Mr Jonathan Pym August 2017 Representations in Response to the First Draft Central Bedfordshire Local Plan 2015- 2035 On behalf of Mr Jonathan Pym CAPL247279/A3 savills.co.uk Representations in Response to the First Draft Central Bedfordshire Local Plan 2015-2035 On behalf of Mr Jonathan Pym Contents 1. Introduction 1 2. The Preparation of the Local Plan 2 3. The Content of the First Draft Plan 3 4. Summary and Conclusions 10 Appendices 11 Appendix 1 Indicative Urban Extension Concept 12 Mr Jonathan Pym August 2017 1 Representations in Response to the First Draft Central Bedfordshire Local Plan 2015-2035 On behalf of Mr Jonathan Pym 1. Introduction 1.1. This document has been prepared by Savills (UK) Limited on behalf of Mr Jonathan Pym. It provides comments on the First Draft version of the Central Bedfordshire Local Plan 2015-2035, issued by Central Bedfordshire District Council, as a Local Planning Authority. 1.2. Mr Jonathan Pym is the owner of land to the east of Sandy, Bedfordshire. The Estate consider that this land holds latent development potential which can help fulfil, in part, the Council’s vision for the area as now expressed in this first draft of the Local Plan. Indeed, the Estate are of the view that, if properly approached, this land can better satisfy many of the key themes and objectives set out within this First Draft plan than alternatives being offered. In particular, it is considered that it would be better to focus growth in and around the market town of Sandy, in preference to developing a new Growth Location around the former Tempsford Airfield. 1.3. In consequence, this submission provides comments in support of these arguments by reference to relevant parts of the Consultation Document. 1.4. The Estate, and their advisers, is keen to continue the established dialogue with the District Council, and other stakeholders, in support of the arguments made. To that end, it is hoped that the District Council will respond pro-actively to the alternatives mooted, so as to deliver a more robust, sound, Local Plan. Mr Jonathan Pym August 2017 1 Representations in Response to the First Draft Central Bedfordshire Local Plan 2015-2035 On behalf of Mr Jonathan Pym 2. The Preparation of the Local Plan 2.1. Once adopted, the new Local Plan will replace a range of existing development plan documents. These documents pre-date publication of the National Planning Policy Framework (NPPF) and will extend the planning horizon for the district in an up to date manner to 2035. Therefore, support is given to the commitment to produce a new Local Plan in accordance with the core principles for planning found within the NPPF. 2.2. Paragraph 1.6.4 of the Consultation document acknowledges that any cross boundary issues should be resolved in an open and transparent manner in accordance with the “duty to cooperate”. This is to be commended. It is to be hoped that close partnership with adjacent authorities will remain at the heart of the plan preparation process. Although the duty to cooperate is not a duty to agree, the Estate would encourage the District to pay due regard and attention to the needs, opportunities and views of neighbouring authorities. This is in the interests of both the local area and the nation as a whole. 2.3. However, it is concerning that significant doubts have already been expressed by neighbouring authorities about the strategy put forward within this First Draft Local Plan. For example, South Cambridgeshire District Council has concluded that the proposals are ‘not effective or justified’ (their Planning Portfolio Report of 25 August 2017). Likewise, Bedford Borough Council has voiced similarly strong criticisms. The plan is still at an early stage in its evolution. In consequence, as acknowledged within its Foreword, it is very much hoped that the District will continue to listen to the reasonably expressed views of all stakeholders and interested parties. These First Draft proposals should be capable of significant change. 2.4. In consequence, the Estate object to the current intention, set out in Section 1.5 of the document, to progress from this initial Regulation 18 consultation direct to a Regulation 19 consultation in Spring 2018 unless and until the current significant flaws in the plan are remedied. In view of the significant risks and challenges now apparent, we consider that a further round of consultation will be prudent, revisiting and revising the options mooted in this early, first draft of the plan, before progressing to invite formal comments on the ‘soundness’ of the plan at the Regulation 19 stage. Otherwise, it seems very likely that the plan will face significant, cogent and well founded objections that it is not been positively prepared; is