Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9897

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

5. Policy DS2(S) Spatial strategy and Policy DS5(S) Distribution of growth
5.1 Policy DS2(S) and Policy DS5(S) sets out the proposed distribution of growth. The key locations are:
• Within the urban area – 1,200
• Strategic locations adjacent to the urban area which contribute to delivering the
Forest of Marston Vale incorporating the Bedford Milton Keynes Waterway Park and
the Bedford River Valley Park – 1,500
• South of Bedford including new settlement 7,050
• Little Barford new settlement 3,800
• Some development will take place beyond the plan period – 400
• Remaining rural area / villages - Completion of sites previously allocated in local plans and neighbourhood plans
5.2 Paragraph 4.31 states:
“Policy DS5S sets out where growth will be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040. There will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres. No new allocations are made in these villages in the Local Plan 2040, although some Parish Councils may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs”.
5.3 We have a number of concerns with the strategy.
5.4 Our first concern is that the total supply from these sites in the plan period is 13,550. When added to the 14,824 dwellings committed, the total is 28,374 dwellings. At 4.7% this does not provide the necessary level of flexibility required in the SA of 10% to meet the requirement. Indeed, it is even lower than the 11% flexibility found acceptable by the examining Inspector in the LP2030.
5.5 Our second concern is that new settlements form part of the strategy. However, paragraph 2.5 of the Development Strategy Topic Paper states:
“The results are summarised in the Issues & Options Consultation - summary and responses document. The (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth options..
5.6 Therefore, the results of the Issues and Options showed that the options for new settlements and dispersed growth were most unpopular. Despite this, new settlements form the bulk of the strategy in the Plan. We questioned the merit in undertaking consultation at the Issues and Options when at that early stage in LP2040 no meaningful account has been given to the public responses and this has been carried forward in the Plan. Our overarching objection is that land adjacent to urban area and higher order sustainable large villages has been dismissed in favour of new settlements and unsustainable allocations (HOU13 and HOU16 for example).
5.7 Some of the proposed allocations have viability issues. For example, the Viability Study states:
“The two largest strategic sites (Little Barford and Kempston Hardwick) are identified as having challenging viability at current costs and values.”
5.8 As to the Development Strategy meeting affordable needs, the Viability Study states:
“Further, the Council’s policies build in an appropriate level of flexibility i.e. Policy DM1 (S) (Affordable Housing) is applied subject to viability and allowing for future reviews of viability as the development progresses.”
5.9 This shows that the Plan is predicated on viability issues being raised and less affordable housing delivered. As we set out under DS3 there is a significant and worsening affordability crisis in Bedford. If the Council are committed to meeting affordable housing needs, and the current strategy is adopted, there will need to be clear monitoring policies to ensure action can be taken as soon as possible to meet affordable needs if allocated sites do not deliver the required on-site affordable homes.
5.10 In the case of extensions to urban areas, paragraph 3.5 states:
“In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area - performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth. However, the adjoining the urban area component performed worse than the urban component in relation to maximising development on previously developed land. The risk of coalescence of rural settlements was also noted.”
5.11 In that context we consider that sites adjoining the urban area and which do not result in coalescence should have been allocated. In Section 7 we set out the merits of the land at Bromham Road, Biddenham (Site ID7432) which should have been allocated on that basis.
5.12 With regard to villages, paragraph 3.6 states:
“3.6 The worst performing component was the village related growth component. It was likely to have a more negative effect than the other components, particularly in relation to reducing carbon dioxide emissions, protecting water resources, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer positive effects than any of the other components of growth.”
5.13 As we set out at the Issues and Options stage, this conclusion must be read in the context that the Development Strategy Topic Paper6 which has a Village Related Growth Option were all based on over 4,000 new homes ranging from 28% to 41% of the total requirement. We do not advocate such a dispersal strategy but clearly recommend that there should be growth at Key Service Villages and Rural Service Centres.
