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

Object

Representation ID: 7563

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

We note that the proposed total housing requirement for the period 2020 to 2040 of 25,500 dwellings, is derived from the annual requirement of 1,275 dwellings set by the Government’s standard method. Looking ahead to the way in which the options are presented, we consider that the total housing requirement for the Plan period should be expressed as a single figure, qualified by such phrases as “at least” or “a minimum of” to reflect national guidance and indeed paragraph 3.2 of the current Plan document. This is because of rather than despite the uncertainties briefly referred to at paragraph 3.3.

Object

Representation ID: 7564

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

We note what the Council describes as a “stepped trajectory” approach which involves keeping the annual requirement at 970 dwellings until 2030 and increasing it to 1,580 dwellings for the remainder of the Plan period.
Phasing of this kind has long been discouraged by Governments and finds no explicit support in current guidance. The potential practical difficulties would not so much involve restraining growth in the first ten years as increasing it suddenly and markedly (by 63%) for the last ten. We note what the Council considers to be the underlying constraints – the timing of the completion of the East-West rail link and the improvements to the Black Cat junction on the A1. We also understand the need for infrastructure to facilitate or at least keep up with development. Nevertheless, we see that the Council itself describes at paragraph 3.3 the increase in the annual requirement from 970 dwellings to 1,275 dwellings (305, or 31%) as a considerable challenge. An increase of nearly two thirds in the annual housing requirement (from 970 to 1580 dwellings, or 63%) halfway through the Plan period would be an even greater challenge and is in our view wholly inappropriate and unrealistic. The Council should instead adopt a broadly level trajectory where the inevitable fluctuations in market demand (and indirectly the provision of affordable housing as part of mixed schemes) can more easily be accommodated and managed.

