Question 4
5.1 The Issues and Options document outlines the current development strategy and correctly concludes that it will not deliver sufficient growth to meet the anticipated needs over the longer period that the Local Plan Review will need to provide for. 5.2 As set out under question 1, the standard methodology, and other material considerations, mean that the level of homes that will need to be planned for in the longer term will increase. This means difficult decisions will need to be made locally about where development will be located and may mean some settlements taking more growth than previously envisaged. 5.3 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. 5.4 It will be key that the strategy for accommodating this housing growth is coordinated with infrastructure investment and the strategy for meeting employment growth needs as part of a sustainable strategy for growth. 5.5 There are 7 locations which have been identified as options for accommodating potential growth in the Issues and Options Consultation document. 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. 5.6 Given the level of growth that will need to be accommodated in the area, the strategy will likely need to accommodate components of most of the suggested options. However, there a several key points that Taylor Wimpey believe need to be given consideration in refining the strategy moving forward. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 9 Neighborhood Plan Growth 5.7 In line with policy 4S of the adopted Local Plan, it is likely that in addition to the delivery of new growth, the review of the Local Plan will need to make land allocations in a number of settlements in order to ensure the delivery of the number of homes expected in the rural area as part of the Local Plan 2030.. 5.8 Moving forward, as was set out by a number of parties at the examination of the adopted Local Plan, Taylor Wimpey consider that sites in the rural area should be allocated through the strategic plan rather than deferred to Neighborhood Plans to avoid this situation re-occurring. This will be particularly important if sites in the rural area are likely to make a greater overall contribution to meeting housing need, as may need to be the case given the constraints to development around the urban area of Bedford, including the level of existing commitments. 5.9 Whist there may be scope for Neighborhood Plans to allocate growth in some of the smaller settlements, this approach should only be used for minor development which is not integral to the overall strategy. 5.10 Locations such as Willington and Wilstead, which are located in the A421 corridor and close to the potential East West Rail station area to the east, are strategically important to the overall development strategy and should be the focus of allocations through the Local Plan Review, rather than allocations being deferred to Neighbourhood Plans. A421 based growth 5.11 Taylor Wimpey UK Ltd support a strategy which focuses a proportion of growth along the A421 corridor. The A421 is a focus of employment growth in the area and a key route for movement within and through the Borough. It also provides road access to the key centres of Milton Keynes and Cambridge. 5.12 As referenced in the Issue and Options Consultation 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. This demand is expected to remain moving forward, particularly in relation to logistics given the ever-increasing emphasis on online sales. It therefore logical for a proportion of future housing growth to be accommodated close to employment opportunities so that they can be accessed easily by employees. 5.13 Whilst employment growth could be accommodated in the immediate vicinity of junctions and close to the urban area, and there may be opportunities for residential development close to the main urban area, there are rural settlements including Willington and Wilstead in the corridor where additional residential growth should be considered favorably and would be a more desirable setting for future residents. 5.14 Outside of the main urban area, Willington and Wilstead are some of the most appropriately located rural settlements to accommodate growth. Both have good access to the A421 from where employment, leisure and retail opportunities can be accessed with ease, including by public transport. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 10 5.15 Physically, both villages are separated from Bedford by the A421 and surrounding villages, meaning the separate identify of both settlements can be protected. 5.16 The adopted Local Plan directs 25-50 homes to be allocated through the Neighborhood Plan in Willington which is identified as a rural service centre. This is consistent with other rural service centres, irrespective of their sustainability and location. 5.17 The adopted Local Plan does not identify Wilstead for housing growth on the grounds that the village has seen significant growth in recent years. However, it is notable that the village is identified a Key Service Centre which is well served by a good range of services and well connected to larger town centres by regular public transport. 5.18 Taylor Wimpey consider that it is important that growth is focused along the A421 corridor moving forward and that the potential of settlements such as Willington and Wilstead contribute to the development strategy for the corridor rather than being subject to a standardised level of growth as was the case in the Local Plan 2030. 5.19 Particularly with regards to Wilstead, the fact that no growth was allocated to the village in the adopted Local Plan, means that of all the Key Service Centres, given its location, it is one of the most appropriate places to direct new development through the review. Dispersed Rural Growth 5.20 Taylor Wimpey support a development strategy which includes growth and development in variety of settlements over the plan period. Taylor Wimpey recognise that strategic scale growth and potential new settlements represent a logical strategy for growth, however alongside this, deliverable growth in sustainable rural locations should be supported as part of a flexible strategy ensuring a mixture of growth typologies. 5.21 In this regard, rural settlements where development can contribute to achieving more than one objective of the Local Plan should be given priority. 5.22 In the adopted Local Plan, as noted above, a ‘one size fits all’ approach was taken to the Key Service Centres and Rural Service Centres, with each allocated 500 dwellings (where allocations were made) and 25-50 homes respectively. Taylor Wimpey suggest that this approach needs to be refined in the Local Plan review and greater development focused on those rural settlements where growth is more suitable and can deliver wider plan objectives. As noted above, this would mean settlements such as Wilstead and Willington would be allocated a greater level of growth than more constrained or less well-located Key and Rural Service Centres. Urban Based Growth 5.23 Taylor Wimpey support the role of urban based growth as part of the development strategy, but growth located on the urban fringe of Bedford should not be achieved at the where it would compromise the character of the urban fringe through the introduction of inappropriate and out of place higher densities. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 11 5.24 In certain locations and in certain site-specific cases, where opportunities are identified through the SHLAA, higher density development may be appropriate but generally increasing densities in new development is likely to be detrimental to the character of the area. 5.25 The urban fringe is generally of rural character, particularly to the north of Bedford where there is limited separation between the urban area and a number of rural settlements and in these locations development should either be avoided or be of a scale and character commensurate with its setting. Rail related Growth and New Settlements 5.26 It is logical for any new settlement to be focused on, or close to, any new rail station on the East West Rail route to the north/north east of Bedford. 5.27 East West Rail will be one of the key infrastructure investments in the area over the plan period and the improved accessibility that the route will provide for new and existing residents should be taken advantage of. 5.28 If a new settlement were to provide part of the development strategy to 2040, it would be illogical for this not to be linked in some way to the East West rail route and be close to other pieces of key infrastructure in the area, including the A421 and A1. 5.29 Taylor Wimpey UK Ltd have submitted a separate representation outlining their aspirations for a new settlement at Wyboston. This recognises that new settlements take a long time to plan and build and require significant investment in infrastructure, as noted in the SWOT analysis included within the Issues and Options Document. Delivery will therefore not be immediate and will not help meet local housing need for a number of years. 5.30 Therefore, whilst they advocate the inclusion of a new settlement in the Local Plan Review, this should not be at the expense of allocations elsewhere as part of a sustainable, flexible and deliverable growth strategy.
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.
In terms of the potential growth we support the “Urban based growth” option. In relation to the urban area of Bedford bpha is investing extensively in our tower blocks within Bedford town centre. More information on this can be viewed on our website at : https://www.bpha.org.uk/about-us/regeneration/ Through land assembly and joint working, we consider that our existing blocks at Greyfriars could be included in a comprehensive housing-led regeneration of the area which could bring significant benefits to the town centre. bpha is keen to continue to work with Bedford Borough Council on assets within Bedford in order to facilitate a joined up approach to creating a strong affordable housing offer that meets the needs of the community. At Rushden and St Neots future developments would require strong integration into the town centres. In terms of the other options at Tempsford where East West Rail is proposed to meet the East Coast Main Line this could provide an opportunity to develop a new settlement at a sufficient scale with good transport links. Whilst a dispersed approach to major housing growth is not supported it is important that there is a supply of affordable housing within villages which could include exception sites.
Urban based growth should be limited to brownfield land and change of use from say, commercial to housing. Large developments on the edge of town result in villages losing their identity and becoming part of the town A421 and Rail growth As here is already a road network, development along these locations would be acceptable EWR Northern station. East west rail has said that it is not in their remit to build a station north of Bedford, as this would increase travel time and cost. Anyway there is no suitable land for either a station or housing development. The road infrastructure in this area is already inadequate for the current traffic let alone for any further development. Dispersed growth should be in proportion to the size of the village and local amenities. Villages like Ravensden, which has already has proposed new growth of 50% ( Graze Hill development) should not have any more large developments
Urban&Civic are now confirmed as the promoters and master developers of Land at Tempsford, shown outlined in red on the attached plan. The site is identified by the Issues and Options Report as having significant potential for growth, as part of the “pink” or “rail growth” option. The site has also been identified by adjacent local planning authorities, as having potential to deliver a substantial new settlement, accelerated by existing and planned strategic infrastructure and the immense economic, social and environmental potential in this highly propitious, central Arc, location. U&C are committed to all that is necessary to plan, design and deliver this opportunity and are uniquely placed to exercise control over substantial landholdings, comprising land owned by the Wynne Family (The Tempsford Estate) and Mrs Codd. Adjoining land is owned by the Executors of the Countess of Erroll (The Erroll Land), who are also promoting the new settlement at Tempsford, and wider development aspirations can be coordinated over time. These comments are submitted in response to the Issues and Options consultation relating to the Bedford Borough Local Plan Review, with Bedford Borough committed to submitting an updated or replacement plan for examination by January 2023.
