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

Representation ID: 6360

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Representation Summary:

Taylor Wimpey is encouraged to see that growth in the A421 corridor is included within three of the four options presented in the paper (for which commentary on the fourth option which focuses growth on two new settlements is discussed in more detail below), as well as rail-based growth being included in all four options identified.
However, Taylor Wimpey do still have some outstanding concerns about the detail behind Options 2a, 2b and 2d (the three options which contain growth in the A421 corridor); this primarily focuses on the level of growth directed to the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period and the deliverability of 5,500-7,000 homes in the rail corridor. These are discussed in more detail below.

Rail related growth
Whilst in principle Taylor Wimpey support growth in the rail corridor to the south of Bedford, there are a number of key matters in relation to the approach taken to this growth by the Council which requires further consideration.
Firstly, it is unclear how it will be possible to deliver the scale of growth proposed by the Council (50% of the housing requirement). An extract of the Call for Sites map has been overlaid with the rail related growth area identified in Options 2a - 2d and is included at Figure 1 below. As can be seen from Figure 1, there are a limited number of sites which have been put forward to the Council as being available in this area – with the majority of the large sites that have been put forward having been identified for potential employment use.
Secondly, the justification for the extent of the catchment area for these rail station locations has not been properly elaborated on. Additional opportunities may be available on the periphery of this area, in settlements such as Wilstead, which could contribute to delivery (which is currently classed as being in the A421 corridor). Wilstead is a settlement with a range of services and is in easy commuting distance of Wixams including via sustainable modes of transport such as cycling. It is in close enough proximity to Wixams that a local gap is currently included within adopted policy in order to separate the two settlements.
Without expanding the catchment area for the rail-related growth, combined with concerns about the ability to delivery 3,000 in and around the urban area, further emphasis should be placed on the role of land in the A421 corridor within the development strategy, with a particular focus on those settlements, such as Wilstead, which can be classed as lying in both.

Delivery in New Settlements
Taylor Wimpey recognise that there is a role for a new settlement as part of the development strategy,
As previously noted, the NPPF 2021 includes the new provision that new settlements will need to present a long term, 30 year vision and a new settlement will therefore present the opportunity to deliver new homes later in the Local Plan period.
However, there will be a significant lead in time with any new settlement, with completions not likely to be realised until well into the Local Plan period. An over reliance on new settlements to meet housing need would therefore be a detriment to meeting housing requirements in the short to medium term, particularly when there appear to be sufficient suitable and deliverable sites available to meet the need in a timely manner. This issue would then be further exacerbated in a strategy which relies on the creation of two new settlements.
If a new settlement is to be included in the strategy, which would be a reasonable approach given the challenges in the area, the number of homes to be delivered in the plan period should be realistic. It is noted that the options currently assume the completion of either settlement option within the plan period. This is not a realistic assumption given the stage the plan is at and the lead in time on matters such as land assembly, planning and infrastructure delivery.
The Council will need to ensure that the residual requirement that has been identified above in the earlier plan period is picked up through the development strategy. Given the constraints with other elements of the strategy, emphasis should be placed on the importance of the A421 corridor to deliver growth and the wider catchment area around key rail locations and the approach taken in Option 2c reconsidered.

The Apportionment to the Southern Parishes
Aside from option 2c (the two-settlement option), which has been addressed above, each of the options include an element of growth in the A421 transport corridor. This level of growth varies from 1,500 dwellings in option 2b and 2d to 2,000 dwellings in option 2a. Taylor Wimpey consider that these options significantly downplay the potential of the area to deliver additional housing numbers and note that there is a need to rely on sites in this location given the issues identified above.
Figure 1(below), an extract of the Call For Sites map, identifies that there are a number Key Service Centres located within this corridor such as Wilstead (where Taylor Wimpey are promoting land), as well as Wootton, Wixams, Shortstown and Great Barford. These settlements are highly sustainable and have the ability to provide additional sites beyond the housing apportionment currently stated. In the adopted Local Plan, Key Service Centres were seen as suitable for 500 dwellings, and indeed higher level of growth in some locations were assessed early in the process as being appropriate.
There are also other larger settlements in the corridor that could take growth, such as Willington (where Taylor Wimpey have land interest) which have been excluded from the A421 Corridor, despite being in the same transport corridor as the likes of Wootton, Wilstead, Cotton End and Shortstown (which are included in three of the options). From a review of the evidence it is not clear why this is the case.
No justification has been given as to why the options limit potential growth to 2,000 dwellings and therefore this comes across as an arbitrary number that is not underpinned by the necessary evidence. This is particularly noticeable when the issues raised above with the other options are taken into account.
A finer grain assessment of site availability and suitability should be undertaken to inform the development strategy. Taylor Wimpey consider that this will identify a greater level of potential for growth in the A421 corridor.
The whole of the A421 corridor should be looked at as one moving forward, with no arbitrary distinction between the eastern and southern parishes. This will allow a proper review of all settlements and sites on a comparable basis and avoid suitable sites being missed out.

Neighbourhood Plans
It is noted that there are a number of emerging Neighbourhood Plans which seek to address the housing need requirements identified for certain villages in Policy 4S of the Local Plan 2030.
If a Neighbourhood Plan is made ahead of the adoption of the Local Plan 2040, this should not influence the strategy included in the emerging plan.
The emerging Local Plan should revisit the level of growth apportioned to each settlement as part of a review of the growth strategy for the area and allocations should be made in settlements, such as Wilstead and Willington, in order to ensure that the housing needs for Bedford Borough are met.

Location for Growth
− There is a concern that the assumed delivery of the settlement options may be being overstated.
● The assumed capacity of the urban area/urban fringe and the rail focused options to deliver the stated level of development should be reviewed.
● The two-settlement option is not a robust or sustainable approach to meeting housing need.
− A focus for growth within the A421 corridor is supported by Taylor Wimpey and it is asserted that there is a need to increase the level of development focused along the A421 corridor due to the constraints which effect other options. It is noted that the Council have created an unjustified split in the parishes along the A421 corridor and that a more appropriate approach would be to look at the area as a whole and identify the most appropriate available sites.