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

Object

Representation ID: 8718

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

5.1 This section of our representations should be read alongside the standalone Review of the Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review support the Modifications in this part of the representations. This section also reinforces our specific comments on the Council’s Preferred Strategy Options.

Paragraph3.17andOption2d–Comment
5.2 These representations endorse the inclusion of the ‘east’ corridor parishes as part of Preferred Option 2d but in practice indicate that this is illustrative of a need for a ‘hybrid’ approach to provide for an appropriate strategy in accordance with national policy and guidance (NPPF2021 paragraph 35(b)).

5.3 These representations conclude that any selected strategy option that does not include growth in the ‘east’ corridor parishes would be unsound and fail to comprise an appropriate strategy or genuine reasonable alternative for the purposes of the Sustainability Appraisal. This is due to soundness issues identified with the delivery of large-scale strategic growth comprising other components of the Council’s Preferred Options.

5.4 The benefits of Option 2d reflect the ability to promote and maximise the benefits of what is in-effect village-related growth at the Key Service Centre of Great Barford, which is very sustainably located within the A421 corridor. Growth at Key Service Centres is an approach that the Council has accepted as sustainable in the spatial strategy of the adopted LP2030, and the evidence base for the Local Plan 2040 indicates no in-principle constraint to capacity for further development at Great Barford that could not be adequately mitigated.

5.5 Endorsement of growth at Great Barford under Option 2d in the context of a ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’ growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of their capacity to contribute towards sustainable development. The benefits of ‘village-related’ development do not suddenly materialise only where Key Service Centre and Rural Service Centres are located in the A421 corridor and do not evaporate altogether outside of it.

5.6 To achieve the objectives of the emerging Local Plan 2040 it is necessary to support further village extensions to the settlement of Great Barford, incorporating our client’s Willoughby


Park proposals, to secure contributions to sustainable development that are assessed favourably in the draft Sustainability Appraisal (including new green infrastructure, community facilities and opportunities for recreation). The potential to secure these benefits should be reflected within the Council’s conclusions on site selection and evidence base for the submission draft version of the Plan, once finalised, including the Infrastructure Delivery Plan and Settlement Hierarchy Review, which both remain awaited.

DraftSustainabilityAppraisal–SuggestedAppropriateStrategyAlternative
5.7 A ‘hybrid’ option would assign the ‘village-related’ growth component only to those settlements outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an indicative distribution, have been retained at 500 units in Key Service Centres and 35 units in Rural Service Centres albeit these are arbitrary figures and should be determined on a case-by-case basis. Wixams has been excluded from the total for Key Service Centres (reflecting its inclusion in the locations for rail-based growth). The only exception, taking account of this, is an increase of 215 units in the distribution to Oakley (based on its suggested reclassification as a Key Service Centre set out in representations on behalf of other clients submitted to this consultation).

5.8 For the A421-based components of the strategy the total distribution to the ‘east’ corridor parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d. This marginally exceeds the Council’s arbitrary figures applied for the purpose of testing Great Barford, Roxton and Willington as ‘village-related’ growth but would in our view represent a more realistic starting point taking account of the capacity for growth at Great Barford and in-particular our client’s Willoughby Park site. There is no site-specific justification or settlement-specific justification as to why this figure should be limited to 750 dwellings.

5.9 In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of large- scale strategic growth included in the strategy options. We have included the Council’s minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic timescales for development.

5.10 Including both components, if required (New Settlements and rail-based growth) would comfortably exceed the minimum 12,500 units required from additional allocations, with an


appropriate buffer for flexibility and contingency (particularly in terms of the prospects for meeting increased needs before 2030). There is no reason higher quanta could not be included as part of an extended plan period. Equally, this could allow some settlements outside of the transport corridors to be excluded from further village-related growth. We would, however, not recommend this where Neighbourhood Plans being prepared have failed to address important strategic priorities (as at Oakley and Sharnbrook, for example).

5.11 The ‘hybrid’ strategy based on these components are summarised in Table 1 below:

SEE ATTACHMENT FOR TABLE

5.12 We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with the standalone findings for growth components and the Council’s Options 2d and 3c, as well as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable


development are enhanced.

