Object

Representation ID: 9785

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 HOU14 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. Kempston Hardwick is reliant on two new train stations, which requires a significant amount of infrastructure delivery within a short timeframe. The timing of the delivery of these key pieces of infrastructure is uncertain.
The delivery of 3,800 units over the plan period to 2040 is ambitious when there are multiple land owners in play. Delivery could therefore be complex, delayed and incoherent.
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.
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 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