5.1 The Issues and Options document outlines the current development strategy and correctly concludes that it will not deliver sufficient growth to meet the anticipated needs over the longer period of the Local Plan Review. 5.2 As set out under question 1, the Standard Methodology, and other material considerations, mean that the level of homes that need to be planned for in the longer term will increase. This means difficult decisions will need to be made locally about where development will be located and may mean some settlements taking more growth than previously envisaged. 5.3 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 identified to ensure delivery. 5.4 It will be key that the strategy for accommodating this housing growth is coordinated with infrastructure investment and the strategy for meeting employment growth needs as part of an overall sustainable strategy for growth. 5.5 The Issues and Options document sets out 7 locations under consideration by the Council to accommodate growth: ● 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. 5.6 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 most of these options. However, there a several key points that Axiom believe need to be given consideration in refining the strategy. Neighbourhood Plan Growth 5.7 In line with policy 4S of the adopted Local Plan 2030, in a number of settlements it is likely that the Local Plan Review will need to make land allocations to deliver those homes expected to be allocated in the rural area through Neighbourhood Plans. 5.8 If this is the case, this should not prevent further growth being directed to these settlements where it can be accommodated sustainably and would help to meet the wider strategic objectives for the area. 5.9 Care will need to be taken to ensure that any growth deferred to Neighbourhood Plans is of a quantum that does not jeopardise the delivery of the overall development strategy should those plans be delayed. This will be particularly important if sites in the rural area are likely to make a greater overall contribution to meeting housing need, as may need to be the case given the constraints to development around the urban area of Bedford. 5.10 It will also be particularly important in locations such as Great Barford, which is in the A421 corridor, close to the potential East West Rail station, and therefore a strategically important location in the overall development strategy. 5.11 Whilst there may be scope for Neighbourhood Plans to allocate growth in some of the smaller settlements, this approach should only be relied on for development which is not integral to the overall growth strategy. A421 based growth 5.12 Axiom support 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. 5.13 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 its location in both the Oxford to Cambridge Arc and the M1 corridor. It is expected that this demand will remain in the future, particularly for logistics given the ever-increasing emphasis on online sales. It therefore makes sense for a proportion of future housing growth to also be accommodated in the area where employment opportunities can be readily accessed. 5.14 Whilst employment growth is best located in the immediate vicinity of major road junctions and close to the urban area, there are rural settlements which are within the A421 corridor, with good access to employment opportunities where additional residential growth should be considered favorably. 5.15 Outside of the main urban area, Great Barford is one of the most appropriately located rural settlements to accommodate growth. It has good access to the A421 from where employment, leisure and retail opportunities can be accessed with ease. Importantly, it is also close to the proposed new East West Rail station to the east from where access to Cambridge will be possible. 5.16 Great Barford is physically separated from Bedford by the A421 and an area of flood risk which limits the potential for coalescence with the main urban area, meaning the settlements’ separate identities can easily be protected. 5.17 The adopted Local Plan 2030 directs 500 dwellings to Great Barford, to be allocated through the Neighbourhood Plan. Site assessments to support the Neighbourhood Plan have identified that there are several suitable sites in the village which, if all developed, could provide significantly more homes than currently proposed for allocation, which clearly demonstrates the potential of the area. 5.18 Axiom considers it important that future growth is focused along the A421 corridor and that the potential of rural settlements to contribute to the strategy for the corridor is recognised. Dispersed Rural Growth 5.19 Axiom support a development strategy which includes growth and development in a variety of settlements over the plan period. Whilst strategic scale growth and potentially new settlements will play a logical role in the strategy, deliverable growth in sustainable rural locations should be supported as part of a flexible strategy which does not overly rely on limited growth typologies. 5.20 In any dispersed strategy, priority should be given to growth in those rural settlements where development can contribute to achieving more than one objective of the Local Plan Review. 5.21 In the adopted Local Plan 2030, a ‘one size fits all’ approach was taken to the Key Service Centres, with 500 dwellings allocated to most of the identified villages based on future educational provision. Axiom suggest that this approach needs to be refined in the Local Plan Review and greater development focused on those rural settlements where growth is more sustainable and can help deliver the wider plan objectives. Urban Based Growth 5.22 Axiom support the role of urban based growth as part of the spatial strategy but not at the expense of the character of the urban fringe, particularly through development at higher densities around the edge of Bedford. 5.23 In certain locations and in some site-specific cases, higher density development may be appropriate but generally increasing densities in new development is likely to be detrimental to the character of the area. 5.24 The urban fringe is generally rural in character, particularly to the north of Bedford where there is limited separation between the urban area and a number of rural settlements. In these locations development should either be avoided or be of a scale and character commensurate with its setting. Rail related Growth and New Settlements 5.25 The response on these two growth typologies are combined as it is logical for any new settlement should be focused close to new rail station(s) on the East West Rail route to the north/north east of Bedford. 5.26 East West Rail will be one of the key infrastructure investments in the area over the plan period and it is important that advantage is taken of the improved accessibility the route will provide for new and existing residents. 5.27 Given the SWOT analysis in the Issues and Options document picks up on the fact that new settlements provide an opportunity to deliver sustainable transport links between new settlements and urban areas, it would be illogical for a new settlement proposal not to take advantage of the opportunities presented by East West Rail. 5.28 As identified in the SWOT analysis, new settlements also take a long time to plan and build and require significant investment in infrastructure. It is therefore important that any assumptions made about the delivery of new settlements are realistic and do not overestimate the short-to-medium term rate of housing delivery which would negate the need to make allocations elsewhere. 5.29 Experience shows that any housing delivery from a new settlement will be towards the back end of the plan period, with the majority of completions in years beyond 2040. This needs to be reflected in the development strategy to avoid any short-to-medium term land supply issues emerging which would be to the potential detriment of the overall growth strategy.
After reviewing the location options in Table 1, Urban Based Growth and Dispersed Growth are considered to be the most appropriate strategies. However, it is also considered that the full housing and employment needs for the Borough will need to be met by using a range of the different growth scenario options. In this regard, consideration should be given to a strategy that seeks to accommodate both urban and dispersed growth. Urban Based Growth is supported in that it will encourage additional development and inward investment in close proximity to the key service centres of Bedford and Kempston. As identified within the consultation document, it is very unlikely that urban growth can be met by redevelopment of brownfield land within Bedford and Kempston. Therefore, it is important that consideration is given to releasing appropriately located greenfield land within the countryside around Bedford and Kempston for allocation. As set out within the attached Vision Document, land at Gibraltar Corner, is located within the ideal location to assist with meeting an Urban Based Growth Approach, being within short walking and cycling distance to Kempston. The approach to dispersed growth, is also supported, however, it is considered that this dispersed growth should be situated in more sustainable locations in close proximity to key service areas, such as Bedford and Kempston. It is considered that large scale growth within the less sustainable and more remote northern areas of the Borough is not appropriate in that it would result in over - reliance on use of the motor car and new housing being situated a long distance from the principal settlements of Bedford and Kempston. However, provision for dispersed growth on urban edge settlements such as Gibraltar Corner is strongly supported, in that it will provide a good quality of life for new residents at an appropriate density for rural/urban edge locations. It will also ensure that development is located within village settlements that have very good accessibility to Kempston and Bedford. The approach to meeting the majority of growth by provision of new settlements is not supported. New settlements generally require substantial infrastructure in order to be deliverable and any new settlement is not likely to be deliverable within the short to medium term. It is very important that a number of medium and smaller sized sites (circa 500 dwellings or less) are allocated in order to meet the identified housing needs within the short to medium term. In particular, we consider that this approach will ensure consistent delivery across the plan period by avoiding an over concentration of development in a specific area or an over reliance on large strategic sites. This is particularly important for areas such as Bedford Borough, given the significant number of strategic sites that are being delivered through the current Local Plan 2030. In addition, growth in and around urban areas are more likely to support the key vision of the Local Plan, which is to create vibrant town centres in Bedford and Kempston. No objection is raised to provision for some growth along the new railway and A421 Corridor to the west of Bedford. However, this growth will only be appropriate to meet a proportion of any new growth allocated as part of the new Local Plan. It is considered to be a less sustainable approach than providing growth around the principle settlements of Kempston and Bedford. In particular growth along the A421 Corridor is likely to result in additional use of the motor car.
