Question 4
No but the sites should not be impacting the beautiful countryside of North Bedfordshire by concreting over meadows and arable fields. The Brown option states this land is underused and brown field when in reality it is productive farmland and open countryside enjoyed by parishioners and wildlife.
No answer given
It is important for the Local Plan Review to recognise that housing and employment need are primarily generated from within existing communities within the Borough. Therefore in order to best meet those needs, and enable those communities to thrive, growth will need to be dispersed to all settlements of a certain size. The level of growth apportioned to each settlement needs to be assessed in light of the overall housing requirement, reflect the settlement hierarchy, and be informed by the housing land availability assessment. Dispersed growth is therefore the supported option as it is the most sustainable way to meet future need. In terms of the disadvantages of the dispersed growth option noted in the consultation paper, reference is made to it may be requiring growth in communities with no or very few facilities. That disadvantage could be avoided at the stage at which growth is distributed. Reference is made to a lack of a critical mass making providing new strategic infrastructure more difficult, however the way in which infrastructure is funded is clearly evolving in light of the Government’s intentions in its White Paper. Reference is also made to it being unlikely to facilitate employment growth due to dispersed nature, however a broader range of sites and sizes would provide more opportunities for housebuilders of all sizes. In terms of the other options presented, urban and new settlement based growth would not necessarily locate housing and employment in locations accessible to those existing communities where the need is derived. This is a particular issue in terms of affordable housing, where those residents in housing need are often reluctant to take properties in locations remote from family, social networks, or workplaces, such as those identified on the edge of the Borough around Rushden or St. Neots. Further, focussing significant amounts of investment and public resources into creating new settlements, diverts attention away from addressing the needs of existing communities in terms of improved infrastructure and facilities. As noted in the consultation paper, given the length of time required in bringing new settlements forward (8.4 years from validation to first completions based on the Start to Finish Second Edition research), they can also only realistically play a small part in terms of housing and job delivery in the short to medium term. The options linked with sustainable transport corridors, whether that is rail stations or bus routes along the A421, clearly have the potential to encourage greater use of sustainable modes of travel and are therefore consistent with national policy in that respect. As a factor, therefore, this might influence the proposed distribution of growth between settlements, but not to the extent that settlements outside of these corridors do not expand. Many of the settlements outside of these corridors still have good sustainable transport links, particularly those around the urban edge of Bedford. New development in such locations will support the continued operation of transport connections and provides the opportunity to enhance such connections. With specific reference to Rainier Developments land interests at Bromham, which has been presented to the Council through the ‘call for sites’ process, support is given for a strategy which includes housing growth at Bromham. Bromham is a key service centre in the adopted Local Plan and very close to the urban edge of Bedford. Indeed, in the Settlement Hierarchy evidence submitted in support of the adopted Local Plan, it is identified as the highest ranking and largest of the settlements within the key service centres category. Beyond Bedford/Kempston urban area, it is arguably one of the most sustainable locations to accommodate growth within the Borough and therefore must play a role in meeting future needs identified through the Plan Review. Bromham is identified to deliver 500 homes within the plan period to 2030, and it would be appropriate to take at least a similar quantum of growth again over the longer plan period to 2040.
It is important for the Local Plan Review to recognise that housing and employment need are primarily generated from within existing communities within the Borough. Therefore in order to best meet those needs, and enable those communities to thrive, growth will need to be dispersed to all settlements of a certain size. The level of growth apportioned to each settlement needs to be assessed in light of the overall housing requirement, reflect the settlement hierarchy, and be informed by the housing land availability assessment. Dispersed growth is therefore the supported option as it is the most sustainable way to meet future need. In terms of the disadvantages of the dispersed growth option noted in the consultation paper, reference is made to it may be requiring growth in communities with no or very few facilities. That disadvantage could be avoided at the stage at which growth is distributed. Reference is made to a lack of a critical mass making providing new strategic infrastructure more difficult, however the way in which infrastructure is funded is clearly evolving in light of the Government’s intentions in its White Paper. Reference is also made to it being unlikely to facilitate employment growth due to dispersed nature, however a broader range of sites and sizes would provide more opportunities for housebuilders of all sizes. In terms of the other options presented, urban and new settlement based growth would not necessarily locate housing and employment in locations accessible to those existing communities where the need is derived. This is a particular issue in terms of affordable housing, where those residents in housing need are often reluctant to take properties in locations remote from family, social networks, or workplaces, such as those identified on the edge of the Borough around Rushden or St. Neots. Further, focussing significant amounts of investment and public resources into creating new settlements, diverts attention away from addressing the needs of existing communities in terms of improved infrastructure and facilities. As noted in the consultation paper, given the length of time required in bringing new settlements forward (8.4 years from validation to first completions based on the Start to Finish Second Edition research), they can also only realistically play a small part in terms of housing and job delivery in the short to medium term. The options linked with sustainable transport corridors, whether that is rail stations or bus routes along the A421, clearly have the potential to encourage greater use of sustainable modes of travel and are therefore consistent with national policy in that respect. As a factor, therefore, this might influence the proposed distribution of growth between settlements. In terms of the detail of the option presented, it is queried why the A421 based growth option referred to in the consultation paper does not reference Roxton at the eastern end given its position within the corridor. With specific reference to Rainier Developments land interests at Roxton which have been presented to the Council through the ‘call for sites’ process, support is given for a strategy which includes housing growth at Roxton. Roxton is a rural service centre in the adopted Local Plan, and falls on the A421 sustainable transport corridor between Bedford and St. Neots. The frequency of services to nearby centres makes this a suitable location to accommodate growth, and a strategy that aligned housing and employment growth along this corridor with investment in improving the frequency and quality of services on this route, would be of benefit to Roxton. Roxton is identified to deliver 25 to 50 homes within the plan period to 2030, and it would be appropriate to increase this amount over the longer plan period to 2040 to reflect the focus on sustainable transport.
