Object

Representation ID: 9000

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section of our representations should be read alongside the standalone Review of the
Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review
support the Modifications in this part of the representations. This section also reinforces our
specific comments on the Council’s Preferred Strategy Options published in the main
consultation document.

These representations propose an alternative ‘hybrid’ spatial strategy. This is consistent with
the Council’s evidence base for the emerging Local Plan 2040; would overcome the
soundness issues identified with the Council’s Preferred Options; and would comprise an
appropriate strategy for the purposes of Paragraph 35(b) of the NPPF2021.

The ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’
growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of
their capacity to contribute towards sustainable development. The benefits of ‘village-related’
development do not suddenly materialise only where Key Service Centre and Rural Service
Centres are located in the A421 corridor and do not evaporate altogether outside of it.

The Council expressly recognised this in the evidence base for the current Development
Plan. In the current Preferred Options, it has taken an inconsistent approach to assessing
the effects of the ‘village-related’ development component by reaching different conclusions
for exactly the same settlements (in the ‘east’ and ‘south’ corridors) when they are assessed
as part of the Preferred Options as opposed to other strategy options (e.g., Option 3c).

The ‘hybrid’ option assigns the ‘village-related’ growth component only to those settlements
outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an
indicative distribution, have been retained at 500 units in Key Service Centres and 35 units
in Rural Service Centres albeit these are arbitrary figures and should be determined on a
case-by-case basis. Wixams has been excluded from the total for Key Service Centres
(reflecting its inclusion in the locations for rail-based growth). The only exception, taking
account of this, is an increase of 215 units in the distribution to Oakley based on our
recommendation for it to be reclassified as a Key Service Centre and growth east of Station
Road being specifically supported.
For the A421-based components of the strategy the total distribution to the ‘east’ corridor
parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d.

In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of largescale
strategic growth included in the strategy options. We have included the Council’s
minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and
New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic
timescales for development.

Including both components would comfortably exceed the minimum 12,500 units required
from additional allocations, with an appropriate buffer for flexibility and contingency
(particularly in terms of the prospects for meeting increased needs before 2030). There is no
reason higher quanta could not be included as part of an extended plan period. Equally, this
could allow some settlements to be excluded from further village-related growth albeit we
would not recommend this where Neighbourhood Plans being prepared have failed to
address important strategic priorities (as at Oakley and Sharnbrook, for example).

The ‘hybrid’ strategy based on these components are summarised in Table 1 below: (see attachment)

We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the
Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with
the standalone findings for growth components and the Council’s Options 2d and 3c, as well
as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable
development are enhanced. This is as a result of recognising that the potential negative
effects the Council assigns to village-related growth are incorrect and, in any event,
inaccurate because it ignores the location of some Key Service Centres and Rural Service
Centres within the A421 corridor. It also recognises that some the benefits of what is in reality
‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across
settlements elsewhere in the hierarchy. The results are summarised in Table 2 below: (see attachment)

Comments on the Strategy Options and Supporting Evidence
The section of the representations provides observations on the soundness of the Council’s
overall approach towards preparation of the Local Plan 2040 and identification of the strategic
priorities it is required to address. Comments specifically relate to Chapter 3 of the
consultation document. Issues relating to the ability of the Council’s approach to maintain a
rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped
trajectory) are dealt with separately in Section 6.

The preferred options for development, as set out in the Draft Local Plan, focus the allocation
of a minimum 12,500 units around the urban area of Bedford, the A421 and the A1 transport
corridors. This approach is unsound (not effective, not justified, not positively prepared and
not consistent with national policy) in creating an effective embargo on any further
consideration of village-related growth outside of these areas as part of the Council’s planmaking
process to prepare strategic policies or to necessitate the review of Neighbourhood
Plans that look forward only to 2030.
Reasoning

Whilst we are in support of parts of the Council’s ‘Preferred Options’ 2a-2d, insofar that they
recognise the potential for benefits from what is in-effect village-related growth at some Key
Service Centres (KSC) and Rural Service Centres (RSC), we note the absence of any
development being allocated to the northern parishes.

KSC’s and RSC’s outside of the ‘east’ and ‘south’ corridors are capable of delivering
development within the Plan period up to 2040 and addressing the significant increase in
housing need that must now be planned for. The evidence bases for emerging
Neighbourhood Plans and details of suitable sites being identified in the Call for Sites event
that Bedford Borough Council undertook in the Summer of 2020 are illustrative of this fact.

With respect of the KSC of Sharnbrook, this is evident in the circumstances for the
Neighbourhood Plan which the local planning authority and qualifying body (Sharnbrook
Parish Council) intends to put in place (following issue of the Examiner’s Report on 21 of July
2021). Sharnbrook as a settlement is identified in the adopted Development Plan as a KSC,
meaning that it has a good provision of services and facilities to facilitate development. The Neighbourhood Plan, covering only the period until 2030 in any event, does not provide for
development that is immediately adjacent or well-related to the existing Settlement Policy
Area boundary or that seeks to sustain and enhance the role of the settlement.

