Question 4
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. The development of Land South West of Williamson Road would comprise of urban based growth,; such allocation 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 6 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 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. It is considered the site would support existing infrastructure and service / amenities and it would not lead to undue pressure or significant adverse impact. 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.
The consultation document sets out a number of potential locations for housing and employment growth. It is our view that growth should be directed to the locations that can facilitate sustainable development, whether that be a sustainable urban extension to an existing settlement or a new sustainable community. It is therefore, our view that the growth scenario should comprise all the following growth locations: - expansion of the Bedford/Kempston urban area; - further regeneration within the Bedford/Kempston urban area; - new settlements in locations with good accessibility - development around an East West Rail norther station; - development along the A421 corridor; - more dispersed development throughout the Borough including the expansion of villages; and, - expansion within the Borough boundary, of neighbouring urban areas, such as Rushden and St Neots. It is unlikely that any of these scenarios in isolation would deliver a sufficient number of homes, therefore, a combination of the scenarios set out above would ensure a wide variety of sites are allocated in sustainable locations. This would allow the Council to incorporate large scale strategic sites which have greater benefits through the provision of a social infrastructure to benefit both existing and new residents whilst ensuring a sufficient supply of medium sized sites (eg 100 – 500 dwellings) which can be delivered quickly and have a meaningful contribution to housing land supply, ensuring at least 10% of the housing supply is delivered on sites no larger than one hectare in accordance with the NPPF paragraph 68.
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. In incorporating dispersed growth as part of a strategy, many rural communities, such as Oakley, 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.). 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.
Garden Cities near good communication routes
We support options 'Yellow' and 'Pink'. We regard Options 'Orange', 'Grey', 'Red', and 'Brown' as being not just disadvantageous to our current Parishioners, but also to result in a suboptimal outcome for the population of the planned new developments. Options 'Orange', 'Grey' and 'Red' all require either dispersed, or concentrated, but substantial development in the countryside. The current infrastructure, both in terms of the existing road network and public transport (or more accurately, the lack of public transport) already struggle to support the existing rural population. Traffic congestion makes access to employment and schooling in the urban centres a time-consuming and miserable experience. The villages of North Bedfordshire regularly identify 'traffic and speeding' as one of the main problems affecting the population. In our view, traffic and speeding is simply a reflection of the large number of cars per household and the number of journeys which are required to access work and schooling in Bedford (and London via the Bedford train link), Milton Keynes, Northampton, Cambridge or Oxford. The historic fabric of the North Bedfordshire villages and the local geography exacerbate the traffic problem. Each of the historic villages has its unique traffic bottleneck, be that a single lane bridge or a single or narrow lane in the village centre. In addition, the regular and frequent flooding of the River Great Ouse requires lengthy journeys up or down stream to avoid closed bridges. This is the case even before the housing required by the 2030 Local Plan has been built. We believe that each of the options 'Orange', 'Grey' and 'Red' will worsen the current situation. In addition, 'Orange' is entirely predicated on an additional train station North of Bedford along the Oxford/Cambridge train line. Given the lack of certainty of the planned route and the likely opposition to an additional stop just outside of the main Bedford station, this option strikes us to be predicated on unrealistic or undeliverable assumptions. We are concerned that option 'Brown' could add significant pressure on the A6 access route into Bedford. The A6 is the main access for the North Bedfordshire countryside into Bedford, and it is not unusual for 20 minute traffic delays to build up from 7.30am every morning. By contrast, options 'Yellow' and 'Pink' would be based along existing well-developed, or planned, traffic infrastructure capable of supporting the additional growth.
The Dispersed Growth option allows growth to be distributed proportionally throughout the Borough. We agree that the majority of development will still be focused around Bedford but growth will also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites.
On behalf of the identified client’s, we advise they would support the Dispersed Growth option which allows growth to be distributed proportionally throughout the Borough. It is recognised that the majority of development will still be focused around Bedford but growth could also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites. The majority of new infrastructure will be focussed in and around Bedford but a proportional amount can be accommodated in the rural areas so those communities can also benefit. Under the dispersed growth strategy, a proportional number of larger sites should be allocated in suitable locations in the rural area which are or can be made sustainable, and are well related to an existing settlement. Larger sites can contribute towards enhancing or providing new infrastructure such as schools, community facilities, and open space, as well as increasing the vitality of existing settlements and their services. Larger sites can also provide a large amount of affordable housing. Where these sites are in more rural areas, larger sites can make a valuable contribution towards the significant undersupply of affordable housing in these areas. There is far less likely to be affordable housing in the rural area without new allocated development so affordability will continue to worsen unless a sufficient number of sites are allocated. The following larger sites are all in suitable locations for a housing allocation: • Land North Of Chawston Lane, Chawston • Land North Of School Lane, Roxton • Land South Of School Lane, Roxton • Land At Riseley Primary School • Land Adjoining Box End House, Box End Road, Kempston Rural • Land Off New Road, Great Barford • Land at Cranfield Road, Wootton Green • Land South Of Bedford Road, Cople • Land At 66 Hall End Road, Wootton • Tinkers Corner, Wootton • The Chequers, Wootton • Land At Luton Road, Wilstead • Hookhams Lane, Renhold; • Land East Of Bedford Road / Oldways Raod, Ravensden, • Land East Of Church Road, Chapel End, Colmworth; • Land West Of Church Road, Chapel End, Colmworth • Shrubbery Farm, Wilden • Land South Of Home Farm, Renhold • Land Rear Of Home Farm, Renhold; • Land At Top Farm (Incorporating Chawston Lake & Morris Walk) • Land To The West Of Heddings Farm, Wyboston
On behalf of the identified client’s, we advise they would support the Dispersed Growth option which allows growth to be distributed proportionally throughout the Borough. We agree that the majority of development will still be focused around Bedford but growth will also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites. The majority of new infrastructure will be focussed in and around Bedford but a proportional amount can be accommodated in the rural areas so those communities can also benefit. Our clients are promoting several suitable sites through Neighbourhood Plans, and our client’s will continue to focus and engage in this process as directed by the individual parishes. However, as the Plan period exceeds that of the Neighbourhood Plans, these sites have also been submitted in parallel through the Local Plan “Call For Sites” process. These sites are all in sustainable locations which are well related to the existing settlements and are suitable for allocations, either now through the Neighbourhood Plans, or if not identified, they could come forward at a later stage in the new Local Plan. These sites are: • Land South Of Keeley Lane, Wootton • Tinkers Corner, Keeley Lane, Wootton • The Chequers Public House, Hall End Road, Wootton • Land East Of Bedford Road / Oldways Road, Ravensden
The council’s acknowledgement that a combination of development strategy approaches may be required to achieve the anticipated scale of growth is welcomed. We support the strategy of facilitating a new parkway station to the north of Bedford. This will help to reduce the congestion problems in this part of the Borough and will improve sustainable transport links. The search corridor is currently very narrow but if the route were to be moved slightly further north, our client’s site at Lower Farm Road, Bromham would be a suitable location. This site has been submitted as part of the Call For Sites process and identified as a mixed use proposal for a parkway station and housing. We also support the strategy for growth along the route of the East-West railway. Some of our client’s sites are within this location and would be suitable for an allocation for residential development. These sites have been submitted as part of the Call For Sites process and comprise of the three sites at Home Farm, Ravensden and Land east of Bedford Road, Ravensden. Land North Of Home Farm can accommodate 30 dwellings, Land South Of Home Farm can accommodate up to 50 dwellings, and Land To The Rear Of Home Farm can accommodate up to 550 dwellings. The landowner is keen to facilitate self-build plots on these sites particularly on the smaller sites where these would be more suitable. The site east of Bedford Road, Ravensden, accessed via Oldways Road, can accommodate 70 dwellings comprising of market and affordable housing and the possibility of self-build plots. The development of these sites would contribute towards the ambitions of delivering development near to the future East-West rail line.