Historic England has no particular preference on the specific geographical spilt however we recommend that the density, scale, character and detailed designed of new housing be appropriate for its context. The capacity for an area to accommodate Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. new housing development whilst maintaining its historic environment should be a key consideration, so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Allocation of new housing sites should be considered in the most sustainable locations and densities and character should reflect that of the surrounding area. This approach will require a careful and detailed analysis of locations to ensure that distribution of housing is appropriate. The historic environment is a critical factor in this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. Any proposals for growth should consider the potential impact on the historic environment. Our advice note (HEAN) 3 on Site Allocations in Local Plans offers information on a methodology for site selection assessment: https://historicengland.org.uk/images-books/publications/historic-environment-andsite- allocations-in-local-plans/ Further detail is given on this aspect later in the letter and in our response to your Call for Sites consultation in August. We have included a few brief comments below on some of the potential locations for housing and employment growth and identified some of the key historic environment considerations for particular areas. This is by no means an exhaustive list but offers a starting point for the consideration of heritage in relation to these different options. Potential locations for housing and employment growth a) further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites; Regeneration and densification can be useful in accommodating the required growth. However, where there are opportunities for densification, this must be managed carefully in a way that seeks to conserve and enhance the historic environment. Much of the central area of Bedford is designated as a Conservation Area. We refer you to our publication, ‘Increasing residential density in historic environments’ which can be found here. This study explores the factors that can contribute to successfully delivering developments which increase residential density in historic environments. It uses a combination of literature review and case studies to provide a series of recommendations to support decision making. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. Whilst taller buildings may be appropriate in some areas, there is an on-going question of scale. It is important that densification, including tall buildings, respects and does not harm the historic environment. WE recommend that you consider undertaking a tall buildings study to inform your strategy and include a policy for tall buildings in your Plan. Finally, densification is particularly appropriate in the context of brownfield development. Whilst densification of some areas may be appropriate, it is important to protect and enhance open spaces within urban areas and villages as these open spaces can constitute an important aspect of the character of a place, may help protect the setting of heritage assets or even be a heritage asset in their own right. Open spaces can provide important green lungs and help in tackling climate change. And they may also serve as important recreation and leisure areas. b) expansion of the Bedford / Kempston urban area; The NPPF (paragraph 72) states that the supply of large numbers of new home often can be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns. Criterion 3 of the paragraph states that they should ‘set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City Principles). That said, Bedford has already experienced large scale urban extensions. The river and its floodplain represent a constraint both to the east and west of the town. There are also a number of historic villages and conservations areas around the exiting built up area, which raises the issue of coalescence and the importance of maintaining the integrity, separation and identity of these communities. To that end, urban extensions will need to be carefully considered, taking the impact on the historic environment into account. c) expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; Immediately to the south of Rushden lies the grade I listed parish church of St Lawrence at Wymington. To the south of St Neots lie a cluster of listed buildings centred on Little Barford and Wyboston. To the west of the town, across the A1 there are a number of listed buildings and scheduled monuments including Bassmead Manor Farm moated enclosure, Bushmead Priory and The Camps moated site and fishponds. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. d) development along the A421 corridor; There are a number of Conservation Areas and clusters of listed buildings along the A421 corridor including at Wootton, north of Shortstown, Elstow, Cardington, Willington, Great Barford and Roxton. There are also a number of scheduled monuments along the route with a particular cluster to the east of Bedford. e) development around an East West Rail northern station; There are a number of grade II listed buildings and structures in this area. Yarl’s Wood hermitage and moated site lies to the west of this area. f) new settlements in locations with good accessibility; The NPPF (paragraph 72) states that the supply of large numbers of new homes often can be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns. Criterion 3 of the paragraph states that they should ‘set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City Principles). Whilst Historic England broadly welcomes the idea of new settlements in locations with good accessibility, it is important that these are carefully located and planned with respect to all three strands of sustainable development. One of the strands of sustainable development includes the protecting and enhancing the historic environment. Landscape and heritage assets should be considered from the outset when determining the location of a new settlement in order to ensure that development can be delivered whilst having regard to the these assets. It is expected that strategic new settlement policies makes reference to the historic environment and the need for its conservation or enhancement. In considering potential locations for new settlements, it is important to consider the potential impact of new development on character and vitality of existing historic places. Consideration should also be given to the landscape character/context and how any new development would relate to it. Any new place has a past. Attention should be given as to how heritage can shape our future places and how new development might respond to our heritage to enhance the place and those assets. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. Whilst we recognise that it is hard to avoid all heritage assets for new settlement proposals given the scale of the proposed development, never-theless sites where should be chosen where there are likely to be fewer heritage assets and where harm to heritage can be avoided or at least minimised. The key to the development of large strategic sites, be they new settlements or urban extensions, is early Heritage Impact Assessment prior to allocation and before the site is included in a Local Plan, to determine suitability of site per se and, if so, which parts of site developable and to recommend appropriate mitigation. We would also emphasise the importance of clear policy wording and ideally a concept diagram to show key principles for the new settlement including heritage mitigation. Many Local Plans state that new settlements should come forward as a new ‘Garden Village’ based on the Town and Country Planning Association’s principles for Garden Cities. It is important at this stage to highlight that whilst these principles are useful and do embody a number of modern town planning concepts, they do not address the historic environment. It is therefore unclear how the TCPA principles can be reconciled with the NPPF’s definition of sustainable development in terms of its environmental strand which requires the conservation and enhancement of the historic environment. Whilst the TCPA Garden Cities Principles are silent on the historic environment, their 2017 publication “The Art of Building a Garden City” does provide a further level of detail, particularly with regards to the siting of new settlements. This publication states that, “locations for new garden cities should not only avoid damaging areas that are protected for their ecological, landscape, historic or climateresilience value but should actively be located in areas where there can be a positive impact on these assets. Underpinning the consideration of sites for new garden cities or towns should be the extent to which each one … will allow for positive impacts on assets of historic value”. (Emphasis added, pg. 100) In drafting any principles for the development of new garden communities, we would suggest that you ensure that reference is made to the need to conserve and enhance the historic environment. You will recall that we made a number of comments of proposed new settlements during the last Local Plan Review. Given that these sites are now being reconsidered as part of this Local Plan Review exercise we include our Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. comments on these new settlements for your ease of reference. WE have not taken a view at this stage as to which if any of these sites might be suitable but advise that further detailed assessment in relation to heritage will be required to inform any decision. 1. Lee Farm / Colworth Lee Farm / Colworth has been identified as a potential new settlement site. There are a number of designated assets within the site including the grade II* listed Colworth House, and New Farmhouse and Antonie Farmhouse, both listed at grade II. There are also numerous heritage assets located around the site. The site lies adjacent to and includes a small part of the Sharnbrook Conservation Area. The Conservation Area includes the grade I listed Church of St Peter, together with approximately 40 buildings or structures listed at grade II. A further cluster of listed buildings, including All Saints Church and a further 11 buildings listed at grade II lie to the north west of the site within the village of Souldrop. Hinwick Lodge and Barn, both listed at grade II, lie to the north of the site whilst to the north west Hinwick House is listed at grade I and Hinwick Hall and the garden entrance gates both at grade II*. In addition there are a further 25 buildings listed at grade II in the vicinity and Hinwick House Registered Park and Garden is listed at grade II. The Podington Conservation area contains a further 24 listed buildings including the grade I listed church of St Mary and to the south west, Odell Conservation Area contains approximately 20 listed buildings including the grade I listed All Saints Church. Hobbs Green Farmhouse (grade II) lies outside of the conservation area but closer to the site allocation. In addition there is a scheduled monument, a moated site in Castle Close, just to the south east of the site as well as Wold Farm Moated Enclosure, a scheduled monument, to the west of the site. The HER indicates that this is an area of very high archaeological potential with a high concentration of records in this area dating from the late prehistoric through to twentieth century features. These include late pre-historic enclosure, iron age cropmarks, iron age ditches, rectangular enclosure, iron age pottery, a Roman road, a Roman site, Tofte Manor, medieval bloomeries (iron works) and a World War II searching battery. Given this rich concentration of heritage assets, any development at Colworth therefore has the potential to impact upon these assets or their settings. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. 2. Thurleigh This proposed new settlement site was a World War Two Royal Air Force and United States Army Air Force bomber airfield. The airfield was constructed in the early 1940s. In 1942-3 the runways were extended. Technical facilities were located on the east side of the airfield but have now been demolished. The airfield was designated as USAAF Station 111 by the Americans. In 1946 a temporary wind tunnel (the largest in the United Kingdom at that time) was erected on the airfield in one of the hangars but was subsequently dismantled. The airfield was rebuilt between 1951-1954 in parallel with the development of the Royal Aircraft Establishment Wind Tunnel site south from the airfield. Surrounding the airfield are a number of other designated heritage assets including grade II Blackburn Hall Farmhouse and scheduled Blackburn Hall medieval moated site which is an above average example of a Bedfordshire moat with well-preserved archaeological structures. Although partially excavated, the monument displays a wide diversity of surviving features including fishponds and a rare association with quarry pits. 3. Twinwoods Twinwoods wraps around to the north, south and east of the village of Milton Ernest. It incorporates or is immediately adjacent to three scheduled monuments and potentially affects the setting of two grade I and some grade II listed buildings. Two of the scheduled monuments relate to the shrunken medieval village, the other a set of enclosures. The grade I listed buildings are Milton Ernest Hall which is William Butterfield's only complete country house and the parish church of All Saints. 4.Wyboston The proposed new settlement site to the east of Wyboston includes two grade II listed buildings. It is adjacent to or includes the medieval moated site of Chawston Manor. Chawston Manor forms one of a pair of moated sites in the vicinity of Wyboston. This proximity will allow chronological and social comparisons between the two sites. Documentary evidence concerning the history of Chawston Manor moated site further enhances its importance. The silts within the ditches and the water-logged deposits in the fishpond will contain environmental and artefactual evidence related to the occupation of the site; and, despite some disturbance caused by later constructions, the island will retain the buried remains of earlier buildings. The major part of the Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. western enclosure is undisturbed and will also retain buried archaeological features. 5. Tempsford (mentioned in the rail growth option) We have previously provided advice to Central Beds in relation to a possible new settlement site at Tempsford. Given the proposals for a station in this broad area as part of the EWR proposals, we understand that you are exploring the potential for a new settlement in this broad location, on the boundary with Central Bedfordshire. There are a number of designated and non-designated assets in the area. These include Roxton, Tempsford – Langford End and Church End Conservation Areas, a number of listed buildings including the Church of St Peter, Church of Saint Mary Magdalen and Congregational Chapel, all listed at grade II* and numerous grade II listed buildings. There are also several scheduled monuments in the area; the Gannocks Castle moated site, Biggen Wood moated enclosure and Story Moats moated enclosure at Everton. The Hazell’s Registered Park and Garden is located to the south east in an elevated position and offers commanding views over the Tempsford area. Tempsford Airfield is a non-designated heritage asset. We would refer you to two publications which may be of use in assessing this site. The first, https://www.historicengland.org.uk/images-books/publications/nine-thousandmiles- of-concrete/ is essentially an audit of airfields. Tempsford is mentioned and is rated 1-2 (low grade) and to that end we would recommend that standard investigation would be needed to establish in any earlier airfield remains lie beneath the surface. We would also highlight the following publication: https://content.historicengland.org.uk/imagesbooks/ publications/historic-military-aviation-sites/heag048-historic-militaryaviation- sites.pdf/ In order for any of these new settlement sites to be brought forward we would expect detailed site specific evidence prepared, for example through a proportionate Heritage Impact Assessment, which could assess the impact of development on heritage assets and their settings has to the assets’ significance and what, if any, mitigation or enhancement opportunities there are within the proposal. We also would expect to see a clear justification why such sites are being preferred over alternatives where there is considerable impact on the historic environment. Without this level of detail it is difficult to advise where such large allocations are proposed. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. Further assessment of potential impacts is necessary and any site allocation will need to be justified in terms of its heritage impacts. If taken forward for allocation, appropriate development criteria would need to be set. It may not be possible to allocate based on these impacts. g) more dispersed development throughout the borough including the expansion of villages. Any proposed growth of villages should give consideration to settlement character and identity. Development of jobs and homes should seek to conserve and enhance the historic environment through appropriate development that minimises harm to the historic environment through careful siting and appropriate design. There may be some villages that are more or less suited to absorbing additional growth, in part dependent upon their historic character and settlement morphology. Consideration will need to be given to the capacity of individual villages and their sensitivity to change. Where there is a Conservation Area Appraisal in place, this may help to inform decisions regarding potential locations for growth within villages.
