Object

Representation ID: 8874

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Comment
2.2 The identification of growth in the ‘south’ corridor as part of the Council’s Preferred Options 2a, 2b and 2d is welcomed in principle. This is considered to form an important component of any appropriate strategy option albeit this will require recognition of the benefits of ‘village-related’ growth across the settlement hierarchy.
2.3 The identification of Kempston Rural parish within this corridor is also welcomed. This is considered to reflect the excellent links between the development pattern within the parish (particularly at Green End) and services and facilities within the urban area. Where the Council identifies figures of 2,000 and 1,500 respectively for ‘south’ corridor parishes in Options 2a and 2b without specifying any settlement-specific or site-specific distribution it is assumed that this recognises the capacity to sustainably support growth at Green End.
2.4 Reservations are expressed, however, in terms of the Council’s treatment of Kempston Rural for the purposes of apportioning village-related growth, where the parish is excluded from the relevant total of 4,280 units as a result of not comprising a designated Rural Service Centre. Further reservation is expressed in terms of the distribution of growth in the Council’s Preferred Options where this refers only to dwellings and not the approach required to deliver the housing needs of different groups, including specialist housing for older people.
2.5 The Council’s own evidence base identifies a substantial need for housing for older people, including a net demand for over 1,500 units of Extra Care accommodations (owned and rented) over the Plan period. However, the Council’s Sustainability Framework (Appendix 1 of the draft Sustainability Appraisal findings) indicates that the positive effects associated with meeting particular housing needs will only be weighed when testing site-specific development options.
2.6 The implication of this is that the Council intends to reject altogether strategy options providing for ‘village-related’ growth outside of the ‘east’ and ‘south’ corridor parishes and may opt for lower levels of development in the ‘south’ corridor prior to assessing all site
specific reasonable alternatives.
2.7 Our client’s land at Green End, Kempston, is a good illustration of why a flexible approach to testing needs to be adopted and why the parish has correctly been identified as an area with overall potential for development. At this stage the Council’s evidence has no regard to whether its Preferred Strategy options - heavily reliant on large-scale strategic growth with potential constraints to land availability, viability, and development timescales – would be capable of meeting specialist housing needs for older people over the Plan period.
2.8 In contrast, our client’s land at Green End (in-keeping with other opportunities in the rural area) satisfies the key characteristics of sites suitable to provide for retirement village schemes in terms of its scale, location, and accessibility. The benefits of the potential to provide specialist housing for older people in this location should remain subject to further assessment (alongside general needs housing) due to the ability to contribute towards overall development needs. This is irrespective of the strategy options selected by the Council to meet the minimum need for new residential allocations. Recognition of this underpins our clients broader argument that meeting the requirements for preparation of the Local Plan 2040 must rely upon a flexible, ‘hybrid’ approach.