Object

Representation ID: 9643

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

4.1 For the reasons set out earlier in this response, AWG strongly supports the principle of
the South of Bedford Area as a focus for environmental-led and sustainable growth.
However, for the reasons set out below, AWG considers the focus of the Plan and Policy
HOU12 on the delivery of an “innovation hub” at Kempston Hardwick to be unsound.
This fails to recognise the importance of other sectors and locational advantages of the
south of Bedford area and the Kempston Hardwick site, particularly for industrial and
logistics uses. The overreliance on innovation uses also poses a threat to the delivery of
the overall employment and economic needs of the area. Furthermore, the proposed
mix of uses, density and quantum of housing is likely to lead to a shortfall in housing
across the HOU12 area. This is considered in more detail below.
4.2 AWG support the principle of Policy HOU14 and the proposed new settlement at
Kempston Hardwick. Cloud Wing set out, in detail, their comments in respect of the
Vision, and Policy HOU12 (south of Bedford Area) and these representations should be
read in conjunction with that submission.
4.3 The strategy of focusing growth on the south of Bedford area (Policy HOU12) is
supported by AWG. However, AWG find that the approach taken to allocating sites and,
in particular, the quantum of development allocated on certain sites, is not justified nor
consistent with national policy, for the following reasons.
4.4 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13,
HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear
understanding and expectation as to the quantum of development that the Plan is
proposing in these locations.
4.5 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been
proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
4.6 What is not evident from the evidence base or the Local Plan, is the approximate
developable areas and thus whether these are realistic densities. Upon examination of
the Policies for each site, and the Figures in the Local Plan which accompany each, the
only way to achieve all the Policy requirements, in particular the amount of open space
and green infrastructure, would necessitate very high densities on most of these sites
(c. 50/60+ dph).
4.7 There is no evidence accompanying the Local Plan which justifies this approach; the
HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which
a high density would lead to, nor is there market evidence supporting housing demand
for such a high quantum of small units in these locations.
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4.8 This is likely to lead to future applications which either decrease the number of homes,
resulting in unmet need (in terms of overall quantum and/or mix) and possibly nondelivery
of key infrastructure. Alternatively, it may lead to non-delivery of green
infrastructure due to pressures to deliver housing numbers.
4.9 The quantum for each allocation is not based on a proportionate or robust evidence
base and are therefore not sound.
4.10 To make the Local Plan sound, additional allocations are therefore necessary to make
up this shortfall in numbers. Doing so would have the further benefit of addressing the
stepped trajectory shortcomings as set out in Section 2 of these representations.
4.11 AWG supports the principle of the allocation of the land at Kempston Hardwick for
development. However, for the reasons set out in detail in Cloud Wing’s
representations, Policy HOU14 proposes insufficient employment land on the parties’
land at Kempston Hardwick. AWG also has significant concerns over the overreliance
and inappropriate emphasis on delivery of innovation uses at the site, which do not
appear to be justified and pose risks to the delivery of economic needs and the overall
effectiveness of the Plan. The allocation should state “employment uses”, rather than
specifically identifying innovation uses.
4.12 AWG is also concerned by references in the draft Plan and its supporting evidence
which suggest that development at Kempston Hardwick and other strategic sites would
only be able to come forward post-2030 following the delivery of East-West Rail and
completion of various highway improvements, which in turn appears to be driving the
Council’s proposed approach to a stepped housing trajectory.
4.13 For the reasons set out in detail at paragraphs 6.9 to 6.69 of Cloud Wing’s
representations, a larger amount of employment land, including industrial and logistics
uses, could start to be delivered earlier than 2030. The site is already a suitable location
for employment growth. It is accessible by public transport and would be capable of
supporting early delivery of infrastructure improvements including improvements to the
surrounding highway network (i.e. the package of improvement works to Junction 13 of
the M1 and the junction of the A6 and A421 which have been developed in detail
through discussion with Highways England as part of the outline planning application for
the Bedford Business Park) and deliver sustainable transport improvements (i.e.
improvements to pedestrian and cycle accessibility and public transport).