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”. Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 5 5.5 Locations such as that south of Bedford in the Marston Vale show that there are suitable sites which meet most of these criteria, being on the edge of urban areas, close to the A421 and adjacent to the mainline railway line.
The JPDU engaged positively with Bedford Borough Council (BBC) through the preparation of the JCS and the Bedford Borough Local Plan. A number of Duty to Cooperate meetings were held with the JPDU, BBC, East Northamptonshire Council, Borough Council of Wellingborough and Northamptonshire County Council (NCC) Highways to discuss cross-boundary issues. This positive engagement is ongoing. Of most relevance to North Northamptonshire are the potential locations for growth, particularly the options described in the paper as: • Brown- Urban based growth: Growth in and around the Bedford / Kempston urban area, together with extensions to Rushden and St.Neots. Building at higher densities in and around urban areas could deliver a significant number of homes. • Red- New settlement based growth: In addition to expansion of Wixams (new settlement) a number of new settlements could be developed. During the course of the preparation of the Local Plan 2030 four potential new settlement options were discussed but were not taken forward at that time. These and other new settlement options that have yet to be put forward could be considered as part of this plan. Brown- Urban based growth This option would include extensions within Bedford borough that would functionally act as an extension to Rushden. The scale and location of growth at Rushden is a matter for the update of the JCS through the North Northamptonshire Strategic Plan, although cross-boundary considerations will need to be progressed with BBC as the plans are developed. It is important to note that the consultation paper makes no reference to a need for North Northamptonshire or other adjoining authorities to take Bedford’s growth. This has also not been raised in discussion to date with BBC. It is noted that Table 1 in the Issues paper provides a high-level summary of potential advantages and disadvantages of the options. It is noted that this identifies as a disadvantage for Urban based growth that “Growth may overstretch existing services, facilities and infrastructure in towns”. Infrastructure and service provision will be a key consideration in assessing options. The issues identified in this response should be included in this assessment process. The potential option identified in the Issues paper relates to zone RUS1 Rushden South, Between Wymington and south of Bedford Road (A6) that was previously assessed and discounted in considering options for expansion to Rushden. This work is summarised in the Rushden Sustainable Urban Extension Background Paper January 2015. The key positive attribute(s) were summarised as “Good connectivity to Rushden town centre via Wymington Road (emerging USS) and the key negative attribute(s) as “Development would lead to coalescence with Wymington. Contrary to adopted Bedford Borough Core Strategy). The summary/overview of the assessment recognised the need for issues to be considered through concurrent plan-making: “Expansion to south would entail full/ fundamental review of Bedford Borough Core Strategy. This would need to run concurrently with the NNCS Review and would be likely to lead to major delays in the process”. As previously identified, coalescence and the impact of growth on settlements such as Wymington will be an important consideration in assessing potential growth options in this locality. Whilst the comments regarding conformity with the Bedford Borough Core Strategy and the impact on the NNCS Review have been superseded, it will be important to consider opportunities/issues relating to growth at Rushden through both plans (see response to Q.3). In considering future levels and locations of growth at Rushden, alongside the issues identified in the summary table, and the issue of coalescence, the impact of future growth on the Upper Nene Valley Gravel Pits Special Protection Area (SPA) will also be a key consideration in developing the respective plans. In North Northamptonshire, the current SPA mitigation strategy focuses on the impact of recreational disturbance to the wintering waterbirds. Natural England (NE) are becoming increasingly concerned regarding functionally linked land to the SPA. There is a need to understand the interaction with the SPA and surrounding land as well as the impact from visitors. The JPDU have initiated discussions with NE regarding the scope of this work and it is noted that officers from BBC have stated they would wish to be involved in discussions. BBC has undertaken preliminary investigations into the potential for a new station on the Wymington Loop. This work is still in the exploratory stages and they will be keeping neighbouring authorities informed as work progresses. This is not identified in the consultation document so at this stage there is no detail on specific location and whether this may be deliverable. Provision of a deliverable station in this locality could provide future opportunities that may benefit North Northamptonshire. Opportunities provided by a deliverable railway station could provide significant benefits for North Northamptonshire and would be a key consideration in assessing the sustainability of potential growth options to the south/south west of Rushden. Policy 17 of the JCS North Northamptonshire’s Strategic Connections identifies investigating the longer-term potential for a railway station at Irchester (to serve Irchester, Higham Ferrers and Rushden) as a priority for further work and investment at criterion a) iv. Substantive progress has not been made on investigating this potential. Should a railway station at Wymington be proven to be deliverable, the impact on service provision from Wellingborough station, and the relationship with potential for a station at Irchester will be important considerations. It may be the case, that such a station could provide the same benefits sought by the JCS. Red- New settlement based growth The North Northamptonshire JPC previously made representations objecting to the Bedford Borough Local Plan 2035: Plan for Submission. These representations related to the proposed Colworth Garden Village (Policy 27 of the Local Plan 2035) and raised concerns as to whether the necessary supporting evidence base (specifically transport modelling) had been undertaken to justify the Garden Village proposal; such that the scheme as envisaged by policies 26 and 27 was not (considered to be) justified. They also set out that given the scale of Colworth Garden Village, that to be effective Policy 27 should give further consideration to the wider spatial implications of CGV beyond its immediate locality (Sharnbrook/Santa Pod). To be justified (in accordance with the soundness test) policy criteria should give consideration to broader connectivity; with particular reference to green infrastructure, walking, cycling and public transport. Following substantive changes to the Local Plan, including the removal of the Colworth Garden Village from the Plan, the JPC’s substantive objections were withdrawn. It is considered that the issues raised in the representation remain relevant to any consideration of the Colworth Garden Village site through the Local Plan Review. The recognition in the disadvantages section of the summary table that “Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated” is welcomed. It is noted that the Issues Paper states that: “New settlements remain an option for this plan but only where there is a clear case that they would be developable in the plan period”.
2.10 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. 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.
