Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9429

Received: 29/07/2022

Respondent: L&Q Estates Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The scale of housing is not specifically included in the policy. For clarity, it would be helpful if the allocations policies identified the scale of housing proposed and that these figures represent a minimum provision.
If contribution is required to fund infrastructure improvements or whether infrastructure improvements need to take place ahead of the development of the allocation should be determined through the development of the comprehensive transport assessments as part of the development management process.
This allocation should only have to contribute towards education contributions proportionally with the other allocations in the area.

Full text:

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16. L & Q Estates Ltd supports the proposed allocation East of Wixams as it represents a sustainable and deliverable development that will make an important contribution to meeting housing needs over the plan period.
The following sections set out our comments on relevant sections and policies in the plan.
Policy HOU16 Land at East Wixams
Policy HOU16 allocates land at East Wixams for residential, community and open spaces uses. The scale of housing is not specifically included in the policy. For clarity, it would be helpful if the allocations policies identified the scale of housing proposed and that these figures represent a minimum provision.
Wixams East is proposed to accommodate at least 1,800 dwellings, and associated infrastructure. Access is proposed via two existing roundabouts along the A6. The proposed access strategy will also promote access to and from Wixams and the scheduled Wixams Station for all modes of transport with particular emphasis on walking and cycling. It is proposed that Wixams East will be an extension to Wixams and one community will be formed in the longer terms.
Policy HOU16 states that the development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan. The Infrastructure Delivery Plan at Table 5-2 states that the A421 widening to 3 lanes between A6, and Carrington Road (A603 junction) would need to be delivered before this site allocation comes forward. The Infrastructure Delivery plan states at paragraph 2.6 that with the growth included in the current adopted Local Plan, in 2030 the A421/A6 and A521/A603 junctions are operating over capacity. However, it is not clear how much of the growth allocated in the adopted Local Plan 2030 has been developed. The infrastructure delivery plan assumes that all the allocations have been developed which may not be the case. Whilst L & Q Estates is supportive of delivering infrastructure that is required by the development, the restriction on Land East of Wixams from being delivered until the transport improvements are in place is not justified. It is possible that land to the East of Wixams could come forward before some allocations identified in the Local Plan 2030, helping to support the delivery of housing to meet requirements. Therefore, whether a contribution is required to fund infrastructure improvements or whether infrastructure improvements need to take place ahead of the development of the allocation should be determined through the development of the comprehensive transport assessments as part of the development management process. The policy already appropriately sets out the requirement for a full Transport Assessments as part of any applications, which is supported.
Policy HOU16 states that the development will include:
• provision of two 2.4 ha serviced sites to accommodate two 2 form entry primary schools to include early years’ provision.
• Provision of an 11 ha serviced site to accommodate a nine-form entry secondary school to include sixth form provision;
• financial contribution towards secondary school provision;
The Local Plan 2030 – Education Implications (2030) with Addendum (2022) indicates the potential education needs arising from new development and includes broad costs for the provision of new schools.
At this stage it appears that the Local Plan is seeking primary and secondary school places more than what would be reasonably justified to meet the needs of the East of Wixams housing allocation. It is possible that Wixams East has been identified to meet the additional needs of other proposed allocations. This has not been justified or supported by sufficient evidence. If this is the case, it would be necessary for other allocated sites to contribute proportionately to the cost of the additional land, the lost opportunity cost of the land and building work and the relevant policies amended to make this requirement for contributions clear. The development of the land at Wixams East should only be required to mitigate the impacts arising from this development alone. It is unjustifiable to impose additional infrastructure burden on this site to mitigate impacts arising from development proposals elsewhere.
For primary schools, The Education Implications paper provides for new pupil product ratio for primary pupils of six pupils per year group per hundred dwellings. This is given as " a 1 form entry school for 500 dwellings, a 2-form entry school for 1,000 dwellings and a 3-form entry school for 1,500 dwellings.”
The Local Plan is seeking approximately 0.4FE primary school places more than what is require by the proposed East of Wixams allocation. Whilst the need for some flexibility across the area is understood, with the Wixams East site proposed for 1,800 dwellings, no more than 3.6FEof primary provision is warranted to meet its needs. One 2FE primary school is supported. A further 2FE should be planned for, but with only 1.6 FE of the land and construction costs funded by the development and the remainder met by one of the other local developments. Alternatively, the provision of one 4FE primary school on the site could benefit from economies of scale in its construction and running and still meet the educational requirements of East of Wixams. Such an approach is being undertaken for the remaining education provision in the existing Wixams settlement.
The Education Implications Paper, states that a 2FE site is expected to be provided at 2.4ha, including sufficient space for early years provision. This is considered high, as DfE Guidance provides for a 2FE site to be scaled at between 1.6ha and 2ha. The Local Plan and Education Implications paper has, therefore, opted for the maximum size and then increased the requirement by 0.4ha for early years. This is not justified as there is no indication as to how this level of requirement has been reached, either in terms of pupil numbers or in terms of the space breakdown. For the Wixams East site, each of the 2FE sites should be containable within a 2ha site. If the provision of the 4FE approach is adopted then the site area required reduces to 3.39ha as demonstrated on the Wixams town centre school that is currently being planned for. There is no justification for requirement of 4.8ha for primary education provision at the East of Wixams.
For Secondary school provision, Wixams East is requested to provide a 9FE entry school with sixth form which is 5.4FE more than the needs created by the allocation. It is clearly anticipated that this new school is intended to meet the needs of other allocation in the area. However, at 9FE, our evidence suggests that it exceeds the overall requirement for the area by 1.8FE. a requirement of 3.6FE (at 4.14 ha) is supported. A further 3.6FE should be funded by other developments and contribute proportionately to the cost of the additional land, the lost opportunity cost of the land and building work and the final 0.8ha to meeting any additional needs up to 8FE should be funded by the Education Authority. The indication of a 9FE with sixth at an 11ha site size is considered excessive. A site of between 8.1ha and 10.1 has (including sixth form) is the range recommended by the DfE for an 8FE school. There is no evidence to support the provision of more than the minimum. Additionally, there is no rational justification as to why Wixams East needs to be burdened with the provision of a secondary school whilst other allocations in the area do not. This is an unduly onerous and inequitable requirement.