Further delays for Central Bedfordshire Council
Cast your mind back several years, among other things the examination of Central Bedfordshire Councils (CBC) 2014 Development Strategy may spring to mind. The planning Inspector found that CBC had failed to comply with the duty to cooperate when preparing its Local Plan. The Council applied for a judicial review, which ultimately ended with CBC withdrawing their draft Development Strategy.
Three years later in 2018 CBC submitted their new Local Plan, the hearing Sessions ran from 21 May to 25 July 2019, and are now closed. A significant amount of additional information was submitted following the start of the examination, and the Inspector was left to fully consider the ramifications of all the new evidence in order to deliberate the best course of action.
On the 30th September 2019 CBC received a letter from Inspectors Matthew Birkinshaw and Helen Hockenhull outlining issues related to the plan’s sustainability appraisal and strategic allocations.
The Inspectors have found that the sustainability appraisal has not adequately demonstrated that the spatial distribution of housing and employment is the most appropriate strategy given the reasonable alternatives available. Key issues include;
- Concerns regarding the assessment of reasonable alternatives to the North of Luton allocation as part of the sustainability appraisal. Without considering the full potential of the site it is difficult to see how the Council has concluded that Policy SA1 is the most appropriate strategy for expanding Luton.
- Significant discrepancies within the evidence base.
- The sustainability appraisal does not adequately demonstrate that the Plan is the most appropriate strategy when considered against the reasonable alternatives, most significantly this applies to the new M1-A6 link road.
The Inspectors have requested modelling for the M1 Junction 13 which is critical to understanding whether improvements can be undertaken that effectively mitigate the impact of additional development in this location.
The Inspectors also have serious concerns regarding the soundness of several strategic allocations, including;
- Harlington (HAS20), in the absence of additional school places the allocation is unsound,
- Barton-le-Clay (HAS04), ownership conflicts, the site is therefore not considered to be deliverable,
- Chalton (HAS09) the exceptional circumstances necessary to justify releasing from the Green Belt have not been demonstrated, and the allocation should be deleted from the Plan,
- Hockliffe, further work would need to be published, consulted on and examined to demonstrate exceptional circumstances,
- Sundon Rail Freight Interchange (SE1) is dependent upon the new M1-A6 link road. There is an absence of robust evidence to justify the exceptional circumstances necessary to alter the Green Belt boundary.
- Marston Gate (SE2) the extent of the allocation is not justified due to the harm that would be caused to the landscape character of the area,
- Aspley Guise (HAS03) the exceptional circumstances necessary to justify releasing from the Green Belt have not been demonstrated, and the allocation should be deleted from the Plan,
- East of Arlesey (SA3), concerns regarding the level of growth proposed, the scale and location of development is not justified,
- Holme Farm (SE3), it would be very difficult to effectively screen the site by landscaping alone. The allocation is not justified due to its harmful impact on the landscape character of the area,
- East of Biggleswade (SA4), further work would therefore be required to justify its inclusion as a strategic allocation in the Plan.
- The Council should plan for the future reuse of RAF Henlow within this Plan.
All things, considered a vast amount of work for CBC to undertake.
CBC have responded outlining their intended actions to rectify the above, these included;
- Reassigning an independent consultant to revise and improve the Sustainability Assessment’s methodology and findings,
- Update stakeholders and interested parties with responses to specific questions relating to M1-A6 link road,
- Provide more technical information on transport relating to M1-J13 concerns,
- Put forth a technical paper on employment to address issues relating to Marston Gate, Holm Farm and Sundon RFI,
- Produce a technical paper on housing to address the points relating to Harlington, RAF Henlow, Hockliffe, East of Arlesey and East of Biggleswade allocations,
- PINS openness and transparency has also been called into question.
The Council believe “that the plan can be progressed and that…the plan is capable of being made sound.” They expect to complete the work and consultation by April 2020. Following that additional hearings can be held from June 2020.