Issues and Options

No

Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (henceforth: the Respondent) consider that the scope of the Local Plan review should be expanded to consider changes to a number of older policies. Specifically, Policy AD23 contained in the Allocations and Designations Local Plan (ADLP) (adopted 2013) which allocates land at Bedford River Valley Park (BRVP) for ‘enabling development’ to deliver the consented water sports lake. Representations to this effect have already been submitted on behalf of the Respondent as part of the Call for Sites exercise. Those representations set out in greater detail the amendments that are considered necessary, however, for ease of reference, these arguments are briefly summarised here. Policy AD23 allocates land at BRVP to deliver development across a range of uses. This allocation serves as ‘enabling development’, the funds from which will be used to deliver the consented water sports lake. The uses permitted by Policy AD23 do not currently include residential development, however for the enabling development to generate sufficient funds to deliver the water sports lake residential development will be necessary. This is a result of the viability of the enabling development being impacted by various changes in circumstances since the ADLP was adopted, relating to both site specific matters and wider economic and social transitions, including to the planning policy context of the wider area, which has moved on considerably since the original allocation was adopted, particularly in respect of the need for new housing in the Borough. The representations provided as part of the Call for Sites exercise enter into greater detail on this matter and should be read in conjunction with this response. A Vision Document has also been provided in support of these representations and is enclosed herewith. The Vision Document provides an insight into how the water sports lake could be delivered in conjunction with residential development, an educational facility and a local centre, and demonstrates that a high-quality and thriving leisure amenity can be created. The water sports lake represents an opportunity to turn BRVP into a highly sought after and valuable leisure resource that will bring inward investment and will also benefit the local population through improved connectivity and leisure opportunities. However, to fund the delivery of the water sports lake, it is necessary to update Policy AD23 contained in the ADLP to reflect the impact of the aforementioned circumstances on the viability of the ‘enabling development’.

The Respondent supports the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live, and commends the Council’s strategy to deliver more multifunctional green spaces and Green Infrastructure. The Respondent also supports the Council’s vision that the Forest of Marston Vale will continue to grow and mature, and that, together with the completed BRVP, this part of the Borough will be transformed through new leisure opportunities, encouraging increased visitor numbers The Vision document provided in support of these representations demonstrates in greater detail how the water sports lake and associated infrastructure could be delivered at BRVP, and it is clear that a high quality leisure amenity that improves the overall quality of the Forest of Marston Vale Landscape could be created; this would also contribute significantly towards Green Infrastructure in the area. By updating Policy AD23 contained in the ADLP and unlocking the viability of the water sports lake, Bedford River Valley Park would make a significant contribution to the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live.

Brown – Urban based growth , Yellow – A421 based growth , Grey– Dispersed growth , Red – New settlement based growth

The Respondent considers that the ‘Yellow – A421 based growth’ strategy is logical. Development in this location corresponds with development at BRVP and would serve to enhance the connectivity and range of services/amenities in this location. BRVP’s location alongside the A421 makes it an ideal location for delivering the water sports lake and will ensure that is eminently accessible for motor vehicles as well pedestrians and cyclists. With regard to the ‘Brown – Urban Based Growth’ strategy, the Respondent considers this to be logical. This strategy would see Bedford expand eastwards towards BRVP. This would improve connectivity between BRVP and Bedford and would mean that the water sports lake is eminently accessible for those living within Bedford. It would also mean that potential future residents of BRVP are able to seamlessly access services, facilities and businesses within Bedford town centre. Development at BRVP would also overcome the limitation to his strategy insofar as opportunities for growth within urban areas are limited. BRVP is only located a short distance from the urban area of Bedford and offers an opportunity to deliver a substantial number of dwellings that would be strongly associated with Bedford. Turning to the ‘Grey – Dispersed growth’ strategy, the Respondent considers this to be a rational strategy. Dispersing growth more widely around the area will improve access to services and amenities for more people and would lessen the overall impact of development in terms of pressure on existing services and amenities. As part of this dispersed strategy, growth at BRVP would make total sense insofar as it located close enough to Bedford to take on a proportion of the significant amount of growth required within and around Bedford. The delivery of new education facilities and a local centre would also be a significant benefit to the surrounding smaller settlements, most notably Cople and Willington. Lastly, in respect to the ‘Red – New settlement-based growth’, the Respondent considers this a sensible strategy and one which development at BRVP aligns closely with. As noted previously, BRVP is sustainably located and there are ample opportunities to create connections for walking and cycling. Coupled with the delivery of an education facility and local centre, development at BRVP is an excellent opportunity to create a new self-contained and sustainable settlement centred around a valuable amenity resource in the form of the water sports lake. The Vision Document which accompanies these representations sets out in more detail how development at BRVP could be delivered as a new self-contained and sustainable settlement that will also provide significant amenity enhancements to the surrounding area Regardless of the growth strategy chosen, the Respondent considers that the strategy should make allowances for the delivery of development at BRVP. The delivery of the water sports lake in conjunction with residential development at BRVP has been demonstrated by the Vision Document as being wholly logical, beneficial and should be facilitated by the Council as a result.

