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Form ID: 3338
Agent: Gladman Developments Ltd

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4.4.1 The Plan needs to actively enable economic development and growth, prioritising central government projects that have local, regional and national implications, such as the Oxford-Cambridge Arc. Following the completion of Phase 3 of East-West Rail, the connectivity of Bedford will be significantly enhanced. The Plan therefore needs to take a mixed approach to the location of new housing, in order to fully capture the benefits associated with this critical infrastructure investment across all communities. 4.4.2 With the cross-boundary effect of the Oxford-Cambridge Arc, and under the Duty to Cooperate, Bedford Borough should state how it intends to work with all neighbouring authorities and for cohesiveness, the other 30 local planning authorities within the Arc Group that they have previously committed to working with13. The approach to fulfilling the Duty to Cooperate should be regarded as a vitally important consideration from the earliest stages of the plan making process and communicated through the Council’s consultation material in a transparent manner. There will also be a need to consider whether the Borough can assist in accommodating unmet housing needs arising from London because Bedford and the surrounding area benefits from being within reasonable commuting distance of the capital, particularly when aligned with the likelihood of an increased trend in home working over the course of the plan period. 4.4.3 Gladman encourage the Review to be undertaken on a ‘boundary blind’ basis in order to fully recognise and reflect the way people live their lives across local authority boundaries. The nature of connections between places in this area and future infrastructure projects like East-West Rail will have impacts across authorities and will be central to developing a sustainable strategy for the growth of Bedford Borough over the plan period. It will be important for this to be fully recognised by the Council and its neighbouring authorities, working under the Duty to Cooperate, as the process of reviewing and updating multiple local plans is undertaken.

Form ID: 3339
Agent: Gladman Developments Ltd

4.5.1 Gladman agree with the ambition of the East-West Rail through Bedford being complete and other infrastructure associated with the Arc, but suggest that the vision should also embed an ambition to have fully supported opportunities for associated economic development and growth. For instance, how will housing be incorporated into Bedford’s vision? And how does Bedford’s vision embrace and express the relationship between East-West Rail and the location and trajectory of housing development? 4.5.2 Gladman are concerned with the approach to housing through neighbourhood plans and its potential impact on delivery. There is a contradiction between supporting the growth of the Arc and East-West Rail, and neighbourhood plans that provide housing in “areas of tranquil retreat”. While Gladman would also encourage quality in design, it would be helpful to explain how neighbourhood areas will contribute towards the quality and quantity of growth necessary for the borough and the wider Arc. At the time of writing, it is notable that from the 20 designated neighbourhood areas, only 5 plans have been submitted and 2 ‘made’.

Form ID: 3340
Agent: Gladman Developments Ltd

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4.6.1 Gladman agree that a 20-year period would be suitable as it is in line with the 15-year minimum set out in national policy. However, the plan period should be considered in the context of long-term ambitions for the Oxford-Cambridge Arc area that extend beyond 2040. For instance, Milton Keynes have suggested a strategy extending to 2050.

Form ID: 3341
Agent: Gladman Developments Ltd

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4.7.1 Gladman support a combined approach to the potential locations of growth outlined by Bedford Borough. To meet housing need and capture the socio-economic benefits of the infrastructure associated with the Oxford-Cambridge Arc throughout and beyond the LPA, Gladman suggests proportionate growth in settlements across the hierarchy, sustainable urban extensions and new settlements. In order to ensure choice and competition in the market and to support and secure sustained levels of housing delivery, housing should be planned at settlements across the hierarchy. It will therefore be necessary for the housing requirements of neighbourhood areas to be revisited and/or for the Council to allocate land in these locations through the Local Plan Review. 4.7.2 The Planning Practice Guidance (PPG) highlights that “A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness15.” All settlements within the borough boundary have the potential to contribute towards the overall development requirement and there is a need to plan to ensure that services can be maintained and enhanced in these locations to meet the day to day needs of residents. A study of the sustainability credentials of settlements across the hierarchy should therefore be undertaken to fully explore the potential of these settlements to accommodate modest levels of growth, factoring in demographic information over the duration of the plan period and the availability of day-to-day services and facilities. Indeed, the NPPF 2019 sets out that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services16. Furthermore, the retention and development of accessible local services and community facilities should be enabled by planning policies and decisions. 4.7.3 It is important that the local plan enables the delivery of a wide range of sites in order to support the delivery of housing at the levels that are required by the Standard Method. The approach should embrace the need to support sites of all sizes. It is important not to overly rely on large scale strategic locations for growth; by enabling the widest range of sites across settlements throughout the hierarchy, Bedford will maximise delivery and satisfy housing need in the borough. 4.7.4 As the Planning Practice Guidance (PPG) highlights, “A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.

Form ID: 3342
Agent: Gladman Developments Ltd

4.8.1 It is recognised that Bedford’s central location within the Oxford-Cambridge Arc will provide the opportunity to plan for strategic improvements to road and rail infrastructure in the area. Infrastructure planning for the Local Plan Review should however also embrace a wide range of community and social infrastructure, including that associated with an increased prevalence of remote and home working. The spatial strategy should positively seek opportunities to improve the sustainability of all settlements in the Borough by fully exploring the role that new development can take in supporting the delivery of new community infrastructure and the sustainability of existing facilities as set out in paragraph 4.7.2 above.

Form ID: 3343
Agent: Gladman Developments Ltd

4.9.1 As of 2018, Oxford Economics reported that Bedford’s productivity was approximately £45,000 GVA per head, £5,000 lower than the national average19. This emphasises the importance of the Oxford-Cambridge rail infrastructure provision in enabling connectivity to other cities, to support an increase in GVA per head. In order for Bedford to maximise its socio-economic potential, it should invest in housing in both existing settlements and new settlements. Growth in housing will mutually support the growth of employment sites.

Form ID: 3344
Agent: Gladman Developments Ltd

4.10.1 As set out in our responses to the previous questions, the local plan’s spatial strategy must provide settlements across the hierarchy with the opportunity to benefit from opportunities associated with growth, including improved connectivity to other economic centres through East-West Rail. A balanced approach to housing distribution will assist in in improving the value of the economy across Bedford Borough.

Form ID: 3345
Agent: Gladman Developments Ltd

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4.11.1 Gladman always encourage the sustainable development of housing developments to mitigate against climate change. The Council should continue to take account of climate change and continually update guidance in relation to the NPPF, PPG and other central government guidance. 4.11.2 Stakeholders within the property and construction sectors would welcome regular updates to reflect such changes and to communicate the LPA's position on new technology for housing that could help to mitigate climate change. 4.11.3 Gladman encourages that any updates on technological or policy responses to climate change be centred around the three pillars of sustainability (economic, social, environmental) so as to create balanced and reliable solutions.

Form ID: 3346
Agent: Gladman Developments Ltd

4.12.1 Gladman believe that there is no local evidence or need to exceed the national standard. Central government are undertaking a detailed exercise to develop new standards sufficient across LPAs.

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