On behalf of the identified client’s, we advise they would support the Dispersed Growth option which allows growth to be distributed proportionally throughout the Borough. We agree that the majority of development will still be focused around Bedford but growth will also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites. The majority of new infrastructure will be focussed in and around Bedford but a proportional amount can be accommodated in the rural areas so those communities can also benefit.
On behalf of the identified client’s, we advise they would support the Dispersed Growth option which allows growth to be distributed proportionally throughout the Borough. We agree that the majority of development will still be focused around Bedford but growth will also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites. The majority of new infrastructure will be focussed in and around Bedford but a proportional amount can be accommodated in the rural areas so those communities can also benefit. It is important that the Plan is not overly reliant on larger scale strategic sites as these will tend to come forward later in the plan period. Small sites have the advantage of being able to be delivered quickly and their allocation will enable the Council to boost housing supply in the early years of the Plan which will help meet the ambitious housing trajectory. The Council need to have a 5 year supply or housing land when the plan is adopted and the inclusion of a sufficient number of small sites will help them to achieve this in the early years while larger scale sites come on stream. Housing in sustainable locations in the rural area also helps to support services, some of which may located in nearby villages, and this is supported by the NPPF. Small sites in the rural area are also important for the delivery of affordable housing. Affordability is worsening in the rural area due to a shortage of supply. There is less likely to be affordable housing in villages without new allocated development so affordability will continue to worsen unless a sufficient number of small sites are allocated. The following sites were submitted as part of the Call For Sites process and are suitable for small scale development in the rural area: • Myers Hill Farm, Bolnhurst • Land At West End, Little Staughton • Land Adj 14 Box End Road, Kempston Rural • Land At Northampton Road, Bromham • Land At 138 Milton Road, Clapham • Land At Church End, Willington • Land South Of Keeley Lane, Wootton • Land Adjacent Town Lot Lane, Felmersham • Land To The West Of 52 Keeley Lane, Wootton • Land East Of Box End Road, Bromham • Woodland Manor Hotel, Clapham • Land North Of Cornfilelds Public House, Colmworth • Land At The Rear Of Cornfileds, Colmworth • Land East Of Vicars Close, Biddenham • Top Farm, Wyboston • Land North Of Home Farm, Renhold
The strategy should include the allocation of rural tourism opportunities. Sustainable rural tourism is encouraged by the NPPF as part of supporting a prosperous rural economy. There is an opportunity to allocate our clients site known as Great Barford Lakes which has been submitted as part of the Call For Sites process. This site measures 23.5 ha and can accommodate a mixture of Static Caravans, Camping Plots, Holiday Lodges and a facilities Centre including shop and restaurant to support a range of leisure activities including angling, a range of water sports, and walking and cycling. This site benefits from good connectivity to the A1 and A421 and is on the Oxford To Cambridge Growth Arc.
In order for sustainable growth to be delivered across the Borough at the level that is required, the local plan strategy is likely to need a combination of elements from all the various potential areas of growth identified in Table 1. Whilst a larger proportion of housing and employment growth should be focused on the urban or improved infrastructure areas, growth should also be located within the more rural areas, within smaller scale settlements, such as rural service villages, that have previously been considered as sustainable. Considering the potential uplift required from the Standard Method, it likely that the Neighbourhood Plans which have been ‘made’ will be in need of reviewing, in order to not restrict growth in these locations or for the plans to not be in accordance with the new Local Housing Need. These settlements should contain sufficient services and facilities to meet every day needs of future residents, accepting that in more rural areas future residents may need to travel in the most sustainable way to get to these services and facilities. In addition, sustainable development across the Borough, would help to assist in maintaining the vitality of rural areas including the retention of services and facilities that depend on economic growth. This is especially the case within Bedford Borough, where there is likely to be growth in currently more ‘rural’ areas, in line with the potential Oxford to Cambridge Arc. Often, the sites which would be considered as ‘dispersed growth’ are smaller and can be delivered at a faster rate than the larger, allocated sites. Such sites form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow the Council to continuously maintain a healthy and constant supply of deliverable sites. By combining the options provided in Table 1, this would ensure that there was a level of housing growth across the Borough in areas where those houses are needed. It would promote housing in future economic growth areas and strategic corridors so that economic growth and housing delivery can be developed as a comprehensive strategy rather than a staged process. It would also ensure that rural areas received appropriate growth levels to maintain and enhance economic vitality and the services and facilities required would be maintained.
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.
It should be made clear that no single way forward would deliver enough housing to satisfy the Conservative Government’s imposed target. However, a mix of the options, preserving the distinctiveness of our rural communities whilst sharing development fairly between different areas will be of critical importance. Urban and brown field sites should, where possible, be prioritised.
In relation to the wider context of the Oxford -Cambridge Arc, there is a clear imperative to deliver more homes in sustainable locations as well meeting the general wider housing needs. The Government’s longterm ambition for the Arc is to see it as a driver for major economic growth, identifying it has having the potential to become an economic asset and for the benefit of local communities and the wider region. A major pillar of the Government’s strategy is to deliver sufficient, affordable, high quality homes to increase affordability and support growth in the Arc. The NPPF identifies that a supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as significant extensions to villages or towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. The ‘new settlement based growth’ option within the Issues and Options Consultation document has the potential to meet this objective. It proposes that Wixams would be expanded, which is supported. Wixams is designated as a Key Service Centre is the Local Plan and its role will grow as the settlement continues to be built out. The longer-term delivery development of Wixams as a New Town will see the delivery of a new town centre, strategic employment areas and a wide range of leisure and education uses alongside employment provision (eg Wilstead Industrial Park) and new transport infrastructure including the new Wixams railway station. These enhanced facilities are in place or committed and the expansion of Wixams would ensure future residents’ needs would be met without the need for wider travel. It is considered the logical expansion of Wixams is to the south given the constraints of the A6 to the east and B530 to the west. There are logical links to the suggested ‘rail growth’ option which notes the opportunity to extend the established settlement at Wixams, increasing access to the new Wixams Rail Station (Thameslink and a link into an enhanced station on the East-West rail line). It is considered therefore a combination of the two options would allow new residential development to assist in providing a critical mass to ensure best use is made of existing infrastructure and where necessary, providing enhancements to it. An example of such appropriate, achievable and deliverable development includes ‘Wixams End’ as identified in the recent Council Call for Sites submission during August 2020.
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. 2.11 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 6 an approach was not appropriate. 2.12 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. Given the number of allocations and permissions already in place, the Council must have evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure capacity. 2.13 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. 2.14 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. 2.15 We concur that the eventual strategy could be a combination of the listed options, but consider it must include an element of dispersed growth. Dispersed growth has a number of advantages and cannot be fully excluded in any adopted strategy. Firstly, the Council’s adopted strategy promotes a level of dispersed growth. Moreover, in the development of the adopted Local Plan, the Council did consider, and at one stage prefer, a strategy of greater dispersed growth, including higher levels of growth directed to both the Key Service Centres and Rural Service Centres such as Wilstead. We consider the Council should revisit such proposals, particularly in light of the increased housing requirement derived from the Standard Methodology and influenced by the Oxford-Cambridge Arc, which is likely to see the housing requirement further increase by at least 200 dwellings per annum (thereby an overall requirement of circa 1,360 dwellings per annum). Smaller sites in sustainable locations are also likely to be able to deliver quickly, which will also enable the authority to respond quickly to the increase in housing requirement. As a number of large sites are already allocated in the adopted Local Plan, this should be balanced with sites being allocated for less than 100 units which can come forward quickly and assist the Borough in housing delivery, affordable housing 7 delivery and maintaining their housing land supply. By allocating sites in the Key Service Centres and Rural Service Centres the Borough would secure a mixture of sizes to ensure development can be brought forward to meet the needs of the community.
