Object

Representation ID: 9762

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We consider there is insufficient evidence to demonstrate that the vision over the plan period is deliverable because of the proposed spatial strategy and site allocations.
The starting point for the spatial strategy should be development at Bedford Town and Kempston, followed by locations which are accessible to these urban areas.
The strategic locations adjacent to the urban area under this policy cannot claim to be adjacent in the ordinary sense of the word, in that they are not next to or adjoin the urban area of Bedford Town and Kempston. Figure 5: South of Bedford Area needs to identify the urban area so that the proposed allocations can be seen properly in context. The Figure also needs to identify in the Key the various proposed allocations.
We consider that Policy DS2(S) Spatial Strategy should be subject to change from strategic locations adjacent to the urban area to strategic locations which are accessible to the urban area. This will entail a re-assessment of the evidence base including land availability, rightly bringing into consideration land at Box End, West of Bedford, which is being promoted by BDW Trading Limited for an exemplar sustainable urban extension of some 1,150 homes that meets or even exceeds policy requirements in relation to issues such as bio-diversity net gain, renewable energy etc.
The spatial strategy does not demonstrate deliverability of the sites proposed and it does not factor in sufficiently flexibility for under-performance should the spatial strategy and site selection remain unchanged through the examination process.
BDW Trading Limited includes Barratt Developments who are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022, this is a record 13th year in a row.
Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards large developer 2021. Barratt Developments have an enviable track-record of delivering sustainable development and high-quality place-making in Bedfordshire and beyond including at Wixams.
We consider that in order to be found sound the local plan should be subject to main modifications in respect of a range of matters. However, for the purpose of this response we confine our comments to the need to review the evidence base and proposed spatial strategy and site allocations.
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 deliverable. 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.
The spatial strategy is reliant upon further decisions to be made by other parties in respect of East-West Rail including fundamental considerations of the route west of Bedford Town, locations of stations and timing of subsequent stages for the planning for the development and delivery. The consultation on this local plan comes ahead of refinement of the detail of these extremely important matters and yet the local plan is not scheduled for submission for examination until January 2023. With this consultation comprising the plan for submission (Regulation 19) there would ordinately not be any further opportunity for stakeholders to comment ahead of submission of the local plan (Regulation 22). As the spatial strategy and some of the proposed site allocations rely on delivery of East-West Rail this is a real point of vulnerability which should have been avoided by first having clarity on this ahead of consultation under Regulation 19.
The Infrastructure and Projects Authority, which is the Government’s centre of expertise for infrastructure and major projects, published its Annual Report on Major Projects 2021-22 on 20 July 2022. This has found that stages 2 and 3 of East West Rail appears to be unachievable.
In this report the East West Rail Connection Stage 2 and 3 which comprises predominantly upgrading of existing infrastructure (between Bletchley and Bedford) to allow services between Oxford and Bedford and East West Rail CS3 which involves building a new line, between Bedford and Cambridge, to extend the railway and facilitate services from Oxford to Cambridge, is identified as 'red' meaning that the successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability reassessed.
A copy of the report is available via: https://www.gov.uk/government/publications/infrastructure-and-projects-authority-annual-report-2022
We question whether the number of dwellings identified for sites is achievable for example whether the potential dwelling yield at Little Barford and south of Bedford are achievable, which we summarise below.
Kempston Hardwick (HOU14)
• There is currently a pending planning application for employment on the site – Ref. 18/02940/EIA – Outline application with all matters reserved except access, for a commercial and industrial development providing up to 780,379 sqm of floorspace for B1, B2 and B8 uses and ancillary service uses (A1, A3, A4 & A5) and associated infrastructure including open space and landscaping.
• There are multiple land owners within the Kempston Hardwick allocation, meaning delivery could be delayed, complex and incoherent.
• The delivery of 3,800 units over the plan period is somewhat ambitious.
• The location of the allocation is based around the delivery of the East-West rail station, the location of which is uncertain at this moment in time.
Little Barford (HOU19)
• The delivery of 3,800 over the plan period is somewhat ambitious.
• There are potential cross-border issues to address as the Site sits on the edges of HDC and CCC.
• There are likely to be some potential capacity issues within the local highway network e.g. Black Cat roundabout.
• This site is based around the location of the East-West rail stations. At this moment in time, the locations of which are uncertain. This is a real point of vulnerability.
Land south of Wixams (HOU15)
• We would query where the projected dwelling yields are found in proposed policy terms