Issues and Options

No

25. The Issues and Options Paper includes a list of eight bullet points which set out the proposed scope of the Local Plan Review. The absence of any reference to the Oxford – Cambridge Arc is a significant omission. 26. As set out above, the context underpinning the preparation of Local Plan review, not to mention reason behind the requirement for an early review, is the need to sustainably facilitate the economic and housing growth that is required to support the Government’s ambitions in respect of the Arc. As such, the scope must explicitly refer to developing a strategy to achieve this aspiration.

27. The absence of any explicit reference to the Cambridge - Milton Keynes - Oxford Arc within the draft Vision is a significant omission. As set out in our response to the first question, the context underpinning the preparation of the Local Plan review, not to mention the reason behind the requirement for an early review, is the need to sustainably facilitate the economic and housing growth that is required to support the Government’s ambitions in respect of the Arc. As such, an aspiration to fulfil this task must be front and centre of the vision for 2050. It is therefore essential that the vision is amended to make the following key points: • Bedford Borough falls within Oxford – Cambridge Arc, a sub-region that will have experienced significant economic growth and is recognised globally, alongside areas such as Silicon Valley, as a hub for high-tech and science investment. • The significant level of economic growth will have been accompanied by a commensurate increase in housing and necessary infrastructure. This growth will have been achieved in a sustainable manner that protected and enhanced key natural, built and historic environments.

I do not agree with this plan period

28. The need for an early review of the Local Plan is in large part due to an acknowledgement that the recently adopted Local Plan does not appropriately respond to the longer term growth requirements of the Oxford – Cambridge Arc. As set out earlier in these representations, the Government’s ambitions in respect of the Arc initially relate to the period up to 2050 and, as announced in the March 2020 Budget, involve the preparation of a Spatial Framework to cover that period. On this basis it would be prudent for the Local Plan Review period to cover 2020 to 2050. 29. As discussed in our response to the Question 4 (below), there will unquestionably be a need to allocate one or more new settlements in order to achieve the increased housing requirement resulting from both the standard methodology for assessing housing need and the further uplift required to achieve the Government’s aim of delivering up to one million new homes within the Arc by 2050. New settlements necessarily have longer lead in times than smaller developments and as such it is logical to ensure that the plan period is sufficiently long to cover their delivery and/or to enable them to make a significant contribution to the housing requirements of the plan period(particularly where considerable upfront infrastructure is necessarily required).

