Object

Representation ID: 8075

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

1. Notwithstanding our comments on the overall housing and employment numbers proposed in the plan and the need to add an uplift associated with the Oxford to Cambridge Arc strategy, it is considered that the preferred spatial strategy (Options 2a, b, c, and d) have significant merit subject to the following qualifications.

2. Firstly, the strategy proposes development of 1,500 dwellings within the urban area.

3. Clearly there is merit in re-using urban sites and locating new homes close to key infrastructure, shops and services. However, concern is raised as to the deliverability of the levels of growth proposed.

4. The evidence base so far provided does not clearly demonstrate where the 1,500 homes would be accommodated within the urban area within the proposed plan period.

5. Urban sites are often constrained by existing uses, including commercial operations, car parks, supermarkets, government buildings etc. and / or have complicated ownerships and sitting tenants such that delivery is slow and uncertain.

6. As the Council will be aware a number of urban sites were previously identified as opportunity sites or ‘Areas of Change’ in the Town Centre Area Action Plan and so highlighted for potential development back in 2008. The majority of these have still not come forward some 13 years later.

7. There is also concern regarding the viability of urban sites to come due to higher existing use values but more specifically to come forward whilst delivering a full policy compliant level of affordable housing.

8. Subject to the level of certainty and viability assessment that the Council can place on the Urban Area sites it is submitted that the figure should be reduced to approximately 1,000 rather than 1,500 with the balance (500) being added to the ‘Adjoining the Urban Area’ category where sites are less constrained and very clearly deliverable.

9. Turning to the proposed ‘Adjoining the Urban Area’ category, it is assumed that any sites within Parishes adjoining the urban edge would qualify for consideration.

10. That is, sites for example in Renhold could be allocated as part of the 1,500 figures, it is not simply sites within the southern Parish’s which adjoin the urban area, that is a separate category. If that is a correct interpretation then this approach is supported.

11. All of the Option 2 spatial strategies include reference to the “A421 transport corridor with rail based growth parishes and southern parishes”.

12. The reference to the A421 transport corridor suggests that development close to the A421 would be favoured. This approach obviously has great merit as the A421 provides excellent linkages to the west and east and is also central to the Oxford to Cambridge arc.

13. However, the Transport Corridor options included in the list beneath the title seem to then reference only parishes south of the A421. This appears to ignore for example Renhold and its sustainable location close to a major junction onto the A421 (unless Renhold is considered to fall within the ‘Adjoining the Urban Area’ category as highlighted above).

14. Notwithstanding this it is considered that the corridor strategy should properly consider sites well related to the A421 but not necessarily only the southern parishes.

15. Of all of the Spatial Options the sustainability appraisal considers Option 2a the most sustainable.

16. This excludes new settlements. Whilst new settlements can be important in delivering new infrastructure, they are also prone to delay and uncertainty over delivery rates.

17. It was the proposal for the Colworth new settlement falling away which ultimately resulted in an unsatisfactory local plan to 2030 and a need for early review. Concern would again be raised as to the realistic deliverability of a new settlement option.

Conclusion
18. The Howbury Hall Estate broadly agrees with the Council’s assessment of the differing Spatial Development Strategy Options

19. Notwithstanding this general support, concern is raised in respect of what could be an over-reliance upon uncertain urban sites.

20. Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it whilst exhibiting far fewer viability / deliverability issues and as outline we submit should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

21. Our clients land on the east side of Bedford at Howbury Hall Estate is available and deliverable as set out in the Call for Sites submissions (Site 765) and in further representations now made in respect of the Call for Sites Assessment Proformas.