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Representation ID: 8400

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

For the new local plan to meet the tests of soundness at examination it will be extremely
important for the growth strategy to be both deliverable and flexible without an
overreliance on strategic scale allocations such as new settlements. It is worth noting that
the St Albans Local Plan was withdrawn in November 2020 following a number of serious
concerns raised by the Inspectors which included an overreliance on a small number of
large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller
scale subareas. The Inspectors noted that a range of sites, including smaller and medium
sites, can provide benefits, in that they can be delivered more quickly without requiring
additional infrastructure, provide choice and flexibility in the housing market , and secure
affordable housing more immediately. They also referred to paragraph 68 (now paragraph
69) of the NPPF which indicates that small and medium-sized sites can make an important
contribution to meeting the housing requirement of an area and are often built out relatively
quickly.

The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local
Plan were similar. In that particular case, the Inspector considered it was highly ambitious
to rely on three new Garden communities (Easton Park, North Uttlesford and West of
Braintree) and not include a wider range of small and medium sized sites as advocated
by paragraph 68 of the NPPF.

Accordingly, it is considered the correct strategy for the emerging Local Plan 2020 – 2040
will be to avoid any short term reliance on strategic scale developments such as the new
settlements at either Wyboston or Little Barford and instead to include a significant and
extensive range of small and medium-size sites.

Paragraph 6.8 of the Strategy Options and Draft Policies consultation document indicates
that the new plan should provide three new business park sites, each of about 30 ha with
the remaining 63 ha of employment land allocated in smaller sites. However, it is noted
that potential employment sites are still being assessed. The employment sites will then
be identified to align with the preferred growth strategy. Again this suggests that a more
flexible strategy with a wider choice of potential site allocations should be followed.

The four growth strategy options are listed as follows:
Option 2a: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes.
Option 2b: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes, plus one new settlement.
Option 2c: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and, plus two new settlements.
Option 2d: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes, southern parishes and eastern parishes, plus one new
settlement.

It is noted that all four options will deliver the same amount of dwellings within the urban
area and adjoining the urban area (3,000 dwellings) along with 51 ha employment land.
It is assumed that the employment land provision will predominantly be made up of
existing commitments and therefore the sites for new business parks will need to be found
elsewhere. It is also noted that all four options include up to 80 ha of employment land
within the transport corridor, rail based growth. It is therefore considered that the extent
of employment land should be increased to 90 ha to allow for the identification of three
new business park sites of 30 ha each.

It is also noted that all four options aim to deliver a similar total number of dwellings, 12,500
or 13,085 if a new settlement at Little Barford is included. It is however considered that a
blended option should be the preferred choice, which is more aspirational, with the
potential to deliver a higher number of dwellings along with the maximum amount of
employment land to better reflect the national growth aspirations for the Arc.

In respect of the growth options, clearly the opportunities for accommodating any
significant further growth within the urban areas of Bedford and Kempston are limited,
having already been extended up to their boundaries with the A428. However, the urban
areas remain the focus for employment and retail activity and transport connectivity within
the Borough. It therefore seems logical and sustainable to identify opportunities for future
growth in close proximity to the urban areas, not only in the rail based transport corridor
around the five stations and A421, but also in the southern parishes where sites can be
identified close enough to the urban areas to allow active travel modes and the use of
public transport to be a realistic alternative.

The inclusion of Kempston Rural Parish as one of the transport related southern parishes
is therefore strongly supported and the site, the subject of this representation, is one such
location. The land at Gibraltar Corner is located only 600 m (0.3 miles) walk from
Kempston (at its nearest point). The road from Gibraltar Corner to Kempston has a
pavement on both sides and a dedicated cycle and pedestrian route exists under the A428
which provides very safe, quick and easy access to the Lidl supermarket and Kempston
High Street. The key service centre of Wootton is only 2 km to the south of the site and a
pavement exists along the full length of the road between the site and the cent re. Wootton
provides an alternative range of services and facilities.

Bus stops are located approximately 330 m to the south of the site and regular buses are
provided to Bedford, Wootton, Kempston, Bromham, Cranfield and Milton Keynes (Buses
53, 53A, A2 and C1). This also means there is convenient access to Bedford train station
(Buses 53 and C1) connecting Bedford to London and the wider south-east region. The
site is also located conveniently for connections to the wider highway network with easy
access to the A421 and A428.

