Site Assessment Pro Formas

Object

Representation ID: 7369

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

The Council's consultation page identifies a number of documents which sit behind the Local Plan, key amongst these are the 'Site Assessments' and the Sustainability Appraisal.
Lone Star consider that the Site Assessments report does not accurately reflect the submissions made to the Council to date with regard to their individual site assessment.
In particular the Site is identified by the Council as having possible Highway capacity issues. This query, however, is not supported by the Highway department comments identified in the Site Assessment pro-forma, which acknowledge that the Site could deliver betterment to local connectivity (i.e. widen pre-existing footpaths), and notes that there are no access constraints.
The Site is assessed as being Best and Most Versatile (BMV) agricultural land, whilst Lone Star's submission documents to the Call for Sites made clear that whilst it is in class 3, it is unclear if the land is Class 3a (BMV), or 3b (not BMV). In any event, the size of the Site and location of the Site do not make it critical to the viability of an agricultural unit. Finally, the Site Assessments report queries the Site's ecological value. Detailed survey work has been undertaken on site (attached as Appendix B) and identifies that whilst the habitat may be suitable for reptiles, the nature of the Site is such that it has low potential of supporting any viable population, and that standard working practice surveys can avoid any harm. The report also identifies how a net gain in biodiversity could also be delivered at a nearby off-site location to mitigate any loss on site, a point which was also incorrectly referenced in the Council's assessment as being 'uncertain'.
The Sustainability Appraisal (“SA”) identifies a number of options which have been considered for assessment as 'reasonable alternatives'. The SA identifies that the Option 2 scenarios are the 'best performing', and of those the SA selects Option 2a as performing better than options 2b-2c. This is based on an assessment that rail access above all other factors, is the key component of sustainability which will drive a shift away from reliance on the private car.
Such an approach, however, fails to have regard to numerous other key aspects of sustainable living. For example, directing employment growth alongside new residential development, proposing housing at locations already well served by shops services and facilities (so as to remove the demand for travel at source), or to recognise that the planned rapid shift away from fossil fuel transportation modes may shift the emphasis about what is important in terms of rail accessibility.
In particular whilst the SA recognises the role of transport corridor growth and especially the role of the A421 corridor, it seems perverse to narrow the identification of Great Barford to just one of the four variations of Option 2 proposed. Great Barford is after all, a Key Service Centre at the second Tier of the existing settlement hierarchy behind only the Bedford/Kempston urban area. Great Barford was assessed at this level in the hierarchy, following the Council's own methodological approach in the 2018 Settlement Hierarchy Paper, still part of the 2040 Local Plan evidence base.
As the current Core Strategy identifies, Great Barford contains 'a good range of services and [is] well connected to larger town centres by regular public transport.' As a Key Service Centre, the current Core Strategy recognises that it provides a 'strong service role for the local community and surrounding area.'
The current SA strategy over emphasises the potential role of rail in meeting the sustainable transport needs of the Borough. Rail is important, but by its nature is a fixed piece of infra-structure with fixed starting points and destinations. It has an important role, but one which is necessarily limited. Optimising use of existing sustainable settlements, with 'regular public transport' which is flexible in its routing and frequency, and settlements which meet a 'strong service role' should play an equally important part in the growth strategy of Bedford Borough to 2040.
Lone Star would welcome further engagement with officers to address the technical delivery aspects of their site, in order to rectify any misgivings as identified through the Council's Site Assessment process regarding its ability to deliver sustainable development, before the publication of the Council's Regulation 19 Local Plan.