Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4994

Received: 02/09/2021

Respondent: Rainier Developments Limited (Bromham)

Agent: Marrons Planning

Representation Summary:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.

Full text:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that rural population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
However, the key point here is that some villages are better related to Bedford town centre, the wider urban area, and have more sustainable travel options than other villages. To categorise all growth in the villages as having a major negative effect in relation to these SA objectives is inaccurate as some settlements are very close to the urban area with high levels of sustainable travel links to Bedford town centre, such as Bromham.
To put that point in context, Bromham is the largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre (circa 5km) than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and therefore was found sound by the Inspector. Hence, Bromham is inherently a very sustainable location to accommodate growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in the generation of strategy options at 3.12. It only appears in two options which are realistic (namely 3b and 3c which include development in and around the urban areas). Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options.
Again, the appraisal of these two options (3b and 3c) in the Draft SA is skewed by the assumption that all growth in the villages is in locations where there is a greater need to travel and which is more likely to be by car. The specific merits of Bromham as a location where the need to travel is reduced and where there are sustainable travel options are therefore not captured in the current draft of the SA, and this is a significant omission.
The Topic Paper concludes on these two options that they do not perform as strongly compared to others with reference to highway constraints on the A6 north of Bedford, the need to allow villages to assimilate already planned growth, and the loss of focus on EWR.
In response, Bromham as a location would not impact the A6 north of Bedford as traffic routes to Bedford and the M1 via the A4280, A428 and A422. This would therefore not be a constraint to growth at Bromham.
Planned growth at Bromham within the Neighbourhood Plan is likely to be delivered early in the Plan period, and thus there will be a lengthy period of time during the Plan period within which development could come forward. There is no evidence to suggest Bromham needs such a lengthy period of time to assimilate planned growth, nor that the benefit of any period would outweigh the need for Bromham to contribute to a sustainable pattern of development and meet needs arising from the urban area.
More fundamentally, however, this is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase in its housing requirement per annum and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change (particularly in the context of a higher housing requirement).
Additional growth at Bromham of up to 345 dwellings (reflecting the capacity of Site ID 757 as discussed below) need not detract from a focus on EWR given the scale of housing need to be met across the Borough.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs.
Furthermore, and more fundamentally, it is requested that the Council reconsider the role of Bromham given its location on the edge of the urban area, its proximity to the town centre and Bedford train station, and its sustainability credentials. The scale of growth that could be accommodated at Bromham need not challenge or threaten a strategy focussed on the urban area and rail based growth, but complement it in identifying deliverable sites in a sustainable location that can boost supply to meet the higher housing requirement.
For the avoidance of doubt, these representations are not suggesting all Key Service Centres should accommodate further growth of 500 dwellings as assessed in the Options. Our representations are that deliverable sites in sustainable locations around villages near the urban area, should contribute to boosting supply in the early part of the Plan period to meet the new housing requirement. Bromham is unique given its close relationship to the urban area of Bedford and the town centre and train station, and there is a strong case for this settlement to form part of the final preferred strategy (either recognised on its own, or recognised as part of the wider urban area).
Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy.
The site adjoins the settlement boundary, and is enclosed by built development (existing and committed) on two sides to the east and south, and by the road network (Northampton Road and A428) to the north and west. Built development also exists at Chestnut Avenue to the north of Northampton Road.
Its development would therefore be restricted by physical features, and would represent a logical rounding off of the settlement within the confines of the built form and complimenting the committed site to the south at Beauchamp Park. The site was previously identified as a ‘preferred site’ and considered as a reserve site by the Parish Council in its preparation of its Neighbourhood Plan. It is fair to say that the site is recognised as the next logical allocation for residential development in the settlement.
There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning. Taking these into account, the site has capacity for approximately 345 dwellings.
The development of the site would clearly make an important contribution to housing supply, including affordable housing at 30% (circa 100 dwellings). This is significant given it has been resolved that the undetermined outline planning application (19/01904/MAO) at Beauchamp Park will only provide 15% affordable housing, resulting in a shortfall of supply (circa 60 affordable dwellings) against the level expected to be delivered to meet the significant affordable need within the area during the Plan period. There are other environmental benefits, including biodiversity net gain and an extension to the Bromham Heritage Trail through new areas of open space. There will also be economic benefits in terms of jobs generated from the construction phase, and an increased population supporting the viability of services and facilities within Bromham, and nearby Bedford.
The site benefits from good access by sustainable modes of travel to facilities within the village as demonstrated previously within the Vision Document, as well as nearby Bedford. There is capacity within those facilities, particularly the local school which at present is 3 Form Entry but has the capacity to expand to 4 forms of entry as explained in the Neighbourhood Plan and agreed with the Local Education Authority. There is therefore capacity to accommodate additional spaces to meet demand arising from the development of Site ID 757 within the local school which is the preference of the Parish Council.
Separate representations have been made in response to the Site Assessment Consultation on Site ID 757.