It is important for the Local Plan Review to recognise that housing and employment need are primarily generated from within existing communities within the Borough. Therefore in order to best meet those needs, and enable those communities to thrive, growth will need to be dispersed to all settlements of a certain size. The level of growth apportioned to each settlement needs to be assessed in light of the overall housing requirement, reflect the settlement hierarchy, and be informed by the housing land availability assessment. Dispersed growth is therefore the supported option as it is the most sustainable way to meet future need. In terms of the disadvantages of the dispersed growth option noted in the consultation paper, reference is made to it may be requiring growth in communities with no or very few facilities. That disadvantage could be avoided at the stage at which growth is distributed. Reference is made to a lack of a critical mass making providing new strategic infrastructure more difficult, however the way in which infrastructure is funded is clearly evolving in light of the Government’s intentions in its White Paper. Reference is also made to it being unlikely to facilitate employment growth due to dispersed nature, however a broader range of sites and sizes would provide more opportunities for housebuilders of all sizes. In terms of the other options presented, urban and new settlement based growth would not necessarily locate housing and employment in locations accessible to those existing communities where the need is derived. This is a particular issue in terms of affordable housing, where those residents in housing need are often reluctant to take properties in locations remote from family, social networks, or workplaces, such as those identified on the edge of the Borough around Rushden or St. Neots. Further, focussing significant amounts of investment and public resources into creating new settlements, diverts attention away from addressing the needs of existing communities in terms of improved infrastructure and facilities. As noted in the consultation paper, given the length of time required in bringing new settlements forward (8.4 years from validation to first completions based on the Start to Finish Second Edition research), they can also only realistically play a small part in terms of housing and job delivery in the short to medium term. The options linked with sustainable transport corridors, whether that is rail stations or bus routes along the A421, clearly have the potential to encourage greater use of sustainable modes of travel and are therefore consistent with national policy in that respect. As a factor, therefore, this might influence the proposed distribution of growth between settlements. With specific reference to Rainier Developments land interests at Wootton, which has been presented to the Council through the ‘call for sites’ process, support is given for a strategy which includes housing growth at Wootton. Wootton is a key service centre in the adopted Local Plan and very close to the urban edge of Bedford/Kempston. It is the third largest of the key service centres, and falls on the A421 sustainable transport corridor. Although Wootton was not identified to accommodate further growth within the adopted Local Plan due to existing commitments, it clearly was a settlement of a scale and structure that could accommodate growth in the order of 500 homes to 2030 as per the other key service centres. It should therefore play a key role in meeting future needs identified through the Plan Review given its ability to contribute towards a sustainable pattern of development.
No answer given
No answer given
Qu. 4 Growth locations The Pink option is strongly preferred, followed by orange (but there would be much more uncertainty around the latter because of East West rail’s plans and Route E being stated as the most costly). The emphasis must be on quality high density housing with much higher densities using exemplary developments like Alt Erlaa in Vienna (which achieves 133 high quality homes/hectare) and the Stirling Prize winning Goldsmith Street social housing in Norwich, also relatively high density.
Of the options for growth we recommend an emphasis on Option 1 to be supplemented by the organic expansion of village settlements in accordance with neighbourhood plans. Not only does planned urban expansion allow for higher density housing, which meets the needs of a large proportion of our residents – particularly the younger residents, it also enables greener transport options which will reduce car usage when compared to scattered housing estates. It may be bad drafting but the “Orange” option of northern station growth has two unmentioned adverse problems. The first is that East-West rail has significantly shortened journey times as an objective and they have no plans for a station between Bedford and St Neots/Sandy. The second is that that the area referred to as the “north of Bedford” is a network of villages set in a rolling landscape that is one of Bedford’s assets and which is wholly without the road infrastructure that significant development would require. As mentioned above it is also not a green option.
The Pink option is strongly preferred, followed by orange (but there would be much more uncertainty around the latter because of East West rail’s plans and Route E being stated as the most costly). The emphasis must be on quality high density housing with much higher densities using exemplary developments like Alt Erlaa in Vienna (which achieves 133 high quality homes/hectare) and the Stirling Prize winning Goldsmith Street social housing in Norwich, also relatively high density.
I do not support the East-West rail northern station growth as I do not believe it could go ahead without seriously and irrevocably damaging the natural environment of the local area.
No answer given
The future housing requirement for Bedford Borough is likely to mean that a combination of these options is required. The focus of the chosen option should be the delivery of sustainable development, in particular in terms of access by walking cycling and public transport and the delivery of affordable housing. Any new settlement option should only be taken forward if the promoter can commit to the delivery of policy compliant levels of affordable housing and infrastructure for sustainable modes of transport. There is also scope for some of the existing larger villages to become more sustainable with additional development that also delivers new community and physical infrastructure e.g. supermarket, doctors surgery, better bus services etc.
No answer given
Given that it is likely that a combination of the suggested approaches will be used, we feel it is more important to ensure that whatever the outcome it is underpinned by strong policy and guidance. Any growth will need to represent a step change in quality and quantity of environmental provision (including Net Biodiversity / Environmental Gain). While we would expect new settlements to have the highest design, environmental and sustainability standards, we equally wish to ensure that if the same, very high level of growth is translated into a much more dispersed pattern that it would still be important to ensure the same high standards. Equally we would expect whichever growth scenario is selected to take account environmental limits, such as: Water resources (including carbon implications of pumping water) Ability of watercourses to accept sewage discharges without adverse impacts on water quality Avoiding important wildlife sites It is also important to ensure that sustainable transport options are available for people wherever they live, which would support a growth pattern that creates employment close to growth and delivers sustainable travel options. The Bedfordshire LNP is currently working with BBC and the other Bedfordshire authorities on a project to map Bedfordshire’s Natural Capital assets, and the Ecosystems Services they deliver, as well as where demand currently is. It would be extremely beneficial to re-run this element of the exercise again once the options for growth are narrowed down, to help identify what natural capital will be needed to support different growth options, and feed into the decision-making process. It would also be beneficial to look at how natural capital can be provided at different levels in the size of development hierarchy, e.g. up to 50 houses, up to 150 and 150+. The LNP would be keen to explore opportunities for taking such work forward collaboratively and better informing development decisions.
Identified potential locations for growth include “expansion within the borough boundary - of neighbouring urban areas - Rushden & St Neots” & more dispersed development development throughout the borough including the expansion of villages. To what extent , if any, are any of the villages including LS considered for expansion in this location. It appears Wyboston is on the expansion agenda and what impact will this have on LS? What impact will HDC’s planned expansion and use of LS Airfield and its surroundings have on LS?
No answer given
• Brown – urban based growth alone leaves rural areas less disrupted provided that growth is kept to ‘brownfield sites’, but is probably impractical for the numbers required within Beds Borough. • Yellow- A421 based growth contradicts most of the above issues particularly in taking large areas of productive food producing land and countryside. • Pink – rail growth has the same negative issues as Yellow. • Orange – Eastwest Rail northern station would again produce the same problems as yellow and has been thrown out as impractical in the past. • Grey - dispersed growth could be possible provided that careful consideration is given to avoiding the issues related above. We do know that a significant area of brownfield and waste land is available around the town and some villages. • Red - new settlement-based growth ignores all of the above issues. Hence again has the same downsides as Yellow devouring large areas of good farmland and blighting beautiful rural areas. The so-called new garden villages (small towns) are just excuses for more urban sprawl over various areas of countryside.