Red – New settlement based growth

30. The consultation document lists seven potential options for housing and employment growth, namely: • Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites • Expansion of the Bedford / Kempston urban area • Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots • Development along the A421 corridor • Development around an East West Rail northern station • New settlements in locations with good accessibility • More dispersed development throughout the borough including the expansion of villages. 31. Our position in respect of the potential options for growth is set out below. However, it important to preface this with a brief discussion of the step change in housing requirement between the adopted 2030 Local Plan and the Local Plan Review, the scale of which is likely to require a spatial strategy comprising (regardless of anu other option), the allocation of new settlements, and this is the approach being advocated here. Housing Requirement The housing requirement in the adopted Bedford Local Plan 2030 is 14,550 dwellings for period 2015 to 2030 (970 dwellings per annum). In contrast, the current standard methodology for assessing housing need generates a minimum requirement of 1,305 dwellings per annum, an increase of 35% on the adopted figure. It is noted that BBC suggest, on page 18 of the Issues and Options Paper, that a reduced figure of 800 dwellings per annum could be required if the standard methodology was revised to utilise the 2018-based calculations. This is RAPLEYS LLP 6 considered extremely unrealistic as even before the consultation on the new standard methodology began in August 2020, the Government had clearly indicated that the purpose of the revising the methodology would be to significantly increase the overall housing requirement for England. 32. The figure generated by the standard methodology is expressed as a minimum, as Planning Policy Guidance (PPG) advises that there are circumstances under which it would be appropriate to plan for a higher housing need figure than the standard method indicates (e.g. areas subject to growth strategies). Given that Bedford Borough falls within the Oxford - Cambridge Arc which is considered a key economic priority by the Government, it is reasonable to assume that a significant uplift to the minimum requirement of 1,305 dwellings per annum will be required. It is noted that BBC state, on page 7 of the Issues and Options Paper, that work on the Local Plan will focus solely on the housing requirement generated by the standard methodology. This is an entirely unacceptable position as one of the key reasons behind the need for an early review of the Local Plan 2030 is the stated acknowledgement that it fails to appropriately respond to the longer term growth requirements of the Oxford – Cambridge Arc. 33. Notwithstanding the implications of the arc, which clearly need to be addressed, the minimum annual housing requirement generated by the current standard methodology itself would result in an overall housing requirement of: • 26,100 dwellings for a plan period comprising 2020 to 2040 (the minimum period); or • 39,150 dwellings for a plan period comprising 2020 to 2050 (our recommended plan period). 34. The Issues and Options Paper indicates that, at the time of writing, existing commitments in the Borough total around 11,000 dwellings. This will therefore require the Local Plan Review to allocate as a minimum, without any additional allowance in respect of the Arc, sufficient land to accommodate between 15,100 and 28,150 dwellings (depending on the plan period). In contrast, the Local Plan 2030, once commitments were taken into account, was only required to allocate sufficient land to accommodate 3,169 dwellings, which were distributed as follows (the total new allocations for the plan equate to 4,470 dwellings): • Bedford Urban Area: 2,647 dwellings (of which 1,900 dwellings are to be delivered by 2030) • Urban Extensions: 210 dwellings • Stewartby Strategic Brownfield Allocation: 1,000 dwellings (of which 100 dwellings are to be delivered by 2030) • Key Service Centres: 2,000 dwellings • Rural Service Centres: 260 dwellings. 35. In respect of the above, it is important to reiterate that when the CGV allocation (2,500 dwellings by 2035) was removed from the emerging Bedford Borough Local Plan in 2018, the Council did not allocate alternative sites to address the shortfall as would normally be expected. Instead, a decision was made to shorten the Plan period from 2035 to 2030, thereby reducing the overall housing requirement. This indicates that there is not a bank of readily available development sites within the Borough. Potential Options for Growth 36. The step change in growth set out above necessitates a fundamental rethink of the spatial strategy contained in the adopted 2030 Local Plan (and in this context we are advocating the creation of new settlements). The key points to note being: • Bedford / Kempston Urban Area: The Bedford / Kempston conurbation is the main settlement within the Borough and contains services and facilities which mean that it is a sustainable location for new development and that intensification should clearly be a component of the spatial strategy. However, in the recently adopted 2030 Local Plan, the area accommodated approximately 47% of the dwellings allocated for delivery within the plan period (2,110 of the 4,470 dwellings). Carrying that proportion forward in the Local Plan Review would require the allocation of land sufficient to accommodate between 7,097 and 13,230 dwellings (depending on the plan period). This is clearly unrealistic, irrespective of which strategy is selected. RAPLEYS LLP 7 • Stewartby Strategic Brownfield allocation: The site comprises former brickworks allocated for 1,000 dwellings, of which only 100 are expected to come forward within the plan period. A greenfield extension to the site may be possible, but even if the extent of the allocation were doubled the delivery of a further 1,000 dwellings would only comprise 6.6% of the 15,100 dwelling requirement or 3.6% of the 28,150 dwelling requirement. • Key Service Centres: In the adopted Local Plan Key Service Centres (i.e. 8 large villages) are expected to deliver approximately 44% of the new allocations within the plan period. Carrying that proportion forward in the Local Plan Review would require the allocation of land sufficient to accommodate between 6,644 and 12,386 dwellings (depending on the plan period). This is an average of between 830 and 1,548 dwellings per village which is clearly both unrealistic and undesirable, irrespective of which strategy is selected. 37. Based on the above, it is clear that the level of growth that the Local Plan Review will be required to deliver, will necessitate a new spatial strategy involving the allocation of one or more new settlements. As the Issues and Options Paper acknowledges, the advantages of new settlements are: • “Potential for sustainable growth using garden village principles, creating self-contained new communities with good infrastructure provision. • Would reduce the amount of development that must be accommodated in other locations. • Detached ‘rural’ setting enable property construction and create ambiance which higher value occupiers aspire to. • Provides opportunities for sustainable and active transport links, both between new settlements and to the urban areas.” 38. In terms of potential locations for new settlements, CGV is the standout candidate, whether one or more new settlements are needed. It was one of four new settlements considered during the preparation of the Local Plan 2030, but was the only one to be identified as a proposed allocation in the January 2018 Regulation 19 Submission Version. 39. It is acknowledged that the CGV allocation was subsequently removed from the Local Plan due to BBC concerns in respect of noise mitigation and deliverability of the railway station. However, as set out earlier in these representations, the recent Call for Sites submission includes information which both addresses those concerns and demonstrates that the reasons that led to BBC to propose the allocation of CGV remain the same today, namely the ability to deliver a genuinely sustainable development with the provision of a new railway station. Therefore, CGV should from part of the spatial strategy for the Review Local Plan.

40. In respect of infrastructure provision generally, it is essential that new development is supported by the social and physical infrastructure required to ensure that it is sustainable. This can often be difficult in situations where sites seek to ‘plug into’ and / or improve local infrastructure that may already be over capacity or in less than optimal locations. In contrast, proposals for new standalone settlements, such as CGV, are able to ensure that all of the homes, facilities, and employment development necessary for a truly sustainable settlement are provided in the right locations at the right time. 41. In respect of infrastructure issues within Bedford Borough, two of the key issues impacting potential growth are the capacity issues at Bedford station and the congestion issues on the A6 into Bedford particularly from the north. The CGV proposal helps to rectify both these issues through the delivery of a parkway station, mitigation measures at A6 junctions and improvements to the bus service on the A6 corridor.

