Comment

Representation ID: 10067

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

This representation has been prepared on behalf of Richborough Estates in respect of their land interests at Land at to the east of Newton Lane, Turvey as illustrated on Figure 1 below. This site is an omission site in the emerging Bedford Local Plan 2040.
1.2 The site is considered suitable for allocation in the scenario that further housing sites are required to enable the Local Plan to be found sound (as we consider to be the case as set out within these representations).
Figure 1: Opportunities and Constraints Plan: Land at Newton Lane East, Turvey

Turvey is a sustainable settlement designated in the adopted Local Plan as a Rural Service Centre.
Turvey is one of the highest scoring Rural Service centres in the Borough, scoring only a few points
less than settlements designated as Key Service Centres (Settlement Hierarchy 2030 (Addendum April 2022) Figure 3). The adopted Local Plan seeks to deliver 25 - 50 dwellings through the emerging Neighbourhood Plans (this is in contrast to the 500 dwellings in the Key Service Centres, which Turvey falls just outside of). In historic iterations of the Bedford Local Plan (2015 consultation paper) the Council produced evidence which demonstrated that the Rural Service Centres could each accommodate up to 150 dwellings. The Council recognised the benefits of delivering larger developments in the Rural Service Villages advising that:
“Some villages have experienced the loss of vital services such as shops and pubs in recent years. Changing the current strategy of restraint in the rural policy area could increase the population and change the age profile of rural villages. An increase in activity and spending power would support existing vulnerable village services and facilities, and possibly lead to new provision. Furthermore, larger developments would be likely to bring with them a range of types and sizes of housing, which would provide more choice for existing residents wanting to stay within a village but down-size.” (Development Strategy and Site Selection Methodology Background Paper, September 2015)
1.4 The draft policies at that time supported such an allocation. Despite this latent capacity, the Council ultimately sought to reduce the quantum of housing to be delivered within the Rural Service Centres in favour of a new settlement, however, when the viability and deliverability of this was challenged the Plan period was reduced with an early review mechanism. Richborough
Estates and a number of interested parties objected to this approach of the new settlement and the reduced Plan period allowing the Plan to be found sound with the new settlement removed.
1.5 Turvey Neighbourhood Plan has since progressed to referendum on 15th July 2021. The result was marginal with 52% of votes in favour of the Neighbourhood Plan and 48% against. The Neighbourhood Plan was ‘Made’ on 1 September 2021.
1.6 The Neighbourhood Plan identifies land to deliver 50 dwellings across two allocations. Notwithstanding this, as has previously been evidenced by the Council, settlements such as Turvey remain well positioned to provide additional sites to ensure the Council can meet its future housing needs. Sites in the Rural Service Centres can deliver quickly and ensure that the step
change in delivery is met in the initial years of the Plan period whilst maintaining the vitality and viability of the services and facilities these settlements offer.
1.7 The land east of Newton Lane can deliver circa 80 dwellings, as demonstrated in the Vision Statement which is again submitted alongside these representations (having previously been sent to the Council through previous consultations). It is considered this is commensurate with the size and sustainability of the settlement and combined with the 50 dwellings to be delivered through the Neighbourhood Plan would still be below of the 150 dwellings the Council has previously evidenced the settlement could deliver within the Local Plan period to 2030. Indeed having regard to the sustainability of the settlement, and its place within the settlement hierarchy, just below those settlements which are expected to deliver 500 dwellings in the adopted Plan, it is considered that the capacity of Turvey to accommodate new homes could be far greater than
150 dwellings.
1.8 Richborough Estates are a respected land promotor who contribute high quality new residential development land and who have a strong track record of delivery in the local region.
1.9 This representation follows policies in the order that they appear in the consultation document.

It is our view, for the reasons set out below, that the Local Plan is not sufficiently justified, is not effective and is not consistent with National Policy. It therefore fails to meet the legal tests of soundness.

The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives. Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement:
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need. Option 2D was identified as a reasonable alternative.
2.7 As detailed in response to Policy DS3 and DS5, there seems an absolute reluctance by Bedford Borough to allocate any further additional growth at the Rural Services Centres despite the acknowledged available capacity and the benefit being that some proportionate growth would be delivered earlier in the Plan period rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and with the current cost of living crisis, failure to deliver housing (both market and affordable) in settlements such as Turvey will result in more and more young people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. Your attention is brought to the LPDF publication ‘The Housing Emergency’ (appended for information), which sets out key impacts of the housing crisis and demonstrates the need for increased housebuilding nationally. Key metrics demonstrating the scale and impact of the crisis include the increase of age of first time buyers from 27 in 2007 (in 26 it was 1997) to 34 in 2020. In addition, over the last 11 years the number of households renting has gone up 24%; during this time average rents have increased by 46%, far in excess of wage growth. Nationally there are 3.66 million concealed or overcrowded houses. 17.5 million people are impacted by the housing emergency, living in overcrowded, dangerous, unstable or unaffordable housing. 1 in 5 adults regard housing issues as having a negative impact on their mental health.
2.8 All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth to ensure they do not age and stagnate.
2.9 Land east of Newton Lane, Turvey has shown that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars, public transport and cycling. Moreover, due to an increased prevalence in home working and online deliveries, people are able to live more sustainably in what was traditionally considered to be a less sustainable location. The evidence which supports the Neighbourhood Plan confirms that the land East of Newton Lane is the best remaining available site within the village (Turvey Site Assessments and Allocations Report (April 2020).
2.10 The Plan and Strategy has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.