Of the options for growth we recommend an emphasis on Option 1 to be supplemented by the organic expansion of village settlements in accordance with neighbourhood plans. Not only does planned urban expansion allow for higher density housing, which meets the needs of a large proportion of our residents – particularly the younger residents, it also enables greener transport options which will reduce car usage when compared to scattered housing estates. It may be bad drafting but the “Orange” option of northern station growth has two unmentioned adverse problems. The first is that East-West rail has significantly shortened journey times as an objective and they have no plans for a station between Bedford and St Neots/Sandy. The second is that that the area referred to as the “north of Bedford” is a network of villages set in a rolling landscape that is one of Bedford’s assets and which is wholly without the road infrastructure that significant development would require. As mentioned above it is also not a green option.
The pink option for Rail Growth makes more sense if the plan were to be aligned with the 2050 targets for the Oxford Cambridge Arc, but some dispersed growth may also be desirable.
Hallam considers that a preferred strategy should combine elements of the options proposed to best achieve the scale of growth that is likely to be required. The weighting or emphasis afforded to these options will be reliant on the development opportunities available and how they can best align with the spatial strategy that will emerge for the Oxford Cambridge Arc. Not one of the options, on its own, has the ability to deliver a comprehensive strategy for future growth of the Borough. A successful strategy must embrace a range of options if the delivery of housing numbers are to be met, that offers an appropriate geography of opportunities. The combination of options must also be designed to ensure that there is a robust trajectory of delivery, which will require a significant number of smaller to medium size opportunities to be commenced and completed prior to major strategic sites in excess of 1,000 dwellings, which are likely to take several years to deliver housing numbers. This will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. While, inevitably, it is understood that the options need to be distinctively defined to provide a picture for consultation, Hallam considers that a number of the options are narrowly defined – potentially unintentionally. Whilst accepting that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford including neighboring settlements that are sustainable, accessible and have capacity for accommodating growth. It is unclear where this key opportunity sits in the Council’s strategy options. Perhaps this most clearly falls within the Brown-Urban based growth option, but equally, would be consistent with the Pink – Rail growth option and indeed would form part of the Grey – Dispersed growth option. Specifically each of these options could and should embrace the opportunities for significant growth and community enhancement at Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). It becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. As discussed in relation to previous questions there are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the village. The potential for Clapham to accommodate future growth, whilst being distinct from Bedford as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham present the opportunity for the Borough Council to encapsulate a Greater Bedford option in its plan preparation and in due course in the plan strategy. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions. A Greater Bedford element to the plan would reflect that ambition and provide a positive framework for investment. Passing reference is made in the Issues and Options report to growth not being directed to larger villages where there are already significant large-scale commitments. This simply is not relevant in the context that the Council faces and given the opportunities for sustainable development in some of those villages (sites allocated and not allocated have been identified in the Clapham Neighbourhood Plan that have been independently assessed as being unconstrained, have the potential capacity to accommodate some 1,000 dwellings plus whilst integrating an extensive green infrastructure and open space network, and supporting community facilities and sustainable connections to Bedford. Both sites underscore Clapham’s potential to accommodate future growth. With regard to the other remaining potential elements of a multifaceted strategy, we would make the following additional observations: • The Pink-Rail growth option should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in the station and in East West Rail – rail related potential is not limited to the south of the town; • The Orange East-West rail northern station option – were it to happen would support more general growth north of Bedford not simply with new settlement options which, in this general area, present a number of difficult issues. It is not correct in any shape or form to argue (as per page 23) that development north of Bedford is unlikely to be possible without a northern station. • The Dispersed option – for further consideration needs to have additional details – specifically not an impression of widespread dispersion but focus on the most sustainable settlements – especially Key Service Villages Including Clapham.
It is appreciated that the implications for the Borough in respect of the Ox Can Arc, particularly in respect of future economic and housing growth and the associated infrastructure delivery, are not clear at this stage. As such, it is difficult to develop a spatial strategy for the Local Plan Review beyond that which addresses development needs solely related to meeting the needs of the Borough itself. This issue will however need to remain flexible as it is likely that progress will be made during this Plan’s preparation and the emerging strategy will need to be adjusted to address this over the coming months. In solely considering the growth requirements of the Borough, it is agreed that it is likely that the chosen strategy will need to be a combination of the growth options identified. It should however be acknowledged that the current Local Plan 2030, as recently adopted, already provides an appropriate sustainable strategy for the distribution of growth within the Borough that was found sound by an independent Inspector. In the first instance therefore, we would support an approach based on the adopted strategy and consider this should be the starting point for the consideration of further growth in future years, generally reflecting a combination of Brown (Urban based growth) and Grey (Dispersed growth). These options remain appropriate in that they would benefit from access to a range of existing services and facilities and ensure the benefits of growth are distributed across the Borough to support and enhance both urban and rural communities. Inevitably however, these sources are unlikely to be sufficient to fully meet the Borough’s own growth needs and other sources to accommodate the additional growth will be required. Of the remaining options, all potentially have a role to play. However, our concern with a number of these options is their reliance on the delivery of major infrastructure. For instance, Orange (East-West rail northern station growth) is reliant on a new rail station north of Bedford which is not part of any emerging proposals in connection with the Ox Cam Arc and unlikely to be acceptable if this increases journey times between Oxford and Cambridge, as highlighted. The other remaining options may well be better placed to respond to the wider Ox Cam Arc growth aspirations once their implications for the Borough are better understood.