At this stage, it is not possible to offer a preference for any one particular option, as there is insufficient information provided to make an informed decision. However development where there are already excellent road links and a station would seem sensible. It is suggested a detailed constraints plan is provided detailing the various limitations to growth. This should not be limited to environmental matters, but should include information on the capacity of corridor movements and other infrastructure constraints such as water and energy provision, flooding and strategic gaps to avoid coalescence. This is important as communities such as Clapham are constrained by existing features, such as a flood plain, the proposed alignment of EWR and limited highway capacity. Consideration of constraints should be extended beyond the Borough boundaries as future growth areas may be best suited adjacent to or outside the immediate area. In the consideration of growth options, and the provision of necessary infrastructure to support particular scenarios, there needs to be some realism on what could be provided given the affordability and timescales for any provision. Consequently, although there is insufficient information to give a preferred option, there is some merit in the consideration of a new settlement, as the quantum of development may be sufficient to provide the required supporting infrastructure. Whilst it is appreciated the Borough Council is limited in time to take forward the new plan, it is requested that constraints information should be followed by a suitable workshop so that the key issues can be discussed and debated, and consensus reached with the parishes.
Page 16 of the Issues and Options consultation document states, “this consultation seeks views on a housing figure in the range of 800-1,305 dwellings per annum. It should be borne in mind that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum.” It goes on to state, “Once existing commitments, currently around 11,000 dwellings, are taken into account (including allocations in earlier local plans, neighbourhood plans, and planning permissions granted) BBC considered that it may need to make new allocations to provide between 5,000 and 15,000 additional new dwellings over a plan period to 2040.” The proposed new standard method for BBC is 1,153 dwellings per annum. The six locations considered on pages 18 to 24 of the Issues and Options – Consultation Paper, Summer 2020 have acknowledged advantages and disadvantages. The majority appear to be based on planning principles of sustainability. However, no one locational strategy can deliver the growth needed in the borough and we therefore support an approach that would combine the best and deliverable elements of these as set out below. Brown – urban based growth We support the broad principles of urban based growth as part of a mixed distribution strategy. We are encouraged by BBC’s consideration of urban extensions to settlements adjacent to the eastern boundary of the borough specifically St Neots in the neighbouring authority of Huntingdonshire District. However, we have concerns regarding the legitimacy of an urban expansion where integration with the main settlement is limited by the A1. The A1 which acts as a barrier would cause considerable challenges in terms of sustainable transport links to St Neots. Integration of a western expansion to St Neots is further frustrated by the built context on the St Neots side of the A1 which prevents suitable connections being constructed to cross the A1. A reasonable alternative and we contend a more sustainable option, is the expansion to the south of St Neots at Little Barford. Development has already expanded south of St Neots beyond the existing A428 which is to be reclassified once the A428 expressway is open. There are no major barriers to the integration of a new community at Little Barford with St Neots to the north. Additionally, Little Barford benefits from its proximity to the new East West Rail station to the south. Whilst the exact location for the station is to be confirmed, access to the south is provided in the form of a road overbridge enabling the existing Barford Road to cross the A428 Black Cat roundabout to Caxton Gibbet road improvement. Yellow – A421 based growth The diagram on page 18 Issues and Options – Consultation Paper, Summer 2020 extends growth north of the A421 along the A1. Given the limitations of the A1 to serve and integrate new development by sustainable means of transport the yellow line on the diagram should stop at the Black Cat roundabout. Should BBC wish to continue growth beyond the A421 road corridor an alternative would be to extend the yellow line along the A428 Black Cat roundabout to Caxton Gibbet improvement insofar as it exists within the borough. Pink – rail growth Bedford Borough is centrally located within the area defined as the Oxford-Cambridge Arc. The government has designated the arc as a key economic priority and expressed its ambition for up to one million new homes to be built across the area by 2050. The Oxford-Cambridge Arc: Government Ambition and Joint Declaration Between Government and Local Partners, March 2019 states that meeting “the long-term economic and housing delivery ambitions of the arc will require long-term commitments to provide enabling infrastructure, in the widest sense, that communities and business will need.” We agree with BBC’s assertions that the East West Rail route and associated new locations for new stations and the A428 Black Cat to Caxton Gibbet improvements (expressway) are fundamental schemes for unlocking the arc’s growth potential. Of the six options this is the growth strategy we believe has the potential for delivering sustainable development. Although the exact location of the East West Rail station has not been confirmed the area of search extends from Little Barford in Bedford Borough south to Church End in Central Bedfordshire. Growth at Little Barford would benefit from sustainable transport connections to St Neots. In addition, due to location and context of the land and the ability to design in sustainable transport and associated facilities to accommodate journeys between development at Little Barford and the new station this option has significant potential to provide sustainable travel choice. Whilst we acknowledge Central Bedfordshire’s choices related to growth surrounding Tempsford, we consider that whatever the outcome of Central Bedfordshire’s local plan, Bedford Borough can also benefit from the area of search for the location of the new station. We consider the land around Little Barford (refer to drawings 068-001-004 (AL1), 068-001-005 (AL2), 068-001-006 (AL3) and 60830-PP-005) is an area within Bedford Borough that would be suitable to deliver rail based growth. The submissions made during the Call for Sites process by CODE on behalf of the Executors of the late Nigel Alington for the land to the east and west of Barford Road, Little Barford are in the location of the potential development location shown on page 19 of the Issues and Options - Consultation Paper, summer 2020. Those submissions included proposals ranging from 270 – 3,955 dwellings and circa 6,500sqm-20,500sqm of employment plus associated infrastructure commensurate with the scale of development. Figure 2 on page 6 of the Issues and Options – Consultation Paper, Summer 2020 identifies the preferred corridor for the East West Rail north of Bedford. Whilst the exact route is not yet decided it provides a clear indication of where the line will go and those locations which could benefit. The “potential EWR station St Neots/Sandy area” provides additional opportunities. The construction of a station creates an additional access point to the rail network and an opportunity to promote sustainable transport methods. The station would provide north-south (East Coast Main Line) and east-west (Cambridge to Oxford) travel choices both for short journeys to St Neots and Bedford and longer journeys to Cambridge, London and Oxford and beyond. Areas such as Little Barford which are convenient and accessible by modes other than the private car should be the focus of growth in the plan period 2020-2040. Orange – East-West Rail northern station growth A rail station north of Bedford is not part of the East West Rail route proposal so we have no further comments on this growth strategy. Grey – dispersed growth We support the broad principles of a dispersed growth strategy subject to full investigations of sites for potential development. The diagram shown on page 20 of the Issues and Options - Consultation Paper, Summer 2020 only identifies settlements defined in the current Local Plan 2030. Such an approach excludes and fails to assess reasonable alternatives such as Little Barford. Currently, Little Barford is a settlement that does not have a defined development boundary in the Local Plan 2030 and therefore is defined as “countryside” for development management purposes. We do not consider this a justified reason to rule out development in the future through a review of the local plan. The level of growth required in Bedford Borough and Little Barford’s proximity to both St Neots and the “potential EWR station St Neots/Sandy area” and the A428 expressway providing a defined boundary to the east, elevates Little Barford as a sustainable location for growth of varying scales. Over the plan period to 2040, development around the historic core of Little Barford could grow to create a sustainable settlement. The scale of the settlement is not constrained by ownership as the land is in one ownership. Phasing of the development commensurate with infrastructure and the character of the existing settlement provides an opportunity to create a place which has its own identity whilst benefiting from its proximity to St Neots and a new East West Rail station to the south of the settlement. The dispersed growth strategy should be broadened to include “potential areas of growth and change” to consider areas in locations that can benefit from the planned strategic infrastructure of the East West Rail route stations and changing status of the existing A428 following the opening of the A428 expressway. Red – new settlement based growth We also support, in broad terms, a growth strategy that considers the potential for new settlements. However, given the changes that have emerged since the adoption of the Local Plan 2030, especially regards housing numbers the potential locations for these new settlements should not be limited to Wixams and the four new settlements put forward for the Local Plan 2030. A small number of large sites can mathematically achieve this number, however, consideration needs to be given to whether the specifics of larger strategic sites will enable “multiple starts” on site by different housebuilders and whether the site can be marketed in a way that would enable small and medium size housebuilders to compete with the nationals. In this way and in parallel with other mechanisms, variety and a sense of place can be created whilst at the same time delivering homes in the early years of the plan period. We consider that the existing built form of Little Barford, its wider locational context and the spatial shift required in the distribution of Bedford Borough’s growth due to the East West Rail route and new station requires Little Barford and the land promoted by the Executors of the late Nigel Alington as a reasonable alternative for a new settlement. The above comments demonstrate how the sites AL1, AL2 and AL3 at Little Barford can support a number of the proposed growth strategies put forward in the Issues and Options - Consultation Paper, Summer 2020. We emphasise that there is a need for BBC to consider all possible locations and sites that would support these strategies.
