Issues and Options

3.1 The Draft Vision set out on pages 13 and 14 of the Issues and Options document is generic. It does not focus on key considerations included within the scope of the Local Plan Review such as how and where growth will occur across Bedford Borough. 3.2 Whilst it is recognised that at this stage options still need to be assessed and decisions made about the spatial strategy, Taylor Wimpey UK Ltd consider that future iterations of the Vision should be more specific and set out clearly what the area will be like at the end of the plan period. 3.3 For example, whilst growth which is already planned for in the town centre and to the west of Bedford is included in the Vision, there is no reference to the role of other settlements, how they relate to infrastructure enhancements nor how they will contribute to the overall aspirations for the Borough. This is an omission and will need to be amended in future iterations of the Vision. 3.4 The Vision notes that there will be sensitive development in rural areas which is to be identified through neighbourhood plans. This appears to pre-empt that the Local Plan Review will not plan for growth in rural areas and suggests a degree of pre-determination to a strategy prior to the outcome of the Issues and Options consultation. As will be considered later in relation to Question 5, Taylor Wimpey UK Limited consider that it would be more appropriate for the Local Plan to make strategic decisions about land allocations in rural areas to ensure the deliverability of the plan and because the use of such a strategy as part of the Local Plan 2030 has been unsuccessful in delivering the required homes. 3.5 The use of objectives is commonly associated with a Local Plan vision, setting out what the Local Plan should achieve to make the Vision a reality. The next iteration of the Local Plan should include objectives so that it can be seen in more detail what the Council are trying to achieve over the plan period.

I agree with this plan period

4.1 Taylor Wimpey UK Ltd consider 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. 4.2 Paragraph 22 of the NPPF states that the strategic policies for an area ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.3 Based on this assumption, the revised Local Plan will be adopted in the winter of 2023 and therefore the plan period will run until the end of 2038 at the earliest. 4.4 This assumes that the preparation and adoption of the Local Plan happens in line with the expected timetable, which recent experience has demonstrated can be difficult to achieve. Therefore, a plan end date of 2040 only provides the flexibility of 24 months in the production process to ensure the plan looks ahead 15 years from adoption. 4.5 Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would be more appropriate and would provide flexibility in the timetable.