The Respondent considers that Green Infrastructure is key to the delivery of sustainable growth in Bedford Borough. Development at BRVP, and specifically the water sports lake, offers an opportunity deliver a substantial and high-quality area of Green Infrastructure that will benefit local people as well as those from further afield. The range of activities the water sports lake could offers would provide a monumental bolstering to the range of amenity opportunities available around Bedford and would be a resource that could serve to support other development throughout the area. The benefits and importance of delivering Green Infrastructure is arguably more pronounced than ever by virtue of the continuing trend towards home working. As this trend continues to gather pace, accessible Green Infrastructure within walking distance of people’s homes will be critical to meeting their day-to-day amenity requirements. The water sports lake at BRVP will provide an attractive and enjoyable amenity provision within walking distance of Bedford and which will greatly enhance activity choices for local people.

The Respondent considers that the Local Plan Review fails to adequately plan to meet the Borough’s Local Housing Need as derived from the ‘Standard Method’ - a new version of which is currently being consulted on - and the does not properly plan for implications of the Oxford-Cambridge Arc or East-West Rail. This is at odds with the Government’s objective of significantly boosting the supply homes as per paragraph 59 of the National Planning Policy Framework (adopted 2019). It is likely that the Local Plan Review will have to plan for an unprecedented level of housing growth in the Borough with the annual local housing need requirement under the Government’s updated Standard Method being some 1,153 dwellings per annum. This is a significant increase over the current Local Plan housing target of 970 dwellings per annum. Consequently, a substantial amount of new land will need to be allocated for housing. On this basis, and coupled with the need to accommodate for future growth as part of the Oxford-Cambridge Arc, which itself requires that up to a million homes are delivered in the Arc by 2050, the delivery of new homes in this area is a matter to which significant weight should be attached. The Vision document articulates in greater detail how the water sports lake could be developed in conjunction with a high end, attractive residential scheme set within the attractive confines of the circa 800ha BRVP landscape. An assessment of site constraints and a land budget exercise have informed the Concept Plan contained in the Vision Statement and it is considered that the site would be capable of accommodating circa 700 – 850 ha dwellings based on an assumed low – medium density range. This is a substantial number of dwellings that would contribute towards the Council’s challenging housing need and which would also facilitate the delivery of the water sports lake. The Respondent would also highlight the geo-environmental benefits that will accrue from the development, in addition to other environmental benefits outlined. Part of the site is known to be contaminated and the delivery of the development will facilitate the remediation of the contaminated land, constituting a significant local benefit.

The draft vision is duly noted for wanting this Borough to become a greener, more sustainable and more attractive place to live. Matters such as climate chance appear to be at the heart of the vision to mitigate its effects through the inclusion of green infrastructure, energy efficiency, flood risk reduction and so on. Also notably included within the vision is the benefits brought about by the Ox-Cam Arc, which currently is derived from the progression of the East-West Rail. Furthermore, the consultation paper continues on to acknowledge the Arc is a key economic priority and the Government ambition for up to one million homes by 2050. The East-West Rail and the new expressway as part of this project are already coming into fruition; however, the paper raises questions about the progress of the Arc’s strategy for housing growth. It summarily dismisses the need for additional housing due to the Arc, stating “little progress has been made” on how the strategic growth will be delivered. In short, this plan focuses solely on Bedford Borough’s own growth requirement which is claims will be a significant challenge due to a potential “35% increase in the annual level of housing growth contained in the Local Plan 2030”. The matter of how many houses this plan should accommodate is covered in more detail later in this response; nonetheless, the inclusion of the benefits of the Arc and consideration as to how best to capture such benefits for the Borough residents remains a key question at this stage for this Review, surprisingly. Surely, if the infrastructure required for such growth is being implemented, then a spatial strategy itself is imminent for the Arc. This consultation itself acknowledge the need for appropriate infrastructure prior to accommodating significant growth. Yet, this Authority makes no attempt to query its citizens on what they believe should be a suitable vision in this respect. Certainly, even if accommodating a one third increase in the level of housing will be a challenge, surely this Council must now at least make attempts to help facilitate growth for when a strategy is realised. This is indeed the motivation and justification for the inclusion of Policy 1 within the currently adopted Plan. The examining Inspectors, as explained in the paper, set out that “there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible” (emphasis added). At best, this Authority should make full provision to accommodating further, projected growth given its fundamental location at the heart of the Arc. At worst, it should seek the views of its communities, residents and businesses on the matter as part of this, or any future, consultation to fully assuage whether this is truly unfeasible at this stage rather than irresponsibly dismiss planning for the Arc altogether.

