Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9973

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

DS2(S) Spatial Strategy
Gladman are seeking changes to the spatial strategy of the Local Plan. More small and medium sites should be allocated to ensure that housing delivery can be increased in the short term to a level required by the standard methodology.
The spatial strategy can be summarised as growth opportunities within the Bedford urban area, strategic expansion of the urban area and strategic sites in transport growth corridors. Even growth to the villages is of a strategic scale. The nature of the sites proposed mean that housing delivery will not increase in the short term. Sites in the urban area may not be immediately available and the strategic sites are reliant on proposed strategic infrastructure.
We have submitted detailed commentary around the SA and the testing of options including village growth and we feel that any spatial strategy that overlooks the pivotal role growth in the villages can play in the timely delivery of housing is unsound.
The Council has deliberately sought to avoid allocating growth to settlements that were required to take growth in the adopted local plan, yet this plan only covers the period to 2030. There would be a ten-year period where these settlements are receiving no additional housing growth, set against a backdrop of the acute affordability issues across Bedford this is only likely to increase unaffordability in the villages. There will be a housing need in the villages beyond 2030 but this not currently addressed in the pre-submission draft. Another opportunity to increase housing delivery in the shorter term is a reconsideration of sites adjoining/adjacent to the urban area. However, the Council have opted to include only two strategic scale sites, adjacent to urban areas, on the basis of a green and blue infrastructure led approach. Concerns around potential coalescence are noted, but there are sites available to the Council in close proximity to the existing urban area that can contribute to the provision of green infrastructure whilst also delivering housing in the short term.
The inclusion of two new garden settlements to deliver a significant proportion of development in the latter stages of the plan period is a concern from a deliverability perspective. New settlements can play an important role in the delivery of new housing to meet the needs of a district, whilst avoiding some of the major constraints that may limit development elsewhere. However, the lead-in time and delivery of such schemes must be realistic and it is unlikely that these will start to deliver units in the first five years of the Plan. Therefore, any new settlements must be complemented by a range of additional smaller scale sites in both urban and rural locations that will deliver units in the early part of the plan period and provide flexibility if the larger sites do not deliver as quick as anticipated. If large scale housing targets are to be met a range of sites of differing scales and locations is vital.

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