Object

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

Representation ID: 6124

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

Representation Summary:

4.10 The Bedford Local Plan 2040 examines a total of 13 development strategies but have focussed on 4 as being preferential.
• Option 2a: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes & south parishes (2000 dwellings).
• Option 2b: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, south parishes (1500 dwellings), plus one new settlement.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, south parishes (750 dwellings) and east parishes, plus one new settlement.
4.11 The four strategies identified as preferential for delivering growth are broken down into different locations and spatial options. Within the A421 corridor, existing and planned railway stations and 1 or 2 new settlements are considered alongside village-related growth in ‘east’ and ‘south’ corridor parishes. The following observations are key:
o Whilst the Local Plan 2030 identifies a need for 970 dwelling completions a year, the Local Plan 2040 must be based on a minimum of 1,275 dwelling completions a year (based on the standard method). This is a significant (33%) increase. This higher number will apply across the plan period (2020-2040) resulting in the need for a ‘top up’ for the period 2020 to 2030 (an additional 305 dwellings each year / 3,050 across the ten years), followed by the full 1,275 for each year between 2030 and 2040.
o Over the plan period, in total, the strategy will need to allocate land to enable a minimum of 25,500 dwellings to be delivered (20 x 1,275). Current commitments amount to around 13,000 dwellings which means that land to accommodate in the region of 12,500 dwellings must be allocated in the new local plan.
o The Council’s strategy states that to make provision for this level of growth it will require allocation of land at a strategic scale which in turn will rely on the timely delivery of strategic infrastructure. For that reason, one option is for the plan to be based on a “stepped trajectory” which would mean, for example, that the delivery target could be kept at 970 per year until 2030 and then increased to 1,580 dwellings per year to make up the rest of the plan requirement over the remaining 10 years.
o To what extent have the preferred options taken account of circumstances where it may be appropriate to plan for a higher number of dwellings that indicated by the government’s standard method for the calculation of local housing need? This is a key consideration the Borough’s key location within the Oxford-Cambridge Arc.
Strategic Dependencies
4.12 The preferred strategy of the proposed Local Plan 2040 has a number of strategic dependencies and influencers which are beyond the decision making, time scale and delivery of the Borough Council. These strategic dependencies are the Ox-Cam arc, East-West rail improvements, strategic road schemes including A1 and Black Cat junction.
4.13 None of the preferred strategy options include other village-related or New Settlements outside of the A421 corridor.
4.14 While there are four elements to the strategy for the A421 corridor there is a heavy reliance on ‘rail focused’ growth in the preferred options (as highlighted) and thus a need for significant investment to deliver a high proportion of the strategy options.
4.15 The Council indicates that by 2030 the Black Cat Junction improvements will be complete, the East West Rail section through Bedford Borough will be complete (including new and re-modelled stations) and sufficient lead-in time will have been available for strategic projects to be planned in detail, enabling these higher numbers to be achieved. The Council suggests forward planning will include arrangements for new sustainable travel links, with the intention that these are available from day one in order to embed and promote sustainable travel choices.
Rail focused growth comprises between 31% and 60% of units required to meet the total allocation of 12,500 additional dwellings.
4.17 Meeting the housing targets is also dependant on at least a single if not two new settlements. For this reason, the strategy is looking to back load the delivery to the later stages of the plan. New settlements are a notoriously high risk and take a substantial time to get delivered. Indeed, even delivery towards the end of the plan period can be viewed as optimistic. The delivery of the proposed new settlement options thus requires further examination.
4.18 Additional flexibility in delivery, particularly where this has potential to complement growth along the A421 corridor, is therefore a key component of any appropriate strategy option to be selected by the Council. This is necessary in order to demonstrate compliance with national policy and guidance.
4.19 There is no evidence available to the Council to reject village-related growth in the ‘south’ corridor parishes as part of the selected strategy option. We would endorse that the minimum figure of 1,500 units identified in the Council’s Option 2b would represent an appropriate starting points as part of a wider ‘hybrid’ strategy.
4.20 While the Council’s Preferred Options are not based on settlement-specific assumptions for the distribution of growth within this 1,500 unit total we would urge the Council to adopt a flexible approach. Within this scenario some settlements may be subject to less growth. In the case of Wootton, given its important role as a Key Service Centre and good accessibility strategic scale village extensions would form part of an appropriate strategy thus making a potential capacity in excess of 500 units a useful starting point for testing site options.