6.1 The context for the Council’s Review of the Local Plan 2030 is substantially broader than the relatively narrow scope of objectives and options for distribution that the Inspectors accepted as reasonable for the purposes of the plan period to 2030. 6.2 Paragraph 48 of the Inspectors’ Report confirms that options for spatial distribution to meet requirements beyond 2030 did not require explicit consideration. For the same reason, reasonable alternatives for the scale and distribution of growth were constrained to within +/- 20% of the selected requirement that the Council has provided for as a result of the NPPF 2012’s transitional arrangements for housing need. 6.3 In terms of the options for the Local Plan Review the Council must ensure that this format of constraints to the alternatives being assessed are removed in their entirety. This will provide for substantially more flexibility in terms of meeting a broader range of objectives over the plan period. This broader scope accords with the Council acknowledging that an appropriate spatial strategy is likely to combine a number of the options identified. 6.4 The background to preparation of the Local Plan 2030, including adopting a foreshortened plan period, is relevant to the identification of options for the Review. This reflects constraints to strategic growth options comprising New Settlements and large-scale urban extensions. 6.5 The Borough Council has no recent track record of outcomes under the Duty to Cooperate for exploring meeting needs elsewhere or at the administrative boundary with other neighbouring authorities (save for the Wixams). This should frame the Borough Council’s understanding of whether large-scale strategic options are justified or would make an effective or positively prepared contribution towards meeting needs in the early part of the plan period. 6.6 During the Examination of the Local Plan 2030 DLP argued on behalf of numerous clients that the submission version of that Plan was a substantial departure from previous iterations. This was reflected in its increased proportion of growth in the rural areas, whilst removing altogether the strategic priority of providing for a New Settlement as well as acknowledging constraints to the rate of development in the urban area. 6.7 These arguments were in effect accepted due to the requirement for an immediate review under Policy 1. Furthermore, the Review of the Local Plan 2030 must ensure that the priorities of the current plan remain a key part of the objectives. This includes addressing delays to bringing forward allocations in the rural area and rates of development in the Town Centre as well as meeting an increase in current and future needs from 2020. It is therefore not a logical conclusion that certain options identified by the Council represent reasonable alternatives to meeting the Plan’s overall objectives and requirements in the early part of the plan period, albeit they may make a greater contribution in later years. 6.8 For this reason, we recommend that the Review of the Local Plan 2030 is based around a composite strategy based on the three main elements: • Grey– Dispersed growth • Brown (Urban-based) • Yellow – A421 based growth 6.9 Further initial observations on these components of an appropriate spatial strategy as well as observations on the potential for other options to make a longer-term contribution towards development needs are set out below and should be read alongside our representations as 21 a whole. Summary of Conclusions on Preferred Spatial Distribution Options 6.10 Grey– Dispersed growth – Further substantial testing of this spatial option is self-evidently critical to the soundness of the Review given its importance to delivery of the strategic priorities of the current Plan. The Council recognises the benefits of early delivery, which is essential to meet the increased annual requirement for development in the period 2020- 2040, associated with this option. This means that meeting additional requirements for development through the Local Plan Review cannot rely on options where delivery is deferred to 2030 or beyond. 6.11 This option is consistent with a number of key elements of national policy that should be considered when reviewing existing policies (including flexibility and maintaining housing land supply). This option would have to fulfil and maximise the overall potential for sustainable development in the rural area that was curtailed by the timeframe and underprovision against full housing needs in the adopted Local Plan 2030. This can be achieved through a review of the classification of the settlement hierarchy and the distribution of requirements based on updates to Policies 3S and 4S in the Local Plan 2030. 6.12 Brown (Urban-based) – We support that the testing of options needs to differentiate Town Centre locations with sites across the borough and at the urban edge. Noting constraints to the existing strategy, increased reliance on the Town Centre would lead to potentially exacerbating existing constraints to timeframes and rates of development in this location. The Local Plan 2030 does not maximise opportunities for small-scale extensions to the urban area, which can be sustainably incorporated into the spatial strategy while the Council assesses other longer-term strategic options 6.13 Yellow – A421 based growth – It is recognised that the list of advantages associated with this option seek to and capitalise on committed and planned infrastructure improvements including works to the A421, Black Cat and Caxton Gibbett roundabout. 6.14 The improvements complement longer-term strategic objectives for planning across the subregion so that this option is capable of supporting further large-scale growth in the future. Critically, options to increase levels of sustainable development exist based on the characteristics of existing settlement and land use patterns across the A421 corridor. This avoids some of the constraints to other strategic options, in terms of scope to deliver needs throughout the extended plan period. This option could not, however, deliver the Plan’s increased requirement for development in its entirety. 6.15 It is noted, however, that these more immediate opportunities are focused upon the capacity for growth within the existing settlement hierarchy, including the Key Rural Service Centre of Great Barford and the Rural Service Centre at Roxton. Opportunities to maximise the benefits of sustainable development are thus focused upon a review of the distribution of growth provided for by Policy 4S of the current Local Plan. To this extent we would identify that this spatial option is not viewed in isolation but is considered alongside a review of the capacity for growth in other larger villages based on their alignment with the Plan’s wider priorities. Summary of Conclusions for Alternative Spatial Distribution Options 6.16 For the avoidance of doubt, it is not the purpose of these representations to state that reasonable alternatives for further testing do not exist within the other spatial distribution 22 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 NPPF 2019 and in-particular part (d) requiring consideration of likely delivery in the plan period. 6.17 Amongst the disadvantages associated with the remaining spatial options, the Council lists the following: • Other locations would miss the benefits associated with growth (Pink, Orange and Red) • New settlements take a long time to plan and build, generating short to medium-term housing supply shortages (Red, but also potentially applicable to other options) • Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated (Red) • Exact route of the railway not yet known (Pink and Orange). 6.18 The Council therefore acknowledges that a similar pattern of constraints exists in relation to all three remaining options. The scope for the Review of the Local Plan 2030 should explicitly recognise this amongst reasons to select an appropriate strategy. 6.19 The Council also acknowledges that other locations would miss the benefits of growth if these strategic options were selected. However, in our view this is already an outcome of the existing Local Plan 2030 in terms of its reduced housing requirement and deferral of allocations to Neighbourhood Plans (as well as the current distribution of growth set out in Policy 4S). The Review of the Local Plan 2030 is also necessary to secure delivery of the Plan’s objectives in these other locations, including at Key Service Centres and Rural Service Centres. 6.20 Due to the combination of potential disadvantages it also follows that future solutions in terms of larger-scale development might look to resolve these in a manner that ensures these are overcome as part of options that maximise the benefits of these strategic options – for example New Settlement options that align with the delivery of East-West Rail. The Council’s Orange – ‘East-West rail northern station growth option’ would most closely reflect these principles, albeit there remain extreme uncertainties regarding timing and the approach to delivery of East-West Rail. 6.21 It is important to stress that given the potential timescales for East-West Rail any further assessment of such options is not incompatible with delivery of a range of other spatial options and achieving a sustainable distribution of growth in the rural area earlier in the plan period. Spatial Option and Site Assessment Considerations for the Local Plan Review: Turvey/Turvey Station 6.22 Our client’s interest comprises land adjacent to the former grain store at Station Road, Turvey. Planning permission has been granted under reference 19/01018/M73 for 128 Class C2 units (Phase 1) and 19/01956/MAF for 62 Class C2 units (Phase 2) on land adjoining this site to the east for a Class C2 Care Village on behalf of Inspired Villages. Development on this additional parcel of land would be a modest addition as a phase 3 for approximately 20 23 Class C2 units and would form part of the previously approved care village to provide additional accommodation, parking, and landscaping etc. The proposal would provide much needed suitable accommodation for older people as well as enhanced landscaping to the boundaries and also within the site. The proposed development would also create jobs and improve the existing connectivity with existing public footpaths. 6.23 Our client’s site would contribute towards meeting the rising need for elderly accommodation and furthermore, the Council acknowledge that this is a suitable location to provide this type of accommodation. 6.24 The site itself is located adjacent to the built form of Turvey Station and is well related to it. Turvey Station has a concentrated and recognisable built form and comprises a distinct group of buildings and built development. Development on this site would be well related to structure, character and form of the settlement and is distinct from the countryside beyond. 6.25 Turvey Station lies a short distance to the east of Turvey, a large village with a number of local facilities and services. Turvey Station serves as a village end for Turvey and is well located to the village which provides for a variety of local needs including a post office and village store, Public Houses, places of worship, employment, a primary school, and a village hall. In functional terms Turvey Station is viewed as part of Turvey from which it draws its services and is a suitable and sustainable location for new development. 6.26 A site location plan is included at Appendix 1 of these representations. 6.27 Notwithstanding the outcomes of this process it is essential that Bedford Borough Council objectively assesses all site options to achieve the longer-term requirements for development in Turvey/Turvey Station, as well as informing conclusions on the most appropriate strategy to meet needs identified in the current development plan, should a Neighbourhood Plan not proceed.
The most crucial elements of growth to include as part of a spatial strategy going forward would be for increased levels of rural growth. To date, and as is proposed under some potentials options for growth, the Bedford and Kempston rural area has always been subject to significantly higher levels of housing growth with many settlements, including the sustainable Key Service Centres, receiving a very small proportion of planned growth under the previous plan (now superseded) and currently adopted plan. The implications for sustainability in this context are very clear, and indeed are listed within the pros and cons for the potential growth options. Urban based growth presents increasingly limited opportunities for developers to assist in meeting the objectives of sustainable development. Beyond high density schemes, very little alternatives exist to realise the level of growth that would be required as part of this Local Plan Review within the Bedford & Kempston rural area. This includes development on the urban fringe which in turn would encourage less sustainable transport methods as these would require significant further investment to facilitate a continued outward expand of the urban area. Urban based growth would equally starve more rural locations of much needed growth -housing or employment – while in turn risking the buildup of urban sprawl. Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Bromham which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future. In incorporating dispersed growth as part of a strategy, many rural communities such as Bromham 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.). Some draft and adopted Neighbourhood Plans envisage that the (potential) sites for allocation will assist significantly in providing for a news school and / or expanded school capacity at existing institutes, for instance. This is one such approach that can help maintain and upgrade the existing levels of facilities and services, and subsequently the sustainability, of villages such as Bromham without giving rise to undue burden on local communities or the Council. 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.
