Support

Representation ID: 9998

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

5. POLICY DS2 - SPATIAL STRATEGY
5.1 Wates supports the primary principle behind the proposed spatial strategy. This is that Bedford strives to become a net zero carbon emission Borough, situated at the heart of the Oxford – Cambridge Arc. This aspiration is reflected in a proposed strategy for growth which centres on sustainable (transport-oriented) locations, as situated within the A421 / East West Rail Corridor.
5.2 A key aspect of this approach concerns the South of Bedford Policy Area (designated under Policy HOU12). This includes the proposed new settlement at Kempston Hardwick, the expansion of Shortstown and the completion of the Wixams new settlement on the Midlands Main Line and at Gibraltar Corner. The balance of growth is then mainly to be provided within and adjoining the existing Bedford Urban Area.
5.3 It is considered that this approach accords with NPPF paragraph 11, which requires all Plans to promote sustainable patterns of development. The proposed approach also finds favour in NPPF paragraph 104(b), which indicates that opportunities from existing or proposed transport infrastructure should be realised. Indeed, paragraph 105 adds that;
“…Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes”.
5.4 There are clearly opportunities to create new planned communities (of a strategic-scale) within the Bedford Borough. As evidenced by Wixams, such new towns and settlements have proved an effective strategy for meeting housing, economic and social needs, both within the Borough and across the wider region. The creation of new communities continues to be strongly supported in current national planning policies, with the NPPF (at paragraph 73) stating that;
“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).”
5.5 The overall spatial strategy generally aligns with Option 2b(i) of the Development Strategy Topic Paper (May 2022), which seeks to concentrate growth within the A421 transport corridor and rail-centric development, whilst also identifying and allocating suitable sites within and around Bedford. Noting that an option centred solely on urban-based growth (i.e., at Bedford) would fail to meet housing needs or would require unacceptable / unrealistic densities, the A421 transport corridor (with rail-based growth) clearly emerges as the most sustainable and suitable option when compared to the alternatives identified.
5.6 At paragraph 5.16, the document is clear that the approach to the South of Bedford Policy Area will be to maximise the benefits of rail-based growth, with higher density development achieved close to rail stations. This is indeed consistent with the NPPF, which at paragraph 125(b) indicates that Plans “should contain policies to optimise the use of land in their area”, adding that Plans should apply minimum density standards to seek a significant uplift in locations that are well-served by public transport.
5.7 The distribution of growth proposed through the Draft Local Plan is also consistent with the findings of the Sustainability Appraisal (SA). The SA sets out, at paragraphs 1.8 to 1.15, that five broad growth options were explored, with the transport corridor option being further disaggregated to test four sub-options. This process presented fourteen alternatives options which could potentially meet the identified scale of housing and economic growth.
5.8 The ‘Option 2’ sub-options 2b (i), 2b (ii) and 2b (iii) all performed similarly positively, with it being judged that (in addition to growth with the Bedford Urban Area) rail-centric development at Stewartby / Kempston Hardwick would give rise to the highest probability of travel by public transport, as an alternative to private car use. The variation between these sub-options is largely limited to the exact scale of growth at Stewartby / Kempston Hardwick and Wixams respectively, with this having limited effect on the SA’s evaluation.
5.9 It is recognised in draft Policy DS2(S) and its supporting text, that bringing forward strategic development (e.g., new settlements) requires extended lead-in times and relies on the delivery of significant new infrastructure. Indeed, East West Rail and the associated new station to serve the proposed Kempston Hardwick new settlement, are not expected to be completed before 2030. For this reason, the Draft Local Plan does not anticipate delivery until the latter part of the Plan-period
5.10 In this context, it is welcome that the Plan also allocates sites that can deliver new housing earlier within the Plan-period. This is necessary to comply with NPPF paragraph 60, which requires that “…a sufficient amount and variety of land can come forward where it is needed”, to support the Government’s ongoing objective of “significantly boosting” the supply of homes. Diverse sources of housing supply will also be needed if the Plan is to prove effective in sustaining a five-year housing land supply, in accordance with NPPF paragraph 74.
5.11 The southern expansion of Wixams (as is envisaged in draft Policy HOU15) provides one such opportunity for early delivery. Growth at this location allows for a continuation of existing development strategies and avoids the need to start anew. Clear masterplanning principles have already been established and have guided development at Wixams for many years4. Furthermore, existing cross-boundary governance mechanisms already exist in the form of the Wixams Joint Development Committee, which comprises Members from CBC and BBC.
5.12 There is now much more certainty that a new Train Station will be delivered at Wixams, with the proposals having progressed to the ‘Stage 2b’ design-stage in 2021. In January 2022, BBC selected the preferred design for the station and indicated that it intends to bring forward a planning application, to allow construction by 2024. It is then highly likely that the proposed train station will be brought forward, thereby creating the opportunity to deliver new sustainable development at Wixams in the short-term.
5.13 These precedents will facilitate timely delivery, which is a fact that distinguishes the proposals on Land South of Wixams from other proposals within the broader South of Bedford strategy (as per draft Policy HOU12), that may take longer to bring forward.
Compliance with the Tests of Soundness
5.14 Overall, Wates supports the proposed spatial strategy, in so far as it seeks to provide for further strategic growth through new settlements, balanced by the expansion of existing settlements, alongside a portfolio of other smaller allocations throughout the Borough. This approach is justified and consistent with national planning policies, which require Local Plans to promote sustainable patterns of development. Conversely, the inclusion of a portfolio of smaller allocations will support housing delivery throughout the Plan-period, thereby facilitating the effectiveness of the Plan overall.