Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9760

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We consider the spatial strategy including site selections will not minimise the need to travel and hence fail to minimise carbon emissions from new development.
The location of some of the proposed allocations are not considered to be well related to existing urban areas and whilst new places of certain scale are able to become more self-sufficient over time depending on the mix of development and deliverability, there is uncertainty and risk over the means by which to achieve this. Some of the locations seem not to relate well to facilities within Bedford Town and Kempston and some will be reliant on
provision of East-West Rail which as our other representations have identified remains uncertain.
Land at Box End, West of Bedford performs well in accessibility and connectivity terms. The development will be designed to be a 20-minute community, where day-to-day facilities are accessible within 20-minutes by active travel. As the development will provide a mixed-use community, internalised based trips will be maximised.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are well related to Bedford Town and Kempston or can be largely self-sufficient in terms of the scale and mix of development.
These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
Paragraph 66 of the NPPF states that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply
and mix of sites, taking into account their availability, suitability and likely economic viability.
Bedford Borough Council is the strategic policy-making authority in this instance and we accept that the Council has undertaken a call for sites and has taken this into consideration in arriving at the proposed strategy and objectives but we consider there is a fundamental issue
over deliverability.
The policy does not include any target or means by which to assess performance against policy and hence it is not measurable and hence it is not achievable.