5.13 This is as a result of recognising that the potential negative effects the Council assigns to village-related growth are incorrect and, in any event, inaccurate because it ignores the location of some Key Service Centres and Rural Service Centres within the A421 corridor. It also recognises that some the benefits of what is in reality ‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across settlements elsewhere in the hierarchy. Likewise, the assessment of positive effects for strategy options including the ‘east’ transport should be increased due to the ability to provide for sustainable village extensions at Great Barford. The results are summarised in Table 2 below:

SEE ATTACHMENT FOR TABLE

Object

Representation ID: 8719

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

6.1 This section of the representations should be read alongside the separate Delivery Assessment included at Appendix 5. This addresses the ability of the Council approach to maintain a rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery Assessment also illustrates that the Council is unable to demonstrate a five year supply of deliverable sites based on its own published position (at a base date of 1 April 2019) or when this is rolled forward to 1 April 2021.

6.2 In summary, the Council’s proposed approach to managing the delivery of housing over the plan period is unsound. The Council indicates a proposed 20-year plan period (2020 to 2040) for the Local Plan Review. The Local Plan Review must meet minimum annual local housing need calculated in accordance with the standard method. Planning Practice Guidance ID: 68-031-20190722 answers the question ‘how can past shortfalls in housing completions against planned requirements be addressed’? and states:

“Where the standard method for assessing local housing need is used as the starting point in forming the planned requirement for housing, Step 2 of the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure. Under-delivery may need to be considered where the plan being prepared is part way through its proposed plan period, and delivery falls below the housing requirement level set out in the emerging relevant strategic policies for housing.”
6.3 Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will be relevant to assessing the soundness of the Local Plan 2040. Performance for this period will therefore be substantially informed by the Council’s current evidence of deliverable supply against the Local Plan 2030 housing trajectory (and extant consents).

6.4 The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on a ‘stepped trajectory’ for the plan period to 2030 (retaining an annual requirement of 970 dwellings per annum). The Preferred Options principally rely on large-scale strategic sites with limited prospects for delivery within five years from adoption (2023 to 2028). The Council’s supply for this period will therefore also substantially be informed by the Local Plan 2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).


6.5 The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed in the separate Delivery Assessment, demonstrates that these do not achieve an early prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030 Examination relating to constraints to viability and availability of the sites identified, particularly within the Town Centre.

6.6 Regarding Town Centre sites identified in the Local Plan 2030 and the associated longstanding delays to development there is no mention of a Development Corporation in either the Council’s consultation document or consultation on a Vision for the Oxford- Cambridge Spatial Framework. The Council has previously indicated that this may be the route to unlocking sites and overcoming barriers to development for which there is currently no clear solution.

6.7 In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a stepped requirement appropriate for plan-making’? and sets out:

“A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period. Strategic policy-makers will need to identify the stepped requirement in strategic housing policy, and to set out evidence to support this approach, and not seek to unnecessarily delay meeting identified development needs. Stepped requirements will need to ensure that planned housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may wish to identify priority sites which can be delivered earlier in the plan period, such as those on brownfield land and where there is supporting infrastructure in place e.g., transport hubs. These sites will provide additional flexibility and more certainty that authorities will be able to demonstrate a sufficient supply of deliverable sites against the housing requirement.” (SPRU emphasis)
6.8 There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:

□ The change in housing requirement cannot be considered significant. The Council was fully aware of these circumstances when the Local Plan 2030 was adopted with the requirement for early review. Planning for a difference in the annual requirement of around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest change in the context of a recently adopted Local Plan that should maintain a minimum rolling supply against the OAN figure
□ The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with


the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that problem
□ The current Local Plan 2030 housing trajectory provides for no flexibility or certainty (particularly given issues with Neighbourhood Plans and Town Centre sites). The Council’s Preferred Options provide no resolution to this.
□ The use of a stepped trajectory will not ensure needs are met in full. There will be a substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the latest information regarding supply). A reliance on large-scale strategic sites beyond 2030, for which there is a poor record of success in the borough in terms of timescales and rates of delivery, does not provide a reasonable prospect of development in accordance with PPG ID: 68-019-20190722)
6.9 Those issues relating to the current Local Plan 2030 mean that there is no prospect whatsoever that extant commitments and allocations alone would allow the Council to demonstrate a five year supply of deliverable sites based on the calculation of minimum annual local housing need upon adoption of the Local Plan 2030.

6.10 Our analysis demonstrates that the Council’s proposed approach to rely on a stepped trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon adoption of the Local Plan 2040 without significant support to prioritise the early delivery of additional sites.