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Representation ID: 7413

Received: 03/09/2021

Respondent: Axiom Great Barford Limited

Agent: Axiom Great Barford Limited

This Issues and Options representation is made on behalf of Axiom Great Barford Limited (‘Axiom’) who have land interests in Great Barford. The Axiom site forms part of the Policy H1 housing allocation in the emerging Great Barford Neighbourhood Plan, which is currently at examination. The site is also put forward for consideration through the call for sites process in 2020.
Axiom are promoting land off Bedford Road, Great Barford on behalf of two landowners and their site can accommodate at least 350 new dwellings, community facilities, open space and landscaping.
The emerging Neighbourhood Plan Policy H1 allocation encompasses a wider area of land, to meet the 500 home requirement for Great Barford identified in the adopted Local Plan 2030. The reminder of the land within the emerging allocation is controlled by Countryside Properties, who will be making separate representations to this consultation.
Whilst Axiom continue to work closely with the Great Barford Barford Parish Council, Bedford Borough Council Assets and Countryside Properties to secure allocation of the site through the Neighbourhood Plan, Axiom continue to promote the merits of Great Barford in general as a location for growth, and the suitability of their land for development through the preparation of the Local Plan 2040.
It is worth noting that the Draft Strategy Options were prepared ahead of the publication of the revised NPPF, which introduced the requirement at Paragraph 22 for Local Plans which include new settlements or significant extensions to towns/villages, to be set within a vision which looks at least 30 years ahead. This policy clearly applies to the Bedford Borough Local Plan 2040 and it is considered likely that the Council will need to undertake additional work to establish a longer-term vision within which the policies for the Local Plan 2040 can be set.
Chapter 3 of the Strategy Options consultation document sets out that the standard method figure for Bedford Borough is 1,275 dwellings per year or 25,500 dwellings in total and that after existing commitments are taken into account, the Local Plan 2040 needs to allocate land to provide a further 12,500 new dwellings over the plan period.
It is unclear whether the existing commitments include allocations in the emerging Neighbourhood Plans which will satisfy the requirements of the adopted Local Plan 2030 Policy 4S. If these are included as commitments, it is important to note that the minimum level of growth that will need to be delivered via the Local Plan 2040 may need to increase should any of the emerging Neighbourhood Plans fail at examination or not pass referendum.
Should any Neighbourhood Plan not progress as expected it will be important that the Local Plan 2040 firstly allocates the growth directed to rural settlements such as Great Barford, before any consideration is given to the wider development strategy, which could include an additional level of growth at the Key Service Centres. It is also important to note that the 25,500-home requirement is the minimum number of homes that need to be delivered over the plan period. To ensure this figure is delivered, there will need to be an additional allowance made in the allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays.
Normal practice would suggest a 10% additional allowance should be made which would equate to a further 2,550 homes. Whilst reference is made to ‘choice and flexibility’ at paragraph 1.50, this is only in response to the potential additional growth that could come forward via Neighbourhood Plans. This is an unknown and it is therefore important that the level of growth planned for in the Local Plan 2040 is in excess of the required 25,500 to ensure the minimum number of homes are delivered.
We suggest this means planning for 28,050 homes (25,500 +10%) rather than the 25,500 currently being considered in each of the options. Subject to the strategy being adopted, this approach would also help ensure that the requirements of NPPF paragraph 68, which require a deliverable supply of land for years 1-5 of the plan, plus an appropriate buffer.
The Council will also need to consider the level of growth to be planned for in the Oxford to Cambridge Arc, where Bedford Borough sits in a key central area. If the economic benefits of the Arc are to be realised, it is likely that additional housing will be required to support a growing working age population. If the economy grows without the required housing, it may have knock-on impacts for existing residents in terms of increased house prices and worsening affordability.
Therefore, in addition to the need to plan for flexibility and contingency in setting the housing requirement, we would encourage giving full consideration to the impacts of longer-term economic growth to understand if there may be additional housing requirements.