Issues and Options

No

1.1 The local plan review should focus predominantly on the key strategic plan-making issues which have been derived from the updated development needs of the area, to provide a strategy for accommodating the appropriate requirement of housing and employment space. Such an approach is in line with the guidance set out in the recent White Paper and the fact that the development management policies which currently sit alongside the spatial strategy in the Local Plan 2030 have only recently been adopted, and are therefore likely to remain fit for purpose. 1.2 As such, reviewing the adopted development strategy and considering where land should be made available to meet identified housing and employment needs should be the focus of the revised Local Plan. This is consistent with the conclusions of the Inspector in finding the Local Plan 2030 sound. 1.3 Whilst the approach of the Council will need to be refined once the emerging requirements of the White Paper work their way through to national policy, it is encouraging that the Issues and Options Paper suggests that the Local Plan will make such land allocations to ensure the identified need will be met. However, the scope also suggests that a number of other very detailed topics will be addressed, which we suggest have the potential to take focus away from the primary purpose of the review. Particularly in light of the recommendations set out in the White Paper, we suggest the review should avoid dealing with such policies, which would be better addressed through neighbourhood plans where appropriate. 1.4 The scope of the review set out in the Issues and Options document does not explicitly address the fact that the scale of future housing and employment need will need to be reviewed. Whilst it is touched on under the spatial strategy, we feel that the quantum of development to be planned for is key and should be given more prominence in the scope of the review. 1.5 As is indicated in the document (page 16), the Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per year across Bedford Borough. At this time, it should be this level of growth, as a minimum, that the Local Plan seeks to provide. The Issues and Options Paper goes on to suggest a review of the Standard methodology may see the housing need figure drop to 800 dwellings per year. 1.6 The White Paper sets out the revised standard methodology and this indicates that the revised method would give a minimum housing needs figure of 1,153 per year, just below that of the current standard method – but in excess of that which forms the basis of the adopted Local Plan (970). Land west of Wyboston 1.7 Until the consultation on the revised standard methodology is over, we suggest that the current standard methodology figure of 1,305 dwellings per year should be seen as the starting point for the review. This would require that the plan review sets out to accommodate a minimum of 15,000 1.8 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations) with addition land identified to provided flexibility and contingency in supply. 1.9 The second key issue not fully addressed in the questions is the extent to which the ambitions for the Oxford to Cambridge Arc are addressed in the review. Whilst there is currently no arc-wide spatial strategy, progress has been made on a number of key infrastructure projects in the area and there is a clear intent from the Government to drive forward growth in the Arc. 1.10 As part of the most recent Budget announced in March 2020, it was confirmed that: The government has designated the corridor of land connecting Oxford, Milton Keynes, Bedford and Cambridge (the OxCam Arc) as a key economic priority. Earlier this year, the government announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… The Budget announces plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the OxCam Arc. This will support the area’s future economic success and the delivery of the new homes required by this growth up to 2050 and beyond. The government is also going to examine and develop the case for up to four new Development Corporations in the OxCam Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge, which includes plans to explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development.” 1.11 It is therefore clear that the Government remains committed to the Arc with the expectation being that there will be significant residential development to support the economic potential of the area. 1.12 Alongside the Government’s statements on the Arc, policy 1 of the adopted Local Plan requires the Local plan review to address Arc related issues. This suggests that the scope of the Local Plan review needs to give more emphasis to assessing the implications of Arc related policy announcements and infrastructure investment decisions. This is particularly important given the Government’s specific reference to a Development Corporation for Bedford, which we consider could have within its remit the delivery of a new settlement, such as that which Taylor Wimpey are proposing. 1.13 There are likely to be further announcements in relation to the Arc over the course of reviewing the Local Plan which the Council will need to be aware of and be in a position to respond to within the scope of the review. Additionally, the implications of the White Paper will also need to be considered within the scope. 1.14 One such implication is the potential abolition of the Duty to Co-operate. Whilst this is likely to be a positive as it will remove one of the legal tests to plan-making, the White Paper is clear that there will still be a need to consider strategic cross boundary issues through plan making. It states: Land west of Wyboston the Duty to Cooperate test would be removed (although further consideration will be given to the way in which strategic cross-boundary issues, such as major infrastructure or strategic sites, can be adequately planned for, including the scale at which plans are best prepared in areas with significant strategic challenges) 1.15 In this regard, the scope of the assessment needs to address the close relationship between Bedford Borough and Central Bedfordshire, including along the A1 corridor which is a key area of infrastructure investment. The proposed revisions to the standard methodology push Central Bedfordshire’s housing need up to 2,752 per year, significantly above the current level of need being planned for, which is likely to be difficult for them to accommodate. Therefore, it will be imperative that the scope of the review is expanded to ensure that cross boundary issues are sufficiently addressed.