The Respondent considers that the ‘Yellow – A421 based growth’ strategy is logical. Development in this location corresponds with development at BRVP and would serve to enhance the connectivity and range of services/amenities in this location. BRVP’s location alongside the A421 makes it an ideal location for delivering the water sports lake and will ensure that is eminently accessible for motor vehicles as well pedestrians and cyclists. With regard to the ‘Brown – Urban Based Growth’ strategy, the Respondent considers this to be logical. This strategy would see Bedford expand eastwards towards BRVP. This would improve connectivity between BRVP and Bedford and would mean that the water sports lake is eminently accessible for those living within Bedford. It would also mean that potential future residents of BRVP are able to seamlessly access services, facilities and businesses within Bedford town centre. Development at BRVP would also overcome the limitation to his strategy insofar as opportunities for growth within urban areas are limited. BRVP is only located a short distance from the urban area of Bedford and offers an opportunity to deliver a substantial number of dwellings that would be strongly associated with Bedford. Turning to the ‘Grey – Dispersed growth’ strategy, the Respondent considers this to be a rational strategy. Dispersing growth more widely around the area will improve access to services and amenities for more people and would lessen the overall impact of development in terms of pressure on existing services and amenities. As part of this dispersed strategy, growth at BRVP would make total sense insofar as it located close enough to Bedford to take on a proportion of the significant amount of growth required within and around Bedford. The delivery of new education facilities and a local centre would also be a significant benefit to the surrounding smaller settlements, most notably Cople and Willington. Lastly, in respect to the ‘Red – New settlement-based growth’, the Respondent considers this a sensible strategy and one which development at BRVP aligns closely with. As noted previously, BRVP is sustainably located and there are ample opportunities to create connections for walking and cycling. Coupled with the delivery of an education facility and local centre, development at BRVP is an excellent opportunity to create a new self-contained and sustainable settlement centred around a valuable amenity resource in the form of the water sports lake. The Vision Document which accompanies these representations sets out in more detail how development at BRVP could be delivered as a new self-contained and sustainable settlement that will also provide significant amenity enhancements to the surrounding area Regardless of the growth strategy chosen, the Respondent considers that the strategy should make allowances for the delivery of development at BRVP. The delivery of the water sports lake in conjunction with residential development at BRVP has been demonstrated by the Vision Document as being wholly logical, beneficial and should be facilitated by the Council as a result.
4.1 The Issues and Options document correctly concludes that the current development strategy will not deliver sufficient growth to meet the anticipated needs over the longer period that the Local Plan will need to provide for. It is therefore right that the Council are looking at various options that could deliver additionality over the plan period. 4.2 In looking at the options, it is important not to forget work already undertaken and what can be learned from this. In this regard, it should be remembered that in preparing the adopted Plan, new settlements were considered but not taken forward and the implication was that the plan period had to be shortened in part due to the lack of other sustainable options. This indicates that should a deliverable and sustainable new settlement location be identified; this could deliver additionality over the plan period. 4.3 Secondly, the adopted plan places a reliance on Neighbourhood Plans to deliver a proportion of the housing need at Key Service Centres, a strategy which to date has not delivered. This means it is likely the review will have to pick up allocations in those areas where Neighborhood Plans have not progressed, which should have been made in the adopted Local Plan. 4.4 The implication of this is that it will be difficult for the review to direct even more growth to the Key Service Centres when the last round of growth has yet to be planned. This exacerbates the need for an alternative strategy and places increased emphasis on the importance of a new settlement. 4.5 Whilst Taylor Wimpey advocate a strategy which has an element of dispersed growth to ensure a variety of sites are available to the market, the scale of growth that needs to be delivered and the constraints associated with significant growth in existing sustainable locations, means that ‘New Settlement Based Growth’ has to be given serious consideration through the review. 4.6 It is of note that of the six spatial options set out in the Issues and Options document, five indicate that land to the west of Wyboston could be a suitable opportunity for development. 4.7 The urban based growth option refers to possible extension of St Neots, to the west of the A1. Whilst a new settlement west of Wyboston would not be considered as an extension to St Neots, in this location it would be well related to the town and could be planned with strong linkages between the two ensuring they are mutually beneficial. Land west of Wyboston 4.8 West of Wyboston is also adjacent to the A421 corridor along which it is noted that road based public transport could be enhanced. As is set out in the accompanying Vision document, it would be expected that a new settlement in this location would be built around a strong public transport network with improved access to the A421 for residents. 4.9 In relation to rail, the land west of west of Wyboston lies to the north of the preferred route for the new east west rail route between Bedford and Cambridge. It therefore could be the perfect location for an additional station north of Bedford, if one were one to come forward. Equally, the land is also in close proximity to the area identified for a new station on the intersection of east west rail and the east coast mainline in the St Neots/Sandy area. A new settlement west of Wyboston could easily be liked to this station via direct public transport, aiding the sustainability of the location. 4.10 Lastly, the Issues and Options document correctly identifies land west of Wyboston as one of the four possible locations for a new settlement. For the reasons set out in our call for sites submission and built on in the accompanying Vision document, in all regards, west of Wyboston is the most suitable location for a new settlement given the area’s strategically important location in relation to key transport links, combined with limited physical and policy constraints to development. Additionally, the extent of land now assembled by Taylor Wimpey will allow us to deliver a truly sustainable settlement. 4.11 In reviewing advantages and disadvantages associated with the various types of growth set out in the Issues and Options document, it is apparent that there are disadvantages associated with each of the options put forward. However, it is clear that those disadvantages associated with new settlements can be readily overcome in relation to land west of Wyboston. 4.12 In terms of deliverability, whilst a new settlement will inevitably take a long time to deliver, assuming smaller, deliverable site allocations are made as part of the revised strategy (including those to meet the lack of Neighbourhood Plan allocations) short term delivery should not be an issue. There is a presumption that a new settlement would start delivering towards the end of the plan period and support delivery in years beyond 2040. However, by this time, it is likely the local plan will have been reviewed again, providing an opportunity to top up land supply as necessary. 4.13 In the case of Wyboston, the involvement of Taylor Wimpey as a major PLC housebuilder, delivering around 16,000 news homes annually, hopefully also gives confidence that progress on the delivery of a new settlement in this location would be expedited compared to other schemes put forward by land promoters only. Additionally, our work to date on the site indicates that whilst investment in infrastructure enhancements will be needed to release the whole site (as will be the case with all potential new settlement sites), around 2,500 dwellings could be provided in the shorter term with minimal infrastructure enchantments. This means that west of Wyboston could make a contribution towards meeting housing need sooner than may be expected. 4.14 It is accepted that a new settlement could impact local landscapes, but as is set out in the Vision document, land to the west of Wyboston does not lie in a sensitive landscape and is well suited for development. The masterplan included in the Vision document shows how up to 10,000 new homes could be accommodated on the assembled land alongside significant new green spaces and structural landscaping which would help integrate the development with its surroundings. Land west of Wyboston 4.15 It is also accepted that significant new infrastructure may be required to allow growth to be accommodated. Again, of all the options for new settlements, this points towards land west of Wyboston being ideally located given its proximity to recent and future infrastructure enhancement including: • The enhanced A421, • The upcoming enhancements to the Black Cat roundabout • East West Rail • Future improvements to the A1 4.16 In relation to the issues identified as part of the previous promotion, Taylor Wimpey are keen to work with the Council to understand any concerns and provide comfort that a sustainable development in this location is deliverable. It is important that any promotion is backed-up by appropriate evidence and Taylor Wimpey are committed to engaging with the appropriate stakeholders to ensure this is provided when required.
