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Representation ID: 6477

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

General approach 1. 2. 3. 4. 5. 6. The general strategy running through all four development options is supported in terms of the need to distribute growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Each of the options do however present varying concentrations of growth within these categories with resulting positive and negative outcomes. We have provided a detailed commentary on each below. Urban Centre and Edge A total of 3,000 homes are proposed within and adjoining Bedford Town Centre with 1,500 homes specifically targeted in the urban area alone. This seems an overly ambitious level of growth for the urban area given the limited land available, the presence of several heritage and environmental constraints and pressures to safeguard land for critical infrastructure such as Bedford Hospital. We would question how the delivery of this number of homes would protect the character of the town given the likely density required to reach this target and the high levels of traffic and congestion already experienced in the town. There will be viability and land assembly challenges for urban land and substantial development has already taken place on the edge of Bedford. Whilst residential development has a place in town centres, there also needs to be an appropriate balance between residential growth and employment/retail/leisure offerings. This is to ensure the vitality of the town centre and its recovery post pandemic. A detailed analysis of the town’s context and capacity for further density/storey heights needs to be carried out before such an option is considered sustainable and achievable. New settlements Paragraph 73 of the NPPF requires LPAs to identify suitable locations for large scale development where this can help to meet identified needs in a sustainable way. This should include: • considering the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains; • ensuring that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access; • set clear expectations for the quality of the places to be created and how this can be maintained (such as by following Garden City principles); and ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed and beautiful homes to meet the needs of different groups in the community; • make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development corporations); and • consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size. Taking into account the above points, it is clear that the advantage of the proposed new settlement at Little Barford is that it would benefit from direct access to the new East West Rail station that is proposed southwards of St Neots. Several of the proposed routing options for the railway line will however 5 constrain the site to an extent. In contrast, a new settlement at Wyboston, given its remoteness from existing urban areas, would have greater reliance on the use of private cars and fewer opportunities to promote active travel and create viable public transport services. This concern is supported by the transport evidence prepared by Aecom on behalf of the Borough Council. 7. 8. 9. 10. 11. 12. 13. Paragraph 73 of the NPPF states that large scale development should be supported by the necessary infrastructure and facilities to include a genuine choice of transport modes. Given the sustainable transport interventions needed to ensure climate change actions are met, delivering a new settlement the equivalent size of a new town in this location cannot be the preference. Furthermore, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another giving rise to concerns around delivery rates as well as significant pressure on existing road infrastructure. Rail based growth parishes The development strategy options include rail based growth at land within the parishes of Kempston Hardwick, Stewartby and Wixams ranging between 3,915 - 7,500 dwellings and 80ha of employment. Currently, the Stewartby and Kempston Hardwick large site promotions include mainly employment development with current applications submitted by Cloud Wing for a 780,379sqm business park and 1,000 new homes at Stewartby. The draft Local Plan development options run contrary to these current land promotions and lack accompanying evidence of deliverability, viability and capacity testing. Delivery of a new railway station and the closure of the exiting Kempston Hardwick and Stewartby stations also affects the masterplanning of the area and could give rise to potentially long lead in times in combination with the extensive remediation works required and off-site highway junction improvements. The principle of development in this location is understood but we would question how much reliance can be placed on the medium-high growth level scenarios delivering within the proposed plan period and how accurately this level of growth can be set out in the Council’s housing trajectory in the absence of evidence concerning lead-in times, infrastructure requirements, remediation works and costs, financial viability testing, masterplaning/capacity testing etc. We would suggest that growth at Stewartby is only capable of delivering post 2035 given the considerable challenges faced with making the site acceptable for development. The principle of further growth at Wixams is also understood although this should be re-categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario and included in the rail based growth parishes to acknowledge the strategic presence of Wixams and focus sustainable growth, investment and infrastructure towards it in a holistic manner rather than invite piecemeal delivery on the edges of Wilstead. Southern parishes Development in the Borough’s southern parishes that surround the A421 has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. This follows paragraphs 68 and 79 of the NPPF and the requirement to promote sustainable development in rural areas where it will enhance or maintain the vitality of rural communities and, more generally, the need to identify a sufficient supply and mix of housing sites. Options 2a, 2b and 2d include potential for 750-2000 dwellings to be delivered within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton. Option 2a includes the higher range (up to 2000) and if distributed equally between these villages would amount to approximately 333 homes each. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability, providing more day-to-day services and facilities and higher levels of self-containment. 6 For this reason, these settlements have potential to accommodate higher levels of growth especially where sites are located within reasonable travel distances of Bedford’s Town Centre and major employment areas, and benefit from existing sustainable travel infrastructure such as cycle/walking routes and bus services. 