Object

Representation ID: 9519

Received: 27/07/2022

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy DS2(S) Spatial Strategy
2.3 The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives.
6
Fisher German LLP is a limited liability partnership.
Registered in England and Wales. Registered
Number: OC317554. Registered Office: The Head
Office Ivanhoe Office Park, Ivanhoe Park Way,
Ashby-De-La-Zouch, Leicestershire, England, LE65
2AB. A list of members’ is available for inspection at
Head Office.
2.4 Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement: this included potential growth at Willington.
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need. Option 2D was identified as a reasonable alternative.
2.7 Willington was included in growth option 2D, outlined above, whereby growth at villages including Willington in the transport corridor-east would have been combined with other growth options such as development in and around the urban area and one new settlement.
2.8 The Council considered that the benefits of Option 2D are that housing development in the wider Parishes would enable housing delivery to be achieved earlier in the plan period (this is a very strong benefit consistent with the aims of Government).
7
Fisher German LLP is a limited liability partnership.
Registered in England and Wales. Registered
Number: OC317554. Registered Office: The Head
Office Ivanhoe Office Park, Ivanhoe Park Way,
Ashby-De-La-Zouch, Leicestershire, England, LE65
2AB. A list of members’ is available for inspection at
Head Office.
2.9 The negatives identified with Option 2D were that development would be considered to be more dispersed which could reduce the amount of development where railway stations could be accessed by active travel. There was also a perceived impact upon the landscape and settlement characters (not necessarily specific to Willington). Option 2D is noted in the topic paper to be the least popular option with the public.
2.10 Overall, village related growth was considered by the Council to be the worst performing option compared to the other growth options. However, no further comment is made in detail on option 2D despite its similarity with option 2B being noted within the Topic Paper (and option 2B was ultimately assessed as the most appropriate growth option).
2.11 As detailed in response to Policy DS3 and DS5, there seems an absolute reluctance by Bedford Borough to allocate any further additional growth at the Rural Services Centres despite the benefit being that some proportionate growth would be delivered earlier in the Plan period rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and withe current cost of living crisis, failure to deliver housing in settlements such as Willington will result in more and more young people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth to ensure they do not age and stagnate.
2.12 Land at Barford Road Willington has shown that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars.
2.13 The Plan and Strategy also has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.