not sufficiently justified; is unlikely to prove fully effective; and is inconsistent with national policy. Mr Jonathan Pym August 2017 2 Representations in Response to the First Draft Central Bedfordshire Local Plan 2015-2035 On behalf of Mr Jonathan Pym 3. The Content of the First Draft Plan Section 2 – Key Themes 3.1. Support is given to the statements made in Paragraphs 2.4.1 and 2.4.2. Some market towns are indeed finding it increasingly difficult to maintain their services and economic strength. This is, in large part, due to increasing competition. Therefore, a key challenge to be met by the Local Plan is to manage growth so that as far as practical it avoids damaging Central Bedfordshire’s market towns. Growth should be directed to locations where it can make a real difference, by helping to sustain and improve existing local services and communities. Section 5 – Development Strategy 3.2. Support is given to the strategy expressed within Figure 5.1, and in Paragraph 5.3.5, that a key strategic growth option ought to be growth along the A1 corridor, acknowledging that this will require significant new infrastructure provision to unlock its potential and provide balanced growth. Section 6 – Vision and Objectives 3.3. Objection is made, in part, to the “Vision for 2035” expressed in Paragraph 6.1.1. This is currently unsound in that it is neither justified nor likely to be effective on the basis of current evidence. The ambition to preserve the heritage and distinctiveness of the market towns and villages, and enhance these by appropriate growth, is whole heartedly supported. However, as the consultation document itself accepts (see pages 63, 88 and 90 therein) the route, location and timing of any East - West railway link has yet to be decided and remains uncertain. Hence the assumption in the vision that a new rail station will serve a new market town at Tempsford is unsound. 3.4. In Summer 2016, Network Rail only announced the preferred geographic corridor for the East – West Rail Link Central Section. No specific alignment has yet been adopted. Hence there can be no certainty that it will serve any particular development location as yet. Network Rail considers that a true preferred route will probably be selected in 2018, following public consultation. The Key Diagram, Figure 8.1 of the First Draft Plan prematurely suggests a ‘preferred corridor option’ for the central section of the proposed new rail link. This is unreliable. It is to be assumed that this is only the District Councils preferred option. This may, or may not, turn out to be the one eventually chosen. So, both the vision and the key diagram are based on currently unproven assumptions. Mr Jonathan Pym August 2017 3 Representations in Response to the First Draft Central Bedfordshire Local Plan 2015-2035 On behalf of Mr Jonathan Pym 3.5. In addition, according to Network Rail, construction of such a new railway line may possibly start in the mid 2020’s, with trains operating from the early 2030’s. Therefore, any vision put forward in the Local Plan that relies in major part upon this new railway can only reasonably assume that it will play a role in serving the development needs of the District from the early 2030’s at the earliest - very close to the end of the plan period in 2035. There must be doubt at present as to the reliability of this particular railway timetable as well. There is no firm, reliable programme for delivery as yet, only an indicative programme. In practice, its opening could readily slip beyond the current end date of the plan. 3.6. These uncertainties over the delivery, timing and route of the proposed new railway mean that a major plank of the First Draft Plan’s vision is at present unreliable. Nor are all of these uncertainties likely to be resolved before the intended date of submission of the Local Plan in October 2018. Consequently, the vision for 2035 ought to more accurately state, in part, that; ‘Multi-service hubs have been delivered to support strong local communities, including new infrastructure such as the Oxford to Cambridge Expressway road, and new rail stations, if these have been provided within the plan period, to ensure excellent connectivity ‘ . Section 7 – The Spatial Strategy 3.7. Support is given to the commitment, in Paragraph 7.1.4, that the Draft Local Plan will propose to deliver a minimum number of new homes over and above the existing commitments. Furthermore support is given to the view, expressed in Paragraph 7.3.1, that transport infrastructure often has the biggest impact on the delivery of such new development. Thus a key part of the Local Plan strategy should be to place as much of the growth as possible close to sustainable transport corridors and interchanges.