Issues and Options

Yes

3.3 The scope is set out on page 11 of the Consultation Document. De Merke agree with the extent of areas covered, however raise concern that only the policies in relation to the Environment Act would be considered. With Britain leaving the European Union together with the fundamental changes the Government proposes to the planning system in England there are likely to further implications on legislation. 3.4 It is suggested that the scope of the Local Plan Review should consider all relevant legislation changes and revise all policies appropriately. This will ensure the Plan is legally compliant and passes the necessary tests of soundness.

3.5 The draft vision appears, on first reading, to be comprehensive. It however fails to emphasise the need to deliver new homes, in the right places, at the right time, where they are needed most. This has direct parallel into policy on housing strategies including the spatial distribution of new homes. Housing does not appear to be an emphasis on this Local Plan Review draft vision, despite an increase of 335 dpa requirement set out by the current Standard Method. The White Paper on Planning Reform (August 2020) may also result in further changes to the standard method calculation, altering the Plan’s housing requirement. 3.6 The current consultation version of the Standard Method 2 proposed by Government would result in a minimum Local Housing Need of 1,153 dpa, which would still equate to an uplift of at least 183 dpa when compared with the current adopted Local Plan 2030 requirement (a 19% uplift). De Merke Estates Representation 4 Land East of Clapham Road, Clapham, Bedford Issues and Options Consultation Neame Sutton Ltd. 02392 597 139 August Chartered Town Planners info@neamesutton.co.uk 2020 3.7 Housing will therefore continue to be a key emphasis of the Plan and remains at the top of the Government’s agenda for planning particularly in the context of restarting the economy following the national lockdown as a result of the COVID-19 pandemic. 3.8 It is suggested that planning for housing is made a clear, separate, and detailed focus for the vision.

I agree with this plan period

3.9 The plan period is suggested to be 20 years. This plan period is considered suitable, and it is likely that further information about the Cambridge-Oxford Arc and the delivery to the east-west train line would require a further review of the Local Plan review during that time. 3.10 The 20 year plan period should remain.

Nothing chosen

3.11 The Consultation Paper provides 6 individual options for growth. De Merke consider that this is a silo approach to dealing with growth and instead a hybrid approach of 3 options should be considered. 3.12 A hybrid approach is suggested of a single new settlement, intense urban growth where there is existing infrastructure to cater for increased densities combined with a reduced need for dispersed growth across the borough. 3.13 A singular new settlement should be considered. As written within the disadvantages of this option, new settlement requires significant master-planning and supporting planning policy to enable growth of this scale. Proposing 4 new settlements is considered ambitious and therefore for a singular settlement is suggested to take a significant amount of planned housing and economic growth. 3.14 With a single centre for new growth, this will leave a remaining economic and housing need to be met by urban growth and dispersed growth. 3.15 It is logical that the strong and well used existing infrastructure links within the City should support new homes and industry. It is therefore suggested that in urban areas where a higher density of housing would be consistent with the existing character of the area, that the urban fringe is extended to accommodate high density housing. The remaining housing numbers should then be met by settlement growth through a dispersed model throughout the borough, according to the settlements available and planned services, such as schools, medical services and transport links to accommodate new development, as set out in a settlement hierarchy. 3.16 It is suggested that a hybrid approach to the options for local growth which focuses on one new settlement, high density growth around Bedford city and high order settlements in the borough such as Clapham (which relates closely to Bedford) and dispersed growth of the remaining housing requirement based on a settlement hierarchy focused on available and planned services. 3.17 Clapham in particular presents an opportunity for an expanded settlement taking advantage of a good level of local services, facilities, employment and public transport opportunities. The Council has previously assessed the settlement as having a sustainable capacity for at least 750 no. dwellings, yet only 500 no. dwellings were allocated to the settlement in the current adopted Local Plan 2030. The settlement therefore has further capacity, based on the Council’s own assessment, for at least a further 250 no. dwellings and considerably more. 3.18 Alongside a new settlement proposal the expansion of Clapham would offer the opportunity to further reinforce the sustainability of the settlement along with the provision of housing during the early/middle part of the Plan period. This would allow the Council to balance housing supply across the Plan period and whilst any new settlement proposal is gearing up for delivery. 3.19 This option should be explored as part of any sustainable development strategy taken forward through the Local Plan Review. 3.20 Within this context, Land East of Clapham Road, Clapham (see Appendix 1) offers an ideal opportunity for early delivery of sustainable residential development as part of the Local Plan Review together with the potential for high quality employment floorspace in the form of storage and distribution uses to service the growing need for ‘last mile’ distribution that has been fuelled by increased demand for home shopping particularly in relation groceries.

3.21 It is quite clear that the new rail link will be the impetus to further growth. Facilitating and planning around connectivity to rail and road links will be paramount. 3.22 New housing and employment floorspace should be supported by services, some may require enhancement facilitated through Community Infrastructure Levy.