Nothing chosen

5.1 The Issues and Options document outlines the current development strategy and correctly concludes that it will not deliver sufficient growth to meet the anticipated needs over the longer period that the Local Plan Review will need to provide for. 5.2 As set out under question 1, the standard methodology, and other material considerations, mean that the level of homes that will need to be planned for in the longer term will increase. This means difficult decisions will need to be made locally about where development will be located and may mean some settlements taking more growth than previously envisaged. 5.3 A minimum of 15,000 new homes will need to be delivered over the Plan period (assuming a 2040 end date) meaning land for around 16,500 -18,000 new homes will need to be planned for to ensure delivery. 5.4 It will be key that the strategy for accommodating this housing growth is coordinated with infrastructure investment and the strategy for meeting employment growth needs as part of a sustainable strategy for growth. 5.5 There are 7 locations which have been identified as options for accommodating potential growth in the Issues and Options Consultation document. These are: ● 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. 5.6 Given the level of growth that will need to be accommodated in the area, the strategy will likely need to accommodate components of most of the suggested options. However, there a several key points that Taylor Wimpey believe need to be given consideration in refining the strategy moving forward. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 9 Neighborhood Plan Growth 5.7 In line with policy 4S of the adopted Local Plan, it is likely that in addition to the delivery of new growth, the review of the Local Plan will need to make land allocations in a number of settlements in order to ensure the delivery of the number of homes expected in the rural area as part of the Local Plan 2030.. 5.8 Moving forward, as was set out by a number of parties at the examination of the adopted Local Plan, Taylor Wimpey consider that sites in the rural area should be allocated through the strategic plan rather than deferred to Neighborhood Plans to avoid this situation re-occurring. This will be particularly important if sites in the rural area are likely to make a greater overall contribution to meeting housing need, as may need to be the case given the constraints to development around the urban area of Bedford, including the level of existing commitments. 5.9 Whist there may be scope for Neighborhood Plans to allocate growth in some of the smaller settlements, this approach should only be used for minor development which is not integral to the overall strategy. 5.10 Locations such as Willington and Wilstead, which are located in the A421 corridor and close to the potential East West Rail station area to the east, are strategically important to the overall development strategy and should be the focus of allocations through the Local Plan Review, rather than allocations being deferred to Neighbourhood Plans. A421 based growth 5.11 Taylor Wimpey UK Ltd support a strategy which focuses a proportion of growth along the A421 corridor. The A421 is a focus of employment growth in the area and a key route for movement within and through the Borough. It also provides road access to the key centres of Milton Keynes and Cambridge. 5.12 As referenced in the Issue and Options Consultation Paper, the A421 has seen considerable growth in employment floorspace over recent years given the location in both the Oxford to Cambridge Arc and the M1 corridor. This demand is expected to remain moving forward, particularly in relation to logistics given the ever-increasing emphasis on online sales. It therefore logical for a proportion of future housing growth to be accommodated close to employment opportunities so that they can be accessed easily by employees. 5.13 Whilst employment growth could be accommodated in the immediate vicinity of junctions and close to the urban area, and there may be opportunities for residential development close to the main urban area, there are rural settlements including Willington and Wilstead in the corridor where additional residential growth should be considered favorably and would be a more desirable setting for future residents. 5.14 Outside of the main urban area, Willington and Wilstead are some of the most appropriately located rural settlements to accommodate growth. Both have good access to the A421 from where employment, leisure and retail opportunities can be accessed with ease, including by public transport. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 10 5.15 Physically, both villages are separated from Bedford by the A421 and surrounding villages, meaning the separate identify of both settlements can be protected. 5.16 The adopted Local Plan directs 25-50 homes to be allocated through the Neighborhood Plan in Willington which is identified as a rural service centre. This is consistent with other rural service centres, irrespective of their sustainability and location. 5.17 The adopted Local Plan does not identify Wilstead for housing growth on the grounds that the village has seen significant growth in recent years. However, it is notable that the village is identified a Key Service Centre which is well served by a good range of services and well connected to larger town centres by regular public transport. 5.18 Taylor Wimpey consider that it is important that growth is focused along the A421 corridor moving forward and that the potential of settlements such as Willington and Wilstead contribute to the development strategy for the corridor rather than being subject to a standardised level of growth as was the case in the Local Plan 2030. 5.19 Particularly with regards to Wilstead, the fact that no growth was allocated to the village in the adopted Local Plan, means that of all the Key Service Centres, given its location, it is one of the most appropriate places to direct new development through the review. Dispersed Rural Growth 5.20 Taylor Wimpey support a development strategy which includes growth and development in variety of settlements over the plan period. Taylor Wimpey recognise that strategic scale growth and potential new settlements represent a logical strategy for growth, however alongside this, deliverable growth in sustainable rural locations should be supported as part of a flexible strategy ensuring a mixture of growth typologies. 5.21 In this regard, rural settlements where development can contribute to achieving more than one objective of the Local Plan should be given priority. 5.22 In the adopted Local Plan, as noted above, a ‘one size fits all’ approach was taken to the Key Service Centres and Rural Service Centres, with each allocated 500 dwellings (where allocations were made) and 25-50 homes respectively. Taylor Wimpey suggest that this approach needs to be refined in the Local Plan review and greater development focused on those rural settlements where growth is more suitable and can deliver wider plan objectives. As noted above, this would mean settlements such as Wilstead and Willington would be allocated a greater level of growth than more constrained or less well-located Key and Rural Service Centres. Urban Based Growth 5.23 Taylor Wimpey support the role of urban based growth as part of the development strategy, but growth located on the urban fringe of Bedford should not be achieved at the where it would compromise the character of the urban fringe through the introduction of inappropriate and out of place higher densities. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 11 5.24 In certain locations and in certain site-specific cases, where opportunities are identified through the SHLAA, higher density development may be appropriate but generally increasing densities in new development is likely to be detrimental to the character of the area. 5.25 The urban fringe is generally of rural character, particularly to the north of Bedford where there is limited separation between the urban area and a number of rural settlements and in these locations development should either be avoided or be of a scale and character commensurate with its setting. Rail related Growth and New Settlements 5.26 It is logical for any new settlement to be focused on, or close to, any new rail station on the East West Rail route to the north/north east of Bedford. 5.27 East West Rail will be one of the key infrastructure investments in the area over the plan period and the improved accessibility that the route will provide for new and existing residents should be taken advantage of. 5.28 If a new settlement were to provide part of the development strategy to 2040, it would be illogical for this not to be linked in some way to the East West rail route and be close to other pieces of key infrastructure in the area, including the A421 and A1. 5.29 Taylor Wimpey UK Ltd have submitted a separate representation outlining their aspirations for a new settlement at Wyboston. This recognises that new settlements take a long time to plan and build and require significant investment in infrastructure, as noted in the SWOT analysis included within the Issues and Options Document. Delivery will therefore not be immediate and will not help meet local housing need for a number of years. 5.30 Therefore, whilst they advocate the inclusion of a new settlement in the Local Plan Review, this should not be at the expense of allocations elsewhere as part of a sustainable, flexible and deliverable growth strategy.

