4.1

Comment

Representation ID: 9376

Received: 29/07/2022

Respondent: Huntingdonshire District Council

Huntingdonshire District Council's observations on the proposed development strategy. HDC note the reason for pursuing option 2bi over option 2a but still express concern over the deliverability of HOU19.

Comment

Representation ID: 9618

Received: 26/07/2022

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

We note that the growth locations are to be within the urban area, next followed by strategic locations adjacent to the urban area and which contribute to the delivery of key green infrastructure projects and at new growth locations which are focussed along the EWR/A421 transport corridor with potential for rail-based growth, especially in the south of Bedford area and a new settlement at Little Barford.

A number of allocations have come forward within the current Local Plan 2040; however, it is not currently clear how many dwellings these allocations would be able to accommodate, either in total or individually. We maintain that it is essential the Council over-allocates housing land to ensure flexibility, choice and competition in the housing market, reflecting government guidance. We maintain that a mix of smaller and medium-scale sites can be delivered at a faster rate than the larger, allocated sites. These sites, such as our clients, which were submitted in the Call for Sites exercise but not taken forward, form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow Councils to continuously maintain a healthy and constant supply of deliverable sites, especially where there has been such an increase in the housing need figure.

Our previous representations on prior consultations for the Local Plan 2040 has suggested that whilst a larger proportion of housing and employment growth should be focused on the urban area, growth should also be located within the rural areas. We note that Policy DS2(S) Spatial Strategy point xi considers that “The completion of strategic Key Service Centre and more limited Rural Service Centre residential development identified in Local Plan 2030 on sites which are allocated in neighbourhood plans and the completion of Local Plan 2030 Policy 27 Land north of School Lane, Roxton.” We maintain that development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. Alongside promoting housing, this would ensure that rural areas received an appropriate level of growth to maintain and enhance economic vitality, and the services and facilities required would be maintained. As previously highlighted, this approach would take into account Paragraph 79 of the NPPF to promote housing growth in the rural settlements of the Borough. More housing in rural areas would maintain their vitality, including the retention of services and facilities that depend on economic growth, promoting greater and more sustainable development.

The draft plan maintains its reliance on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, as highlighted in previous representations, we maintain that any delays to emerging neighbourhood plans could stall the delivery of housing within the Borough. We maintain that those which have been ‘made’ are based on the Local Plan 2030 housing need of 970 dwellings per annum; considering the significant increase in housing need, these ‘made’ neighbourhood plans are likely to require reviewing. In addition, we reiterate that Neighbourhood Plans are not subject to the same stringent examination as Local Plans, and therefore, the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.

Object

Representation ID: 9755

Received: 27/07/2022

Respondent: De Merke Estates

Agent: Neame Sutton Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

This section addresses the housing requirement and Spatial Strategy set out in Section 4 of the Pre-
Submission Plan.
Housing Requirement
2.2 The starting point in addressing the housing requirement is the Government's standard method (NPPF
2021, para.61). The National Planning Practice Guidance (NPPG, para.002, ID 2a-002-20190220) reiterates
that the standard method identifies the minimum, annual housing need figure, but does not provide the
housing requirement. Paragraph 61 of the NPPF (2021) goes on to state that, in addition to the local
housing need figure, any need that cannot be met within the neighbouring authorities, should also be
accounted for in establishing the housing requirement.
2.3 Being part of the Oxford to Cambridge Arc, Bedford is likely to experience the effects of significant
economic and infrastructure growth, such as an inward population migration and resultant higher housing
need. Coupled with this is the Duty to Cooperate Position Statements (April 2022), where all five of the
neighbouring districts (Central Bedfordshire Council; Huntingdonshire Council; Luton Council; Milton
Keynes Council; North Northamptonshire) acknowledge the likelihood of the need to provide an uplift in
housing requirements to meet the Arc, which will necessitate cooperation.
2.4 The Duty to Cooperate Position Statements document highlights that the neighbouring authorities have
not to date, had sight of the Pre-Submission Plan, and for the moment, the document simply identifies the
potential strategic, cross-boundary matters. Whilst there is evidence to suggest that the Council has been
engaging in Duty to Cooperate meetings, the Pre-Submission Plan and housing requirement remains
unadjusted, as the minimum, standard method figure (1,355 dwellings per annum).

