Comment

Representation ID: 10527

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS2 (Spatial Strategy) sets out a spatial strategy for the local plan and the areas where new development will be directed. It states that development will be focused within the urban area of Bedford, and at specified strategic locations adjacent to the urban area and at growth locations within the A421 / East West Rail corridor. In seeking to meet the need over the Plan period for 27,100 homes, the spatial strategy depends on the delivery of significant development at Kempston Hardwick and a new settlement at Little Barford. Taken together, these locations are expected to deliver 7,200 homes over the final 10 years of the plan.
Whilst we do not object to the proposed allocations in principle, it is considered that the expected rates of delivery on the sites is too optimistic. In order to be considered ‘sound’ a realistic assessment of likely rates of delivery should be provided, in accordance with paragraph 73 (d) of the NPPF. If the housing trajectory was revised to be in line with available evidence on average annual build out rates for large schemes3, the Council will inevitably need to identify additional sites in order to ensure the housing needs of the Borough are met in full.
In identifying additional sites, it is considered that a greater proportion of housing should be directed to smaller sites in urban areas other than Bedford to secure more proportionate balanced growth, such as the Site at Rushden Road, which is located within the Bedford Borough but adjacent to the southern boundary of Rushden (located within North Northamptonshire Council). As demonstrated within the accompanying vision document, the Site is suitable, available and deliverable.
The North Northamptonshire Joint Core Strategy 2011-31 (adopted July 2016) recognises Rushden as a Growth Town (the highest tier of settlements) and defines its ‘spatial role’ as “to provide the focus for major co-ordinated regeneration and growth in employment, housing, retail and higher order facilities serving one or more districts”.
Furthermore, the East Northamptonshire Local Plan Part 2 was submitted to the Secretary of State for Housing, Communities and Local Government on the 29th of March 2021. The Hearing Sessions concluded on Thursday 5th of May 2022. Within the Part 2 Plan, Rushden is identified as a growth town, which will provide the majority of new housing and employment development during the plan period, through a new sustainable urban extension. This includes at least 2,500 dwellings and associated jobs and facilities. This is considered to demonstrate the suitability of Rushden as a location for new development. On this basis, we consider that the Site would align with the Plan’s vision for greener, more accessible, and more prosperous Borough.
Whilst it is acknowledged that ongoing or future infrastructure improvements e.g. Black Cat Junction improvements and the East West Rail section through the Borough are due to be completed later in the plan period, and this may inform the overall growth strategy and trajectory, there also needs to be consideration of smaller, sustainable sites (without extensive infrastructure requirements) that can come forward earlier in the plan period and take pressure off the delivery of a high number of sites and homes between 2030 and 2040 (especially those reliant on the delivery of infrastructure). The wording within the subtext to the policy which states that “the Council will monitor the provision and delivery of infrastructure and, if necessary, bring forward a review of the local plan” is supported.
Notwithstanding the above, the Viability Assessment that has been published as part of the Council’s evidence base to the BBLP40 highlights the challenges of achieving viability in complex urban areas such as Bedford, particularly where schemes may involve a degree of recycling existing buildings (paragraph 6.4). As such, the allocation of greenfield sites in other urban locations such as the Site at Rushden Road will ensure development comes forward in compliance with the Council’s policy requirements e.g. relating to affordable housing, whilst providing holistic / inclusive growth throughout the entire Borough.