2.1 The current Vision set out on pages 13 and 14 of the Issues and Options document is currently very general with a lack of detail as to how and where growth will occur across Bedford Borough. 2.2 Decisions will still need to be made about the spatial strategy and therefore, as this early stage it is difficult for the vison to articulate what the area will be like at the end of the plan period. However, as a general point, we consider that as the review moves forward the Vision should be made more specific and paint a more detailed picture of the expectations for growth and development by 2040. 2.3 Whilst there is reference in the Vision to town centre development and development in rural areas these are the only spatial elements to the vision. We believe, in due course, the Vision should be clear about expectations for a new settlement, give it is likely one will be integral to the future strategy for the area, alongside other types of growth. 2.4 It would also be helpful if objectives are provided alongside the vision in the draft of the Local Plan. These will enable the Council to add more detail to the vision and be more specific about what the Council are seeking to deliver over the plan period.

I do not agree with this plan period

3.1 We consider that an end date for the plan of 2040 generally accords with the NPPF (paragraph 22) requirement which sets out that the strategic policies for an area ‘should look ahead over a minimum 15- year period form adoption’. Assuming the current timetable is followed then an end date of 2040 would satisfy this requirement. 3.2 However, Taylor Wimpey advocate the review looking beyond 2040 which a) ensures the 15-year requirement can be achieved in light of any programme slippage and b) reflects the nature of growth which is likely to be included in the reviewed Local Plan. 3.3 As already set out, Taylor Wimpey are promoting a new settlement which could deliver up to 10,000 new homes. Given the lead in time with any new settlement, it is likely that should a new settlement be included in the strategy it would not be completed by 2040. It would therefore be sensible to consider the contribution the spatial strategy could make to development needs beyond 2040. 3.4 Irrespective of the end date of the revised Local Plan, it is considered that a plan period which starts at 2020 is appropriate given that that this will be the base date for the evidence gathered to support the Plan.

