Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7443

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

Representation Summary:

In considering the proposed spatial development options, the client has discounted
those which seek to deliver a new settlement as the time horizon of the plan is not in
alignment with the provisions of Para 22 of the NPPF. Furthermore, the Council were
right to discount preliminary options 1a and 1b due to the constraints such approaches
would face in and around the urban area of Bedford.
It is yet further clear that the approaches advocated within Options 2b-d, 3a-c and 5-
7 would not achieve the ambitious level of growth which is required in the Borough by
2040.
The client is largely supportive of the approach set out within Option 2a. However, it
is considered that this strategy could be revised to provide a more realistic and
positive approach to achieving the growth, which is required, particularly in terms of
residential development.
In assessment of Option 2a it is considered that the Rail Based Growth Parishes
should be revisited with a greater spatial analysis of those settlements which lie in
proximity to both existing and proposed rail terminals.
The option quite rightly highlights Kempston Hardwick, Stewartby and Wixams as
settlements which should be developed based on their proximity to existing and
proposed rail stations. However, in assessment, it appears that the sustainability
credentials of Wilstead have been overlooked along with its proximity to Kempston
Hardwick Train Station. Similar arguments could be made for Houghton Conquest and
Marston Moretaine which are comparable settlements with good public transport links
including proximity to the station.
Therefore, it is urged that the list of Rail Based Growth Parishes be re-assessed and
lengthened to allow for the inclusion of further settlement. Such an approach would
reduce reliance, and the resultant pressures, for residential housing growth at
Wixams, Kempston Hardwick and Stewartby.
Whilst it is acknowledged that a new station at ‘Stewartby Hardwick’ could be a
catalyst for growth, this realistically will not be achieved until later within the plan
period and development directly related to its delivery will be required for funding
purposes. To this end, an increased level of development at Wilstead could assist in
achieving the delivery of such infrastructure.
Wilstead itself is acknowledged within the settlement hierarchy as a sustainable Key
Service Centre and it is considered that its role could be elevated to account for its
spatial relationship with the Rail Based Growth Parishes. Notwithstanding the above, if Option 2a is carried forward into future iterations of the
LP, it is considered that the proposed levels of growth within the option should be reapportioned
to redistribute growth in a pattern which reduces reliance upon certain
settlements and provides a more positive pattern and subsequent approach to growth.
It is considered that Option 2a should be re-apportioned to acknowledge the
sustainability credential of those settlements in the southern part of the transport
corridor. The following table shows the current pattern of distribution within Option 2a
and the client’s revised approach which reduces reliance upon the urban area which
is already under significant pressure.

(see tables 1 and 2 in attachment)
Please note that the above figures are set against the backdrop of the housing target
contained within the emerging LP, as set out in the NPPG, the local housing need
figure is calculated at the start of the plan-making process, but this number should be
kept under review and when appropriate revised until the document is submitted for
examination. Importantly, and further to the thoughts above, the minimum local
housing need figure for the Borough may change as inputs are variable.