Object

Representation ID: 6506

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Growth and spatial strategy options (Growth strategy options paragraph 3.10)
We are pleased to note that each of the four preferred spatial options identified at paragraph 3.10 of the plan are consistent in their identification of the Bedford/Kempston urban area and its periphery as a principal location for new allocations. What is questioned, however, is why such a low number of dwellings are to be directed towards the town and the urban fringe in particular (only 1,500 of a minimum 12,500 new dwellings by way of allocation).
Firstly, on the proposed allocation of 1,500 dwellings in the urban area (that is within the existing built-up area boundary of both Bedford and Kempston) it is entirely unclear where so many deliverable or developable sites will come from. On the basis that the current Local Plan, which was only adopted 18 months ago, comprises an urban-focused approach to growth it would have been expected that in the instance that significant deliverable sites within Bedford were available at the time of its adoption they would have been identified as allocations. In which case this leads to a suggestion that the additional sites sufficient to yield a minimum of 1,500 homes have either been identified by the Council since this time or are hopefully to be identified through the call for sites process. We consider the presence of such a stock of additional reliable brownfield urban sites to be extremely doubtful, especially bearing in mind both the historic and ongoing issues faced by some of the existing town centre allocations at Ford End Road and Land South of the River in respect of land assembly, availability, and viability.
Then, in all scenarios the allocation of only 3,000 dwellings at Bedford and Kempston then leaves a minimum of 9,500 dwellings to be delivered elsewhere in a Borough with few other large and sustainable settlements. Whilst it is appreciated that each of the four strategies seek to direct these towards specific growth points or corridors it represents a significant move away from the urban focused approach taken by the Local Plan 2030. Whilst we feel that a balance must be struck – the direction of quite so many homes to Bedford’s urban sites currently is one of the main weaknesses of the Local Plan 2030 strategy – it is our clear view that there are ample opportunities on the fringe of the town that would enable growth to be delivered at the most sustainable locations in the Borough. None of the edge of the town is characterised by any restrictive landscape designations and indeed much of the local landscape character is unremarkable. In which case the delivery of unconstrained greenfield sites adjacent to the town and easily accessible to the strategic road and rail networks must present a strategic priority to the Council.
By way of an example our client’s land at Salph End represents one such strategic opportunity at a site described by our previous Call for Sites submissions as one which is entirely suitable for a new urban edge community on land which is devoid of any technical or legal constraints. The merits of the site were neatly but emphatically summarised by an Inspector presiding over a recent appeal at the land1 in respect of a proposed development for 400 dwellings and a new school site (the level and mix of development once again proposed in respect of the Call for Sites) who confirmed:
“Nevertheless, the appeal site is not without its intrinsic merits in terms of the spatial strategy; it is adjacent to the defined Settlement Policy Area of Salph End; within walking distance of a local grocery store and post office, a public transport route and some other local facilities; and it would provide that settlement with education provision and open space facilities. Most of the site was included as an allocation in a consultation version of the Local Plan before its adoption. The eventual decision to exclude the site from the plan was judged by the Inspectors who examined the plan to be a reasonable one, although they note that the matter was clearly finely balanced. It is again included in options being considered in the current review of the Local Plan and so, it is not unreasonable for the appellant’s advocate to imply, as he does in his closing remarks, that it is a matter of when, not if, the site is to be developed.”
Sites such as that of our client must be a focus and a priority in meeting what is a significant additional housing need that must be met by way of further allocations as they were upon the publication of the Council’s ‘Consultation Paper’ in 2017 (the document referred to in the Inspector’s quote above). This was prior to the more intense focus of the Council on complicated urban sites and a subsequent shortening of the plan period from 2035 to 2030 and the resultant reduction of the plan’s housing target. As such we urge the Council to significantly increase the number of homes to be directed towards the edge of Bedford within each of the four growth scenarios described in Section 3 of the draft plan with the identification of our client’s land as one of its key strategic allocations the obvious starting point.