Nothing chosen

4.1 The Issues and Options document correctly concludes that the current development strategy will not deliver sufficient growth to meet the anticipated needs over the longer period that the Local Plan will need to provide for. It is therefore right that the Council are looking at various options that could deliver additionality over the plan period. 4.2 In looking at the options, it is important not to forget work already undertaken and what can be learned from this. In this regard, it should be remembered that in preparing the adopted Plan, new settlements were considered but not taken forward and the implication was that the plan period had to be shortened in part due to the lack of other sustainable options. This indicates that should a deliverable and sustainable new settlement location be identified; this could deliver additionality over the plan period. 4.3 Secondly, the adopted plan places a reliance on Neighbourhood Plans to deliver a proportion of the housing need at Key Service Centres, a strategy which to date has not delivered. This means it is likely the review will have to pick up allocations in those areas where Neighborhood Plans have not progressed, which should have been made in the adopted Local Plan. 4.4 The implication of this is that it will be difficult for the review to direct even more growth to the Key Service Centres when the last round of growth has yet to be planned. This exacerbates the need for an alternative strategy and places increased emphasis on the importance of a new settlement. 4.5 Whilst Taylor Wimpey advocate a strategy which has an element of dispersed growth to ensure a variety of sites are available to the market, the scale of growth that needs to be delivered and the constraints associated with significant growth in existing sustainable locations, means that ‘New Settlement Based Growth’ has to be given serious consideration through the review. 4.6 It is of note that of the six spatial options set out in the Issues and Options document, five indicate that land to the west of Wyboston could be a suitable opportunity for development. 4.7 The urban based growth option refers to possible extension of St Neots, to the west of the A1. Whilst a new settlement west of Wyboston would not be considered as an extension to St Neots, in this location it would be well related to the town and could be planned with strong linkages between the two ensuring they are mutually beneficial. Land west of Wyboston 4.8 West of Wyboston is also adjacent to the A421 corridor along which it is noted that road based public transport could be enhanced. As is set out in the accompanying Vision document, it would be expected that a new settlement in this location would be built around a strong public transport network with improved access to the A421 for residents. 4.9 In relation to rail, the land west of west of Wyboston lies to the north of the preferred route for the new east west rail route between Bedford and Cambridge. It therefore could be the perfect location for an additional station north of Bedford, if one were one to come forward. Equally, the land is also in close proximity to the area identified for a new station on the intersection of east west rail and the east coast mainline in the St Neots/Sandy area. A new settlement west of Wyboston could easily be liked to this station via direct public transport, aiding the sustainability of the location. 4.10 Lastly, the Issues and Options document correctly identifies land west of Wyboston as one of the four possible locations for a new settlement. For the reasons set out in our call for sites submission and built on in the accompanying Vision document, in all regards, west of Wyboston is the most suitable location for a new settlement given the area’s strategically important location in relation to key transport links, combined with limited physical and policy constraints to development. Additionally, the extent of land now assembled by Taylor Wimpey will allow us to deliver a truly sustainable settlement. 4.11 In reviewing advantages and disadvantages associated with the various types of growth set out in the Issues and Options document, it is apparent that there are disadvantages associated with each of the options put forward. However, it is clear that those disadvantages associated with new settlements can be readily overcome in relation to land west of Wyboston. 4.12 In terms of deliverability, whilst a new settlement will inevitably take a long time to deliver, assuming smaller, deliverable site allocations are made as part of the revised strategy (including those to meet the lack of Neighbourhood Plan allocations) short term delivery should not be an issue. There is a presumption that a new settlement would start delivering towards the end of the plan period and support delivery in years beyond 2040. However, by this time, it is likely the local plan will have been reviewed again, providing an opportunity to top up land supply as necessary. 4.13 In the case of Wyboston, the involvement of Taylor Wimpey as a major PLC housebuilder, delivering around 16,000 news homes annually, hopefully also gives confidence that progress on the delivery of a new settlement in this location would be expedited compared to other schemes put forward by land promoters only. Additionally, our work to date on the site indicates that whilst investment in infrastructure enhancements will be needed to release the whole site (as will be the case with all potential new settlement sites), around 2,500 dwellings could be provided in the shorter term with minimal infrastructure enchantments. This means that west of Wyboston could make a contribution towards meeting housing need sooner than may be expected. 4.14 It is accepted that a new settlement could impact local landscapes, but as is set out in the Vision document, land to the west of Wyboston does not lie in a sensitive landscape and is well suited for development. The masterplan included in the Vision document shows how up to 10,000 new homes could be accommodated on the assembled land alongside significant new green spaces and structural landscaping which would help integrate the development with its surroundings. Land west of Wyboston 4.15 It is also accepted that significant new infrastructure may be required to allow growth to be accommodated. Again, of all the options for new settlements, this points towards land west of Wyboston being ideally located given its proximity to recent and future infrastructure enhancement including: • The enhanced A421, • The upcoming enhancements to the Black Cat roundabout • East West Rail • Future improvements to the A1 4.16 In relation to the issues identified as part of the previous promotion, Taylor Wimpey are keen to work with the Council to understand any concerns and provide comfort that a sustainable development in this location is deliverable. It is important that any promotion is backed-up by appropriate evidence and Taylor Wimpey are committed to engaging with the appropriate stakeholders to ensure this is provided when required.

