Object

Representation ID: 9784

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
We consider that Policy HOU12 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 proposed policy is overly reliant on East-West Rail despite there being significant decisions yet to be made on this infrastructure proposal. By pushing ahead with this consultation prior to any definitive progress on East-West Rail there is danger that the spatial strategy including the approach to south of Bedford will unravel.
The locations of proposed sites do not relate well to one another in terms of accessibility and connectivity, and instead rely on higher order settlements such as Bedford, Kempston and Wixams. If the overarching strategy is based on East-West Rail connectivity, this only really relates to the sites with good accessibility to the stations, these being some of the western located sites.
We have explained in our response to the proposed vision, objectives and spatial strategy overall that we consider the tests of soundness have not been met. Land at Box End, west of Bedford is well related to the urban area of Bedford and Kempston and performs well in sustainability terms being to the south west within the broad area defined as ‘South of Bedford Area’ within Figure 5. This land is being promoted by BDW Trading Limited, which includes Barratt Developments, for sustainable and deliverable development. Masterplanning for the site includes land with potential for around 1,150 dwellings, a primary school and a community hub thereby creating a sense of community and potential for some trips to be internalised within the development.
Barratt Developments are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022 and previous years. Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards Large Developer 2021.
As the land at Box End performs so well but is inexplicitly omitted from the proposed sites within the South of Bedford Area, there is a vulnerability in the approach which is not sound.
We have concerns regarding he deliverability of the sites within the South Bedford area. The reasoning of which is contained within the response to Policy DS2(S).
We suggest a review of the evidence base and strategy which would lead to a need for more land for housing-led development including identification of land at Box End, west of Bedford.