Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9462

Received: 29/07/2022

Respondent: Landcrest Developments Ltd

Agent: Woods Hardwick Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The comments by Landcrest set out that the strategy is flawed and sub-optimal in its approach to achieving sustainable growth in the right places at the right time.

Full text:

The spatial strategy is clear at the outset that Bedford is at the heart of the Oxford – Cambridge Arc, and this in part has directed an approach in the spatial strategy to take advantage of existing and future strategic infrastructure such as the A421 and the East West Rail corridor to deliver sustainable development within the borough.
Landcrest consider, however, that the spatial strategy does not fully reflect the full potential for sustainable growth across the borough in accordance with overarching aims of the Oxford-Cambridge, or one that would capitalise on true potential of the existing and future transport corridors. This is evident as the strategy seeks to deliver growth primarily within / around the urban area, and at new settlements. It is clear that more rural locations, including key service centres many of which, such as Bromham, are well served by strategic transport corridors which would perfectly complement additional capacity provided by the East West Rail, have been overlooked in terms of their true growth potential.
To this end, the spatial strategy is not considered appropriate as it is overly reliant on the new settlement proposals to the South of Bedford and at New Barford as evidenced the be the distribution of growth in Policy DS5(s): Distribution of Growth. Key Service Centres’ potential growth have only been given due consideration in terms of their potential for sustainable growth as part of Neighbourhood Plans. The previous development plan that preceded the LP2030 introduced a moratorium on rural growth that quashed the vitality and potential at critical location across the borough. Whilst since then a relatively modest attempt at growth was planned as part of Neighbourhoods Plans, which themselves derive allocation sites and figures from LP2030 and not any higher, represent “one and done” approach to strategically reviewing sustainable rural locations for growth. It should be borne in mind that targets set out within the LP2030 – that of allocation figures distributed across the various rural areas and indeed the housing target as a whole – have always been identified as a minimum and not a maximum. For this authority to then formulate strategy that seeks to achieve the bear minimum in sustainable and planned growth in its rural heartlands gives little confidence that the plan has been positively prepared to meet the wide range of needs of local residents.
The matter is further exacerbated when consideration is given to the fact that the LP2030 had required an immediate review of its strategic policies as per Policy 1, the Council being fully aware of its need to meet higher growth levels in the near future, to only continue to delay meeting its housing need via stepped trajectory. The Standard Methodology (SM) figure for the Borough has not changed considerably since it was first introduced in 2018 and is much higher than the housing target in the LP2030 as acknowledged by the Council. There is thus a genuine concern that this authority is not fully committed to exploring all avenues for growth for real people across the Borough in real need now.
As a whole, the above sets out that in terms of spatial growth the strategy as part of LP2040 is ‘lop-sided’ and nor does it appropriately consider the secondary effects of the East West Rail in enhancing the wider strategic transport corridors that currently existing within the borough, specifically those enjoyed between key service centres, such as Bromham, and the urban area. Equally, there is no effort to prepare to the lack of delivery in the East West Rail given the latest statement made by the Transport Secretary which would then severely impact the sustainability credentials of this proposed plan’s strategy. The consequences of this are further compounded when considered the temporal element of the proposed growth under LP2040, with all elements that suggesting the plan has not been positively prepared, justified or is effective as per paragraph 35 of the NPPF.