Support

Representation ID: 8852

Received: 29/09/2021

Respondent: Mr Alex Simpson

Agent: Bidwells

We are generally supportive of the rationale of future growth within the Draft Strategy Options, with this future growth being focused around the transport corridors, particularly along the A421 which is a key transport route through the Borough connecting the key centres of Milton Keynes and Cambridge whilst being well related to Bedford as the area’s main service centre.
4.2 It is noted from the Development Strategy Topic Paper that the A421 corridor, urban area and rail-based options set out at the Issues and Options stage were the most popular options for commenters.
4.3 The Sustainability Appraisal process additionally shows that the A421 corridor and the rail-based options have performed favourably against the new settlement options, with only urban growth and urban edge growth, unsurprisingly, performing better in sustainability terms.
4.4 In this regard, Option 2c, which intends to focus development on the urban area plus two new settlements in the east of the Borough, is not agreed that this can be considered a realistic option. Whilst acknowledging that there may be scope for the inclusion of one new settlement in the emerging Local Plan, particularly given the NPPF (2021) requirement for the strategy to be set within a 30-year, long term vision, to include two new settlements at the expense of other options would be unsustainable and a highly risky strategy to deliver much needed homes in the short to medium term.
4.5 It is agreed that growth in and around the urban area is clearly a sustainable option for development. However, we have questions surrounding whether this area is capable of delivering 3,000 dwellings, plus the 51 hectares of employment land, over the plan period given the physical constraints in the area. Whilst there may be small-scale opportunities for growth within the town, it will be a challenge to find land capable of delivering 1,500 dwellings over the plan period. In a similar vein, finding 1,500 dwellings on the urban edge of Bedford, which is effectively limited to the north/north-east given the constraints to the southeast and the overlap with other proposed options, to the south, will also be a challenge. Development would also realistically be limited due to the landscape, topography and flood plain constraints that exist surrounding the urban area alongside the proximity to smaller settlements.
4.6 The constraints with new settlements and the urban area, increase the importance of looking closely at the options and opportunities for development within the A421 rail corridors, with this reinforcing the position that these should play an integral part in any future development strategy.
4.7 It is encouraging to see that growth in the A421 corridor is included within three of the four options that are presented in the paper, with our commentary on the fourth, two settlement option, provided above and below.
4.8 There are still, however, outstanding concerns about the detail behind Options 2a, 2b and 2d (the three options which contain growth in the A421 corridor); this primarily focuses on the apportionment of growth directed to the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period and the deliverability of 5,500-7,000 homes in the rail corridor. These are discussed in more detail below.
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Rail Related Growth
4.9 Whilst in principle, growth is supported in the rail corridor to the south of Bedford, there are a number of key matters in relation to the approach taken by the Council that requires further consideration.
4.10 Firstly, whilst in theory focusing 50% of the required additional growth close to the railway stations is laudable, it is unclear how this scale of growth would be delivered in reality. An extract of the Call for Sites map has been overlaid with the rail-related growth area that has been identified in Options 2a – 2d, with this included in Figure 1 below. As outlined in Figure 1, there are a limited number of sites that have been put forward to the Council as being available for development in this area. The large majority of the sites that have been identified are for potential employment uses.
4.11 Whilst additional opportunities may be available on the periphery of this area that could contribute to delivery (some of which may be classed as being in the A421 corridor), we would question whether there is suitable land to deliver the suggested level of growth.
4.12 Secondly, the justification for the extent of the catchment area for these rail station locations has not been properly elaborated. Additional opportunities may be available on the periphery of this area, in settlements such as Cotton End, which could contribute to delivery (which is currently classed as being in the A421 corridor). Cotton End is within easy commuting distance of Wixams including via sustainable modes of transport such as cycling.
4.13 Without expanding the catchment area for the rail-related growth, combined with concerns about the ability to deliver 3,000 in and around the urban area, further emphasis should be placed on the role of land in the A421 corridor within the development strategy