Furthermore, our client submitted substantial objections to the Neighbourhood Plan’s
proposed allocation at Hill Farm in terms of its sustainability and deliverability. The Hill Farm
and NDP allocation proposals would result in the removal of the Primary School currently
being provided in the KSC of Sharnbrook itself (it would relocate to Hill Farm). Our client’s
Stoneyfields scheme could lead to the re-provision of facilities in a highly sustainable
location, especially for existing Sharnbrook residents, amongst numerous benefits directly
related to the village it serves.
Remedy

Therefore, we would ask that Bedford Borough Council addresses their proposed
development strategy and seek to allocate development within the northern KSC and RSC,
where there is both demand for development and the available sites to aid in the delivery of
housing post 2030 or earlier. This could be achieved through allocating additional
development to the northern parishes (as part of flexibility and contingency) or redistributing
the minimum total of additional land to be allocated to address local housing need (and thus
addresses barriers to delivery of large-scale strategic growth within the Preferred Options).

Bedfordia generally support the approach the Council has taken to the Spatial Strategy
across the Authority area; recognising that housing and job growth can be accommodated
through a hierarchy of urban and rural communities.

Paragraph 3.10 of the Local Plan 2040, highlights that, as part of last year’s Issues and
Options consultation, the Council outlined six distribution options which could form part of
the strategy for growth. These were:
• Brown – Urban based growth
• Yellow – A421 based growth
• Pink – Rail based growth
• Orange – East-West rail northern station growth
• Grey – Dispersed growth
• Red – new settlement-based growth

The responses to the issues and options consultation indicated that there was broad
consensus favouring development focused on the existing urban areas and the A421
corridor, and possible new railway stations which might be delivered on the new East-West
Rail Line. This does not, however, provide justification to preclude the potential benefits of
dispersed growth altogether.
Reasoning
In conjunction with paragraphs 3.16 and 3.17 of the Local Plan 2040, an alternative ‘hybrid’
approach is required to provide for an appropriate strategy. This approach is consistent with
the criterion informing the spatial strategy under Policy 3S of the LP2030, supporting
proposals to deliver sustainable development and growth that enhances the vitality of the
Borough’s urban and rural communities. This specifically expects contributions towards the
objectives and policies of the Plan through (inter alia):
(iii) Strategic residential development in key service centres in association with
expanded education provision where necessary.
(iv) Limited development in rural service centres in line with existing and potential
capacity of infrastructure and services.
(v) Delivering the majority of rural growth through Neighbourhood Plans.

On the basis of the Council’s Preferred Options the Plan’s strategic policies would not
continue support for these components of a sustainable strategy beyond 2030. Moreover,
there is an existing conflict arising from the approach to Policy 3S, where Neighbourhood
Plans being prepared are likely to have addressed some but not all of an area’s priorities and
only in the context of the significantly lower OAN adopted in the LP2030. The Council’s
approach in the current Plan led to issues being deferred, rather than dealt with, meaning
that the Preferred Options only seek to compound this problem.

The Council’s Preferred Options must therefore be reconsidered and adapted to coincide
with ongoing support for those parts of the spatial strategy endorsed within Local Plan 2030
Policy 3S that the Council’s own evidence recognises as essential to securing contributions
towards sustainable development.

The annual requirement in the adopted Local Plan 2030 is 970 dwellings per year. The
minimum annual local housing need figure for the Local Plan 2040 represents a substantial increase to the adopted Plan and will bring with it considerable challenges.

Policy 3S was also in reality a ‘hybrid’ approach. The Council recognised it was unable to
make provision for even its own lower figure for objectively assessed needs without
diversification of the spatial strategy. The reasons for this primarily relate to issues that are
not new to this Plan-making process – namely the delivery of extant commitments on Town
Centre sites. The incorporation of new large-scale strategic options, which the Council was
unable to soundly introduce to the LP2030, adds to the number of locations where longer term
development timescales need to be considered but does not change the justification for
a flexible approach already recognised as sustainable.

As such, Bedfordia query the ability of Bedford Borough Council to deliver some 1,275 new
dwellings per annum, given the constraints Bedford faces and historic amount of growth that
has been accommodated to the south of the town, without sustaining a flexible approach.
Further growth should be directed KSCs, such as Sharnbrook, which demonstrate a good
level of facilities and perform an important role in facilitating strategic residential
development, considering the existing and potential capacity of infrastructure and services.
Remedy

As part of this approach the allocation of housing to any KSCs or RSCs needs to have regard
to the overall levels of increased housing need, and where appropriate the quantum adjusted
to reflect both settlement and site capacity.

In the case of Sharnbrook it remains appropriate to adopt a more comprehensive approach
to strategic residential development that is well-related to the village, providing benefits that
cannot be delivered through the allocation of a combination of smaller site options. The
decision of the Neighbourhood Plan to pursue in-effect new freestanding development at Hill
Farm (to be considered in the context of the wider settlement hierarchy) does not impinge on
the reasons to continue to support the justification for Policy 3S at Sharnbrook itself.