1.11. Whilst it is helpful to seek views on the specific, broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one option. 1.12. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the call for sites information will therefore clearly be relevant to the strategy adopted. 1.13. The NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which, if it does not perform as expected, then results in the plan failing to deliver sufficient housing. 4 PHILLIPS PLANNING SERVICES LTD 1.14. Paragraph 72 states that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. 1.15. More generally the NPPF includes a focus for using brownfield land where this is well located and can deliver growth in appropriate locations. 1.16. Having regard to the above Cloud Wing UK Limited consider that there is significant merit in pursuing the ‘Yellow’ A421 based growth option in combination with other strategies such as the ‘Pink’ rail route related growth option to the southwest of Bedford. This is particularly the case given the recommendations of the National Infrastructure Committee in respect of the Oxford to Cambridge Arc which is a key reason for the local plan review taking place. 1.17. The chosen strategy must be capable of delivering the step change in housing and economic growth required with future site selection based upon the potential for future catalytic growth beyond site boundaries.
The most crucial elements of growth to include as part of a spatial strategy going forward would be for increased levels of rural growth. To date, and as is proposed under some potentials options for growth, the Bedford and Kempston rural area has always been subject to significantly higher levels of housing growth with many settlements, including the sustainable Key Service Centres, receiving a very small proportion of planned growth under the previous plan (now superseded) and currently adopted plan. The implications for sustainability in this context are very clear, and indeed are listed within the pros and cons for the potential growth options. Urban based growth presents increasingly limited opportunities for developers to assist in meeting the objectives of sustainable development. Beyond high density schemes, very little alternatives exist to realise the level of growth that would be required as part of this Local Plan Review within the Bedford & Kempston rural area. This includes development on the urban fringe which in turn would encourage less sustainable transport methods as these would require significant further investment to facilitate a continued outward expand of the urban area. Urban based growth would equally starve more rural locations of much needed growth -housing or employment – while in turn risking the buildup of urban sprawl. Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Wootton which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future. In incorporating dispersed growth as part of a strategy, many rural communities such as Wootton 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.). Some draft and adopted Neighbourhood Plans envisage that the (potential) sites for allocation will assist significantly in providing for a news school and / or expanded school capacity at existing institutes, for instance. This is one such approach that can help maintain and upgrade the existing levels of facilities and services, and subsequently the sustainability, of villages such as Wootton without giving rise to undue burden on local communities or the Council. 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.
1.10. Whilst it is helpful to seek views on the broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one single option. 1.11. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. The NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which if it does not perform as expected results in the plan failing to deliver sufficient housing. 1.13. Paragraph 68 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. 4 PHILLIPS PLANNING SERVICES LTD 1.14. Alongside this, Paragraph 72 states that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. 1.15. The NPPF promotes development in rural locations. Paragraph 78 states that in rural areas housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify how new development will enable villages to grow and thrive 1.16. Having regard to the above the Howbury Hall Estate considers that there is significant merit in pursuing a mix of the ‘Yellow’ A421 corridor growth and ‘Brown’ expansion of the Bedford urban area options. This is particularly the case given the recommendations of the National Infrastructure Committee in respect of the Oxford to Cambridge Arc which is a key reason for the local plan review taking place. 1.17. Development along and close to the A421, in locations which good, close access to junctions onto the expressway, particularly if well related to Bedford and existing housing should clearly be favoured.
1.10. Whilst it is helpful to seek views on the broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one option to the exclusion of all else. 1.11. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. The NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which if it does not perform as expected results in the plan failing to deliver sufficient housing. 1.13. Paragraph 68 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. 4 PHILLIPS PLANNING SERVICES LTD 1.14. The NPPF also promotes development in rural locations. Paragraph 78 states that in rural areas housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify how new development will enable villages to grow and thrive 1.15. Having regard to the above Peter David Homes considers that there is significant merit in pursuing a mix of the ‘Yellow’ A421 corridor growth, ‘Brown’ expansion of the Bedford urban area, and ‘Grey’ dispersed growth model allowing some expansion of villages. This would ensure that appropriate regard is had to the Oxford to Cambridge growth arc recommendations, the sustainability of growth adjoining or close to Bedford and also the need for some growth in more rural areas to maintain the vitality and viability of those settlements.
1.10. Whilst it is helpful to seek views on the broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one option to the exclusion of others. 1.11. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the recent call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. In addition, the NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which if it does not perform as expected results in the plan failing to deliver sufficient housing. 4 PHILLIPS PLANNING SERVICES LTD 1.13. Paragraph 68 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. 1.14. The NPPF also promotes some development in more rural locations. Paragraph 78 states that in rural areas housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify how new development will enable villages to grow and thrive. In the context of changing attitudes to and patterns of working from home new development in villages should incorporate appropriate working spaces within new homes to facilitate this and so provide flexibility and contribute towards overall sustainable objectives. 1.15. Having regard to the above the Laing Family considers that there is merit in pursuing a mix of the ‘Yellow’ A421 corridor growth, ‘Brown’ expansion of the Bedford urban area, and ‘Grey’ dispersed growth model allowing some expansion of villages. 1.16. This allows the Council to respond to the recommendations of the National Infrastructure Commission (NIC) in terms of focusing major growth along the A421 corridor but also recognises the sustainability of new development close to or adjoining the Bedford Urban Area and ensuring that there is some growth around villages to ensure the ongoing vitality and viability of such settlements.
The Consultation Document sets out six 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. It is considered that there should not be any significant reliance on strategic sites, particularly in the form of new villages/settlements. 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 unlikely to deliver. New settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. Richborough Estates have previously made reference to the NLP ‘Start to Finish’ report which confirms the above and advises that the determination period of a planning application over 500 dwellings is in the order of 5.3. to 6.9 years. The report advises that “Planned housing trajectories should be realistic, accounting and responding to lapse rates, lead-in times and sensible build rates. This is likely to mean allocating more sites rather than less, with a good mix of types and sizes, and then being realistic about how fast they will deliver so that supply is maintained throughout the plan period. Because no one site is the same – and with significant variations from the average in terms of lead-in time and build rates – a sensible approach to evidence and justification is required.” 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, for example smaller sites which can deliver quickly. 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 this ultimately failed and the site deleted from the Plan late in the day, as the viability and deliverability had not been fully considered. As a consequence the Plan period was reduced to address the shortfall created. With regards to placing greater focus on delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building concurrently in one 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. 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, the need to deliver family homes and housing quality. This a point made in the final report of the Building Better, Building Beautiful Commission which states a need to promote a ‘gentle density’ in the urban area. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. Whilst there is no 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. We consider 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. 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 Rural Service Centres. We consider the Council should revisit such proposals, particularly in light of the increased housing requirement and the need to have regard to its position within 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, such as Turvey, will deliver quickly, which will enable the Borough 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 additional sites being allocated for less than 100 units in the emerging Plan which can come forward quickly and assist the Borough in housing delivery, affordable housing delivery and maintaining their housing land supply. By allocating sites in the Rural Service Centres the Borough would secure a mixture of sizes to ensure development can be brought forward to meet local and Borough wide needs. In addition, delivery of housing in the Rural Centres will seek to ensure the vitality and viability of existing services and facilities in the villages. In settlements such as Turvey which currently has a falling school role, due to an aging population, this is particularly important. As set out previously the Council has previously recognised the benefits that development in these settlements can deliver to existing services and facilities.
2.8 MGH does not have a specific view on how the future growth of the Borough is planned. Notwithstanding this, they have worked closely with the Bromham Neighbourhood Plan Group (NPG) for a number of years and believe that the allocations in the submission Neighbourhood Plan are based on a sound understanding of the needs of Bromham and residents’ views on the scale of development the village should accommodate. It would therefore be unfortunate if the Council were to undo all the hard work of the NPG by allocating further growth to Bromham over and above that already identified in the Neighbourhood Plan. 2.9 Whilst Bromham is a sustainable rural location the Council should look to identify sites that will ensure consistent delivery across the plan period, such as land on the fringes of Bedford. The delivery of greater densities in more urban locations will allow for the most efficient use of land and has the potential to boost the September 2020 | CAM.0109 September 2020 | CAM.0109 Page | 5 supply of new homes in accordance with paragraphs 59 and 122 of the National Planning Policy Framework 2019. There is still an acute need for new homes in the town and focusing future growth on Bedford will relieve some of the pressure on the larger villages that have already taken a proactive approach to accommodating their future growth needs through developing Neighbourhood Plans. 2.10 Whilst the previously proposed policy for self-build housing was not included in the adopted Local Plan the Council has a statutory duty to facilitate the delivery of plots for self and custom build housing. MGH believes that these should come forward as small sites on or near to the edges of settlements rather than as part of major developments. By making self-build plots acceptable outside defined Settlement Policy Area, Small Settlements or the built form of other settlements it is likely to yield more plots than by requiring them on major developments. These plots are also more likely to be in locations where self-builders want to build their homes.
