Object

Representation ID: 6115

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

3.25 The Council’s own evidence demonstrates that the level of rail-based growth at Kempston Hardwick/Stewartby and Wixams relied upon as part of its Preferred Options is unsound. National Planning Practice Guidance ID: 68-020-20190722 states that a pragmatic approach should be taken when considering the intended phasing of sites, where the authority may need to provide a greater degree of certainty than those in years 11-15 or beyond. The PPG expands on this by stating that where longer-term sites are relied upon evidence must be available to demonstrate that they will come forward within the timescales envisaged and at a rate sufficient to meet needs over the plan period.
Reasoning
3.26 The Bedford Local Plan 2040 should be more realistic in the delivery timescales for strategic / complex sites. The delivery of large strategic sites is complex with long lead times; especially when dependent upon delivery of infrastructure such as rail or transport schemes. These issues with existing sites will be compounded in the Council’s trajectory for the Local Plan 2040 (meaning that even its proposed ‘stepped approach’ against a requirement of 970dpa to 2030 will not be effective). These representations further demonstrate the lack of evidence to consider rail-based growth in the A421 corridor as developable any earlier than years 11-15 of the plan period (if not beyond) thus rendering the Council’s Preferred Options entirely unsound.
3.27 The Council’s own Development Strategy Topic Paper identifies multiple risks to the rail-based component of growth in the A421 corridor, including:
• Delivery of new rail stations is proposed, but not yet confirmed.
• Lead in times for remediation of the Kempston Hardwick area and delivery of new rail stations mean that development in this part of the transport corridor will occur later in the plan period.
• Detailed analysis of context and density / storey heights to establish appropriate place making for the rail based growth at Kempston Hardwick and Stewartby has yet to be undertaken.
• The land at Kempston Hardwick is currently being promoted for employment development.
3.28 These points confirm that the Council’s extremely wide range of potential quanta for the development of rail-based growth are not currently informed by evidence of site-specific opportunities assessed as suitable, available or achievable. This means that there is no justification whatsoever for the levels of development summarized at paragraph 3.12 of the Council’s Topic Paper:
“Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams. On the assumption that new rail stations will be delivered at Wixams and Stewartby / Kempston Hardwick, ambitious growth is assumed at both Wixams and Stewartby / Kempston Hardwick in the range of 1,500-3,000 dwellings at Wixams and 2,500-5,000 dwellings at Stewartby / Kempston Hardwick by 2040. Within the options two levels of development are tested: a lower option total figure of 5,500 dwellings (2,000 at Wixams and 3,500 at Stewartby / Kempston Hardwick) and a higher option of 7,500 dwellings (3,000 at Wixams and 4,500 at Stewartby / Kempston Hardwick)”
3.29 There is no evidence to indicate these totals as developable in the period to 2040. In the absence of site-specific testing the Council can have no grounds to suggest how constraints might be overcome, when infrastructure will be provided and whether the extremely high levels of development required to meet these totals over a very short period between sometime after 2030 and 2040 can be achieved.
3.30 The extent of this uncertainty is summarized in footnote 1 on pp.8 of the Development Strategy Topic Paper:
“East West Rail are currently consulting on two options for the Marston Vale Line; one which retains the current stations at Stewartby and Kempston Hardwick, and another that replaces them with a new station (tentatively named “Stewartby Hardwick”) at Broadmead Road. This component of growth is based on development around the new or existing stations in conjunction with development around the new station at Wixams. These stations could provide a focal point for higher density growth supported by the sustainable travel options offered by new and enhanced rail services.”
3.31 The potential for residential development to occur in conjunction with the delivery of new stations as intended by the Council is likely to require a substantially longer lead-in timeframe.
3.32 However, the delay potentially associated with provision of strategic infrastructure could be mitigated through the delivery of modest growth at Key Service centre villages, particularly those are well related to growth corridors and have the ability to provide sustainable growth withing the period, even early in the plan period.