Object

Representation ID: 10208

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
2.26 Through application of the Standard Method for calculating housing need, a total of 27,100 new homes are required in the borough over the plan period 2020-2040. The Local Plan Review, therefore, needs to facilitate the provision of a further 12,275 residential units through allocations beyond those previously allocated in the Local Plan 2030, adopted in July 2021, and Neighbourhood Plans. This comprises a total increase of 40% in comparison to the housing growth outlined in the Local Plan 2030.
2.27 Draft Policy DS5(S) of the emerging Local Plan 2040 sets out proposals for a total of 13,550 residential units through proposed allocations in line with the Spatial Strategy, resulting in an over delivery of 1,274 units throughout the plan period. The over provision outlined implies shortfalls in delivery with the identified approach are already anticipated and this does add some flexibility, but it is unclear what this is based on. Nonetheless, 1,274 units will not be sufficient in overcoming the potentially significant delays in the delivery of new settlement because of identified risks pertaining to infrastructure delivery and delays in the planning process.
2.28 The draft Policy also refers to the remaining rural areas and villages, however, identifies no additional residential land in these locations. As such, it is not considered relevant to note this within the policy as it does not relate to the distribution of growth as set out in the emerging Local Plan.
[see attachment for Wixams a pertinent case study – Figure 2]
3.0 A Flawed Approach to the Rural Area
3.1 Although reference is made to the role of the rural area in the Spatial Strategy, no formal allocations are made for further development in these locations, other than by reference to new settlements and the two strategic sites at Gibraltar Corner and Willington/Cople. Draft Policy DS2(S) states that development in rural areas will comprise the completion of allocations outlined in the Local Plan 2030 and Neighbourhood Plans. No further development is proposed in these areas as part of the emerging plan. Not only is this a missed opportunity it fails to recognise that the review is intended to apply up to date housing figures from the revised housing needs assessment under the standard methodology and that this applies to 2020 - 2040; not just post 2030. Fundamentally the Council’s position is a political one and affords too much protection to existing communities, at the cost of a misconceived approach to sustainable deliverable development. This needs to be reassessed before the plan is tested at an Examination in Public, because there is a serious risk that the plan is found to be unsound.
3.2 To add to this point, there is no recognition in the plan that the Neighbourhood plans are only projected to 2030 and therefore there is no reason given as to why allocations in the rural areas cannot be identified for post 2030, through a phased approach to delivery. This concept is discussed below.
3.3 The Vision and Objectives seek to promote sustainable growth, and this should be similar to the concept in previous Local Plans in Bedford as the context of the Borough has not changed. It remains a Town and Country Borough with a principle Urban Area and a range of settlements that have different levels of facilities that dictates in a clear hierarchy which are the most sustainable locations for growth.
3.4 The Settlement Hierarchy Addendum (2022) supports the emerging Local Plan 2040. The addendum notes that the Key Service Centres and Rural Service Centres identified to deliver growth as set out in the Local Plan 2030, will not change. The Settlement Hierarchy confirms that 6 settlements in the administrative area comprise Key Service Centres. Most of them have allocated around 500 dwellings to be developed in the plan to 2030, all through Neighbourhood Plans. Only Wilstead with zero dwellings and Wootton with 105 dwellings are lower. Wilstead is affected by the role of Wixams whilst Wootton is arguably underprovided given its scale.
3.5 Based on the Standard Method for calculating housing need a total of 27,100 new homes are required in the borough over the whole plan period 2020-2040, therefore only 7.8% of housing allocated through the Local Plan 2030, Neighbourhood Plans and the emerging Local Plan 2040 is to be delivered in some of the most sustainable settlements in the borough. Yet allocations in these rural areas would be immediately sustainable, would not be subject to significant infrastructure projects and could be delivered quickly to provide housing in response to current housing need.
3.6 The same conclusion can be drawn for Rural Service Centres in the borough, of which there are 10. Whilst it is acknowledged that these settlements are smaller, the settlement hierarchy confirms they still score reasonably high on the rankings. They have good road and public transport links and reasonable levels of service provision. Milton Ernest is the 12th most sustainable rural settlement in the Borough and yet it has an allocation of 25 dwellings through a Neighbourhood Plan, amounting to just over 1.25 dwellings to be delivered per annum over the entire plan period. This is a significantly underprovided for the local need of Milton Ernest as well as its important role in the Borough as a whole.
3.7 More recognition of the importance of rural settlements in meeting housing need over the entire 20-year period is required in this plan. The strategy proposed places emphasis on the use of large strategic sites located in isolated countryside locations, in some cases near to or adjacent to settlements that are in the lower rural settlements and are simply not sustainable.
3.8 The allocation of housing on the edges of existing sustainable rural settlements presents a multitude of benefits both to the settlement and the borough through ensuring quick delivery of housing contributing to housing supply and bolstering the sustainable nature and vitality of smaller settlements in the borough. National Policy recognises this stating “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.”