42. Our response to this question relates solely to the Colworth Science Park, (which is surrounded by the CGV promotion site and was included as part of the Colworth proposed allocation in the previous Local Plan process), a leading site for commercial research and development. It is home to Unilever’s Scientific Research in discovery, central product safety, sustainability and global product development activities as well as a range of other growing business organisations and academic research groups. The proposals for CGV include the provision of around 7 hectares of land to allow for future expansion of the Park.

43. Please see our response to Question 5.

COMMENTS ON LOCAL PLAN REVIEW SUPPORTING DOCUMENTS 44. A review of the three available supporting documents has been undertaken and brief comments are set out below. HOUSING & EMPLOYMENT LAND AVAILABILITY ASSESSMENT (HELAA) 45. The Stage 2 Site Assessment section lists the circumstances under which site may be excluded from consideration on suitability grounds. This includes sites that: "Do not relate well to the structure of the settlement and existing facilities. In many cases, to relate well will mean that the site should be within or adjoin the settlement policy area or the urban area, or be within the built form of a defined small settlement. This is particularly important for residential development proposals." 46. The rationale behind the criteria is clearly to exclude sites that are some distance from existing facilities and are therefore result in unsustainable travel patterns. However, the current wording could have the unintended consequence of excluding sites being promoted for new settlements, one of the potential growth options set out in the Issues and Options Paper. These sites may not be well related to existing facilities, but the proposal would be for standalone settlements which include the new facilities required to serve their residents and do not therefore result in unsustainable travel patterns. The criteria should be amended to address this point. SUSTAINABILITY APPRAISAL SCOPING REPORT AND SITE SELECTION METHODOLOGY 47. The Site Selection Methodology contains a set of questions against which each site that the HELAA determines to be deliverable or developable will be assessed. These questions are taken from the Sustainability Appraisal Scoping Report. 48. As with the HELAA the rationale behind the questions is understood and supported. However, the wording of several questions needs to be amended to ensure that they can be applied fairly to proposals for new settlements. For example, question 1b asks whether the site is: “Accessible on foot to a food store? The accessibility by foot to the nearest food store is calculated for each site using TRACC computer software.” 49. A site proposed for a new settlement could potentially score poorly as it may be the case that the nearest existing food store is further than 30 minutes’ walk. This would ignore the fact that a new food store may be part of the development proposals. In contrast some of the questions are worded in a manner that allows the RAPLEYS LLP 9 potential provision of onsite facilities and infrastructure to be taken into account. For example, question 7b asks whether the site is: “Within 800m of a sports facility or proposing a sports facility within it?” 50. The wording of the each of the questions needs to be reviewed to ensure that, where applicable, they allow for the potential on-site provision of the applicable facility / infrastructure item. CONCLUSIONS 51. These representations seek to advance the case for the allocation of Colworth Garden Village (‘CGV’) as a new settlement option within the Local Plan Review. The key points can be summarised as follows: 1. The Government has identified the Oxford - Cambridge Arc as an economic growth corridor that is fundamental to the future economic success of the United Kingdom. 2. The Government has set out a clear ambition to build upon the emerging successes evident within the Arc to ensure that it becomes globally significant (a UK version of ‘Silicon Valley’). They recognise that central to this ambition is the delivery of the homes (up to one million new homes by 2050) and infrastructure necessary to support sustained economic growth within the sub-region and in the areas immediately beyond. This view is shared by Bedford Borough, as evidenced by The Oxford-Cambridge Arc: Government Ambition and Joint Declaration issued in March 2019. 3. The need for an early review of the Local Plan is in large part due an acknowledgement that recently adopted Local Plan does not appropriately respond to the longer term growth requirements of the Arc. It is therefore of critical importance that the key objective underpinning the Local Plan Review is supporting economic growth that is significant in both a national and international context. Every aspect of the Local Plan Review should acknowledge and be driven by this ambition. 4. The standard methodology for assessing housing need and the need to address the Government’s ambitions in respect of the Oxford – Cambridge Arc will result in a significant step change in the housing requirement between the adopted 2030 Local Plan and the Local Plan Review. This will necessitate the allocation of one more new settlements in the Local Plan Review. 5. Colworth Garden Village is the standout candidate in terms of potential new settlements. It was one of four new settlements considered during the preparation of the Local Plan 2030, but was the only one to be identified as a proposed allocation in the January 2018 Regulation 19 Submission Version. Furthermore, the concerns raised by BBC in respect of deliverability have now been addressed.