Nothing chosen

The most crucial elements of growth to include as part of a spatial strategy going forward would be for increased levels of rural growth. To date, and as is proposed under some potentials options for growth, the Bedford and Kempston rural area has always been subject to significantly higher levels of housing growth with many settlements, including the sustainable Key Service Centres, receiving a very small proportion of planned growth under the previous plan (now superseded) and currently adopted plan. The implications for sustainability in this context are very clear, and indeed are listed within the pros and cons for the potential growth options. Urban based growth presents increasingly limited opportunities for developers to assist in meeting the objectives of sustainable development. Beyond high density schemes, very little alternatives exist to realise the level of growth that would be required as part of this Local Plan Review within the Bedford & Kempston rural area. This includes development on the urban fringe which in turn would encourage less sustainable transport methods as these would require significant further investment to facilitate a continued outward expand of the urban area. Urban based growth would equally starve more rural locations of much needed growth -housing or employment – while in turn risking the buildup of urban sprawl. Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. In incorporating dispersed growth as part of a strategy, many rural communities, such as Oakley, would continue to be well-connected places without experiencing overdevelopment (as would be inevitable if Bedford & Kempston continued to receive a proportion of growth in line with that allocated currently/previously). Infrastructure equally would only require incremental improvements as compared to strategic level enhancements to facilitate a more spread out growth option which is more viable and has fewer impacts on the natural environment (in terms of air quality, visual impact, etc.). Dispersing growth further allows for rural centres to retain and enhance their vitality and improve the quality of living in these areas in line with what they are capable of accommodating thereby securing a more vibrant Borough as compared to a single, densified urban area that rural communities become entirely dependent upon.

Public services and sustainable transport infrastructure will remain the most significant required that will enable the Borough to achieve the requisite levels of growth. In dispersing growth across the Borough, facilities and services as schools, doctors, etc., are more readily secured incrementally in locations that can sustain them via developer contributions in a manner that does not overwhelm the communities that need such infrastructure. As aforementioned, the Settlement Hierarchy Background Paper notes several rural settlements as containing an already appreciable level of sustainability in this context, and as such it would not be remiss to continue to expand on and improve existing provisions in areas capable of supporting them further. One key way to enhancing sustainable transport connectivity would be improve links to the major transport hubs within the Borough – at present, and in the future to thereby including the East-Wail Rail, such that the benefits of greater connectivity to places such as Oxford and Cambridge are better captured across the Borough instead of being centralised to strictly where the East-West Rail station will be. Doing so would present people and communities with the opportunity of living in vibrant, rural communities with exceptional employment opportunities not only limited to the Bedford and Kempston Urban area but to also include the wider, regional destinations. The major rural settlements of the Borough contain a reasonably integrated transport network across the Borough with the urban area, and as such reduces the need for strategic level new or improved infrastructure. It therefore makes sound planning sense to look towards further significant development in locations such as Oakley.

Currently, policy inhibits any housing growth beyond in the rural area which is not planned for as part of Neighbourhood Plans. Together, the implementation of a Settlement Policy Area which restricts rural growth and the increasingly limited options for growth within the Bedford and Kempston urban area lead to situation wherein currently adopted policies, unintentionally or otherwise, fail to sufficiently accommodate growth in a manner that is commensurate with Paragraph 170 of the NPPF. Paragraph 170(a) states that Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Paragraph 170(b) requires that those policies and decisions recognize the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. The terminology used above is very clear in that non-valued landscapes should not be protected and instead be recognized. A number of policies across the country which have come into conflict with the NPPF for blanket protection of the countryside have been ruled inconsistent with Paragraph 170(b) for this reason. Whilst this may not be the case here, it is evident nonetheless, that the scope within which one can bring forward development to enhance the vitality and wellbeing of local communities is extremely limited despite the sustainability credential of some of the more major rural settlements in the Borough. Certainly, windfall sites should they come forward never intend to compete with allocated / Neighbourhood Plan sites. They provide housing growth in addition the minimum levels of growth that the Borough must deliver and, where they constitute sustainable development, they often fall foul of very technical considerations such as Settlement Policy Area. Whilst relevant for considering when specific policies (such as Policy 7S) may come in to play for applications and proposals, it has had the inadvertent consequence of severely restricting levels of growth that may be in line with Paragraph 170(b), but will fail to completely account for other policies, to include that of Paragraphs 77 and 78 on rural growth which do not specify that an identified need (as set out in Policy 7S0 is required to ensure rural vitality. This is particularly so when this Council must duly take account the planned levels of growth for the Borough due to revisions in Standard Methodology; issues with affordability; the Ox-Cam Arc; and even the specific context within with this Government views proposals that boost the supply of housing even when authorities demonstrate a 5YHLS. These are all matters expanded on below.

