellings to the settlement in the next plan period.

4.2 We must raise objection and highlight that the exclusion of strategic growth in this part of the Borough is a missed opportunity; and that the reasoning given in the sustainability appraisal for discounting this level of growth are considered superficial and indicate an underlying bias towards urban centric growth.

4.3 It is important to note that many of the options were not discounted due to issues with allocating growth to Sharnbrook itself, but because there are considered to be issues with the overall strategy in those particular options. For example, Options 4 and 6 were discounted primarily because they do not include any development in the urban area which the Sustainability Appraisal identifies to be the most sustainable location. Most of these options also include the delivery of two new settlements, two of which are proposed off the A6. However, the transport modelling has found that the A6 does not have sufficient capacity to accommodate this scale of development, and yet does not address whether smaller scale growth, such as 250 dwellings at Sharnbrook, could be accommodated.

4.4 It is therefore crucial that Sharnbrook is not discounted as a suitable settlement for growth simply because it happened to be one element of an overall strategy in options which are considered to be less desirable. We would strongly contend that the sustainability credentials of Sharnbrook should be considered on its own individual merits.

4.5 Sharnbrook is a Key Service Centre and a sustainable settlement in the North of Bedford Borough and is an ideal location for delivering further growth in this Local Plan Review. We would therefore contend that deliverable sites in Sharnbrook be considered on their own merits, and that a more targeted analysis of impact is undertaken.

4.6 The site at Hill Farm, Mill Road has been independently assessed as part of the Neighbourhood Plan process, and the site has been considered as sustainable and suitable to accommodate the expansion of the village. Its development avoids the constraints found within or to the west of the village, and within the Strategic Environmental Assessment, performed strongly in respect of the potential effects on ‘Biodiversity’, the ‘Historic Environment’, ‘Landscape’ and ‘Transport’.

4.7 The Examination into the Sharnbrook Neighbourhood Plan has now been completed with the Examiner concluding at paragraph 4.12 of her report:

“I have considered the results of that [Regulation 16] consultation together with the evidence on the site assessment process and the SEA. I find that the decision of the SPC to allocate Site 901, land at Hill Farm, Mill Road is soundly based.”

Object

Representation ID: 8833

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

RESPONSE TO DRAFT SUSTAINABILITY APPRIASAL REPORT

5.1 We raise objection to the contents of the Sustainability Appraisal. The framework for considering sustainability is well established, and we do not raise objection to the general scope of the appraisal. However, it is felt that there is an underlying bias towards urban centric growth, which discounts further growth in the Key Service Centres and smaller sustainable villages.

5.2 The four options in Option 2 are described in the consultation as primarily an urban centric set of options focused on growth in and around the urban area and rail connection points. We would argue this approach is far too simplistic and omits an opportunity to enhance the sustainability of Key Service Centres through the provision of additional services and employment opportunities. It also ignores the potential to build upon the community-led ambitions of the many Neighbourhood Plans that have been prepared in the Borough.

5.3 We note that at paragraph 8.10, the Council comment on the merits of growth around rail hubs and yet ignore to a large extent the value of the bus network with high frequency bus services being a far more flexible and viable option in providing an alternative to the car. The delivery of housing growth along high frequency bus networks, such as that served by the No.50 running between Bedford and Rushden, has the knock on benefit of supporting improvements to services and wider improvements to sustainability across a broader range of settlements.

5.4 An enhanced population along the bus network increases passenger numbers which enables improvements to those existing services to be more viable. By enhancing the network as a whole, you can better serve smaller settlements and improve their sustainability as a consequence.

5.5 We would also highlight that sustainable development needs to plan for the longer term. The private petrol/diesel powered motor vehicle/car is considered to have a harmful effect on the environment, contributing to rising CO2 levels and poor air quality. As a consequence, the language of sustainability talks about “reducing the reliance on the private motor vehicle”. However, as we progress forward in carbon neutral/zero emissions vehicles, this notion will be out of date. The Government has brought forward it’s ban on the sale of new petrol and diesel cars to 2030, with all new cars and vans required to deliver zero emissions from the tailpipe from 2035. The car industry has also reacted with many car manufacturers already committed to being fully electric by 2035. In addition the largest manufacturers, such as Volkswagen Group, have committed to their vehicles being carbon neutral at the point of manufacture.

5.6 With the move towards more environmentally friendly forms of private transport which are driven and supported by the ever-growing energy provision coming from renewable sources, the impact of the private motor vehicle will change, and will be part of a range of sustainable transport options.

5.7 We would also raise objection to the very narrow view that somehow sustainability can only be achieved by one model of growth, with a focus on what is new, being located in only a select few locations; and that somehow everything else is not sustainable, nor could ever be altered to become sustainable. In our view it ignores the wider objective of enhancing the sustainability of existing settlements of all sizes, and fails to support the long-term vitality and viability of those existing settlements and the services and facilities they rely upon.

5.8 It also assumes that travel patterns will continue to grow along the same trajectory, but our collective experiences through the Covid19 pandemic have accelerated the trend of home working, supported by advances in technology. As demonstrated by the pandemic, a large proportion of the economy can continue to function without the need to travel, and to some extent this has opened people up to embracing technology and minimising their need to travel to communicate. All development needs to consider, that going forward, a greater proportion of people will be working from home, or in localised hubs, without the need to travel long distances. That degree of flexibility is already coming in the form of communal work spaces, and hot desking centres. Therefore, the provision of high-speed broadband to all new developments, as well as supporting enhancements to the existing network and local services and facilities, is essential in delivering sustainable growth.

5.9 We would therefore conclude, by arguing that the sustainability credentials of the settlement of Sharnbrook should be assessed independently, and without bias, while opportunities for growth in the settlement should be fully considered in light of its sustainability credentials. It is self-evident that Sharnbrook occupies a sustainable location, served by the A6 and is supported by high frequency public transport links via the No.50 bus service running between Rushden and Bedford. The settlement is independently accessible from the major road network. We believe that the allocation of development at Sharnbrook would meet many of the sustainability objectives the Council are arguing in support of options 2a – 2d, further supporting enhancements to the public transport network serving the village, and as such, would question why further growth here has been discounted.