I do NOT support Brown -– Urban growth : too simplistic, damaging to quality countryside including the setting of the River Ouse. In Ravensden, the site at Graze Hill is a considerable extension which would count to this option. South of Ravensden, land is in setting of Mowsbury Hill, or in floodplain of the brook. Additional development would result in loss of valuable farmland and be contrary to landscape character and dispersed settlement character of villages. Orange –East West Rail northern station : This option would be highly detrimental to the countryside north of Bedford, which is so important for recreation. The scenario is not based on EW Rail’s route planning or the public consultation. EW Rail stated at the public consultation that they did not want an additional "Parkway Station to serve Bedford. It would encourage driving to a station ie not sustainable and would lengthen the journey time on the longest route in both time and track. Road infrastructure is already under great pressure. A station with associated housing and employment would result in unacceptable loss of BMV land , contrary to NPPF. Ravensden and Thurleigh and Wilden are extremely tranquil parishes – this should be a highly valued aspect of the Borough. Grey – Dispersed growth : the settlement hierarchy is important – growth has to be linked to facilities and where road infrastructure and broadband can cope. Local Neighbourhood Plans will mostly support appropriate limited growth for local needs. I have some support for Yellow – A421 Growth : Allocating growth in areas with some urban context limits loss of more valued areas elsewhere. Development would need to be extensively landscaped to enhance amenity. Pink – Rail Growth: Some concerns re growth in the Tempsford area as this is a very rural area with quality farmland and would urbanise the setting of the Greensand Ridge. Red – New Settlements – Some concern about a settlement at Chawston as this is BMV land . Support the use of brownfield land = although as a major runway, Thurleigh is a national asset.
The most crucial elements of growth to include as part of a spatial strategy going forward would be for increased levels of rural growth. To date, and as is proposed under some potentials options for growth, the Bedford and Kempston rural area has always been subject to significantly higher levels of housing growth with many settlements, including the sustainable Key Service Centres, receiving a very small proportion of planned growth under the previous plan (now superseded) and currently adopted plan. The implications for sustainability in this context are very clear, and indeed are listed within the pros and cons for the potential growth options. Urban based growth presents increasingly limited opportunities for developers to assist in meeting the objectives of sustainable development. Beyond high density schemes, very little alternatives exist to realise the level of growth that would be required as part of this Local Plan Review within the Bedford & Kempston rural area. This includes development on the urban fringe which in turn would encourage less sustainable transport methods as these would require significant further investment to facilitate a continued outward expand of the urban area. Urban based growth would equally starve more rural locations of much needed growth -housing or employment – while in turn risking the buildup of urban sprawl. Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Clapham which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future. In incorporating dispersed growth as part of a strategy, many rural communities such as Clapham would continue to be well-connected places without experiencing overdevelopment (as would be inevitable if Bedford & Kempston continued to receive a proportion of growth in line with that allocated currently/previously). Infrastructure equally would only require incremental improvements as compared to strategic level enhancements to facilitate a more spread out growth option which is more viable and has fewer impacts on the natural environment (in terms of air quality, visual impact, etc.). The draft Clapham Neighbourhood Plan envisages that the potential site for allocation will assist significantly in providing for a new school and / or expanded school capacity at existing institutes. This is one such approach that can help maintain and upgrade the existing levels of facilities and services, and subsequently the sustainability, of villages without giving rise to undue burden on local communities or the Council. Thus, dispersing growth further allows for rural centres to retain and enhance their vitality and improve the quality of living in these areas in line with what they are capable of accommodating thereby securing a more vibrant Borough as compared to a single, densified urban area that rural communities become entirely dependent upon.
2.9 The Consultation Document sets out 6 potential options for the spatial distribution of growth through the Local Plan review, these include urban based growth, A421 based growth, rail growth, east-west rail growth, dispersed growth and new settlement-based growth. The consultation document also sets out that any eventual strategy could be a combination of the above options. 2.10 We do not agree there should be any significant form of reliance on strategic sites, particularly in the form of new villages. Strategic sites, including new villages, could be included as a facet of the supply, but any plan which relies on the timely delivery of a number of strategic sites forming the largest component of supply is considered to be problematic. Such a strategy lacks flexibility and the failure of even a small number of sites could have significant impacts on housing delivery. In particular, new free-standing settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. If a new settlement is allocated within the Plan, then caution must be applied when calculating proposed build-out rates and this must be supported with sufficient other methods of delivery to insure the Plan against non-delivery. It is noted that the Council previously promoted a strategy of delivering new settlements as part of the preparation of the adopted Local Plan, but ultimately concluded such an approach was not appropriate. Land at Box End is considered to comprise of urban based growth; such allocations should also be supported by dispersed growth. 2.11 With regards to placing greater impetus on further delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building concurrently in one urban area. The Council must demonstrate evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure 6 capacity. 2.12 Whilst increased densities around public transport nodes or in urban areas is a way of increasing housing numbers and can be appropriate in certain circumstances, regard must be had for issues relating to design and housing quality. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. 2.13 Whilst we do not have any particular objection to basing growth around planned transport infrastructure, clearly such infrastructure is likely to have capacity limitations and over reliance on such may cause significant issues relating to capacity and congestion. Notwithstanding this, it limits the geographical spread of development, which can place undue impacts on infrastructure and capacity of services and facilities. 2.14 We concur that the eventual strategy could be a combination of the listed options.
