Issues and Options
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New searchHallam Land Management Limited (hereon referred to in our response as “Hallam”) agrees with the proposed scope of the local plan review. However, it is considered that the emerging preferred development strategy will need to be aligned with the Oxford Cambridge Arc spatial strategy as it emerges, which will have implications on the housing requirement for contributing towards the ambitions of the Oxford Cambridge Arc, as well as for meeting the Borough’s own housing needs. The Arc strategy will also have implications on the Borough’s preferred development strategy which will need to be aligned with the Oxford Cambridge Arc and be effective at meeting the Borough’s own growth requirements. Consideration will need to be given also to the potential impacts of Government’s review of the wider planning system. Hallam supports a strategy to accommodate growth that will meet national policy requirements and recognises that this will be very challenging but essential in context of the anticipated changes. The existing Standard Methodology anticipates an increase in the housing requirement from the 970 homes per annum planned for in the adopted Local Plan 2030 to 1,305 dwellings per annum (which will need to be addressed in the Local Plan 2030 to avoid a cumulative shortfall in housing delivery). The Oxford Cambridge Arc, proposed changes to the Standard Method and their impacts of growth requirements are key issues need to be addressed. In this context deliverable options need to be considered to facilitate higher levels of growth in sustainable locations that can deliver growth relatively easily, prior to the more strategic options coming forward. Additionally, Hallam supports the need to address quality of development. This should not however be purely aesthetic but be considered in the context of whole communities – considering how new development delivers quality outcomes for existing residents as well as new residents – supporting infrastructure improvements, the range and quality of community facilities and the offer of local services. Consideration should also be given to how and where new development is best located to help support existing local shops and facilities.
Hallam considers that the draft vision is constrained at present by the absence of a preferred strategy for growth. Spatial elements of the vision are focused on Bedford Town Centre. As a development strategy emerges, we would expect the vision to be more spatially relevant in setting out the priorities for growth at more well defined locations across the Borough to provide an appropriate context for the development strategy, the distribution of housing growth, employment and more detailed policies. With reference to the final paragraph on good design, the focus on sustainable neighbourhoods implies sustainable developments in Bedford and Kempston and in village communities. Such a focus needs to be more holistic and not just about design, but also supporting development with adequate infrastructure development. As such, Hallam considers that the Vision should be that by the end of the plan period, major strides will have been made to greatly enhance the sustainability, infrastructure and quality of life of existing communities through the opportunities delivered for sustainable development in and at existing communities. The focus therefore, should be on sustainable communities not sustainable developments.
Hallam does not agree with the shortest local plan period. Hallam considers that the local plan should be prepared to cover a much longer-term period to be more effective. The plan should cover a plan period suitable for meeting a strategy that is enduring for accommodating growth across the Borough, in a way that meets the needs of the Borough and contributes effectively to growth ambitions of the Oxford Cambridge Arc. A longer-term plan period would allow the Borough Council to plan more appropriately for future strategic development allocations / locations which would in turn inform more strategic and longer-term infrastructure requirements. A shorter-term approach is more likely to repeat the cycle of creating local plans that risk being out of date upon adoption, require immediate review, and generate continued uncertainty about how the Borough accommodates development in the future. Shorter term planning is also likely to only enable infrastructure provision that is more piecemeal, short term, and of insufficient capacity, compromising the Borough’s longer-term future growth potential. Hallam proposes a plan end date of 2050 to align with strategic and infrastructure planning in the Oxford-Cambridge Arc.