Yellow - A421 based growth. There are already good strategic road links for new settlement based growth and would contribute to the Oxford to Cambridge arc. Pink - we strongly urge the BBC to reconsider route E as Route B is much the better option as it follows the A421 corridor Brown - we think that this is poorly named as it would suggest that building would be on brownfield sites, and much of it is in open country side but this does seem to make the best use of brownfield sites for urban extensions and under used land and so reduce countryside development, but sustainable travel options must be available. Orange - must be avoided at all costs as it will lead to the destruction of North Beds, is expensive and impractical. Road infrastructure north of Bedford is poor and water and electricity supplies do not meet current demand. There are no brownfield sites on Route E corridor north of Bedford and if this route were chosen it would compromise your own objective of maximising the use of brownfield sites.
4.1 As stated within the Issues and Options document, 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. In addition, there are a number of planned and emerging changes to national planning policy, including the Standard Methodology, the White Paper and the planned development of the Arc that will need to be considered to ensure that sufficient development is planned for to support the demand. 4.2 A minimum of 15,000 new homes will need to be delivered over the Plan period (assuming a 2040 end date) meaning land for around 16,500 -18,000 new homes will need to be planned for to ensure delivery. 4.3 The proposed development strategy must come forward in association with the infrastructure investment to ensure sustainable growth in areas that people want to live, work and relax in. 4.4 The Issues and Options document sets out 7 locations under consideration by the Council to accommodate growth. These are: ● Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites; ● Expansion of the Bedford / Kempston urban area; ● Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; ● Development along the A421 corridor; ● Development around an East West Rail northern station; ● New settlements in locations with good accessibility; ● More dispersed development throughout the borough including the expansion of villages. 4.5 Given the level of growth that will need to be accommodated in the area, it is likely that the strategy will need to accommodate aspects of the majority of these options. 4.6 Our clients land is situated at Cotton End and therefore the particular growth option that is of relevance is the ‘Development along the A421 Corridor’. The site would however support other development strategies such as ‘urban based growth’ and ‘dispersed growth’. Bedford Borough Local Plan Issues and Options Response Land at Cotton End A421 based growth 4.7 Our client strongly supports a strategy which focuses a proportion of growth along the A421 corridor. This is the key route through the Borough which not only provides road access to the key centres of Milton Keynes and Cambridge but is also the focus of employment growth in the area and a key route for movement within the Borough linking the A1 to the M1. 4.8 As already noted, and referred to in the Issue and Options Paper, the A421 has seen considerable growth in employment floorspace over recent years given the location in both the Oxford to Cambridge Arc and the M1 corridor. Moving forward, it is to be expected that this demand will remain. Therefore a proportion of future housing growth should also be accommodated in the area where employment opportunities can be accessed easily. 4.9 Cotton End is well located to existing services and facilities as well as the employment opportunities in Cardington, Bedford and the neighbouring local centres. Outside of the main urban area. Cotton End has good access to the A421 in both directions from where employment, leisure and retail opportunities can be accessed with ease. 4.10 Importantly, it is close to the location of the proposed new East West Rail station to the east, which is likely to be accessible by sustainable modes of transport. East West Rail will be one of the key infrastructure investments in the area over the plan period and it is important that the opportunities associated with this significant investment are maximised. It will provide an important route between Oxford and Cambridge as well as linking to the wider train network. Cotton End is particularly well placed in close proximity to the proposed new station at Wixams as well as the existing station at Kempston Hardwick. 4.11 In addition, Cotton End has good links to Bedford via High Road. The level of development planned for this area will facilitate improvements to the main employment, leisure and retail areas. 4.12 Proposed development at Cotton End would not impact on the planned delivery of the East – West Rail.
5.1 As stated within the Issues and Options document, 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. In addition, there are a number of planned and emerging changes to national planning policy, including the Standard Methodology, the White Paper and the planned development of the Arc that will need to be considered to ensure that sufficient development is planned for to support the demand. 5.2 A minimum of 15,000 new homes will need to be delivered over the Plan period (assuming a 2040 end date) meaning land for around 16,500 -18,000 new homes will need to be planned for to ensure delivery. 5.3 The proposed development strategy must come forward in association with the infrastructure investment to ensure sustainable growth in areas that people want to live, work and relax in. 5.4 The Issues and Options document sets out 7 locations under consideration by the Council to accommodate growth. These are: ● Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites; ● Expansion of the Bedford / Kempston urban area; ● Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; ● Development along the A421 corridor; ● Development around an East West Rail northern station; ● New settlements in locations with good accessibility; ● More dispersed development throughout the borough including the expansion of villages. 5.5 Given the level of growth that will need to be accommodated in the area, it is likely that the strategy will need to accommodate aspects of the majority of these options. 5.6 Given our clients land in Roxton, the growth area that is of particular relevance is ‘Development along the A421 Corridor’. A421 based growth 5.7 Our client strongly supports a strategy which focuses a proportion of growth along the A421 corridor. This is the key route through the Borough which not only provides road access to the Bedford Borough Local Plan Issues and Options Response Land at Roxton 11 key centres of Milton Keynes and Cambridge but is also the focus of employment growth in the area and a key route for movement within the Borough linking the A1 to the M1. 5.8 As already noted, and referred to in the Issue and Options Paper, the A421 has seen considerable growth in employment floorspace over recent years given the location in both the Oxford to Cambridge Arc and the M1 corridor. Moving forward, it is to be expected that this demand will remain, particularly for logistics given the ever-increasing emphasis on online sales and significant investment in the A428 improvements. 5.9 The land at Roxton is ideally located at the important interchange between the A428, A421 and the M1. In addition, it will be in close proximity to the East West Rail. It is therefore considered that this site is ideally located for proposed employment land. 5.10 The road improvements to the A428 / Black Cat roundabout and the East West Rail are the key infrastructure investments in the area over the plan period and it is important that the opportunities associated with this significant investment are maximised. They will provide important connections between Oxford and Cambridge as well as linking to the wider train network. Roxton is ideally located to maximise these opportunities and attract significant investment to the Borough. 5.11 The proposed development at Roxton would not prohibit or curtail any of the planned infrastructure coming forward. Furthermore, it would facilitate the relocation of the existing service station and hotel facilities within close proximity to its existing location.