5.1 The context for the Council’s Review of the Local Plan 2030 is substantially broader than the relatively narrow scope of objectives and options for distribution that the Inspectors accepted as reasonable for the purposes of the plan period to 2030. 5.2 Paragraph 48 of the Inspectors’ Report confirms that options for spatial distribution to meet requirements beyond 2030 did not require explicit consideration. For the same reason, reasonable alternatives for the scale and distribution of growth were constrained to within +/- 20% of the selected requirement that the Council has provided for as a result of the NPPF2012’s transitional arrangements for housing need. 5.3 In terms of the options for the Local Plan Review the Council must ensure that this format of constraints to the alternatives being assessed are removed in their entirety. This will provide for substantially more flexibility in terms of meeting a broader range of objectives over the plan period. This broader scope accords with the Council acknowledging that an appropriate spatial strategy is likely to combine a number of the options identified. 5.4 The background to preparation of the Local Plan 2030, including adopting a foreshortened plan period, is relevant to the identification of options for the Review. This reflects constraints to strategic growth options comprising New Settlements and large-scale urban extensions. 5.5 The Borough Council has no recent track record of outcomes under the Duty to Cooperate for exploring meeting needs elsewhere or at the administrative boundary with other neighbouring authorities (saved for the Wixams). This should frame the Borough Council’s understanding of whether large-scale strategic options are justified or would make an effective or positively prepared contribution towards meeting needs in the early part of the plan period. 5.6 Furthermore, the Review of the Local Plan 2030 must ensure that the priorities of the current plan remain a key part of the objectives. This includes addressing delays to bringing forward allocations in the rural area and rates of development in the Town Centre as well as meeting an increase in current and future needs from 2020. It is therefore not a logical conclusion that certain options identified by the Council represent reasonable alternatives to meeting the Plan’s overall objectives and requirements in the early part of the plan period, albeit they may make a greater contribution in later years. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 23 5.7 For the purpose of these representations it is, however, critical to note that the spatial strategy of the adopted Local Plan 2030 is silent on the relationship between planned and future improvements of the A421 corridor and opportunities to deliver the Plan’s strategic priorities. In recognition of this, a spatial option for A421-based growth is specifically identified in the Council’s consultation documents and is associated with the most substantial balance of advantages in favour of sustainable development. 5.8 For Roxton, the settlement to which these representations relate, it is important to note that within the context of the Council’s settlement hierarchy its designation as a Rural Service Centre is not in dispute. Paragraph 64of the Local Plan Inspector’s Report notes that the settlement scores well in all iterations of testing classifications within the hierarchy. 5.9 It is therefore acknowledged that the Council is assessing various spatial options where further growth at Roxton would make a sustainable contribution to the overall spatial strategy (e.g. as part of a ‘Dispersed’ strategy or a combination of options). However, it is important to note that Roxton’s current classification within the settlement hierarchy takes no account of its positive relationship with planned and future improvements within the A421 corridor nor its wider links with the Oxford-Cambridge Arc. 5.10 These arguments were in effect accepted due to the requirement for an immediate review under Policy 1. 5.11 For this reason, we recommend that the Review of the Local Plan 2030 is based around a strategy that fully reflects and capitalises upon opportunities for sustainable development associated with the Yellow – A421 based growth spatial option. 5.12 Further initial observations on the A421-based growth option as well as observations on the potential for other options to make a longer-term contribution towards development needs are set out below and should be read alongside our representations as a whole. (e) Summary of Conclusions on Preferred Spatial Distribution Option 5.13 Yellow – A421 based growth – Selection of this option for significant further testing is supported. This option would better recognise the strategic priorities and opportunities for development in this location relative to the existing development plan and this is to be encouraged and is consistent with national policy and guidance. The Council’s own BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 24 consultation document acknowledges that this Option has the longest list of advantages and capitalises on committed and planned infrastructure improvements including works to the A421, Black Cat and Caxton Gibbett roundabout. 5.14 The improvements complement longer-term strategic objectives for planning across the sub-region so that this option is capable of supporting further large-scale growth in the future. Critically, options to increase levels of sustainable development exist based on the characteristics of existing settlement and land use patterns across the A421 corridor. This principally includes the Key Rural Service Centre of Great Barford and the Rural Service Centre at Roxton. This option is this capable of achieving moderate to strategic-scale growth based on planned and anticipated improvement in infrastructure. Opportunities to maximise net gains through development in Roxton would be achieved through reviewing the requirements identified in existing Policy 4S. 5.15 It is evident that the minimum requirement identified in the Local Plan 2030 is not sufficient to capitalise on all plan-making objectives in Roxton, which are further impacted by housing not being allocated in Neighbourhood Plans, but instead through the Local Plan. This means that the scope for supplementary allocations and delivery of contributions towards the Plan’s objectives must be led by the apportionment of growth through the strategy of the Local Plan Review. Allocation of our client’s full opportunity for development at Land at Ford Lane (100 units) would make a significant contribution towards an appropriate overall strategy and contribute to addressing the shortfall in meeting requirements set out in accordance with government policy. 5.16 We consider that development opportunities within the corridor east of Bedford are preferable when considering the assessment of alternatives. Specifically, this reflects existing sustainable transport options including the route of the X5 linking Bedford and Cambridge. This area of the corridor also generates less potential impact as a result of cumulative levels of development south and west of Bedford (noting the proposed allocation of Marston Vale villages in the emerging Central Bedfordshire Local Plan and extant commitments at Wixams). (f) Summary of Conclusions for Alternative Spatial Distribution Options 5.17 For the avoidance of doubt, it is not the purpose of these representations to state that reasonable alternatives for further testing do not exist within the other spatial distribution BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 25 options identified in the Council’s consultation document. However, the Council’s own evidence expresses a significantly greater range of uncertainties and potential disadvantage to the remaining Orange, Red and Pink spatial options. Each of these is associated with spatial strategy options primarily focused on planning for larger scale development. In terms of the potential for these options to contribute towards the Plan’s objectives these options should be considered alongside paragraph 72 of the NPPF2019 and in-particular part (d) requiring consideration of likely delivery in the plan period. 