Support

Representation ID: 7565

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

Before the individual options are addressed, some general points are made. The Council has expressed the total residual housing requirement as a single figure for Options 2a and 2c, and as two figures for Options 2b and 2d. In the case the second pair, the entire difference of 585 dwellings (equivalent to 4.7% of 12,500) is explained by the difference in the size of the potential new settlements at Wyboston and Little Barford, the latter being a much more significant 23% larger than the former. There is also an inconsistency in that new settlements both at Wyboston and Little Barford feature in Option 2c, with the same difference in size but within a total residual housing requirement of 12,500 dwellings, rather than 13,085 dwellings. Nor is there any explanation of the reason for the difference in the figures, either in overall terms or for example in terms of capacity or thresholds for the provision of services at the potential new settlements. In respect of thresholds, even the larger figure of 3,085 dwellings is well below that which would require the provision of a new secondary school, but both new settlements at the size proposed would need in the order of three to four forms of entry for primary schooling. Provision of open space and the need for primary health care would in contrast be proportionate to the size of the likely total population. We return to the question of thresholds below. There are clearly elements common to all the options. The first two bullet points for all options refer to 1,500 dwellings within the urban area and a further 1500 adjacent. We support these elements in the sense that they represent some kind of sequential approach. This will be a sustainable strategy in that it accommodates as much development as possible in or next to existing urban areas, reducing the amount of greenfield land taken and the total extent of incursion into the open countryside. Precisely the same can be said of Site 951, as it is effectively next to an existing urban area; it should therefore be regarded as a fixed or common element to all the options.
Despite the fact that the Council has left behind some of the less plausible or appropriate options put forward at the Issues an Options stage, there is nevertheless a significant degree of strategic choice both available and necessary.
Given the similarities between Options 2b and 2d, we address the options in this order: 2a, 2c, 2b and 2d.
Option 2a
Although this option is described as being based on transport corridors the illustration on page 20 of the Local Plan document makes it look much more like the peripheral expansion of Bedford, creating a much more asymmetrical shape to the town which may lead to a less sustainable pattern of transport than could be achieved.
One possible drawback of this option is that it does not take advantage of the potential new railway station on the East-West route as shown on the diagram south of St Neots, although we have doubts about the extent of modal shift that the completion of the rail link will bring about.
We conclude that Option 2a should be discarded at this stage.
Option 2c
This option involves a new settlement at both Wyboston and Little Barford, unlike Options 2b and 2d which involve just one. Eclipse Planning Services considers that to rely on new settlements to deliver 5,585 dwellings, representing 44% of the total residual requirement, is a strategy which may be difficult to deliver. The Plan document provides no explanation of the derivation of the figures. However, it is clear from an examination of the information submitted by the promoters of site 907 at Little Barford (which appears to include site 892 in its entirety) that the figure of 3,085 represents the total capacity of the land (3,955 dwellings) less the number (870) assigned to the period beyond 2040. In other words, the capacity and phasing figures are those provided by the promoters and they have not, it would appear, been subject to any kind of independent assessment or verification.
This option would also locate a high proportion of the residual housing requirement at a greater distance from existing employment opportunities and higher order services at Bedford than other options. We have argued that proximity to St Neots is a significant advantage for Site 951. This however is considered not to apply to Option 2c because of the significantly greater scale of the two potential new settlements, and they are not as close to St Neots as Site 951. Although St Neots is an important employment and service centre, with a population of a little over 30,000 it is significantly smaller than Bedford. Option 2c is therefore likely to result in greater numbers and aggregate distances of journeys to work and for other purposes, particularly shopping for comparison goods and for leisure.
We conclude that Option 2c should be discarded at this stage.
Options 2b and 2d
Attempting to depict each of the four options for the entire Borough on a small part of an A4 sized document imposes severe limitations on the level of detail possible. As things stand, and notwithstanding the limitations imposed by the scale of mapping, we infer that Site 951 is not included in either of these options. If this inference is correct, we would strongly urge the Council to reconsider this and to look in more detail at how these options could be properly shaped.
Both options involve a new settlement at either Wyboston or Little Barford. In the case of Wyboston, the origin of the capacity figure for the new settlement does not appear to be directly derived from the information supplied for site 977, where the claimed capacity is 5,150 dwellings in the Plan period with even more beyond. As with the figures for site 907, there appears to have been no independent assessment. However, in this case they are at least plausible, in the sense that the capacity of the land put forward far exceeds what will be needed.
Option 2d differs only from Option 2b in the location of a relatively small proportion of the residual housing requirement in the transport corridors. Of far greater significance is the choice between Wyboston and Little Barford as the location for a new settlement.
We consider that no significant difference would be made to the thresholds for facilities and services at any new settlement at Wyboston or Little Barford by the allocation of site 951 for among other things the 485 dwellings put forward at the Issues and Options stage. Such an allocation would however carry a significant advantage in terms of keeping incursion into the open countryside to a minimum. It would provide more convenient access to services, facilities and employment in St Neots. In this context we consider that a new settlement at Wyboston would be preferable as site 951 could provide almost as many dwellings as the difference of 585 between Wyboston and Little Barford.
Eclipse Planning Services therefore supports Option 2d subject to the inclusion of Site 951 as part of it.

Object

Representation ID: 7566

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

Turning to Section 6 and employment, we acknowledge that the relationships between land, plot ratios and jobs are difficult to define. We note draft Policy E1S which refers to the remarkably precise figure of 8,642 net additional jobs in the Plan period. Yet there are wide variations in the amount of land proposed to meet this requirement. Not all job growth will necessarily be in sectors which require the allocation of land. We note what paragraph 6.6 says about the “most appropriate” figure of 171 hectares in total and the net requirement of 123 hectares. However, neither of these figures can be related (on the basis of what appears in this document) to the range of 131 to 179 hectares in the four options; nor is there any indication of whether these figures are themselves gross or net. Paragraph 6.8 is inconsistent with both paragraph 6.6 and the options: making due allowance for the word “about” in relation to the three sites of 30 hectares, the total here amounts to around 153 hectares. The key point however is that whatever figure for employment land eventually emerges from the Local Plan process, Site 951 should be regarded, for employment as well as housing, as a common element to all options.