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

Object

Representation ID: 7053

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise significant concerns in relation to the potential for a stepped trajectory to be taken forward in the Local Plan 2040.
The effect of a stepped trajectory, deferring the delivery of the standard methodology until 2030, is to significantly undershoot on the delivery of annual housing need. In itself this is a significant failure, but in this instance the significant adverse impacts are compounded by a Local Plan adopted based on a low locally derived housing need future and therefore already under delivering against actual housing need.
This means that real people in real need now cannot access the housing market because of the lack of housing, affordability ratios will significantly increase and those people on the housing waiting list will also be unable to access affordable housing given that the primary source of affordable housing is from open market housing sites.
A stepped trajectory runs counter to the provisions of Policy 1S of the Local Plan 2030, a policy put in place to ensure an immediate plan review so as to meet the requirements of the standard methodology. If put in to effect, a stepped trajectory would mean that for Bedford the standard methodology will not take effect until approximately 12 years after the standard methodology was first brought in, which by any measure is wholly inappropriate and unjustified.
It cannot be said that the Council do not have the range of smaller and medium sized sites to enable a smooth rather than stepped trajectory – a significant number of the 430 call for sites submissions are capable of being brought forward without significant on or off site infrastructure. This basket of sites can be delivered without delay and do not justify a stepped trajectory.
Paragraph 3.3 of the Local Plan 2040 refers to the considerable challenges in meeting the requirements of the standard methodology. Those challenges will only increase if a stepped trajectory is put in place, since the second half of the plan period will require on an annual basis housing delivery far higher than even the standard methodology.
Option 2a
We raise no specific objections to Option 2a. We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
Option 2b
We raise no specific objections to specific elements contained in Option 2b, relating to proposals adjoining the urban area and transport corridor.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is marginally less reliant on the rail corridor than Option 2a and as a result on the face of it is a superior option – however the introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2b were it to be advanced with a new settlement as part of the overall strategy.
Option 2c
We raise strong objections to Option 2c.
We would question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is heavily reliant new settlements. Given how poorly new settlements fair in the assessments set out in the evidence base this option cannot, by some margin, be considered to be the most appropriate option when considered against the reasonably alternatives. It is also the case that new settlements will inevitably challenge the ability to deliver the (higher) standard method in the early phases of the plan which – as we have set out elsewhere in our submissions – is vital to the success of the Local Plan Review.
Option 2d
We raise no specific objections to specific elements contained in Option 2d, relating to proposals adjoining the urban area, transport corridor south and transport corridor east.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
The introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2d were it to be advanced with a new settlement as part of the overall strategy.

Support

Representation ID: 7054

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We do not raise any significant concerns in relation to Policy NE1, recognising the provisions of the forthcoming Environment Bill. However, the policy could be enhanced by making reference to applying the DEFRA metric as a means to benchmarking the baseline position with regard to environmental quality, and as a means to assessing the contribution that biodiversity enhancements make. This will provide for a consistent approach, and provide those bringing forward housing and other developments with certainty as to the approach to be taken.
As a separate observation, as drafted Policy NE1 makes reference to enhancing or creating off site habitats “in some circumstances”. The policy should be amended to make clear that off-site environmental net gain is an appropriate solution in all circumstances and may in fact lead to the creation of a greater environmental net gain than would otherwise be achieved on site – thus furthering the objectives behind the policy.

Object

Representation ID: 7055

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.