5.14 We consider that the SA has not assessed reasonable alternatives and the options should have assessed a lower total percentage of the total requirement for the Village Related Growth Option and also distinguished between more sustainable Key Service Centres and less sustainable smaller villages, particularly for Wootton which is highly sustainable and lies close to Bedford town and close to Milton Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options for growth at Key Service Centres and Rural Service Centres should have been considered.
5.15 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note that these options state within the ‘parish area’ rather than within or adjacent to parish settlement. Paragraph 3.11 of the Development Strategy states that “development in parishes within the ‘Transport corridor”…. “will not necessarily adjoin existing villages but could be at new locations between a parish”. Development on the edge of existing settlements, and closer to services, are important factors and we consider that new homes would be better located adjacent to settlement boundaries of existing settlements as that is the most sustainable option. Land at Hall End Road, Wootton, which was recommended approval by officers for 81 dwellings, and was considered sustainable in a housing shortfall context, would be one such site adjacent to a Key Service Centre that could accommodate some growth. Land south of Bromham Road, Biddenham, immediately adjacent to the Bedford Urban Area boundary (the most sustainable area in the borough) would also be a logical option for up to 40 homes.
5.16 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby”. (our emphasis)
5.17 The fifth is that it is Intended that if the favoured strategy involves additional development in and around villages, that parish councils will be asked to allocate land in accordance with LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish should be given a housing requirement as required by paragraph 66 of the Framework which states:
“66. Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. Within this overall requirement, strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. Once the strategic policies have been adopted, these figures should not need retesting at the neighbourhood plan examination, unless there has been a significant change in circumstances that affects the requirement.” (our emphasis)
5.18 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban related growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include urban-related growth.
5.19 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs) and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated April 2022. At the time of the Draft Plan this report was not available as there was a “review underway” and was “not yet available for comment, but will be finalised in order to support the plan for submission (2022)”. We highlighted that it is important that this should be the subject of consultation prior to the Submission Plan being published so that any issues are considered prior to the spatial strategy evolving and reducing any potential objections to a key part of LP2040. Whilst it is part of the evidence base, any objections are to go before the Examination rather than being considered prior to Submission. This point applies with even greater force to the HELAA where factual errors or unchecked judgements have resulted in sites not being allocated. If these matters were picked up following consultation, then the evidence base would have been more robust. We examine issues with the HELAA in later sections.
5.20 One of our specific interests is Wootton which is one of the 8 Key Service Centres. In the settlement hierarchy paper, it is one of the most sustainable settlements in the borough. Policy 4S of the LP2030 sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169 dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000 dwellings should be located at Key Service Centres of which Wootton is one. The policy then continues when it states:
“it will be necessary to identify sites to meet the following levels of development, generally in and around defined Settlement Policy Area boundaries. Other than in Roxton, all sites will be allocated in Neighbourhood Development Plans. In rural service centres allocations may exceed 50 dwellings where specific local justification is set out in Neighbourhood Plans demonstrating that it would be appropriate in terms of the scale, structure, form and character of the settlement and the capacity of local infrastructure”
5.21 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there is no specific requirement proposed for Wootton. This was explained in the 2017 version of the LP2030 because Wootton had expanded in recent years. This should not be seen as further development at Wootton not being appropriate; rather it confirms its suitability and capacity as a location for growth. We consider that going forward Wootton should be identified as a location for growth and given a specific requirement. This should be at least 500 dwellings as set out in Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030 and form part of the committed 13,000 dwellings. These settlements could get less or as was the case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have a specific requirement of at least 500 dwellings especially due to its sustainability credentials and its close relationship to Bedford town. If there is a concern about the effects of recent development in Wootton, which in our view do not stand up to scrutiny, there is no reason why the Council cannot suggest a requirement to Wootton to be delivered
later in the plan period.
5.22 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that development should not occur.”
5.23 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed within site specific policies W3 to W6. Development in excess of this figure will only be permitted where the proposal relates to a site within the SPA in accordance with Policy W1.”
