Object

Representation ID: 8397

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

This section provides our formal consultation response in relation to the Issues and
Options and Growth Options Consultation. It sets out our response in relation to chapters
of the consultation that are of relevance in respect of the land that is being promoted at
Gibraltar Corner.
Level of Growth

Based on the ‘standard method’ the new Local Plan will need to identify sites to deliver
over 25,500 new homes to meet the Council’s housing needs for the period 2020 – 2040,
which equates to a delivery 1,275 dwellings per year . To maintain their housing trajectory,
the Council will need to identify a range of sites, so that this housing delivery rate can be
achieved. Currently, existing commitments total 13,000 dwellings which means the new
local plan will need to allocate land for a minimum (emphasis added) of 12,500 dwellings.

Effective housing delivery is essential for the social, economic and environmental
prosperity of the District and the wider spatial area of the Oxford – Cambridge Arc.
Accordingly, it is critical that the assessment of sites submitted through this Call for Sites
process is undertaken in a positive and aspirational manner (NPPF para 16) , and in
accordance with NPPF paragraph 69, allows the identification of a sufficient level of
deliverable and developable sites with sufficient flexibility to react to market trends and
economic changes.

The use of the standard method is supported, however, it is considered that the minimum
number of dwellings for the period to 2040 should be increased to 15,000 to allow the
inclusion of a 20% buffer to build in greater flexibility and more certainty that housing
delivery will actually be achieved. While currently housing delivery is meeting the adopted
local plan target, this only requires an annual requirement of 970 dwellings per year .
There will be a considerable uplift of 280 dwellings per year to meet the 1,275 dwellings
required for the new plan.

Based on planned population growth to 2040 the employment land requirement is
calculated to be 171 ha. The current supply in the Borough is 48 ha leaving the
requirement for a minimum (emphasis added) 123 ha to be allocated in the plan. As with
housing, it is considered equally important that a buffer of 20% should be applied to ensure
the provision of employment land keeps pace with demand, especially given the economic
importance of the Borough within the heart of the Oxford – Cambridge Arc. Accordingly,
it is therefore considered that the Plan should be seeking to allocate 148 ha of employment
land for the period to 2040.

Plan Period
While this consultation does not specifically seek views on the proposed plan period, it is
considered that a longer plan period would be more appropriate. National planning policy
requires a minimum 15 year plan period from adoption (emphasis added) and whilst the
current programme anticipates adoption in Winter 2023 it is a clearly established fact that
local plan preparation nearly always takes longer than anticipated at the outset.
Assuming the local plan is actually adopted at the beginning of 2024 this will only
establish a plan period of 16 years. Paragraph 22 of the NPPF requires a minimum 15
year period, however, the paragraph was also updated in the July 2021 version to suggest
that plans should have a vision of at least 30 years where new settlements or significant
extensions to existing villages and towns form part of the strategy for the area. Clearly,
as set out in the current four options, such developments are likely to form part of the
strategy and, as such, a longer plan period would seem more appropriate. Furthermore,
the nationally emerging Oxford – Cambridge Spatial Framework also seeks to guide
growth to 2050. Accordingly given the current early stage of plan preparation it is
considered that the Bedford Borough New Local Plan should adopt a plan period to 2050
as well.

Extending the plan period by a further 10 years will require further growth locations to be
identified including sites for a minimum additional 12,750 dwellings and a further 62
hectares of employment land. As referred to above, these would be minimum
requirements and a buffer should also be imposed, although given the extended length of
plan period a reduced buffer of 10% may be considered more reasonable. Adopting such
a strategy will allow the plan to consider a wider range of options and contain more
flexibility around delivery in the future. This will sensibly allow for the inclusion of new
settlements which, whilst slow to deliver, are likely to represent the most sustainable longterm
option for economic growth supported by a sufficient delivery of new homes. Such
flexibility will be essential to allow the District to maintain housing land supply at an
increased rate of 1,275 new homes per year over the plan period.