5.1 As noted in relation to question 4, Bedford Borough has already seen significant investment in infrastructure with the upgraded A421 along with a commitment to East West Rail and enhancements to the Black Cat roundabout within the next plan period. There are also improvements in nearby authority areas with the new A428 link, improvements to the A1 and proposed new station in the Tempsford area. 5.2 It is therefore important that it is not just infrastructure enhancements in the Borough which are considered when looking at the strategy. Understanding the plans in adjoining authorities and the improvements that they will bring is also important, particularly in the area around Wyboston which is close to Central Bedfordshire and Huntingdonshire and areas of potential development. 5.3 It should be recognised that Wyboston as a settlement has the existing benefit of a good infrastructure network with its strategic positioning. This is a key consideration in helping to realise the potential of the development and aiding early delivery of units. It also facilitates integration into the existing community from the start. 5.4 As noted earlier, it will be important that even if the duty to co-operate is removed by the Government, cross boundary working remains an integral part of the plan making process to ensure coordinated plans are prepared and any future investment in infrastructure is targeted where it can have maximum benefit for the wider area. 5.5 In this regard, it will be important to talk to neighbours and key stakeholders about (for example) enhancements to the A1, M1 junction 1 and potential railway stations north and east of Bedford, each of which could free up development potential in Bedford Borough and the wider area.

6.1 The areas close to key transport corridors are the logical locations for additional employment growth in Bedford Borough. This includes the corridors along the A421 and A1 and close to new railway stations. 6.2 Land west of Wyboston is therefore ideally located to accommodate an element of employment land as part of a sustainable settlement. The type and amount of employment floorspace would need to be considered in more detail as part of the evolution of the settlement and the suitability and availability of opportunities elsewhere in the Borough, but there could be scope for a technology park, which we understand is a desire of the Council, or more locally orientated opportunities, possibly logistics benefiting from access to the A1. 6.3 The aspirations for the Arc are largely predicated on the economic potential of the area driven by the world class universities in Oxford and Cambridge. In this regard, it needs to be recognised that as well as creating employment opportunities in the Borough, the overall development strategy has to consider the fact that a large proportion of new residents will commute out of the area to work, particularly to Cambridge given its proximity. 6.4 Again, this supports residential development in the area west of Wyboston from where Cambridge will be accessible by both road and rail within the plan period.

7.1 As noted above, it will be important that new residential development is located close to the key pieces of infrastructure which provide access to the key economic centres to the east and west of Bedford. 7.2 It is also important that there is a variety of housing types and locations to satisfy the needs to the residents who are likely to choose to live in and around Bedford and travel elsewhere to work. Many residents who will travel out of Bedford for work may be in management or highly skilled work and will have expectations as to the type of home they want and the location. In many cases, this is unlikely to involve living in high density developments tagged onto the edge of the main urban area of Bedford. 7.3 Creating environments in which these people want to live in is key to increasing the value of the economy of Bedford. It is key that high quality environments with access to good schools, open spaces and community facilities, are created to avoid people travelling elsewhere to spend their disposable income. Notwithstanding this point, good design should promote accessibility for all, providing opportunities for commuting via sustainable modes of transport. 7.4 As will be set out in the accompanying Vision document, in principle the development of a new settlement provides the opportunity to create an environment fit for 21st century living, responding to the current and future demands of the population in a way that urban extensions or individual developments cannot. 7.5 The adoption of Garden Village principles at Denybrook Green, as the new settlement is named, combined with the scale of the opportunity provides real scope create such an environment in a location with strong links to Cambridge as well as Bedford. 7.6 As noted elsewhere in this representation the area is in a location where it could provide for new, strategic employment land, including a science/technology park, linked to the ongoing expansion of the knowledge-based economy in the Arc. Given Green Belt constraints around Cambridge and strong links between the areas, west of Wyboston could be an appropriate location for a technology park for spin off businesses which cannot continue to be accommodate closer to the university town. 7.7 Along with the other locational benefits of land west of Wyboston set out elsewhere in this response, this adds to the rationale that of all the possible locations in the area for new settlements, that promoted by Taylor Wimpey is the most appropriate and logical.