5.24 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale of development in the WNDP, with 73% of respondents strongly agreeing/agreeing with the allocation of sites sufficient to accommodate a total of 145 residential units within the plan period, on the basis of need ascertained by the Housing Needs Survey. This survey aimed to assess the need of local people for either affordable housing or market housing in Wootton, at the time when it was envisaged that the Bedford Borough Local Plan would cover the period to 2035. The quantum of development has been marginally reduced in response to further resident feedback and to reflect the reduced Local Plan period to 2030.”
5.25 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the 105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of the existing residents of Wootton and it takes no account of the newly forming households and the increase in households in the plan period across Bedford Borough that the standard method calculates. This is a particularly important point as the LP2040 consultation confirms that capacity within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet needs of which Wootton can play an important role. However, it demonstrates a continuing need for new housing in Wootton which LP2040 should plan to meet.
5.26 Paragraph 4.12 of the Education Paper states that “Wootton has expanded significantly in recent years and development is soon to commence on land south of Fields Rd. Initially it was thought that there may be scope for some additional capacity in local schools later in the plan period but updated school numbers show that this is unlikely to be the case”. This is not evidenced in that document, yet the IDP states that there is a surplus of 328 places (Figure 48ID). Are these surplus places being taken up by the less sustainable allocations such as HOU13 and HOU16? For example, HOU13 requires a secondary school contribution which demonstrates there is capacity to expand existing schools. Therefore, we have significant reservations on the evidence base and how it has been used to prepare the Plan.
5.27 This was a matter assessed by the Examiner for the Neighbourhood Plan. Paragraphs 4.16 to 4.18 state:
“4.16 Up to 105 dwellings are proposed in policy W2 but it is made clear that this figure could be exceeded on suitable sites within the Settlement Policy Area, subject to the requirements of Policy W1 being met. This approach is based on the findings of the Housing Needs Survey (2017) and is supported by a majority of the local community. I am aware that Wootton is defined within the Bedford Local Plan as a ‘key service centre’ and on my visit I noted the wide range of community facilities and services available. However, I also saw that there has been significant development in the area over recent years and I consider that the Parish Council has adequately justified the reduction in housing numbers from 145 (as set out in policy W2 of the Pre-Submission version of the WNDP document – September 2020) to 105. This reduction is based primarily on resident feedback during consultation on the pre-submission version of the Plan and to reflect the reduced Bedford Borough Local Plan period from 2035 to 2030.
4.17 I note that some local residents questioned the need for more housing in the village and suggested that Wootton has ‘reached the limit’12. However, the housing figure is based on the Housing Needs Survey (2017) and NPPF section 5 confirms that it is the Government’s objective to significantly boost the supply of homes. Paragraph 11 of the NPPF confirms that a sustainable pattern of development should be promoted. I consider that the wide range of community facilities and services that are available in Wootton contribute significantly to its credentials as a sustainable location for development.
4.18 Conversely it was suggested that in order to ‘boost the supply of homes’ 13 more housing should be allocated, and for example, it was suggested that there should be an allocation at the Chequers Public House14. On current evidence I am satisfied that the Parish Council has satisfactorily justified its approach15, but circumstances may change with the adoption of the Bedford Local Plan Review (scheduled for 2023) and that is one of the reasons I am recommending that the WNDP is reviewed every two years (see paragraph 4.56).”
5.28 Paragraph 4.10 referred to the out of date nature of the housing needs and proposed an early review. It states:
“4.10 The Parish Council has based its housing requirement on the 2017 Housing Needs Survey (with a reduction to take into account the reduced Local Plan Period from 2035 to 2030). The Borough Council has not objected to this approach and bearing in mind I am recommending review of the WNDP every 2 years (see paragraph 4.56), I am satisfied that, at this time, sufficient land has been identified for housing development in the village.”
5.29 Therefore, the Plan is wrong to suggest that sites are not required in Wootton given the dwellings delivered to date and commitments. The Examiner proposing an early review confirms that housing needs need to reassessed to meet current and future needs.
5.30 It is clear that the housing needs of the area will not
be met the most sustainable village as set out in Appendix 3 of the Settlement Hierarchy with Addendum which scores Wootton as the highest of the 80 settlements assessed. The Plan needs to be altered to identify a specific requirement for Wootton.