The Local Plan Review fails to adequately consider this Borough’s Local Housing Need as derived from the Standard Method, which in any event is undergoing consultation for proposed changes to its methodology in line with increased levels of planned growth by central Government, in addition to the full implications of the Oxford-Cambridge Arc. This is prior to accounting in any way for the Government objective of significantly boosting the supply homes as per paragraph 59 of the NPPF. Presently, the standard method falls short of meeting the 300,000dpa which the Government has said should be the national annual housing target. The target of building 300,000 homes a year on average in the UK was and remains the founding principle of the Government’s ‘Standard Method’ which was implemented as part of the revised National Planning Policy Framework. This was an effort to standardise house-building targets across the country in an effort to genuinely address the housing needs of real people in real need now. This is now being addressed by the government going forward as evidenced in the White Paper “Planning for the Future” and “Changes to the Current Planning System” which expressly sets out that the government will review the formula for calculating Local Housing Need such that it corresponds to instead to a 337,000 dpa figure (twice the average level of growth in this country). No doubt this Authority is fully considering the implications of the White Paper and revisions to the SM, and as a matter of course will duly consider whether there will be a need to transfer over toward a new form of development plan that considers the predefined “growth, renewal and protection” areas envisaged for new Local Plans in future. Nonetheless, and question that is relevant here and now is that the SM revisions invariably means LPAs across the country will need to deliver more housing against future LHN than what it is identified as at present, including Bedford Borough. This is against the context that Bedford currently faces increasing house prices and increasing monthly rents all set against a backdrop where rates of development has fallen below planned levels. In respect of house prices, the average house price paid in Bedford is £300,477. When compared to an average income of £29,411, an average priced home in Bedford costs 10 times more than an average household earns, meaning affordability is a significant barrier to many people wishing to acquire a suitable home. The lower quartile house price ratio stands at a similarly staggering 10.61 times household income and means that many people at the lower end of the market are pushed into the private rented sector, often with poorer living conditions and insecure tenancies. This situation is fundamentally against Government ambitions to make housing more affordable for everyone, which is why affordability remains a key adjustment factor in the Standard Method, and against ever increasing house prices (despite even the consequences of the current pandemic) it is only reasonably expected that the Council’s LHN will continue to increase in future years due to this factor alone. Coupled with the need to accommodate for future growth as part of the Oxford-Cambridge Arc, which itself aspires to up to a million homes are delivered in the Arc by 2050. Most of the arc is free from constraints like Green Belt, AONB or European protected habitats. Housing delivery on a much larger scale will be planned for in this area. The delivery of new homes in this area is a matter to which significant weight should be attached given this vision for growth by Government and it is unacceptable to this Council to be seeking to meet need as low as potentially “800” homes per year on the basis that the Ox-Cam Arc-wide spatial strategy not being agreed. The East-Wail Rail is progressing in a timely fashion – such that this Council must consider how to best capture the economic benefits of it – is evidence enough that despite there being no clear guidance at present on what is intended for the Arc in terms of housing, these are expected in the very near future and most certainly within the proposed plan period. Current housing targets are at 970 dwellings per annum, shooting to well above 1,000 dpa benchmark due to the Standard Method alone. The supposition that this Council need not plan for a housing figure over and above its own requirement is nonsensical against the above context, and when viewed in the additional context of paragraph 59 of the NPPF. Para 59 sets out ambition for the significant boosting of the supply of homes in this country – an objective which can only be achieved once the minimum levels of growth has been accommodated for. It is an ambition that is further reflected in a recent appeal decision taken by the Secretary of State relating to Land Off Audlem Road / Broadley Lane, Stapeley, Nantwitch (ref: APP/R0660/A/13/2197532), and Land off Peter De Stapeleigh Way, Nantwich (ref: APP/R0660/A/13/2197529). Within the decision letter (DL) at DL28, the SoS accords significant weight to the benefit of delivering new market housing thereby significantly boosting the supply of homes as per paragraph 59 of the NPPF. This is notably in the context of the relevant LPA being able to demonstrate a deliverable five-year supply of housing land. This local authority is also once such authority that claims to have a five-year housing supply of land. Yet, it will flounder and fail to secure even the minimum levels of housing growth over the proposed plan period until 2040 unless it duly accounts for the increasing unaffordability of housing that is explicitly due to such low planned levels of growth, the Ox-Cam Arc, the objective of boosting the supply of homes, and the overall incoming revision to national policy which revises national housebuilding targets to double the average housebuilding rate in the country. Plainly, these are all matters that relevant now and must be accounted for as part of this review.