Object

Representation ID: 7414

Received: 03/09/2021

Respondent: Axiom Great Barford Limited

Agent: Axiom Great Barford Limited

Axiom are generally supportive of the rationale of future growth being focused around transport corridors, in particular along the A421 which is the key route through the Borough, connecting Milton Keynes and Cambridge, and is well related to Bedford as the areas main service centre.
We note from the Development Strategy Topic Paper that the A421 corridor, urban area and rail-based options set out at the Issues and Options stage were the most popular options for those who commented.
We also note that the SA process showed that the A421 corridor and rail based growth options performed favorably against the new settlement options with only urban growth and urban edge growth performing better in sustainability terms.
In this regard, we do not consider Option 2c, which would focus development on the urban area plus two new settlements in the east of the Borough to be a realistic option. Whilst there may be scope for the inclusion of one new settlement in the Local Plan 2040, particularly given the new NPPF paragraph 22 requirement for the strategy to be set within a longer-term vision, to include two new settlements at the expense of other options would be unsustainable and a highly risky strategy to deliver much needed homes in the short to medium term.
Whilst growth in and around the urban area is clearly a sustainable option, particularly given Bedford is the main economic centre in the area, we have doubts whether the 3,000 homes (plus 51ha of employment land) is capable of being delivered in these areas over the plan period.
There may be small scale opportunities in the town, but finding land for 1,500 homes will be a challenge. Equally, finding suitable sites for 1,500 homes on the edge of Bedford – which is effectively limited to the north/north east of the town. Constraints to the south east which overlap with other options to the south – will also be a challenge, particularly given the character of the landscape and topography in this area.
Both of these considerations increase the importance of looking closely at all the options for the A421 corridor and reinforce the position that the A421 and rail corridors should play an integral part of any future development strategy.
It is encouraging to see that growth in the A421 corridor is included within three of the four options presented in the paper – with our thoughts of the fourth, two settlement option, noted above.
However, we have some concerns about the make-up of the three options which include A421 growth primarily being focused on the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period, and the ability to deliver the 5,500-7,000 homes directed to the rail corridor – also to the south of the town.

Rail related growth
Whilst focusing 50% of the required additional growth close to the rail stations to the south of the town is a laudable proposition, it is unclear how this would be delivered. Below is an extract of the call for sites map with the rail related growth area from the options consultation document overlaid in red. It can be seen that there are a limited number of sites put forward in the rail related growth area – with those large sites that have been put forward identified as having employment potential by their promoters, given the surrounding context.
(Refer to map in attachment)

Whilst additional opportunities may be available on the periphery of this area which could contribute to delivery (some of which may be classed as being in the A421 corridor), we would question whether there is suitable land available to deliver up to 7,500 homes in this area.
Along with concerns about the ability to deliver 3,000 homes in and around the urban area, this places further emphasis on the role of land in the A421 corridor within the development strategy

Whilst there is a role for a new settlement as part of the development strategy, we question the ability of any such allocation to deliver in the short to medium term. There will be a significant lead in time with any new settlement and first completions would not be realised until well into the plan period.
In the context of the requirement to have a long term, 30 year vision to satisfy Paragraph 22 of the NPPF, it is logical to plan for a new settlement through the Local Plan 2040. However, this shouldn’t be to the detriment of meeting housing requirements in the short to medium term, particularly when there appears to be sufficient suitable and deliverable sites available to meet the need in a timely manner.
We therefore suggest that if a new settlement is to be included in the strategy, the number of homes to be delivered in the plan period is realistic. At the current time, the options appear to assume the completion of either settlement option in the plan period. We don’t believe this to be a realistic assumption given the current stage of the plan and the lead in time associated with matters including land assembly, planning and infrastructure delivery.
Once delivery rates are looked at in more detail, we believe there will be a residual requirement that will need to be covered in the development strategy. Given the constraints with other elements of the strategy, we again put emphasis on the importance of the A421 corridor to deliver growth in the Local Plan 2040.
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. In our view, each of the options significantly downplay the potential of the area to deliver additional housing numbers.
As can be seen from the call for sites map below, there are a number key service centres in this corridor with the ability to expand and where sites have been put forward for consideration. This includes Wootton, Wixams, Wilstead, Shortstown and Great Barford, where Axiom are promoting land. In the adopted Local Plan, Key Service Centres were seen as suitable for 500 dwellings, and indeed higher levels of growth were assessed early in the process as being appropriate in some locations.
(figure 2 in attachment)
Given there are other settlements in the corridor that could also take growth, such as Willington and Cotton End, it is unclear why the options limit potential growth to 2,000 dwellings. This is particularly the case when the issues raised above with the other options are taken into account.
It is suggested that a finer grain assessment of site availability and suitability needs to be undertaken to inform the development strategy. In our view, if this is undertaken, it will identify a greater level of potential for growth in the area.
Within the three options, we are unclear why areas to the east (land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston) are only included in one of the options, despite being in the same transport corridor as Wootton, Wilstead, Cotton End and Shortstown, which are included in all three. A review of the evidence does not make this distinction clear.
We suggest that in developing the strategy further, the whole of the A421 corridor should be looked at as one, with no 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 of the development strategy based on an arbitrary decision to split the parishes along the corridor.