4.14 Residential development, meanwhile, can come forward in advance of much of the
necessary infrastructure. The land at Elms Farm (considered below) is one such location
where homes can be delivered early, without the requirement for strategic
infrastructure.
4.15 On this basis, the Plan and draft Policy HOU14 risks unnecessarily delaying delivery of
housing and job growth in a sustainable, suitable location and failing to meet economic
needs in the short-term.
4.16 AWG supports the principle of mixed-use development and the allocation of the land in
HOU14 as a strategic allocation for growth in Bedford Borough. For the reasons set out
above, the quantum of employment development should be increased, and the loss of
residential development can be made up through allocating additional land which
directly adjoins the HOU14 area.
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4.17 In this context, AWG’s view is that it is entirely inappropriate for development at the
site to be delayed until late in the plan period and for the policy to prevent permission
being granted until such time that a Supplementary Planning Document has been
prepared by the local authority. Whilst we agree that further work would be required to
develop a robust Infrastructure Delivery Plan for the site and support the Council’s view
that development at Kempston Hardwick should be landscape-led and of high-quality
design, underpinned by an appropriate masterplan, the proposed approach has the
potential to delay and undermine delivery of development early in the plan-period. The
Policy should, therefore, be amended to allow flexibility for the landowners/ developers
to prepare their own masterplan and design code, in accordance with paragraph 129 of
the NPPF.
4.18 The detailed criteria set out in Policy HOU14, the concept plan and the infrastructure
identified in the Infrastructure Delivery Plan and Transport Strategy would also need to
be reviewed, updated, and amended, as appropriate, to reflect changes to the quantum
and mix of residential and employment development proposed in response to our
comments earlier in this response.
4.19 The next section of these representations puts forward a case as to one such location
for growth within the southern parishes, which would deliver growth in accordance with
Policy HOU12, on a site which has erroneously been discounted from the site selection
process
4.20 These remainder of these representations focus on an area of land, known as Elms
Farm, which is partly included and partly excluded from Policy HOU14.
4.21 As set out earlier in this response, Elms Farm is located in a sustainable location,
adjacent to Woburn Road, Manor Road, and the roundabouts on Fields Road. It is a
gateway location at the key entrance to the HOU14 allocation area when travelling from
the west and along the A421, and is, therefore, a prime location for a high-quality
development as part of this wider allocation.
4.22 The land at Elms Farm does not appear to have been assessed by the Council, despite its
location and the fact that part of the site is included within the HOU14 area. Whilst the
site has not previously been put forward through the Call for Sites process, it is in a
sensible and logical location for development.
4.23 Planning Practice Guidance (PPG) Housing and economic land availability assessment
paragraph 11 (reference ID: 3-011- 20140306) states:
“Plan makers should not simply rely on sites that they have been informed about but
actively identify sites through the desktop review process that may have a part to play
in meeting the development needs of an area.”
4.24 Neither the SA, nor any other evidence base document, make any reference to any such
action having taken place.
4.25 HOU14, instead, is presented with an arbitrary boundary through the middle of a field
partly within the Elms Farm premises. Instead, the boundary for HOU14 should be
extended to Manor Road and Woburn Road, as a logical and clear permanent boundary
for the allocation.
4.26 This would increase the amount of land available for residential development,
contributing to the housing shortfall identified earlier in this response. Moreover, as the
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Elms Farm site adjoins the roundabouts on Fields Lane and is a gateway site, it can
deliver early and also contribute to the housing trajectory, similarly responding to the
stepped trajectory point.
4.27 The land at Elms Farm, is readily available, in single ownership from a company with a
proven track record of delivery.
4.28 The Local Plan evidence base finds that this location is a logical and appropriate location
for residential development; The Site would accord with the development strategy for
BBC and would deliver housing in a sustainable location, as advocated in the NPPF.
4.29 As currently drafted, the Local Plan is unsound as it is not justified based on the
evidence base, nor is it effective given it will create an arbitrary boundary, leave an area
of land that is not practical for modern day farming, and will fail to deliver sufficient
housing to meet identified needs.
4.30 The boundaries for HOU14 should therefore be amended and the allocation must
include the land at Elms Farm to make the Local Plan sound.