Object

Representation ID: 6161

Received: 09/09/2021

Respondent: Savills

Agent: Savills

A range of emerging preferred options for the spatial strategy also known as development strategy are
provided in the consultation local plan comprising 2a to 2e. We consider the preferred strategy will to
continue with a focus on the urban area of Bedford and Kempston with additional growth that is spatially well
related to the urban rea. The definition of well related should include land adjoining and land not adjoining
the urban area but which has good connectivity potential such as walking, cycling and public transport. This
would be consistent with paragraph 73 of the NPPF.
Out of the preferred options we consider that Option 2a: Development in and around the urban area, plus
A421 transport corridor with rail based growth parishes and southern parishes, is the most sustainable and
appropriate, followed by options 2b and 2d.
We consider option 2c is least sustainable and least deliverable because of the strategic nature of some of
the locations identified. We do not of course object to the principle of new settlements but rather consider the
complexity in delivery is often underestimated in plan-making.
We do not necessarily agree with the number of dwellings included in brackets within the preferred options.
There is no explanation as to whether this is new going forward or there is an element of deduction to allow
for commitments and/or windfalls although the total figure tallies with the amount given at paragraph 3.2.
This is where more detailed explanation is necessary along with a delivery trajectory. There is no explanation
of land availability and deliverability to understand the wider context. We consider a minimum figure of 2,000
dwellings for all options for the southern parishes is an appropriate starting point.
Land at Box End, West of Bedford is capable of delivering some 1,150 dwellings being well related to the
urban area of Bedford and Kempston. The figure of 12,500 dwellings is not agreed at this stage and even if it
were to be, then this should be seen as a minimum and land identified capable of delivering more than this
minimum. This would be consistent with the NPPF paragraph 68.
Oxford-Cambridge Arc
The consultation draft provides an explanation of the Oxford-Cambridge Arc as it stood at that time.
However, since then the Government has published consultation on a vision for the emerging spatial
framework and therefore this should be taken into consideration in discussions with MHCLG and other
stakeholders.
The spatial framework for the Arc is expected to sit alongside the NPPF as national planning policy.
Therefore the assumption should be that the emerging local plan will need to be consistent with the spatial
framework, being one of the tests of soundness under paragraph 35 of the NPPF.
1.13 in the consultation local plan provides a description of the timeline for both plans and shows that the
spatial framework is likely to be published ahead of examination into the local plan.