5.18 Amongst the disadvantages associated with the remain spatial options, the Council lists the following: • Other locations would miss the benefits associated with growth (Pink, Orange and Red) • New settlements take a long time to plan and build, meaning short to medium-term housing supply shortages (Red, but also potentially applicable to other options) • Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated (Red) • Exact route of the railway not yet known (Pink and Orange). 5.19 The Council therefore acknowledges that a similar pattern of constraints exists in relation to all three remaining options. The scope for the Review of the Local Plan 2030 should explicitly recognise this amongst reasons to select an appropriate strategy. 5.20 The Council also acknowledges that other locations would miss the benefits of growth if these strategic options were selected. However, in our view this is already an outcome of the existing Local Plan 2030 in terms of its reduced housing requirement and deferral of allocations to Neighbourhood Plans (as well as the current distribution of growth set out in Policy 4S). The Review of the Local Plan 2030 is also necessary to secure delivery of the Plan’s objectives in these other locations, including at Key Service Centres and Rural Service Centres. (g) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.21 This commentary relates to the Council’s proposed methodology for site selection and the approach to updating is Housing and Economic Land Availability Assessment (HELAA). It is clear that the Council is seeking to align its conclusions following site assessment and testing of site options against the Plan’s sustainability objectives. This is to be welcomed, but only BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 26 insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.22 Our main concern relates to the following suggestion to exclude “Sites that are not in accordance with the development strategy of the emerging local plan.” The Council’s reasons acknowledge that the development strategy will be subject to substantial further assessment as part of testing alternatives. We therefore consider this criteria as inappropriate for the Stage 1 assessment at the current point in plan-making and that very few candidate sites could be ruled out on this basis. This is on account of the diverse range of spatial options that the Council is required to consider. 5.23 Planning Practice Guidance governing the assessment of land availability is consistent with our suggestions. This stipulates that plan-making authorities should consider how relevant constraints can be overcome and where future policy changes may affect choices on the scale or location of development (PPG ID: 3-018-20190722). It is also the case the Bedford Borough is affected by very few of the constraints identified at footnote 6 to paragraph 11 of the NPPF2019 that may override the assessment of the suitability of land to meet identified needs (ID: 3-002-20190722). 5.24 Where sites put forward in principle accord with any of the spatial options currently being considered (e.g. A421-based growth at Roxton) the Methodology should note that this will be recorded and that such sites will not be excluded on grounds of potential conflict with the strategy. 5.25 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA the Council does not use arbitrary limits to growth (such as the current totals in Policy 4S of the Local Plan 2030) to exclude sites that are contrary to the development strategy. This is essential to ensure that the Council considers a flexible range of options, 5.26 There are four key elements of the Council’s proposed more detailed methodology for site selection: • An Assessment against Sustainability Objectives • Review of Additional Technical and Policy Constraints • Other Considerations including Infrastructure and Contribution to Housing Delivery • Conclusions including contribution to Local Plan strategy and objectives BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 27 5.27 These four stages are essentially the same as the Council’s 2017 Options Assessment, but the Review of the Local Plan 2030 offers an opportunity to formalise the conclusions for site selection. This is imperative in terms of policy development and securing allocations to meet needs over the plan period. Although the stages are comparable the following are important differences to earlier work: • The Council is currently considering a wider range of alternatives to the spatial strategy. This will allow the objective comparison of approaches to secure sustainable development. • The assessment of Sustainability is based on clear indicators and criteria based on the Sustainability Objectives identified via the Council’s Scoping Report. This will inform a wider range of clear conclusions compared to the ‘Red Amber Green’ classification in the 2017 Options Assessment. • The list of secondary constraints is reduced compared to the 2017 Options Appraisal. This is welcomed and avoids duplicating the initial assessment of suitability, availability, and achievability through the HELAA. • At stage 3 (Community Infrastructure) the Council will give specific weight to proposals providing benefit to the wider community. • As part of the overall conclusions the Council will note the “Contribution to strategy”. This is welcome, in the context of considering a more diverse range of site options and aligns with reasons that site options should not generally be excluded as part of the HELAA due to conflict with the options for the emerging spatial strategy. 5.28 The Council also proposes to include consideration of the contribution options are likely to make towards supporting and diversifying Housing Land Supply as part of the site selection process. “Contribution to improving housing supply through broadening the range of sites that are available. The Government recognises that small and medium sized sites can make an important contribution to meeting housing requirements.” 5.29 This is welcomed. However, in rural areas this will also be as part of a boost to supply from options that exceed the 1ha threshold in national policy. 5.30 Our client’s specific interests within Roxton comprise an opportunity for the development of 100 homes at land at Ford Lane. This would contribute towards the strategic priorities and opportunity for growth within the A421 corridor, including meeting a greater proportion of the Borough’s housing requirements in this location. In terms of national policy for rural housing and the role of development in one location helping to support the needs and services of other centres the relationship between Roxton and Great Barford within the A421 corridor should also be weighed favourably in terms of the site selection process. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 28 5.31 Given the underlying issues with the strategy in the Local Plan 2030 in terms of securing options to deliver future requirements for growth it is essential that the objectives for development in the A421 corridor are set out through the policies and allocations in the Plan. The role of Roxton as a Rural Service Centre is key to delivering this spatial option. 5.32 We submit that the most logical and effective basis upon which to plan for growth would be to undertake a thorough analysis of the ability of each settlement to accommodate growth, taking into account factors such as the level of services and capacity of local infrastructure, but also the availability of suitable and available land for development. This would result in a more deliverable and effective approach that would avoid placing arbitrary targets on certain settlements which could arguably accommodate a greater level of growth.