Any new location chosen for housing growth must avoid significant increases in road traffic emissions and congestion. and must not increase carbon emissions the high pollution and . To deliver the level of housing required slight extensions of the urban area or villages would not be sufficient. The need should therefore be catered for by one or more new settlements alongside a new railway station. To be fully sustainable the best location would be the earlier proposed settlement at Wyboston near to the proposed Tempsford/St Neots railway station on the new east-west line between Bedford and Cambridge. It should have a direct cycle link to St Neots town and railway station together with a regular bus service. The settlement would also be adjacent to the new E/W expressway for those that have to use a car.
-Yellow A421 based growth- very unclear which villages you have in mind for potential expansion between Stewartby and Great Bardford -Orange-East West rail route If it's intended to build along the new railway, there will be a significant damage to North Beds countryside. The southern A421 route would parallel all the proposed growth along that route. -Grey dispersed growth looks like a pepperpot. How this relates to existing settlements and landscape is unclear and until that is clear, it is difficult for anyone to make a sensible comment. Earlier plans were discussed for huge development in the Soudrop/Colworth/Sharnbrook area. Little attention seemed to be paid to the very poor road links even to the A6, surely an inadequate road. Anyone wishing to work living in these houses would have to drive into Bedford and on Milton Keynes -Red - New settlement based growth. It is unclear where the starred sites are and until these are identified so that we can see the proposals i realtion to existing settlements, landscape and atrnsport links, it is unreasonable to expect peope to make a judgement either way.
I believe the best option is the ”Pink – rail growth” one, as this would minimise the impact on Bedford town and surrounding villages
5.0 QUESTION 4 – POTENTIAL LOCATIONS FOR GROWTH 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 acknowledged as part of the Local Plan 2030 process. 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 (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. 5.6 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. 5.7 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. 5.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main following elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 5.9 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 a whole. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 22 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission a) Summary of Conclusions on Preferred Spatial Distribution Options 5.10 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. 5.11 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 under-provision 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. 5.12 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. 5.13 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. 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 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. 5.15 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 Key Service Centres and Rural Service Centres based on their alignment with the Plan’s wider priorities (for example the requirements for development in Sharnbrook and Oakley). b) Summary of Conclusions for Alternative Spatial Distribution Options 5.16 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 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 23 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 5.17 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). 5.18 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. 5.19 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. 5.20 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 uncertainties regarding timing and the approach to delivery of East-West Rail. 5.21 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. We consider that the potential list of advantages associated with the Orange spatial option should include opportunities to complement and deliver net benefits aligned to the overall strategy. This is consistent with recommendations for a composite strategy incorporating appropriate assumptions for lead-in timescales and the requirements to support options such as New Settlements. 5.22 For example, there is no reason that future options for development based on the northern route alignment of East-West Rail cannot be achieved in-tandem with sustaining and enhancing the role of nearby settlements such as Milton Ernest and Sharnbrook. Site options associated with this approach, such as the potential Twinwoods New Settlement, could facilitate improvements to the A6 as well as enhancements to public transport and access to jobs and services. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 24 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.23 Appendix 4 of these representations provides commentary on the Council’s proposed methodology for site selection and 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 insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.24 As a result of the lengthy process for preparation of the Local Plan 2030, together with the deferral of site allocations, the Council’s previous evidence base generated disjointed conclusions on recommendations for site allocations. This lack of clarity in terms of findings against objectives for sustainable development means that preferred allocation options (such as those identified in the Council’s 2017 Consultation Paper) including all or part of our client’s sites at Sharnbrook, Oakley and Milton Ernest, are not necessarily reflected in the evidence base for emerging Neighbourhood Plans. 5.25 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA it does 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 In terms of the Site Selection Methodology this is an opportunity to formalise the conclusions for potential allocations including on a number of sites that Council has already assessed favourably. 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. 5.27 The application of the Council’s proposed approach to strategy options, site assessment and site selection in relation to our client’s interests, is set out in the following sections. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 25 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission i) Spatial Option and Site Assessment Considerations for the Local Plan Review: Sharnbrook 5.28 Sharnbrook is an example of Key Service Centre that is demonstrably able to accommodate additional housing growth required in the period to 2030 and beyond. 5.29 The selection of the arbitrary figure of 500 units 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. Sharnbrook comprises a highly sustainable settlement and the Council’s scoring in developing the settlement hierarchy places it in the top six centres under all iterations. 5.30 Furthermore, the provision of both a Primary and Secondary 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 to assessing capacity and having regard to available opportunities. 5.31 Our client’s interests comprise the combined sites at School Approach and Odell Road, Sharnbrook, and together would deliver key objectives for the settlement and wider area. The combined sites, which represent a key opportunity to achieve comprehensive development would deliver at least 500 dwellings. 5.32 The scale of development achievable coupled with and the comprehensive nature of the proposed scheme, enabling benefits to Primary and Secondary education in Sharnbrook, is unique to our client’s interest and fully justifies a somewhat higher overall level of growth than the requirements currently set out in Policy 4S of the adopted Local Plan 2030. 5.33 Critically, it is for the Local Plan to consider and make allocations which relate to strategic provision such as improved educational facilities, which in this case have catchment areas that extend beyond the Parish. These requirements are of greater importance given the cumulative levels of development being planned for, alongside the continued success of Sharnbrook Academy. 5.34 Details of the proposed scheme have been submitted to Sharnbrook Parish Council for consideration as part of the emerging Neighbourhood Plan for the area. A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.35 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 Sharnbrook, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should the Neighbourhood Plan not proceed. In the event that the emerging Sharnbrook Neighbourhood Plan does not address the area’s strategic priorities for secondary education (including meeting the needs for Sharnbrook Academy) the potential for ‘supplementary’ allocations to deliver suitable options to secure these improvements should be assessed favourably as part of the Review. 5.36 We would therefore invite the Council’s Planning Policy Team to consider the previous site assessment findings for this location when assessing the submitted details. Both sites were considered favourably in the Council’s 2017 Consultation Paper, as part of preferred options for site allocation. 5.37 The Council’s 2018 HELAA records both sites as suitable, available, and achievable for development, and in its 2017 Assessment of Site Options the Council identified scope for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Sharnbrook’s role as a Key Service Centre and specific planning considerations regarding our client’s land including meeting the needs of Sharnbrook Academy, requirements for ecological mitigation and highways improvements. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 26 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 5.38 Potential constraints on development in this location have previously been assessed by the Council and did not affect conclusions regarding this location as a preferred allocation. Specifically, in relation to the proximity of the Felmersham Gravel Pits SSSI over 50% of the area for the proposed Masterplan would be devoted to non-built uses. In addition, Bedford Borough Council sought advice from Natural England (received January 2017) regarding the preferred allocation option. This confirmed that subject to an appropriate package of developer contributions the proposed development could be sustainably delivered. Potential impact pathways relating to hydrology and recreation would therefore be assessed and subject to mitigation in perpetuity as part of delivery of the site. 5.39 In relation to the Council’s site selection methodology and sustainability objectives the Council appears to be seeking to place greater weight on the potential adverse effects of sites that are located separately from the existing Settlement Policy Area boundary and relate poorly to settlement form. The Council’s Sustainability Appraisal Scoping Report also records that most of the land surrounding Sharnbrook is Grade 3 agricultural land, except for some Grade 2 ‘Very Good’ quality land immediately west of the A6. 