These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which 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). 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.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
Finally, none of the emerging preferred options allocate any growth to Bromham. Bromham is 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 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 therefore 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 thus was found sound by the Inspector. Bromham is inherently a very sustainable location to accommodate further growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in any of the preferred options. The northern boundary as currently drawn for the southern parishes within 2a, 2b, and 2d is the A428, and yet Bromham to the immediate north of the A428 is as well related to the urban area and would contribute in the same way to a sustainable pattern of development.
As with the point made above, it is acknowledged that Bromham has existing commitments which will deliver housing within the early part of the Plan period. However, Bromham is a sustainable location for growth given its relationship to the urban area and should therefore play a role in meeting the higher housing needs of the Borough (boosting supply in the early part of the Plan period to meet the higher requirement and avoid stepping the trajectory).
This is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase per annum in its housing requirement 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.
Bromham has capacity to accommodate more development. As noted under representations made at paragraph 1.28, land south of Northampton Road, Bromham (Site ID 757) is a suitable and deliverable site, and could complement existing commitments to the south at Beauchamp Park. That site is already well advanced in the planning process and likely to come forward early in the Plan period.
In determining the best growth strategy, we encourage the Council to reconsider its approach to Bromham and include it as a discreet addition to its preferred strategy, and allow for further growth over the Plan period. 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 in this context.