Spatial Strategy
2.5 The Spatial Strategy is taking forward one of the four growth options previously considered by the Council
in the Regulation 18 Strategy Options and Draft Policies Local Plan (Option 2b). The growth locations are:
• Within the urban area.
• At strategic locations adjacent to the urban area.
• At new growth locations focused on the EWR/A421 transport corridor with the potential for railbased
growth, particularly in the south of the Bedford area and at a new settlement at Little
Barford.
2.6 The Council’s preferred strategy fails to take advantage of the opportunity presented by the EWR corridor
to the north of Bedford, particularly in Clapham. The corridor has been defined on the Key Diagram
(Fig.12) and the route to the west has been significantly advanced, therefore, it is evident that this railway
route will be delivered. Clapham benefits from excellent transport links and several services, yet its
expansion is not considered in the preferred growth option.
2.7 Given the likelihood of the EWR being delivered and the change in landscape that will occur as a result,
the Plan has failed to consider the option of further growth opportunities in the vicinity of the proposed
corridor. This is a failing of the Plan. Such an opportunity exists at Clapham, where the proposed route
will release land for development, which should have been explored by the Council.
TC1(S) Hierarchy of Town Centres – De Merke Estates agrees with the Settlement Hierarchy, where
Clapham is identified as a Key Service Centre. The Council has previously allocated 500 homes to
Clapham, recognising its locational sustainability.

Comment

Representation ID: 9887

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

2. Plan Period
2.1 With regard to the plan period the Council will need to consider paragraph 22 of the Framework which was published after the start of the consultation. It states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure.
Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.2 The Plan sets out a significant level of development and new settlements and/or significant extensions to South Bedford. Given the scale of development, the strategy chosen, the stepped trajectory and ambitious annual delivery rates we consider the 400 dwellings that are shown to be post 2040 is an underestimate. We consider that the plan should be extended to 2050 if the
current proposed strategy involving new settlements is adopted.
2.3 A further point on why the plan period should be extended to 2050 is the consultation on the Arc Spatial Framework. Paragraphs 1.9 and 1.10 of the consultation paper for LP2040 states:
“1.15 In response to this, and in order to create a more joined up and legible process, some local authorities in the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. Government, however, has urged Councils in the Arc to carry on with plan-making and, in Bedford Borough’s case, the consequences of not doing so could be significant for the reasons relating to policies becoming “out of date” described above; so local plan work in Bedford Borough continued.
1.16 Whilst this local plan has emerged alongside rather than after the development of the Arc Spatial Framework, it shares many of the overarching principles relating to a focus on climate change, economic growth and the natural environment..”
2.4 We agree that LP2040 should progress and not be delayed by the Arc Spatial Framework, but we do question whether the two plans will be aligned on the key matters, one of which is the plan period with the Arc Spatial Framework planning to 2050 yet the LP2040 to 2040. This approach is different to other authorities within the Arc which are aligning emerging plans for the period up to 2050, such as West Northamptonshire.

Comment

Representation ID: 9935

Received: 28/07/2022

Respondent: Trakbak Racing Limited

Agent: WSP

lease see supporting covering letter which sets out amendments required in order for the plan to be made sound.

This cover letter sets out that Trakbak Racing LTD agree with the council’s assessment that the following six sites, 1002, 529, 531, 527, 519 and 532, are not suitable for a housing allocation. Trakbak Racing LTD object to the allocation of these six sites because their allocation would be contrary to paragraph 35 of the NPPF which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF.

These representations also explain that the ‘Spatial strategy and Site allocations’ chapter of the emerging local plan be amended, with Santa Pod Raceway (SPR) allocated under a specific policy allocation which reflects the primacy of the venue and looks to support its future growth. Further to this, to protect SPR from the effects of inappropriate housing development proposals on its business, it is explained that an exclusion buffer zone for residential development around SPR should be outlined in policy. This would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with, and therefore ensure the soundness of the emerging Bedford Local Plan 2040.