Object

Representation ID: 5662

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraphs 3.17, 3.10-3.16
Hallam Land Management objects to the preferred growth strategy options which are narrowly focussed on those variants of Option 2, and therefore also the decision to reject the alternatives or elements thereof presented in Option 1 and 3-7 and its variants. Hallam considers that a preferred strategy needs to be more reflective of a balanced and appropriately weighted approach in planning for sustainable development across the Borough and in this regard considers that a single preferred strategy must include an appropriate combination of the wider options presented with due weight given to those that can create a balanced and sustainable spatial strategy.
The variants of Option 2, although positive in focus towards Bedford and being aligned, broadly in the context of the anticipated Oxford Cambridge Arc Spatial Framework, notwithstanding the constraints of the A6 corridor, exclude opportunities for development at an appropriate scale to support existing communities. There are also doubts as to whether the most restrained variant – Option 2a would be able to provide sufficient capacity, in isolation, for growth, certainly around rail station locations provide opportunities for maximising sustainable accessibility to Bedford and along the East West Rail corridor.
No change is observed in the evidence base or the outcome of the existing plan – that existing well connected and well served settlements represent highly sustainable options for development. Specifically, the preferred strategy should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in East West Rail and connectivity to Bedford station – rail related potential is not limited to the south of the town and Bedford Station is as, or more, accessible from the north – more so with enhanced sustainable transport links, potentially including the A6 corridor as a focus for infrastructure investment (i.e. more frequent bus services and physical cycle links). The preferred strategy should not therefore rule out opportunities for continued development at Key Service Centres, particularly to the north of Bedford which is otherwise avoided by variants of Option 2 and is likely to rely on windfall development without any additional allocations. Such an approach will fail to realise sustainable investment in those existing communities and their infrastructure. Indeed, the opportunities that do exist to invest in sustainable transport, both for new and existing communities, to the north of Bedford, should be identified and supported through the transport and growth strategies of the plan. That the Council considers mitigation opportunities in the A6 corridor to be insufficient to support major scale development at Twinwoods or Sharnbrook, does not mean that there are not opportunities to be realised through lesser scale sites (than Twinwoods or Sharnbrook) in sustainable existing communities.
In this context, Hallam considers that a preferred strategy should combine elements of the wider discounted options (1 & 3-7) to best achieve the scale of growth that is likely to be required. Hallam considers that elements of discounted options have a part to play if the housing numbers are to be met in capacity terms and in securing an appropriate geography of opportunities and in helping meet the deliverability gap that is implied by stepped housing requirements and any allocations of large scale new communities or settlements. Hallam also considers that the preferred combination of options must be identified to enable a robust trajectory of delivery to come forward. In practice, Hallam have suggested that this will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. Of those locations identified for more strategic scale development along the A421 and East West Rail corridor, account should also be taken of cumulative delivery rates in the context of the scale of delivery being planned in Bedford Borough but also in Central Beds and other adjoining locations as part of the Oxford Cambridge Arc agenda. Some flexibility or tolerance may be required with anticipated delivery timescales. Such uncertainties and a requirement for contingencies translates into a more balanced focus that looks also towards the north of Bedford.
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Whilst considering that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford and therefore, emphasises for clarity, that this must extend beyond the 0.5 miles of the urban area boundary to include the most immediate neighbouring settlements that have significant potential to benefit from enhanced sustainable connections. An example in this context is Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). It becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. There are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the village.
The potential for Clapham to accommodate future growth and being well connected to Bedford, whilst being distinct as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham present the opportunity for the Borough Council to encapsulate a Greater Bedford option or element in its plan preparation and in due course in the plan strategy. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions but needs a comprehensive approach. A Greater Bedford element to the plan, including the urban areas and immediate settlements would reflect that ambition and provide a positive framework for investment and early delivery. .
The Development Options Topic Paper, in referring to the sustainability appraisal of the broad components of growth, considers the urban area component of the preferred options (including the rejected variants of Option 1, which would play a key role in a wider strategy) to perform best and then considers the adjoining urban area component to perform almost as well. In this context it follows, in Hallam’s view, that growth in immediate neighbouring settlements to the Bedford Urban Area such as Clapham are also capable of performing just as well as what is currently considered to be the adjoining urban areas with enhanced sustainable connections in the form of frequent public transport services and active travel routes. In this context a limit to identifying opportunities for growth to within 0.5 miles of the urban area boundary is considered arbitrary and not necessarily reflecting functional relationships. In practice existing settlements such as Clapham are arguably better located than sites in the immediate adjoining area, where patterns of existing development are likely to constrain opportunities for development that can fully exploit and enhance sustainable transport corridors. In Hallam’s view the definition of the adjoining area should be broadened to include the most immediate settlements that are able to be well connected though relatively modest infrastructure investment. In essence, this approach begins to reflect elements of Options 3b and 3c, 4, 6 and 7, insofar that the focus is extended to those smaller settlements that are immediately adjacent to Bedford and have the potential to benefit from enhanced sustainable connectivity.
An added benefit of securing an appropriate level of growth in those smaller settlements, particularly those adjacent to Bedford, would also be to support local services. Key Service Villages such as Clapham with additional development has the potential to support and enhance the offer of local services, including community facilities and local retail. These benefits are particularly important for people who do not have access to a car. A greater reliance of access to local services and facilities have been underpinned recently by the changes to working and living patterns arising through the Covid-19 pandemic.
Furthermore, a rationale in the current adopted development strategy is apportioning growth to Key Service Villages to support the provision of new Primary Schools with a scale of growth sufficient to support the delivery of 1 form of entry accommodation, is at odds with the Borough’s Council’s position (as set out in its paper for Education Provision for the Local Plan 2030) that new primary schools should by preference be for 2-3 forms of entry. It follows in this context that allocating further development to Key Service Villages would enable for the delivery of primary schools that are of an operationally efficient and preferable size (i.e. 2-3 forms of entry).
In identifying a Preferred Spatial Strategy Option, Hallam’s View is that this should be based on:
1. Embrace and include urban based growth and areas adjoining the Bedford urban area boundary including immediate neighbouring settlements (i.e. such as Clapham) that are or have the potential to be well connected to Bedford (therefore, partially reflecting Options 3b, 3c and Options 4 and 6) recognising also the contribution such elements can make before larger scale elements of the strategy
2. Medium to longer term infrastructure focused transport-oriented growth around existing and proposed East-West Rail Stations and key public transport routes or larger scale options (partially reflecting the variants of Options 2 and Options 4,5 & 6).
3. And, to a lesser extent, continue to focus more modest levels of growth at other Key Service Villages outside the Bedford catchment where development will further support local services and facilities to reduce the need to travel for day to day requirements and fully support the delivery of operationally efficient primary schools (as reflected in Options 3b and 3c and Options 4, 6 & 7).