Allowing growth in the southern rural parishes not only represents a sustainable location
for housing delivery close to the Borough’s main source of employment within the Bedford
urban area, but will also allow new homes to be provided in a high quality environment,
where future occupiers will also have opportunities to access the countryside for leisure
purposes, improving their health and well-being. Furthermore, development in these well
located parishes is less reliant on upgrades to infrastructure and will be deliverable early on in the plan period. It is therefore considered vital that the selected growth options
include the opportunity for growth in the southern parishes and especially Kempston
Rural.

Of the settlements within the Kempston Rural Parish, Gibraltar Corner benefits from being
located the closest to Kempston and therefore is a logical settlement within the Parish to
allocate for new growth.

In respect of the specific options we comment as follows:
Option 2a: Strongly Support – this option delivers the greatest range of sites
including small and medium-size sites, which will ensure that housing delivery, and
importantly affordable housing delivery can be maintained. However, it is considered
that the employment allocation should be increased to a minimum of 90 ha in the
transport corridor. This is also in line with the findings of the Development Topic Paper,
which concluded that the sustainability appraisal found option 2a to perform best out of
the four options as it concentrates most growth at the rail based locations at Stewartby
/ Kempston Hardwick, which means a high probability that public transport and cycling
will be an attractive alternative to the private car.
Option 2b: Support – this option delivers a range of sites including small and mediumsize
sites, which will help housing delivery, however the inclusion of a new settlement
presents a risk to delivery given the lead time associated with such development. The
housing numbers in the two transport corridors should therefore be increased to those
in option 2a. Accordingly, this is considered to be a more suitable option if the local
plan period is extended. It is also considered that the employment allocation should
be increased to a minimum of 90 ha in the transport corridor.
Option 2c: Strongly Object – this is the least flexible of all options and includes an
overreliance on new settlements. Furthermore, both settlements are in close proximity
to each other, and as such delivery is likely to be further delayed as a result of
competition in the local housing market. If this option were to be pursued it is
considered that the new plan would fail at examination for the reasons set out above,
having regard to the recent St Albans and Uttlesford Local Plan examples.
Option 2d: Neutral would support with appropriate modification – This option
delivers a range of sites including small and medium-size sites which will help housing
delivery, however the inclusion of a new settlement presents a risk to delivery given
the lead time associated with such development. The housing numbers in the two
transport corridors should therefore be increased to those in option 2a. Accordingly,
this is considered to be a more suitable option if the local plan period is extended. It
does however, provide sufficient employment land and a greater choice of locations for
new business parks.

Accordingly, we would recommend that the new local plan pursues a blended option
based on a mix of Options 2a and 2d as set out below, with a focus for approximately
2000 dwellings within the Southern Parishes. This will provide a sufficient range of sites
across the entire plan period without an overreliance on a new settlement being completed
by 2040. Such an option is more likely to be considered in line with Paragraph 22 of the NPPF, which requires plans to contain strategic policies which should look ahead over a
minimum 15 year period from adoption and, where larger scale developments such as
new settlements are proposed, policies are required to set out a vision that looks further
ahead at least 30 years to take into account the likely delivery timescales.
Proposed Option: Development in and around the urban area, plus A421
transport corridor with rail based growth parishes, southern parishes and east
parishes, plus one new settlement.
 Within the urban area (1,500 dwellings).
 Adjoining the urban area (1,500 dwellings), up to 51 ha employment.
 Transport corridor – rail based growth: land within the parishes of Kempston
Hardwick, Stewartby and Wixams (low option) (7,500 dwellings), up to 90 ha
employment.
 Transport corridor – south: land within the parishes of Cotton End, Elstow,
Kempston Rural, Shortstown, Wilstead and Wootton (2000 dwellings).
 Transport corridor – east: land within the parishes of Cardington, Cople, Great
Barford, Little Barford, Roxton, Willington and Wyboston (750 dwellings), up to 30
ha employment.
 New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings),
up to 20 ha employment.
 Total between 15,750 and 16,335 dwellings, up to 191 ha employment.