3.1 O&H consider the Authority should be more ambitious and seek to draft a plan with a plan period from 2020 – 2050. 3.2 The Authority should consider more than the quantum of housing that would be required when determining the length of the Plan period. Rather, the Authority should be ambitious and seek to a be leader for long-term strategy within the O2C Arc. 3.3 The Government’s ambitions for the O2C Arc along with the Government’s commitment to achieving "net zero" greenhouse gases run until 2050. There would be merit in aligning the Authority’s strategy for the development of the Borough with Government’s ambition for the O2C Arc and commitment to net zero. 3.4 A plan period of 2020 – 2040 would fail to capture the benefits of aligning the plan period with the ambition for the wider O2C Arc and the Government’s environment commitments. 3.5 This Local Plan review present an opportunity for the Authority to offer a greater degree of certainty to developers and local communities than any other Authority within the O2C Arc. It also offers the opportunity to secure the infrastructure necessary for future needs long before it may be required.
o Urban based Growth General expansion of urban Bedford into surrounding rural areas should be resisted with preference given to sites within the urban area forming imaginative and environmentally acceptable developments. Conversion of office space or empty retail property to housing should continue in the post-Covid economy. Other measures in line with evolving Government initiatives should be investigated including use of formal brownfield sites. Plans should be mindful of the need to travel and the potential to reduce pollution and to assist a low carbon society. Existing natural barriers between urban areas and rural communities, green spaces, recreation areas etc. should be maintained. In respect of urban extension of North Bedford and taking into account the Graze Hill commitment there are no suitable sites for significant housing development anywhere in the Ravensden parish, without seriously compromising landscape character, existing or proposed open space, or the characteristics and role of existing settlements. Any such development allowed would add unacceptably to the already high volume of traffic which crosses the parish which creates noise, pollution and significant safety risk. o A421 based Growth This option is wholeheartedly supported as it would integrate new housing with the strategic road network and with major existing and potential new employment sites. It would also be in harmony with the likely wider developments in the Oxford-Cambridge Arc. o Rail Growth This option is supported for reasons similar to support to the A421 growth south-west of Bedford The plans would need to be carefully tailored into currently planned development at Wixams and would require a reassessment of the station proposals at Wixams (for Thameslink) and Bedford South/Parkway (for EWR). o East West Rail Northern Station This option is strongly resisted since there is no “significant potential for growth north of Bedford.” This option would be strongly opposed by residents across all parishes in North Bedford and is unrealistic for the following reasons: a. The precise routing of the EWR remains the subject of detailed review and analysis. Current proposals are contentious and cannot be sensibly included within the immediate Review. b. Any settlement north of Bedford would depend on access to the EWR and Midland Mainline routes. Past evidence is that there is little possibility an additional stop on the Midland Mainline and an extra station on EWR would likely be unacceptable owing to the priority to maintain short journey times. It is also noted that proposing a rail stop in addition to that already provided in Bedford appears to recognise that access to Bedford Midland Station is currently over-congested and any further housing development in North Bedford and greater use of a town centre station, would be totally impractical. This urban congestion logically argues strongly against the use of Bedford Mainline Station for the EWR and therefore supports the option to develop Bedford South Parkway and accept a southern route close to existing and planned developments. c. There is no potential site identified within the published EWR route corridor that would allow building of a station and development in North Bedfordshire. Suggesting site options outside the corridor identified by EWR Ltd would require wholesale reconsideration of EWR plans on which there has been public consultation. d. Road infrastructure to serve any new development north of Bedford is wholly inadequate and other essential services would require significant reinforcement Failure to address this issue would result in dangerous and unacceptable traffic levels on existing rural roads. o Dispersed growth The current local plan 2030 defines a settlement hierarchy and a policy approach to development at settlements which has recently been confirmed to continue. In line with the 2030 Local Plan, any dispersed development proposed for lower order settlements such as Ravensden Church End and Ravensden Crossroads should, if it is needed, be appropriate in scale and well related to the built form of the settlements. Development adjacent to the settlements would also need to be supported by local communities through Neighbourhood Plans or meet a particular local need. Similar constraints would continue on development in the open countryside. o New settlement-based growth New settlement(s) along the A6 corridor as proposed by landowners in the call for sites for the 2030 Local Plan may provide opportunities to make significant use of large brownfield sites, (which the Review intends to prioritise) and all of them would meet a large proportion of the projected housing need requirement, thereby relieving pressure for large scale development on the fringe of Bedford or on an unacceptable scale elsewhere. However, there could be significant traffic impact in the surrounding countryside which would need to be planned for; infrastructure should be provided before development takes place and the environment of existing communities protected. These may need to include traffic management or restrictions, and the effective enforcement of speed.
It is acknowledged that there are an infinite number of growth locations/options which the Council could have considered. We believe a broad range of locations have been considered to enable the key issues of delivering growth across the Borough to be tested. We support the urban based option which would allow growth in locations which already have existing infrastructure and good connections to Bedford town centre. Urban locations have the greatest potential for sustainable travel choices and the urban based growth option would therefore target growth within the most sustainable locations. The A421 based growth option is also supported as it would allow growth to take advantage of existing and proposed infrastructure improvements. Both of the above growth options would allow a phased approach to growth which could be linked to upgraded infrastructure. They would also reduce the need for growth within rural areas which would have the potential to detrimentally impact on the character of these areas. We note the disadvantages set out by the Council of both growth options which include that rural locations would miss the benefits associated with growth, however, as set out within the disadvantages of the dispersed growth option, the majority of rural areas would not have the existing infrastructure in place to accommodate growth if it was evenly dispersed throughout the borough. An even spread of growth across the borough and a lack of focused critical mass would make providing strategic infrastructure more difficult, as the locations would not benefit from economies of scale. As such, the growth options which target growth within areas of the borough with existing infrastructure or the ability to provide enhanced infrastructure should be supported. The East-West rail northern station growth option is not supported, this focuses growth solely within one area of the borough and other sustainable locations would miss out on the benefits associated with growth. The development north of Bedford would require a new northern station which is not currently proposed, the development of this would therefore have significant time implications for achieving growth within this area. The rail growth option would combine some of the benefits of the urban and A421 growth location options. It would provide opportunities for high-tech employment development in association with East-West rail. When considering growth options, it is essential that the Council allow for a consistent rate of growth throughout the plan period. FCC’s site at Elstow South, as shown on Figure 1 will be available for employment development in 2029 which would allow for continued growth in the second half of the plan period within sustainable locations adjacent to the urban area as proposed by the urban growth option. As set out within the urban growth, A421 growth and rail growth options, growth should be focused along intersections with existing major infrastructure which will create new opportunities for logistics and distribution industries, and are also most likely to support new settlements. The final option should ensure sufficient flexibility to meet the changing economic needs over the plan period.
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.
After reviewing the location options in Table 1, Urban Based Growth and Dispersed Growth are considered to be the most appropriate strategies. However, it is also considered that the full housing and employment needs for the Borough will need to be met by using a range of the different growth scenario options. In this regard, consideration should be given to a strategy that seeks to accommodate both urban and dispersed growth. Urban Based Growth is supported in that it will encourage additional development and inward investment in close proximity to the key service centres of Bedford and Kempston. As identified within the consultation document, it is very unlikely that urban growth can be met by redevelopment of brownfield land within Bedford and Kempston. Therefore, it is important that consideration is given to releasing appropriately located greenfield land within the countryside around Bedford and Kempston for allocation. As set out within the attached Vision Document, land at Gibraltar Corner, is located within the ideal location to assist with meeting an Urban Based Growth Approach, being within short walking and cycling distance to Kempston. The approach to dispersed growth, is also supported, however, it is considered that this dispersed growth should be situated in more sustainable locations in close proximity to key service areas, such as Bedford and Kempston. It is considered that large scale growth within the less sustainable and more remote northern areas of the Borough is not appropriate in that it would result in over- reliance on use of the motor car and new housing being situated a long distance from the principal settlements of Bedford and Kempston. However, provision for dispersed growth on urban edge settlements such as Gibraltar Corner is strongly supported, in that it will provide a good quality of life for new residents at an appropriate density for rural/urban edge locations. It will also ensure that development is located within village settlements that have very good accessibility to Kempston and Bedford. The approach to meeting the majority of growth by provision of new settlements is not supported. New settlements generally require substantial infrastructure in order to be deliverable and any new settlement is not likely to be deliverable within the short to medium term. It is very important that a number of medium and smaller sized sites (circa 500 dwellings or less) are allocated in order to meet the identified housing needs within the short to medium term. In particular, we consider that this approach will ensure consistent delivery across the plan period by avoiding an over concentration of development in a specific area or an over reliance on large strategic sites. This is particularly important for areas such as Bedford Borough, given the significant number of strategic sites that are being delivered through the current Local Plan 2030. In addition, growth in and around urban areas are more likely to support the key vision of the Local Plan, which is to create vibrant town centres in Bedford and Kempston. No objection is raised to provision for some growth along the new railway and A421 Corridor to the west of Bedford. However, this growth will only be appropriate to meet a proportion of any new growth allocated as part of the new Local Plan. It is considered to be a less sustainable approach than providing growth around the principle settlements of Kempston and Bedford. In particular growth along the A421 Corridor is likely to result in additional use of the motor car.