Hallam considers that a preferred strategy should combine elements of the options proposed to best achieve the scale of growth that is likely to be required. The weighting or emphasis afforded to these options will be reliant on the development opportunities available and how they can best align with the spatial strategy that will emerge for the Oxford Cambridge Arc. Not one of the options, on its own, has the ability to deliver a comprehensive strategy for future growth of the Borough. A successful strategy must embrace a range of options if the delivery of housing numbers are to be met, that offers an appropriate geography of opportunities. The combination of options must also be designed to ensure that there is a robust trajectory of delivery, which will require a significant number of smaller to medium size opportunities to be commenced and completed prior to major strategic sites in excess of 1,000 dwellings, which are likely to take several years to deliver housing numbers. This will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. While, inevitably, it is understood that the options need to be distinctively defined to provide a picture for consultation, Hallam considers that a number of the options are narrowly defined – potentially unintentionally. Whilst accepting that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford including neighboring settlements that are sustainable, accessible and have capacity for accommodating growth. It is unclear where this key opportunity sits in the Council’s strategy options. Perhaps this most clearly falls within the Brown-Urban based growth option, but equally, would be consistent with the Pink – Rail growth option and indeed would form part of the Grey – Dispersed growth option. Specifically each of these options could and should embrace the opportunities for significant growth and community enhancement at Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). It becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. As discussed in relation to previous questions there are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the village. The potential for Clapham to accommodate future growth, whilst being distinct from Bedford as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham present the opportunity for the Borough Council to encapsulate a Greater Bedford option in its plan preparation and in due course in the plan strategy. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions. A Greater Bedford element to the plan would reflect that ambition and provide a positive framework for investment. Passing reference is made in the Issues and Options report to growth not being directed to larger villages where there are already significant large-scale commitments. This simply is not relevant in the context that the Council faces and given the opportunities for sustainable development in some of those villages (sites allocated and not allocated have been identified in the Clapham Neighbourhood Plan that have been independently assessed as being unconstrained, have the potential capacity to accommodate some 1,000 dwellings plus whilst integrating an extensive green infrastructure and open space network, and supporting community facilities and sustainable connections to Bedford. Both sites underscore Clapham’s potential to accommodate future growth. With regard to the other remaining potential elements of a multifaceted strategy, we would make the following additional observations: • The Pink-Rail growth option should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in the station and in East West Rail – rail related potential is not limited to the south of the town; • The Orange East-West rail northern station option – were it to happen would support more general growth north of Bedford not simply with new settlement options which, in this general area, present a number of difficult issues. It is not correct in any shape or form to argue (as per page 23) that development north of Bedford is unlikely to be possible without a northern station. • The Dispersed option – for further consideration needs to have additional details – specifically not an impression of widespread dispersion but focus on the most sustainable settlements – especially Key Service Villages Including Clapham.
A local plan that considers the long-term growth needs of the Borough and can be aligned with the Oxford Cambridge Arc is fundamental for allowing for investment in infrastructure to be adequate and resilient. Provision aligned with a short-term plan period promotes the risk of securing infrastructure that will be inadequate and compromise the potential for longer term growth. Infrastructure investment in corridors such as the A6 must consider the long-term requirements and how they can be met and therefore, how projects delivered in the shorter to medium term can contribute rather than compromise future growth. As promoters of land at Clapham, Hallam considers that investment in walking and cycling infrastructure and additional support for public transport services will be able to complement longer term investment at corridors such as the A6, and therefore support a more sustainable pattern of growth. Longer term infrastructure planning will make clear the expectations for funding and for securing adequate investment.
Focusing employment, alongside wider strategically important development has the potential to capture the economic benefits that will arise with the Oxford Cambridge Arc. However, it is also important to consider how more indigenous growth can increase the value of the economy in the Borough, not just at Bedford but also at other settlements, particularly in close proximity to Bedford on corridors between Bedford and other key settlements which are important to the economy of the Borough. This underscores the importance of decisions, not only for locating employment land but also for opportunities for home working and community focused co-working hubs.
A preferred strategy for locating employment sites must be aligned with the spatial strategy for the Oxford Cambridge Arc as it emerges. The strategy should be capable of responding to the wider economic development needs of the Borough, not only through the more conventional approach of employment land provision but also in facilitating activities such as working from home and local community facilities that integrate opportunities for co-working. In responding to the Call for Sites, the sites being promoted by Hallam at Clapham have the potential to facilitate more sustainable patterns of living and working within this settlement, with new homes, designed to provide opportunities for home working and to support improvements to community facilities including the provision of co-working facilities.
Hallam considers that efforts to diversify and maximise the accessibility of the town centre will be important for underpinning its attractiveness in the future. Important will be safe and attractive pedestrian and cycle connections and public transport services, which have the potential to connect immediate settlements around Bedford (e.g. Clapham) in addition to the main urban areas of Bedford and Kempston.
Hallam considers that any guidance, whilst having the opportunity to promote good practice for how development can respond to climate change, must be made within the context of national policy and regulations.