6.1 The context for the Council’s Review of the Local Plan 2030 is substantially broader than the relatively narrow scope of objectives and options for distribution that the Inspectors accepted as reasonable for the purposes of the plan period to 2030. 6.2 Paragraph 48 of the Inspectors’ Report confirms that options for spatial distribution to meet requirements beyond 2030 did not require explicit consideration. For the same reason, reasonable alternatives for the scale and distribution of growth were constrained to within +/- 20% of the selected requirement that the Council has provided for as a result of the NPPF2012’s transitional arrangements for housing need. 6.3 In terms of the options for the Local Plan Review the Council must ensure that this format of constraints to the alternatives being assessed are removed in their entirety. This will provide for substantially more flexibility in terms of meeting a broader range of objectives over the plan period. This broader scope accords with the Council acknowledging that an appropriate spatial strategy is likely to combine a number of the options identified. 6.4 The background to preparation of the Local Plan 2030, including adopting a foreshortened plan period, is relevant to the identification of options for the Review. This reflects constraints to strategic growth options comprising New Settlements and large-scale urban extensions. 6.5 The Borough Council has no recent track record of outcomes under the Duty to Cooperate for exploring meeting needs elsewhere or at the administrative boundary with other neighbouring authorities (save for the Wixams). This should frame the Borough Council’s understanding of whether large-scale strategic options are justified or would make an effective or positively prepared contribution towards meeting needs in the early part of the plan period. 6.6 During the Examination of the Local Plan 2030 DLP argued on behalf of numerous clients that the submission version of that Plan was a substantial departure from previous iterations. This was reflected in its increased proportion of growth in the rural areas, whilst removing altogether the strategic priority of providing for a New Settlement as well as acknowledging constraints to the rate of development in the urban area. 6.7 These arguments were in effect accepted due to the requirement for an immediate review under Policy 1. Furthermore, the Review of the Local Plan 2030 must ensure that the priorities of the current plan remain a key part of the objectives. This includes addressing delays to bringing forward allocations in the rural area and rates of development in the Town Centre as well as meeting an increase in current and future needs from 2020. It is therefore not a logical conclusion that certain options identified by the Council represent reasonable alternatives to meeting the Plan’s overall objectives and requirements in the early part of the plan period, albeit they may make a greater contribution in later years. 6.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 6.9 Further initial observations on these components of an appropriate spatial strategy as well as observations on the potential for other options to make a longer-term contribution towards development needs are set out below and should be read alongside our representations as 20 a whole. Summary of Conclusions on Preferred Spatial Distribution Options 6.10 Grey– Dispersed growth – Further substantial testing of this spatial option is self-evidently critical to the soundness of the Review given its importance to delivery of the strategic priorities of the current Plan. The Council recognises the benefits of early delivery, which is essential to meet the increased annual requirement for development in the period 2020- 2040, associated with this option. This means that meeting additional requirements for development through the Local Plan Review cannot rely on options where delivery is deferred to 2030 or beyond. 6.11 This option is consistent with a number of key elements of national policy that should be considered when reviewing existing policies (including flexibility and maintaining housing land supply). This option would have to fulfil and maximise the overall potential for sustainable development in the rural area that was curtailed by the timeframe and underprovision against full housing needs in the adopted Local Plan 2030. This can be achieved through a review of the classification of the settlement hierarchy and the distribution of requirements based on updates to Policies 3S and 4S in the Local Plan 2030. 6.12 Brown (Urban-based) – We support that the testing of options needs to differentiate Town Centre locations with sites across the borough and at the urban edge. Noting constraints to the existing strategy, increased reliance on the Town Centre would lead to potentially exacerbating existing constraints to timeframes and rates of development in this location. The Local Plan 2030 does not maximise opportunities for small-scale extensions to the urban area, which can be sustainably incorporated into the spatial strategy while the Council assesses other longer-term strategic options 6.13 Yellow – A421 based growth – It is recognised that the list of advantages associated with this option seek to and capitalise on committed and planned infrastructure improvements including works to the A421, Black Cat and Caxton Gibbett roundabout. 6.14 The improvements complement longer-term strategic objectives for planning across the subregion so that this option is capable of supporting further large-scale growth in the future. Critically, options to increase levels of sustainable development exist based on the characteristics of existing settlement and land use patterns across the A421 corridor. This avoids some of the constraints to other strategic options, in terms of scope to deliver needs throughout the extended plan period. This option could not, however, deliver the Plan’s increased requirement for development in its entirety. 6.15 It is noted, however, that these more immediate opportunities are focused upon the capacity for growth within the existing settlement hierarchy, including the Key Rural Service Centre of Great Barford and the Rural Service Centre at Roxton. Opportunities to maximise the benefits of sustainable development are thus focused upon a review of the distribution of growth provided for by Policy 4S of the current Local Plan. To this extent we would identify that this spatial option is not viewed in isolation but is considered alongside a review of the capacity for growth in other larger villages based on their alignment with the Plan’s wider priorities. Summary of Conclusions for Alternative Spatial Distribution Options 6.16 For the avoidance of doubt, it is not the purpose of these representations to state that reasonable alternatives for further testing do not exist within the other spatial distribution options identified in the Council’s consultation document. However, the Council’s own evidence expresses a significantly greater range of uncertainties and potential disadvantage 21 to the remaining Orange, Red and Pink spatial options. Each of these is associated with spatial strategy options primarily focused on planning for larger scale development. In terms of the potential for these options to contribute towards the Plan’s objectives these options should be considered alongside paragraph 72 of the NPPF2019 and in-particular part (d) requiring consideration of likely delivery in the plan period. 6.17 Amongst the disadvantages associated with the remain spatial options, the Council lists the following: • Other locations would miss the benefits associated with growth (Pink, Orange and Red) • New settlements take a long time to plan and build, generating short to medium-term housing supply shortages (Red, but also potentially applicable to other options) • Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated (Red) • Exact route of the railway not yet known (Pink and Orange). 6.18 The Council therefore acknowledges that a similar pattern of constraints exists in relation to all three remaining options. The scope for the Review of the Local Plan 2030 should explicitly recognise this amongst reasons to select an appropriate strategy. 6.19 The Council also acknowledges that other locations would miss the benefits of growth if these strategic options were selected. However, in our view this is already an outcome of the existing Local Plan 2030 in terms of its reduced housing requirement and deferral of allocations to Neighbourhood Plans (as well as the current distribution of growth set out in Policy 4S). The Review of the Local Plan 2030 is also necessary to secure delivery of the Plan’s objectives in these other locations, including at Key Service Centres and Rural Service Centres. 6.20 Due to the combination of potential disadvantages it also follows that future solutions in terms of larger-scale development might look to resolve these in a manner that ensures these are overcome as part of options that maximise the benefits of these strategic options – for example New Settlement options that align with the delivery of East-West Rail. The Council’s Orange – ‘East-West rail northern station growth option’ would most closely reflect these principles, albeit there remain extreme uncertainties regarding timing and the approach to delivery of East-West Rail. 6.21 It is important to stress that given the potential timescales for East-West Rail any further assessment of such options is not incompatible with delivery of a range of other spatial options and achieving a sustainable distribution of growth in the rural area earlier in the plan period. Spatial Option and Site Assessment Considerations for the Local Plan Review: Salph End / Renhold 6.22 Renhold / Salph End is an example of a sustainable village that is demonstrably able to accommodate additional housing growth required in the period to 2030 and beyond. 6.23 The omission of Renhold / Salph End within Policy 4S of the current Local Plan is not justified in the context of the potential contribution towards the Plan’s objectives in this location. 6.24 Furthermore, the provision of a both Primary School demonstrates the settlement’s important role in providing services and facilities to the wider rural area. The ability to support higher levels of growth would therefore be justified based on a settlement-by-settlement approach 22 to assessing capacity and having regard to available opportunities. 6.25 Our client’s interest comprises land at Wilden Road, Salph End which lies in a sustainable location close to key services and facilities in the village. 6.26 Details of the proposed scheme are included at Appendix xx of these representations. 6.27 Notwithstanding the outcomes of this process it is essential that Bedford Borough Council objectively assesses all site options to achieve the longer-term requirements for development in Renhold /Salph End, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should a Neighbourhood Plan not proceed.