Object

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

Representation ID: 6241

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Representation Summary:

4.1 The previous Issues and Options consultation outlined six potential approaches
to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based
growth.
4.2 These six options have now been progressed and as set out in the Local Plan
and Development Strategy Topic Paper (June 2021); BBC now seek views on
four ‘preferred options’ to meet the (proposed) level of growth set out in the
Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes and southern parishes;
2. Option 2b: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes and southern parishes, plus one new
settlement;
3. Option 2c: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes, plus two new settlements;
4. Option 2d: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes, southern parishes, and eastern
parishes, plus one new settlement;
4.4 The four options put forward share many common components. In all but one
option (Option 2c), growth is proposed to the south of Bedford, including the
southern parishes. The only option that omits this approach is Option 2c, which
instead proposes the delivery of two new settlements.
4.5 Firstly, Option 2c is not considered a sound approach. As has been
evidenced3, the development of large sites (2,000+ dwellings) takes many years.
The average time quoted from validation of the first planning application to the
first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. The
lead in period to starting on site for new settlements is many years, being further
complicated by matters such as creating the necessary utility infrastructure for a
new settlement.
4.6 The same report also finds that the average annual build-out rate for a scheme
of 2000+ dwellings is 160dpa.
4.7 Working on the basis of a plan led system, any application for a new settlement
would, in theory, not be validated until after the Local Plan is adopted, thus 2024
at the earliest. This means that any new settlement is unlikely to begin
delivering homes until 2032 at the earliest. The proposed new settlements are
3,085 dwellings at Little Barford, and 2,500 dwellings at Wyboston. Little Barford
would take 19.3 years to build out at that rate (almost the entire Plan duration),
and Little Barford 15.6 years.
4.8 If the Plan period runs until 2040, both new settlements would only deliver, at
best, half of their housing numbers within the Plan Period.
4.9 The approach set out in Option 2c would not, therefore, meet the Borough’s
housing needs within the Plan Period and should be discounted as a result.
4.10 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d,
albeit the effect of only having one new settlement would lessen the delivery
issues.
4.11 The option which has the greatest likelihood of delivering growth within the
Plan period, as required by national policy, is Option 2a. This option would
focus growth in the south along the major transport corridors of the A421, A6
and railway line, and in turn would focus development in the most sustainable
locations.
4.12 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the
best performing option. It also finds Option 2c to be the worst performing of
these 4 options, and that is without considering the issue of delivery as set out
above.
4.13 AWG strongly argue that Option 2a should be the preferred Option for growth
that is taken forward in the Local Plan. Option 2a is the best performing of the
various growth options as shown by the evidence base.
4.14 The next section of these representations puts forward a case as to one such
location for growth within the southern parishes, which would deliver growth in
accordance with Option 2a (in fact according with 3 of the 4 development
options).