Figure
Figure 11: Call for Sites Map Extract: Call for Sites Map Extract
Bedford Borough Local Plan 2040 Draft Strategy Options
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Delivery in New Settlements
4.14 Whilst it is recognised there is a role for a new settlement as part of the development strategy, we would be wary of assuming delivery from any such allocation in the short to medium term. There will be a significant lead-in time with any new settlement with any completions not realised until well into the plan period.
4.15 In the context of the requirement to have a long term, 30-year vision to satisfy Paragraph 22 of the NPPF (2021), it is logical to plan for a new settlement through this local plan – but that should not be to the detriment of meeting the housing requirements in the short to medium term, particularly when there appear to be sufficient suitable and deliverable sites available to meet the need in a timely manner. This issue would then be further exacerbated in a strategy that relies on the creation of two new settlements.
4.16 We, therefore, suggest that if a new settlement is to be included in the strategy, the number of homes to be delivered in the plan period should be realistic. At the current time, the options appear to assume the completion of either settlement option within the plan period. We do not believe that this is a realistic assumption given the stage the plan is at and the lead-in time with matters including land assembly, planning and infrastructure delivery.
4.17 The Council will need to ensure that the residual requirement that has been identified above in the earlier plan period is picked up through the development strategy. Given the constraints with other elements of the strategy, emphasis should be placed on the importance of the A421 corridor to deliver growth and the wider catchment area around key rail locations and the approach taken in Option 2c reconsidered.
The Apportionment to the Southern Parishes
4.18 Aside from Option 2c (the two-settlement option), which has been addressed above, each of the options include an element of growth in the A421 transport corridor. This level of growth varies from 1,500 dwellings in Options 2b and 2d to 2,000 dwellings in Option 2a. It is considered that these options significantly downplay the potential of the area to deliver additional housing numbers, particularly given the points raised above about concerns with other spatial options.
4.19 As can be identified on the Call for Sites Map (Figure 2), there are a number of sustainable settlements in this corridor with the ability to expand, with sites being put forward for consideration within these. These settlements include Cotton End. Irrespective of the existing clarification of settlements in this area, they are highly sustainable, due to the strategic road network, and therefore, subject to appropriate investment in infrastructure, have the ability to deliver levels of housing beyond that currently proposed.
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4.20 It is unclear why the proposed options limit potential growth to 2,000 dwellings, given the number of settlements in the area and the presence of opportunities such as that offered at Cotton End. The capacity comes across as an arbitrary number that is not underpinned by the necessary evidence or proper consideration of land availability – both in the corridor and elsewhere.
4.21 It is suggested that a finer grain assessment of site availability and suitability needs to be undertaken across the whole A421 corridor to inform the development strategy. In our view, if this is undertaken, it will identify a greater level of potential for growth in the area and highlight the potential offered by sites such as Mr Simpson’s.
4.22 Additionally, we suggest that in developing the strategy further, the whole of the A421 corridor should be looked at as one, with no distinction between the eastern and southern parishes. This will allow a proper review of all settlements and sites on a comparable basis and avoid suitable sites being missed out of the development strategy based on an arbitrary decision to split the parishes along the corridor.
Summary
There is a concern that the assumed delivery of the settlement options may be overstated.
− The assumed capacity of the urban area/urban fringe and the rail focused options to deliver the stated level of development should be reviewed.
− The two-settlement option is not a robust or sustainable approach to meeting housing need.
● A focus for growth within the A421 corridor is supported by Mr Simpson and it is asserted that there is a need to increase the level of development focused along the A421 corridor due to the constraints which affect other options. It is noted that the Council have created an unjustified split in the parishes along the A421 corridor and that a more appropriate approach would be to look at the area as a whole and identify the most appropriate available sites based on the opportunities presented.
● There is a need to increase the level of development focused along the A421 corridor, given the constraints with other options.