3.11 The Consultation Paper provides 6 individual options for growth. De Merke consider that this is a silo approach to dealing with growth and instead a hybrid approach of 3 options should be considered. 3.12 A hybrid approach is suggested of a single new settlement, intense urban growth where there is existing infrastructure to cater for increased densities combined with a reduced need for dispersed growth across the borough. 3.13 A singular new settlement should be considered. As written within the disadvantages of this option, new settlement requires significant master-planning and supporting planning policy to enable growth of this scale. Proposing 4 new settlements is considered ambitious and therefore for a singular settlement is suggested to take a significant amount of planned housing and economic growth. 3.14 With a single centre for new growth, this will leave a remaining economic and housing need to be met by urban growth and dispersed growth. 3.15 It is logical that the strong and well used existing infrastructure links within the City should support new homes and industry. It is therefore suggested that in urban areas where a higher density of housing would be consistent with the existing character of the area, that the urban fringe is extended to accommodate high density housing. The remaining housing numbers should then be met by settlement growth through a dispersed model throughout the borough, according to the settlements available and planned services, such as schools, medical services and transport links to accommodate new development, as set out in a settlement hierarchy. 3.16 It is suggested that a hybrid approach to the options for local growth which focuses on one new settlement, high density growth around Bedford city and high order settlements in the borough such as Clapham (which relates closely to Bedford) and dispersed growth of the remaining housing requirement based on a settlement hierarchy focused on available and planned services. 3.17 Clapham in particular presents an opportunity for an expanded settlement taking advantage of a good level of local services, facilities, employment and public transport opportunities. The Council has previously assessed the settlement as having a sustainable capacity for at least 750 no. dwellings, yet only 500 no. dwellings were allocated to the settlement in the current adopted Local Plan 2030. The settlement therefore has further capacity, based on the Council’s own assessment, for at least a further 250 no. dwellings and considerably more. 3.18 Alongside a new settlement proposal the expansion of Clapham would offer the opportunity to further reinforce the sustainability of the settlement along with the provision of housing during the early/middle part of the Plan period. This would allow the Council to balance housing supply across the Plan period and whilst any new settlement proposal is gearing up for delivery. 3.19 This option should be explored as part of any sustainable development strategy taken forward through the Local Plan Review. 3.20 Within this context, Land East of Clapham Road, Clapham (see Appendix 1) offers an ideal opportunity for early delivery of sustainable residential development as part of the Local Plan Review together with the potential for high quality employment floorspace in the form of storage and distribution uses to service the growing need for ‘last mile’ distribution that has been fuelled by increased demand for home shopping particularly in relation groceries.
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.
We support: Brown, Urban-based growth. We believe that the housing requirement is so high that further significant growth to Bedford and Kempston is unavoidable. Environmentally it is a priority as it maximises potential for public transport, walking and cycling. The urban extension to Rushden is also supported but the urban extension to St Neots is not supported as the roads from that area to Bedford are all unclassified and unsuitable for large volumes of traffic. Yellow, A421-based growth. This also is a priority as it has significant transport benefits given capacity within road infrastructure, it ties in very well with existing strategic employment sites, minimizing commuting, and has significant housing capacity including unused brownfield land at Stewartby. The A421 would certainly be part of the Oxford- Cambridge Expressway. Pink, rail growth. This makes sense making use of anticipated rail growth locations. We do not support: Orange, EastWest Rail northern station. We believe this is totally unrealistic, EWR stated they have no budget for this and it would extend journey times. Moreover, the amount of E-W commuting is very low compared to N-S commuting to London which this station would not serve, most new residents would drive to work or Midland station. Grey, Dispersed growth. This is the antithesis of planning, totally unresponsive to resources, opportunities or challenges. It represents development without regard to local needs, infrastructure or policy. An element of dispersed growth will be delivered by the Call-for-sites exercise, but for the most part growth should be planned. Red, new settlement-based growth. All the proposed new settlements are based in the open countryside where infrastructure, facilities and services are limited and unable to properly support such large growth to local areas. None of the proposals include sufficient facilities and services to be considered stand-alone communities, all will lean heavily on rural neighbouring communities and overload rural road infrastructure. The weakest of the proposals is the Wyboston site which has no brownfield contribution and would impact severely on local unclassified roads that are incapable of upgrade. NPPF Para 77 states “In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.”
Wixams is designated as a ‘Key Service Centre’ within the existing Local Plan, which highlights its sustainable credentials. Beyond Bedford itself, such settlements are considered the most appropriate for growth. The current Plan did not allocate further growth at Wixams given the current development being undertaken. However, future development of the town centre and its proximity to Bedford ensure it is an appropriate place for further expansion. Table 1 provides options as to where new development could be located. In reality, the spatial strategy will provide a balance between these. The table highlights pros and cons to be considered, which must all be considered in the balance. In line with Government advice and sustainability principles, development in urban areas would be the starting point. However, urban based growth within Bedford is very limited. The current Local Plan focusses growth in this location and there are limited further sites available, particularly to meet the likely housing need requirements of the Plan Review. As such, there will be reliance upon the other locations proposed. Land East of Wixams would represent development in the proximity of the A421 corridor. The table highlights some of the key advantages that development within this area would bring. It also directly references the ability to further extend Wixams. The settlement is expanding, with development and occupations continuing at villages 2 and 4 following the completion of village 1. The location of land East of Wixams and the sustainable benefits it will provide ensures that its development can be planned for through the Review process rather than further into the future. Table 1 provides four ‘cons’ to development in this area and these are listed below, along with a note as to how they relate to development on land East of Wixams: 1) Could encourage car use and increase pressure on A421 junctions: The A421 is a key driver within the Oxford-Milton Keynes-Cambridge arc, and the site is well connected to the road. However, the connection opportunities to Wixams and the employment land to the north as well as to Bedford will provide future residents with sustainable alternatives to the car. 2) Requires improved connections into urban areas in order to access facilities otherwise residents may travel on to larger towns: The scale of the site will allow adequate capacity for some services and facilities within the development. Future residents would have a choice for additional requirements given the proximity to Wixams and Bedford. Development will allow the opportunity to benefit services and facilities within these areas, to the benefit of a significant number of businesses. 3) Could appear as urban sprawl and join-up nearby villages: In order to meet the likely development requirements, it is inevitable that greenfield development will result. As such, the Local Plan Review must ensure development within appropriate sites. Development on land East of Wixams can ensure appropriate space and buffering is provided to the nearby settlements of Elstow, Shortstown, Cotton End and Wilstead to ensure no visible coalescence would occur. 4) Other location would miss the benefits associated with growth: This would be the case for any promoted sites.
Para 23 of the NPPF requires Local Plans to identify broad locations for growth, with land use and allocations for development being identified on a policies map. These representations support the Yellow Growth option highlighted in the Issues and Options Paper, that being growth along the A421 road corridor where there are already good road links and opportunities to further improve connectivity and growth including at villages such as Great Barford. The current Bedford Local Plan 2030 Policy 3S: Spatial Strategy focuses new development on Bedford Town Centre, Wixams new settlement, a strategic village expansion at Stewartby and also on strategic residential development in key service centres. Policy 4S identifies that Key Service Centres should accommodate 2,000 dwellings over the Plan period, with 500 dwellings to be provided at Great Barford, on land to be identified in Neighbourhood Plans. Great Barford are progressing a neighbourhood Development Plan but at the time of writing this has not been published or submitted to the Council. If this is not achieved by January 2021 then in order to be effective, the LPA must seek to allocate land for that development in this Local Plan Review. Development at Great Barford would sit within the Yellow Growth Option for the Local Plan Review, providing development in a sustainable location along a key transport corridor Bedford Borough Council, Great Barford www.pegasusgroup.co.uk Page | 3 that would provide for the delivery of housing and infrastructure to both support the requirements of the existing Local Plan Neighbourhood plan requirements and also for future growth that will fit within wider ambitions for the Oxford-Cambridge Arc. The Government's White Paper: Planning for the Future (August 2020) places emphasis on the need for new development to be developed in locations that can address the associated demand for public services and infrastructure. Whilst the White paper then goes on to set out the Government's proposals to ensure that new development is serviced by the correct infrastructure it is important for the Bedford Local Plan review to ensure it is developing a spatial strategy which takes advantage of existing and proposed infrastructure in the locality. The Government has further pledged a commitment to the Oxford-Arc as an area of significant strength and opportunity for existing and future communities. This includes the provision of housing and infrastructure such as East West Rail and improvements to the strategically important roads network: "We recognise the need to plan for and deliver substantial additional infrastructure ahead of the arrival of new communities, including necessary transport infrastructure, utilities, digital connectivity, health and education."1 The yellow option for Growth would allow improved road links to be brought forward to serve new development and provide links to other forms of transport (such as at the East-West rail station north of Bedford and west of Great Barford), as well as places of work within the Arc and the wider area. The delivery of housing in this corridor would allow people to access places of employment and meet societal demands for infrastructure near where they live, in a sustainable manner. In order for the Local Plan Review to be found 'sound' it must integrate these wider regional and national objectives and their delivery of infrastructure into the Plan in order to be found consistent with national policy, and also effective, working on cross-boundary strategic matters that will deliver, inter alia, infrastructure to serve the local area, the region and wider. The Yellow Growth Option would achieve this.