6.1 Bedford already benefits from a commitment to East West Rail within the next plan period and upgrades to A421. The ability to focus growth around this key infrastructure has put Bedford Borough in a strong position in comparison to neighboring authorities. 6.2 However, infrastructure should not be looked at on purely an authority by authority basis, with cross boundary working key to ensuring available funding is targeted on those area and projects which deliver maximum benefit for the wider area. As a result, it will be important to talk to neighboring authorities and key stakeholders about potential enhancements to the A1, M1 Junction 13, and railway stations to the north and east of Bedford, which could free up the potential for growth in both Bedford Borough and the wider area. 6.3 At a more local, it will be important that the availability of services and facilities in individual settlements are properly assessed and considered as part of developing the spatial strategy. The ability of large-scale growth in rural centres to improve the viability of existing services should not be downplayed. Similarly, new service provision at a local level resultant from new development which delivers homes along with new services, will help address an existing deficiencies in services in Key Service Centres and Rural Services Centres.

7.1 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations, should these form part of the future development strategy. 7.2 Recognition should be given that the many residents of Bedford Borough travel outside of the Borough for work, especially given the proximity to major employment centres such as Cambridge and Milton Keynes and the ability to reach London via train. 7.3 It is therefore important to ensure that not only are employment sites located in sustainable locations within the Borough, but that the overall development strategy, particularly the allocation of residential development land, recognises that many residents will travel for work. This means it is important the new homes are located in areas such as Willington and Wilstead, with good highway access and in close proximity to rail stations

8.1 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. 8.2 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 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. Many may not want to live in a dense urban extension on the edge of a town, preferring a more rural location with a different lifestyle. 8.3 This adds to the importance of considering locations such as Willington and Wilstead within the development strategy where development is likely to be at a lower density than in the urban area and the lifestyle different to that offered in a town.

I agree

9.1 Paragraph 20 of the NPPF makes it clear that planning measures to address climate change are a strategic matter. Climate change should therefore be at the heart of decisions made in relation to the spatial strategy. 9.2 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 rick and biodiversity. 9.3 At a high level, this means development being avoided in area which are more vulnerable to the impacts of climate change, such as flood plain, and ensuring that adaption measures, such as new green infrastructure, are built into plans. The location of development is therefore the key aspect of how the Local Plan should respond to climate change. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be key to this, as will ensuring there are opportunities for existing rural settlements to remain vital with a range of services and facilities for new and existing residents. 9.4 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF. 9.5 Climate change policy and good practice is changing quickly, there needs to be flexibility to accommodate these changes within the lifetime of any planning documentation. Climate change scenarios predict extensive changes by the end of the earliest plan period of 2040, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 9.6 Needless, stringent policy and guidance may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As noted on page 10 of the Zero Carbon Futures Symposium Report (2019) where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on north facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 9.7 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 16 targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 9.8 Importantly, the scope of any policies may also be limited by the changes proposed in the Housing and Planning White Paper which suggests local polices on matters such as climate change will no longer be appropriate. This reinforces the point that the main influence on climate change that local plans can make is ensuring development occurs in the most appropriate locations and design and layout utilises best practice with regard to energy consumption.