8.1 As set out in response to question 1, we consider that the focus of the Local Plan review should be on the overall spatial strategy and not development management policies. The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy and not something that is deferred to ‘further guidance’. 8.2 Paragraph 149 of the NPPF states the Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. This means spatial strategies should avoid directing development to those areas which are more vulnerable to the impacts of climate change, and ensuring that adaption measures, such as new green infrastructure, are built into plans. 8.3 Ensuring the spatial strategy is robust with regards to climate change is therefore key, rather than the provision of detailed guidance for developers. 8.4 In addition to directing development to the less sensitive areas of the Borough, ensuring development is well located in relation to transport infrastructure will be key, as will creating environments which provide a real choice for those wanting to walk or cycle as an alternative to the car. Again, this points to west of Wyboston and the development of a purpose-built new settlement as a key part of the overall strategy. 8.5 As part of the development of a new settlement, best practice in the layout of development and the design of buildings can be picked up to ensure factors such as orientation, massing and landscaping contribute to minimising energy consumption. However, particularly in light of proposal in the White Paper, the setting of standards to be achieved by new development in Development Management policies should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.

1.0 Introduction 1.1 This Issues and Options representation is made on behalf of Taylor Wimpey UK Limited who have land interests in Willington and Wilstead. Separate call for sites submissions have been made for each of these sites. 1.2 Land at Balls Lane, Willington is located on the western edge of the village. It has the potential to deliver up to 150 new dwellings and new green infrastructure to re-enforce the Forest of Marston Vale. 1.3 The site has been promoted for allocation through the emerging Willington Neighbourhood Plan which is being developed by the Parish Council and has also been submitted to the Bedford Borough Council Call for Sites July 2020. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 2 1.4 Land east of Luton Road, Wilstead is located at the southern gateway into Wilstead with good connections to the A6. The village has a good range of facilities. The site has the capacity to deliver approximately 69 dwellings and associated infrastructure. 1.5 This site has been submitted to the Bedford Borough Council Call for Sites July 2020. A planning application was submitted for the site in 2019 which was later refused in December 2019, a resubmission application was then made at the end of July 2020 which has addressed the previous reasons for refusal. This is currently pending. 1.6 This representation is structured around the 13 comments which are set out in the Issues and Options Paper. However, only those questions that are relevant to Taylor Wimpey’s land interests have been answered.