5.40 The Council’s proposed objectives therefore appear to provide scope to demonstrate that our client’s site performs favourably against other alternatives in Sharnbrook given its proximity to existing services and facilities. This would further enhance the site’s ability to secure benefits for existing and future residents given its scope to deliver improvements to social and community infrastructure. ii) Spatial Option and Site Assessment Considerations for the Local Plan Review: Oakley 5.41 Oakley is a specific example of where the Council’s testing of the ‘Dispersed’ spatial option must also take account of the requirement to review the settlement hierarchy classification. The Council’s approach to the assessment of the settlement hierarchy in the Local Plan 2030 is flawed. It fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances provided by the Council. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available. 5.42 In terms of previously assessing the sustainability credentials of Oakley it is notable that the September 2018 Sustainability Appraisal findings (for the development of up to 250 units on Land on the eastern side of Station Road, Oakley – Site Ref 521) records potentially significant, positive impacts relating to minimising growth in car usage, reducing the need to travel and promoting the shift to more sustainable modes of transport. This means that at least 3 out of a list of local services (school, GP, general store, place of employment) are available within a 10-minute walking distance and also takes account of public transport accessibility to alternative services. 5.43 In addition, the Priory Medical Centre, located towards the western edge of Clapham, is easily accessible by walking and/or cycling (less than 0.8 miles). Local bus services also offer access by public transport. 5.44 The Council’s Settlement Hierarchy paper itself acknowledges that excluding specific provision of GP facilities in individual settlements may be more appropriate for determining the hierarchy. Oakley is one example of the rationale for this judgement given the proximity to Clapham and scores more highly in this iteration prepared by the Council. 5.45 Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 27 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission public transport. 5.46 The relative sustainability of Oakley reflects that it incorporates local shopping facilities, significant employment opportunities and has both a Primary and Secondary School. As such Oakley serves a wider catchment area. In this context it is a reasonable alternative to consider a higher level of growth than the 25-50 homes band identified in Policy 4S of the current Local Plan. 5.47 The key issue with the Council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the existing Settlement Hierarchy. As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth. 5.48 Incorporating these plan-making considerations as part of the Local Plan review is covered in the supporting text of the ‘made’ Oakley Neighbourhood Plan at page 12 paragraph 5.15. This includes considering proposals for the expansion of existing organisations (i.e. Lincroft Academy) where this may give rise to requirements for additional car parking. Furthermore, paragraph 4.31 of the Examiner’s Report specifically notes the configuration of the existing Lincroft Academy Playing Fields as part of potential future priorities for Oakley: “The playing fields are separated from the main part of the school buildings and Lincroft Academy wishes to reorganise its land parcels to enable the growth and efficient functioning of the school. In addition, Oakley Football Club has indicated that it is looking for flexibility in case a better site should come forward for the Club’s use. The designation of the site as LGS would limit the future options for the school in that reorganisation.” 5.49 The importance of these strategic priorities is emphasised by Lincroft Academy’s role in meeting increased requirements for school places, to support growth across a range of nearby settlements, including Clapham and Bromham. It is therefore entirely appropriate that the review considers levels of residential development at Oakley commensurate with addressing these local priorities for development, alongside sustaining a contribution towards housing needs in the period to 2030 and beyond. 5.50 A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.51 The proposed comprehensive option for development East of Station Road is supported by a number of sports organisations and Sport England with favourable conclusions previously set out by the Borough Council. Within this context it is important that the future opportunities for sustainable growth in Oakley are fully reflected by the Plan’s strategic policies following a review of the Local Plan 2030. 5.52 We consider that based on the Council’s proposed site selection methodology for the Review of the Local Plan 2030 the conclusions on this location as a preferred allocation option remain valid and would be reinforced. The Council’s proposed sustainability objectives should positively reflect the site’s proximity to existing services and facilities and its contribution towards delivery of new open space and community uses (objectives 7a and 14a). 5.53 There is a strong justification to review levels of growth in Oakley as part of the Review of the Local Plan 2030, including its potential to contribute towards the increased requirements for growth and delivery of other objectives in the period to 2030 and beyond. Recognising this ability to contribute towards the Plan’s objectives would address issues that extend beyond the immediate neighbourhood and relate to the overall level of planned growth. This proposal enables the expansion of education facilities and secures the provision of community use of the school’s enhanced sports facilities addressing acknowledged shortfalls BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 28 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission in community sport and recreation provision in the rural area.
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 acknowledged as part of the Local Plan 2030 process. 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 (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. 5.6 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. 5.7 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. 5.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main following elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 5.9 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 a whole. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 22 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission a) Summary of Conclusions on Preferred Spatial Distribution Options 5.10 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. 5.11 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 under-provision 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. 5.12 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. 5.13 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. 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 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. 5.15 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 Key Service Centres and Rural Service Centres based on their alignment with the Plan’s wider priorities (for example the requirements for development in Sharnbrook and Oakley). b) Summary of Conclusions for Alternative Spatial Distribution Options 5.16 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 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 23 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 5.17 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). 5.18 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. 5.19 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. 5.20 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 uncertainties regarding timing and the approach to delivery of East-West Rail. 5.21 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. We consider that the potential list of advantages associated with the Orange spatial option should include opportunities to complement and deliver net benefits aligned to the overall strategy. This is consistent with recommendations for a composite strategy incorporating appropriate assumptions for lead-in timescales and the requirements to support options such as New Settlements. 5.22 For example, there is no reason that future options for development based on the northern route alignment of East-West Rail cannot be achieved in-tandem with sustaining and enhancing the role of nearby settlements such as Milton Ernest and Sharnbrook. Site options associated with this approach, such as the potential Twinwoods New Settlement, could facilitate improvements to the A6 as well as enhancements to public transport and access to jobs and services. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 24 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.23 Appendix 4 of these representations provides commentary on the Council’s proposed methodology for site selection and 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 insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.24 As a result of the lengthy process for preparation of the Local Plan 2030, together with the deferral of site allocations, the Council’s previous evidence base generated disjointed conclusions on recommendations for site allocations. This lack of clarity in terms of findings against objectives for sustainable development means that preferred allocation options (such as those identified in the Council’s 2017 Consultation Paper) including all or part of our client’s sites at Sharnbrook, Oakley and Milton Ernest, are not necessarily reflected in the evidence base for emerging Neighbourhood Plans. 5.25 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA it does 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 In terms of the Site Selection Methodology this is an opportunity to formalise the conclusions for potential allocations including on a number of sites that Council has already assessed favourably. 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. 5.27 The application of the Council’s proposed approach to strategy options, site assessment and site selection in relation to our client’s interests, is set out in the following sections. