Object

Representation ID: 6662

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 3: Growth and spatial strategy option Subsections 3.1 to 3.10
Level of housing growth required: The borough council have proposed a housing requirement of 1275 /yr. Oakley parish have determined that this figure is higher than it should be. According to estimates prepared by Lichfield Planning Consultancy (see Oakley parish submission), the borough council’s figures are higher than those for surrounding Local Authorities and one of the highest outside the London Metropolitan Area. The borough council should produce a further calculation based on up-to-date ONS data to create realistic figures.
SPC are surprised that given the significant disparity between Bedford Borough’s housing ‘target’, when compared to other local or near neighbour authorities, or any authority outside of London for that matter, that the Borough has not already challenged the use of the government methodology by proposing the use of a more accurate estimation model utilising the latest ONS data.
The current housing ‘target’ also seems to include a very significant increase in net migration to the Borough, SPC would question the sustainability of this approach given the very likely negative impact this new demand would have on housing availability and affordability for existing residents. Our expectation would be that a Local Plan should first and foremost be a tool for ensuring future development meets the needs of the local communities within the plan area, and that desirability of migration to the Borough is a reflection on meeting that objective rather than, as it seems right now, inward migration being one of the primary drivers of the local plan.
Growth and strategy Options: SPC has concerns with the significant uplift in the housing target that is being proposed with the Local Plan 2040. Although cognizant that the government standard method of assessment is being proposed, this method has been widely criticised as being potentially flawed given its reliance on stale and out of date data.
It is also not clear how an uplift of 32% from the current LP housing target can be considered environmentally sustainable when the majority of the land to be allocated in the Local Plan is not brownfield but greenfield, with much of it Grade 2 arable land. Given the growing awareness and importance of producing food locally, this approach would appear to be taking Bedford Borough backwards not forwards in terms of Environmental Net Gain.
If BBC is unable or unwilling to challenge the housing targets identified in the proposed local plan then SPC would be generally supportive of the approach detailed under point 3.5, Growth and spatial strategy options.
Stevington Parish Council have reviewed the four options presented in the Development Strategy Topic Paper and the draft Local Plan 2040. SPC welcome the approach of focusing growth of housing in the Southern parishes of the county. However, councilors have concerns over the proposed level of housing developments generally and feel that the number of dwellings should be minimised as far as possible. Of the four options proposed, although there is little difference between them in terms of their direct impact on Stevington Parish, option 2c is marginally preferred as this appears to have the least overall number of planned dwellings. Whichever option is finally chosen, we ask the Borough Council to ensure that the selected minimises carbon emissions and biodiversity loss.
Although the plan indicates there is to be very little additional housing in Stevington parish, SPC are concerned about the increase in traffic flow through the village that will occur from planned growth of 500 homes in each of Bromham, Clapham, Great Barford and Sharnbrook. This needs to be significantly reduced (halved) in each village as the road network will not be able to cope There are particularly concerns regarding levels of pollution from petrol cars, vans and lorries and also increased safety hazards that this growth will bring.
As there is significant uncertainty on how future work and travel patterns are likely to evolve, post COVID-19, as well as the likely impact of the Oxford to Cambridge Arc Spatial Framework to the plan then it would make sense to take a more prudent approach to year on year development delivery targets in the first half of the plan period. This would allow for future validation of the accuracy of the current net migration and housing demand forecasts and allow the remainder of the plan target to be based, in part, on actual real world rather than forecast data.
Given the significant potential impact of EWR on the LP and the future development of Bedford Borough, SPC would question why the Council opted not to include a section for feedback on the route selection as part of the overall LP consultation phase. Most of the new development options have a reliance, at least in part, on the delivery of EWR to provide the supporting infrastructure for connectivity, so would play a major part in the feasibility and delivery of the Local Plan, but opinion on what is a major decision for the Borough community is not being sought? We find this lack of consultation concerning and view this as a missed opportunity by the Borough.