No

The main purpose of the Local Plan Review should be to confirm the revised development needs of the area and decide where employment and residential growth should be focused. 2.2 The development management policies in the adopted Local Plan have only recently been adopted and whilst these should be reviewed to ensure they are consistent with the National Planning Policy Framework (NPPF) 2019, they are likely to generally remain fit for purpose to guide decision making. 2.3 The Local Plan 2030 Inspector suggested that a review of the adopted development strategy and the identification of new allocations to meet housing and employment needs should be the focus of the Local Plan Review. 2.4 The list of topics in the Issues and Options document suggest that the Local Plan will mainly focus on growth and infrastructure, which is supported. 2.5 However, the list also suggests a number of far more detailed policy areas, such as the control food outlets, which are at odds with the suggestion that the main focus will be on growth and infrastructure. Whilst my client does not have a view of the need for such policy areas to be addressed, these would be better picked up in a general review of development management policies to avoid the focus being taken away from the high-level spatial issues that are integral to the soundness of the Local Plan. Such an approach would also appear to be consistent with the recent Housing and Planning White Paper which suggested policies on detailed topic matters would be set out at a national level rather than in local plans. 2.6 The questions outlined in the Issues and Option document does not address two key issues related to the scope of the Local Plan review and the spatial strategy - the level of housing growth and the implications of Bedford Borough’s location as part of the Oxford to Cambridge Arc. Level of Housing Growth 2.7 Firstly, the overall quantum of housing growth to be planned for should be a key part of the scope of the Local Plan Review. 2.8 The Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per annum over the period to 2040, which is noted on page 16 of the Issues and Options Document. 2.9 However, the Issues and Option Consultation Document goes on to note that the Standard Methodology for calculating housing need could end up using the 2018 Household Projections (replacing the use of the 2014 projections) and that as a result the Local Plan review could need to plan for a housing figure as low as 800 dwellings per year. 2.10 Following the publication of this Issues and Options consultation document, the Housing and Planning White Paper was released on 3rd August 2020 which has provided this expected update Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 4 to the standard method used for calculating housing need. Subject to the outcome of the consultation, the housing requirement for Bedford Borough is now expected to come in at 1,153 dwellings per annum. 2.11 Therefore, the suggestion by Bedford Borough Council in the Issues and Options Consultation Document that 800 dwellings would be the lowest number in the housing range needs to be reviewed immediately and the appropriate development strategy considered in view of this higher figure. 2.12 The plan will also realistically need to plan for 10-20% additional growth above this figure to ensure the minimum need is met (subject to the nature of the proposed strategy and the risk to the delivery of allocated sites). 2.13 Given the Government’s objective of significantly boost the supply of homes, originally set out in the 2017 Housing White Paper and re-iterated in the 2020 Housing and Planning White Paper, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge Arc and the fact that Government confirmed that the 2016-based household projections did not provide an appropriate basis for the standard method, it is unrealistic to suggest that the Local Plan Review should consider such a low housing figure. 2.14 The scope of the Local Plan should therefore be based on providing land to accommodate a minimum of 15,000 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance) in line with the current standard methodology. This would allow the figure to be revised down should the new standard method introduce a small decrease in this figure. As was seen with the preparation of the Local Plan 2030 when the plan period had to be cut, such a change is not possible if insufficient suitable land is identified from the outset. Oxford to Cambridge Arc 2.15 The second key issue which should form part of the scope of the Local Plan review, which is not currently fully addressed in the questions, is Government ambition for the Oxford to Cambridge Arc. 2.16 Policy 1 of the adopted Local Plan 2030 requires the Local Plan review to address Arc related issues. This policy suggests that the scope of the Local Plan review needs to give more attention to assessing the implications of the Arc related policy announcements and infrastructure investment decisions, particularly as they relate to the level of growth to be planned for and spatial decisions. 2.17 Whilst there is currently no arc-wide spatial strategy, progress has been made on a number of key infrastructure projects in the area and there is a clear intent from the Government to drive forward growth in the Arc. 2.18 Notably, in the most recent Budget announced in March 2020, it was confirmed that: The government has designated the corridor of land connecting Oxford, Milton Keynes, Bedford and Cambridge (the OxCam Arc) as a key economic priority. Earlier this year, the government Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 5 announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… 2.19 The Budget announcement included a plan to work with local partners to develop a long-term Spatial Framework to support strategic planning in the OxCam Arc; ensuring both the future economic success of the area and the delivery of the new homes required as a result of this growth up to 2050 and beyond. The government is also in the process of creating four new Development Corporations in the Oxford to Cambridge Arc, at Bedford, St Neots/Sandy, Cambourne and Cambridge, in order to accelerate new housing and infrastructure development. 2.20 It is therefore clear that the Government remains committed to the Oxford to Cambridge Arc, with the expectation being that there will be significant residential development to support the economic potential of the area. 2.21 The position with the Arc is also likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council respond positively and proactively to any announcements to avoid delay in the preparation of the Plan. 2.22 The Oxford to Cambridge Arc should play a key part of the scope of the Local Plan Review.