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 25 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission i) Spatial Option and Site Assessment Considerations for the Local Plan Review: Sharnbrook 5.28 Sharnbrook is an example of Key Service Centre that is demonstrably able to accommodate additional housing growth required in the period to 2030 and beyond. 5.29 The selection of the arbitrary figure of 500 units 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. Sharnbrook comprises a highly sustainable settlement and the Council’s scoring in developing the settlement hierarchy places it in the top six centres under all iterations. 5.30 Furthermore, the provision of both a Primary and Secondary 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 to assessing capacity and having regard to available opportunities. 5.31 Our client’s interests comprise the combined sites at School Approach and Odell Road, Sharnbrook, and together would deliver key objectives for the settlement and wider area. The combined sites, which represent a key opportunity to achieve comprehensive development would deliver at least 500 dwellings. 5.32 The scale of development achievable coupled with and the comprehensive nature of the proposed scheme, enabling benefits to Primary and Secondary education in Sharnbrook, is unique to our client’s interest and fully justifies a somewhat higher overall level of growth than the requirements currently set out in Policy 4S of the adopted Local Plan 2030. 5.33 Critically, it is for the Local Plan to consider and make allocations which relate to strategic provision such as improved educational facilities, which in this case have catchment areas that extend beyond the Parish. These requirements are of greater importance given the cumulative levels of development being planned for, alongside the continued success of Sharnbrook Academy. 5.34 Details of the proposed scheme have been submitted to Sharnbrook Parish Council for consideration as part of the emerging Neighbourhood Plan for the area. A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.35 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 Sharnbrook, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should the Neighbourhood Plan not proceed. In the event that the emerging Sharnbrook Neighbourhood Plan does not address the area’s strategic priorities for secondary education (including meeting the needs for Sharnbrook Academy) the potential for ‘supplementary’ allocations to deliver suitable options to secure these improvements should be assessed favourably as part of the Review. 5.36 We would therefore invite the Council’s Planning Policy Team to consider the previous site assessment findings for this location when assessing the submitted details. Both sites were considered favourably in the Council’s 2017 Consultation Paper, as part of preferred options for site allocation. 5.37 The Council’s 2018 HELAA records both sites as suitable, available, and achievable for development, and in its 2017 Assessment of Site Options the Council identified scope for a positive contribution towards several plan-making objectives. These conclusions remain entirely valid in the context of Sharnbrook’s role as a Key Service Centre and specific planning considerations regarding our client’s land including meeting the needs of Sharnbrook Academy, requirements for ecological mitigation and highways improvements. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 26 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 5.38 Potential constraints on development in this location have previously been assessed by the Council and did not affect conclusions regarding this location as a preferred allocation. Specifically, in relation to the proximity of the Felmersham Gravel Pits SSSI over 50% of the area for the proposed Masterplan would be devoted to non-built uses. In addition, Bedford Borough Council sought advice from Natural England (received January 2017) regarding the preferred allocation option. This confirmed that subject to an appropriate package of developer contributions the proposed development could be sustainably delivered. Potential impact pathways relating to hydrology and recreation would therefore be assessed and subject to mitigation in perpetuity as part of delivery of the site. 5.39 In relation to the Council’s site selection methodology and sustainability objectives the Council appears to be seeking to place greater weight on the potential adverse effects of sites that are located separately from the existing Settlement Policy Area boundary and relate poorly to settlement form. The Council’s Sustainability Appraisal Scoping Report also records that most of the land surrounding Sharnbrook is Grade 3 agricultural land, except for some Grade 2 ‘Very Good’ quality land immediately west of the A6. 5.40 The Council’s proposed objectives therefore appear to provide scope to demonstrate that our client’s site performs favourably against other alternatives in Sharnbrook given its proximity to existing services and facilities. This would further enhance the site’s ability to secure benefits for existing and future residents given its scope to deliver improvements to social and community infrastructure. ii) Spatial Option and Site Assessment Considerations for the Local Plan Review: Oakley 5.41 Oakley is a specific example of where the Council’s testing of the ‘Dispersed’ spatial option must also take account of the requirement to review the settlement hierarchy classification. The Council’s approach to the assessment of the settlement hierarchy in the Local Plan 2030 is flawed. It fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances provided by the Council. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available. 5.42 In terms of previously assessing the sustainability credentials of Oakley it is notable that the September 2018 Sustainability Appraisal findings (for the development of up to 250 units on Land on the eastern side of Station Road, Oakley – Site Ref 521) records potentially significant, positive impacts relating to minimising growth in car usage, reducing the need to travel and promoting the shift to more sustainable modes of transport. This means that at least 3 out of a list of local services (school, GP, general store, place of employment) are available within a 10-minute walking distance and also takes account of public transport accessibility to alternative services. 5.43 In addition, the Priory Medical Centre, located towards the western edge of Clapham, is easily accessible by walking and/or cycling (less than 0.8 miles). Local bus services also offer access by public transport. 5.44 The Council’s Settlement Hierarchy paper itself acknowledges that excluding specific provision of GP facilities in individual settlements may be more appropriate for determining the hierarchy. Oakley is one example of the rationale for this judgement given the proximity to Clapham and scores more highly in this iteration prepared by the Council. 5.45 Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 27 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission public transport. 5.46 The relative sustainability of Oakley reflects that it incorporates local shopping facilities, significant employment opportunities and has both a Primary and Secondary School. As such Oakley serves a wider catchment area. In this context it is a reasonable alternative to consider a higher level of growth than the 25-50 homes band identified in Policy 4S of the current Local Plan. 5.47 The key issue with the Council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the existing Settlement Hierarchy. As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth. 5.48 Incorporating these plan-making considerations as part of the Local Plan review is covered in the supporting text of the ‘made’ Oakley Neighbourhood Plan at page 12 paragraph 5.15. This includes considering proposals for the expansion of existing organisations (i.e. Lincroft Academy) where this may give rise to requirements for additional car parking. Furthermore, paragraph 4.31 of the Examiner’s Report specifically notes the configuration of the existing Lincroft Academy Playing Fields as part of potential future priorities for Oakley: “The playing fields are separated from the main part of the school buildings and Lincroft Academy wishes to reorganise its land parcels to enable the growth and efficient functioning of the school. In addition, Oakley Football Club has indicated that it is looking for flexibility in case a better site should come forward for the Club’s use. The designation of the site as LGS would limit the future options for the school in that reorganisation.” 5.49 The importance of these strategic priorities is emphasised by Lincroft Academy’s role in meeting increased requirements for school places, to support growth across a range of nearby settlements, including Clapham and Bromham. It is therefore entirely appropriate that the review considers levels of residential development at Oakley commensurate with addressing these local priorities for development, alongside sustaining a contribution towards housing needs in the period to 2030 and beyond. 5.50 A copy of the Indicative Masterplan prepared for the scheme is included at Appendix 1 of these representations. 5.51 The proposed comprehensive option for development East of Station Road is supported by a number of sports organisations and Sport England with favourable conclusions previously set out by the Borough Council. Within this context it is important that the future opportunities for sustainable growth in Oakley are fully reflected by the Plan’s strategic policies following a review of the Local Plan 2030. 5.52 We consider that based on the Council’s proposed site selection methodology for the Review of the Local Plan 2030 the conclusions on this location as a preferred allocation option remain valid and would be reinforced. The Council’s proposed sustainability objectives should positively reflect the site’s proximity to existing services and facilities and its contribution towards delivery of new open space and community uses (objectives 7a and 14a). 5.53 There is a strong justification to review levels of growth in Oakley as part of the Review of the Local Plan 2030, including its potential to contribute towards the increased requirements for growth and delivery of other objectives in the period to 2030 and beyond. Recognising this ability to contribute towards the Plan’s objectives would address issues that extend beyond the immediate neighbourhood and relate to the overall level of planned growth. This proposal enables the expansion of education facilities and secures the provision of community use of the school’s enhanced sports facilities addressing acknowledged shortfalls BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 28 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission in community sport and recreation provision in the rural area.
