Object

Representation ID: 8578

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

4.1 The previous Issues and Options consultation outlined six potential approaches to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based growth.
4.2 These six options have now been progressed and as set out in the Local Plan and Development Strategy Topic Paper (June 2021); BBC now seek views on four ‘preferred options’ to meet the (proposed) level of growth set out in the Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes and southern parishes;
2. 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;
3. Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, plus two new settlements;
4. 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;
4.4 All four proposed options include development along the A421 transport corridor, and rail-based growth in the south of the Borough. It is of note that the map alongside each image fails to recognise the proposed new East-West rail station that would be located north of Stewartby (potentially alongside Bedford Business Park). This station would further justify the choice to progress a growth option focused on the A421 and rail corridor.
4.5 AWG supports the proposed strategy of growth along the A421 and rail corridor. However, AWG consider that each of the proposed options fail to identify
sufficient land to meet the employment needs of the Borough (as set out in Section 2 of these representations and in the Cloud Wing representations).
4.6 The Development Strategy Topic Paper states (para 3.13) that 123ha is proposed to be allocated to 2040, based on the Employment Land Study. For the reasons
set out in Section 2, that figure is not considered to be sound and needs to be increased. This would, in turn, result in a requirement for the proposed Development Options (and the final selected Option) to identify further areas for employment growth.
4.7 As well as an insufficient quantum of employment land, AWG contend that 3 of the 4 options may result in insufficient delivery within the Plan period. Firstly, Option 2c is not considered a sound approach. As has been evidenced1, the development of large sites (2,000+ dwellings) takes many years. The average time quoted from validation of the first planning application to the first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. Whilst this relates to dwellings, Option 2c proposes up to 20ha of employment as part of a new settlement. It is reasonable to assume that the 20ha would come forward as part of a holistic approach to a new settlement. The employment could, therefore, be constrained by the delivery of the new housing and associated infrastructure demands.
4.8 The same report also finds that the average annual build-out rate for a scheme of 2000+ dwellings is 160dpa.
4.9 Working on the basis of a plan led system, any application for a new settlement would, in theory, not be validated until after the Local Plan is adopted, thus 2024 at the earliest. This means that any new settlement is unlikely to begin delivering homes until 2032 at the earliest, and potentially employment land until a similar time.
4.10 The approach set out in Option 2c may not meet the Borough’s employment needs in the short term and could result in employment delivery beyond the plan period and should be discounted as a result.
4.11 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d, with the same quantum of employment proposed for one settlement (as opposed to two in the case of Option 2c).
4.12 The option which has the greatest likelihood of delivering growth within the Plan period, as required by national policy, is Option 2a. This option would focus growth in the south along the major transport corridors of the A421, A6 and railway line, and in turn would focus development in the most sustainable locations.
4.13 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the best performing option. It also finds Option 2c to be the worst performing of these 4 options, and that is without considering the issue of delivery as set out above.
4.14 Whilst Option 2a is the best of the options put forward, for the reasons set out in Section 2 of these representations, the proposed level of growth in Option 2a is not sufficient to meet the identified needs for the Borough.
4.15 A new Development Option is therefore required which meets the identified growth needs and, in particular, the opportunity presented by Bedford Business Park to maximise growth in the A421 rail-based growth corridor. This Option would then be the favoured one to progress in the Local Plan, being for some 222ha of employment growth in this location.
4.16 The next section of these representations puts forward a case as to why the land at Broadmead, and in turn the Bedford Business Park, would deliver growth in accordance with the Development Strategy outlined above (in fact according with 4 of the 4 development options).