14. Certain land promotions within the southern parishes present obvious coalescence issues with surrounding villages, which is particularly notable between Gibraltar Corner (see site 636 – land at Gibraltar Corner) and Cotton End (see site 1332 – land at Manor Farm). The Council will need to consider such issues within its site assessments but also be alive to the opportunities presented by other land promotions that present appropriate land for villages to grow especially where this can be comprehensively masterplanned with sufficient land to deliver open space, biodiversity net gain (including Forest of Marston Vale targets), space for recreation, new/enhanced green connections and additional facilities and services. 15. Shortstown is already defined in the current Local Plan 2030 as a ‘Key Service Centre’ comprising a good range of services and facilities and being well connected to the town centre by public transport and cycling. It is approximately a 20 minute cycle and 20 minute bus ride from Bedford Town Centre and railway station and also benefits from close access to the A421 for wider transport connections. As a Key Service Centre, it has the capacity to support further sustainable development. The land promotion at College Farm (Site 1513) includes provision of a new primary school to support housing growth and increase local education capacity in the area. College Farm is also strategically well placed to create important walking and cycling connections to Shocott Spring to the south, Bumpy Lane to the north and the John Bunyan Trail to the west. This would have significant health and wellbeing benefits for the local and wider area. 16. Development at Cardington Sheds (Site 1338) would provide another sustainable location for housing growth in Shortstown, linking into recent development to the east of the settlement. It also creates a unique opportunity to deliver a ‘Heritage Park’ that celebrates the history of RAF Cardington. This would feature public art, educational features, high quality landscaping and play/informal open areas. Further health and wellbeing benefits would be delivered by the introduction of new recreation routes through the site, linking to the A600 (with onward connection to a new primary school at College Farm) and surrounding countryside. 17. Both land promotions would complement rather than compete with the larger potential growth sites, providing Bedford Borough Council with a mix of housing sites and a continuous housing supply throughout the plan period. They can deliver early on in the plan period and deliver growth in a sustainable way that benefits existing and new residents via the provision of new education, recreation and sports facilities, new footpath and cycle connections and a net gain in biodiversity and woodland/tree planting. Eastern parishes 18. 19. Option 2d includes potential growth for 750 dwellings and up to 28ha of employment land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston. The scale and nature of development at either Little Barford or Wyboston will depend on which is chosen as a strategic location for large scale growth. As such, the remaining villages will need to be assessed in terms of their capacity for further growth, their levels of sustainability and local character. The offer of land promotions in this area ranges significantly and does not necessarily present obvious sustainable choices for growth such as Site 878 (Land west of Great Barford south of the A421). At 2,350 houses, this site will be disproportionately large in relation to the size of Great Barford with significant transport implications and the potential to cause very high harm to both heritage and local character. Site 1355 (Trinity College Farm - North and West Off Roxton Road) for 200 dwellings is, for instance, very poorly related to any existing settlement and unlikely to foster sustainable travel movements and integration with the existing community. The level of growth in the eastern parishes will therefore be partly tempered by the offer of land promotions put forward and their levels of sustainability. Their distance further away from key urban areas like Bedford and St Neots compared to the southern parishes means that in allocation terms, overall growth numbers should be lower. 7 Summary 20. We are in broad agreement with the overarching strategy that directs growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Delivering 3,000 homes towards the urban area and adjoining urban area could be overly ambitious for the reasons we have set out above and requires further analysis of the town’s context and capacity to accommodate density/storey heights before such an option is considered sustainable and achievable. 21. In terms of new settlements, Little Barford scores more highly than Wyboston as a sustainable location as it will benefit from the new East West Rail station and a genuine choice of travel modes. However, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another and concerns around delivery rates and infrastructure capacity, and therefore Option 2c is less favourable and more risky from a strategic point of view. 22. Rail based growth is set at high levels within Options 2a, 2b and 2d with up to 5,500 or 7,500 homes being targeted at Kempton Hardiwck, Stewartby and Wixams. The principle of development at Stewartby and Kempston Hardwick is understood but too much reliance appears to be placed on high growth scenarios in these locations with the likelihood that both deliver too late on in the plan period. Further evidence will be required to demonstrate deliverability and viability in this location particularly given the extent of land remediation required and the likely S106 contributions sought in relation to highway mitigation, education and community infrastructure. 23. The principle of further growth at Wixams is understood as well but would be better categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario. 24. Growth within the eastern parishes is presented in Option 2d but we would suggest growth is better directed towards the southern parishes (as in Options 2a) in order to meet sustainability objectives. Development in the Borough’s southern parishes has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability and, for this reason, these settlements have potential to accommodate higher levels of growth. 25. Not all land promotions within the southern parishes present sustainable choices and further assessment will be required to rule out sites that lead to coalescence between villages or relate poorly to existing settlements in terms of size or location. At the same time, the assessments will need to take into account land promotions that provide opportunities to expand existing settlements, giving sufficient weighting to those sites that can deliver early on in the plan period and align with the draft Local Plan objectives to be greener, more sustainable and create strong, safe and resilient local communities.