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’s acknowledgment 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. 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 Great Barford, 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 Key Service Centre is not in dispute. Paragraph 63 of the Local Plan Inspector’s Report notes that the settlement scores well in all iterations of testing classifications within the hierarchy. It is also relevant to note that Great Barford is not affected by the capacity of Primary Education in the same manner as other Key Service Centres. 5.9 It is therefore acknowledged that the Council is assessing various spatial options where further growth at Great Barford 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 Great Barford’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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 20 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 21 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission a) 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 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 Great Barford 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 Great Barford, which are further impact through the deferral of allocations to Neighbourhood Plans. Allocation of our client’s full opportunity for development at Great Barford (Willoughby Park - 500 units) would make a significant contribution towards improvements in green infrastructure and community infrastructure, including delivery of a new medical facility, alongside meeting contributing towards the Borough’s overall needs for development in accordance with this sustainable spatial option. 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). b) 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 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) BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 22 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission • 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. c) Site Selection Methodology and Housing and Economic Land Availability Assessment Methodology 5.21 Appendix 4 of these representations provides commentary on the Council’s proposed methodology for site selection and 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 insofar as the outcomes in terms of suitable options for development must be reflected in the policies and allocations of the Review. 5.22 As a result of the lengthy process for preparation of the Local Plan 2030, together with the deferral of site allocations, the Council’s previous evidence base generated disjointed conclusions on recommendations for site allocations. This lack of clarity in terms of findings against objectives for sustainable development means that preferred allocation options (such as those identified in the Council’s 2017 Consultation Paper) including part of our client’s site at Great Barford, are not necessarily reflected in the evidence base for emerging Neighbourhood Plans. 5.23 In terms of the specific documents it is essential that when assessing sites at Stage 1 of the HELAA it does 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. 5.24 In terms of the Site Selection Methodology this is an opportunity to formalise the conclusions for potential allocations including on a number of sites that the Council has already assessed favourably. 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, BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 23 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 welcomed, 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. 5.25 The application of the Council’s proposed approach to strategy options, site assessment and site selection in relation to our client’s interests, is set out in the following sections. d) Spatial Option and Site Assessment Considerations for the Local Plan Review: Great Barford 5.26 Our client’s specific interests within Great Barford, comprising a comprehensive opportunity for the development of 500 homes at land North of Roxton Road (‘Willoughby Park’) are set out below. Details have also been submitted for a smaller ‘Option 2’ (100 units) to illustrate the suitability of this location as part of a dispersed approach to growth within the village itself. Both options 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. 5.27 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 Great Barford as a Key Service Centre is key to delivering this spatial option. 5.28 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. This should note, for example, the additional capacity for pupils at Great Barford Primary School. 5.29 In terms of the specific planning considerations of the site and opportunities for sustainable development in Great Barford, including ensuring that strategic priorities in terms of infrastructure delivery and enhancement to community facilities and open space are met, we would urge the Council to positively consider the larger 500-unit option in the context of the Review of the Local Plan 2030 and needs across the extended plan period. Details of our client’s site at Willoughby Park (North of Roxton Road) are contained at Appendix 1. 5.30 Spatial options identified by the Borough for further testing identify fewest overall negative aspects to development focused on the A421 corridor. This not only reflects planned highway improvements and existing sustainable transport links (including the X5 link to Cambridge) but also the capacity for development in individual settlements along the corridor. In relation to the Key Service Centre at Great Barford we consider that the capacity is substantially greater than the 500 (minimum) units currently stipulated by Policy 4S of the adopted Local Plan 2030. This follows from the capacity of existing infrastructure as well as the availability of site options to deliver the requirements of sustainable development. 5.31 We would invite the Council’s Planning Policy Team to reconsider the previous site assessment findings for this location when assessing the submitted details. In the case of our client’s site at Willoughby Park, Land north of Roxton Road, Great Barford (Site Ref: 532), the site was partially considered favourably in the Council’s 2017 Consultation Paper BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 24 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission as part of preferred options for site allocation. The Council’s 2018 HELAA records part of the site as suitable, available, and achievable for development and in its 2017 Assessment of Site Options the Council identified scope in elements of the site for a positive contribution towards several plan-making objectives. The proposed site scores highly in terms of meeting the needs of a changing population; reducing levels of deprivation, inequalities and exclusion; promoting community involvement in place-shaping, promoting healthy and safe communities; and minimising the need to travel by promoting the shift to more sustainable modes of transport. 5.32 Development of our client’s site is suitable to provide 500 units, along with an extensive area (totalling 24 hectares) dedicated as a Countryside Park with wildlife ponds and creation of new pathways and access to the surrounding countryside. There would also be the provision of community facilities including the potential for a doctor’s surgery, a Multi-Use Games Area (MUGA) and a further two local areas of play which would be located adjacent to the existing village hall, extending the offer of recreational facilities in this location and to the village. The potential delivery of a new medical facility towards the Plan’s objectives for Healthy Communities is dealt with in greater detail under Question 13 of this consultation. 5.33 The site is within a sustainable location with easy access to a range of local services and facilities within the centre of Great Barford and is accessible by both foot and cycle. Buildings could be accommodated onsite to take account of existing topography, use of natural light source as well as providing natural surveillance to areas of public open space. 5.34 The Council’s proposed site selection methodology notes that landscape impact will be considered as part of overall conclusions regarding a site’s contribution towards sustainability objectives. It is important to note that the Masterplan proposals for our client’s land at Willoughby Park reflect a landscape-led approach to accommodating development within the site. The context for assessment has evolved since the Council’s previous 2017 Assessment of Site Options, although it is important to note that the conclusions of that work do not exclude the land as a potential allocation option as a result of landscape impact, finding no significant impact on key views. Furthermore, the Council’s Sustainability Appraisal of site options does not record adverse effects on local identity or the historic environment. 5.35 Subsequently, the Masterplan proposals for the Willoughby Park site and reduced 100-unit option are both supported by a landscape assessment that reflects key features within the site. Specifically, the proposed 24ha Countryside Park would address the Council’s previous site assessment conclusions regarding how a defensible northern boundary might be established for the site, with this area incorporating substantial opportunities for landscaping, open space and recreation and ecological enhancement. The entire Masterplan is informed by a landscape-led approach, together with incorporating community feedback. This extends to the layout of the site’s frontage with Roxton Road, incorporating areas for a community orchard and green infrastructure enhancement together with areas for attenuation as informed by a drainage assessment prepare to inform the Masterplan. 5.36 The Borough Council’s proposed Site Selection Methodology and Sustainability Objectives proposes to give greater weight (in terms of positive effects from development) for criteria including supporting community cohesion (objective 14a), increasing natural surveillance (objective 14b) and the delivery of new open space and sports facilities (objective 7) as well as potential contributions towards green infrastructure and biodiversity net gain (objective 2). It is clear that these attributes should be weighed favourably in terms of assessing options for development as part of the Review of the Local Plan 2030. 5.37 The ability to secure these requirements on our client’s land at Willoughby Park emphasises the opportunity to deliver the requirements for sustainable development as part of spatial options within the A421 corridor. This supports a review of the housing requirement for Great Barford as set out in Policy 4S of the Local Plan 2030 both in the period to 2030 and beyond BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 25 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission along with setting out strategic policies and allocations to achieve the Plan’s objectives.
4.1 As per the wording of paragraph 22 of the NPPF, the strategic policies for an area: ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.2 If it is assumed that the preparation and adoption of the Local Plan happens in line with the expected timetable, with the revised Local Plan adopted in the winter of 2023 at the earliest, the plan period would run until the end of 2038. By specifying a plan end date of 2040, an allowance of 24 months would be established which would provide some flexibility in the plan production process to ensure the plan looks ahead 15 years from adoption. 4.3 However, recent experience has demonstrated how difficult it can be to deliver a Local Plan in line with the stated timetable; with delays emerging as part of both the plan preparation process and at the examination stage. Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would more appropriate and would provide flexibility in the timetable. 4.4 A plan period which starts at 2020 is appropriate given that that this will be the base date for the evidence gathered to support the Plan.
5.1 We propose that an approach including a combination of elements is the most appropriate one to take in this instance. As the consultation sets out, each proposed approach will have advantages and disadvantages. 5.2 For example, taking an urban based growth approach is unlikely to meet the housing and job needs for the Borough, and will also miss opportunities to support and strengthen local communities outside of the urban areas. Meanwhile, a reliance upon new settlements will not meet needs in the shorter term given the long lead in time for new settlements. 5.3 A dispersed approach is inefficient as it discourages sustainable transport given the rural nature of much of the Borough. 5.4 A logical and sustainable approach would be a combination of urban, with a focus on the transport corridors of the A421 and rail corridors, so a combination of “Brown”, “Yellow”, “Pink” and “Orange”. 5.5 Settlements such as Wootton have historically taken growth and this evidences the suitability of Wootton as a sustainable location to meet housing needs. It is ideally located close to transport corridors and existing and future employment opportunities, whilst benefitting from facilities such as a Secondary School. 5.6 It is also vital that the Council does not concentrate development in specific areas, and instead ensures a variety of sites and locations. Focusing on areas that did not have allocations in the Local Plan 2030, such as Wootton, would enable a wider range and choice of housing to come forward and avoid potential supply issues caused by a reliance on strategic sites or in areas still delivering Local Plan 2030 (or older) sites.