Issues and Options

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Form ID: 2166

Yes

It is noted that the proposed scope of the local plan review will focus primarily on growth and infrastructure (housing, employment and supporting infrastructure). We agree that the focus of the plan should be on these primary strategic issues, particularly in light of the significant growth envisaged in the Borough, and specifically in relation to the Oxford-Cambridge Arc. The Inspector at the adopted Local Plan examination noted the Arc will have significant implications for Bedford, particularly in terms of the need for housing - hence the need for an early review of the plan. The NPPF states that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for housing including affordable housing) and as a minimum, provide for objectively assessed needs for housing and other uses. The plan should ensure that priority is given to identifying sufficient residential sites to meet objectively assessed need. There should be a series of residential allocations that are deliverable and demonstrably available within the plan period - including sites that are available early in the plan period - and located in sustainable locations.

Form ID: 2167

We would suggest the vision should recognise the need to plan positively for new growth and infrastructure, and particularly residential development in order to build upon the wider strategic developments identified. As noted by the Inspector’s Examination Report there is a need for the plan to respond appropriately to longer term requirements, and in particular the Oxford-Cambridge Arc as soon as possible. We agree with the aim of the draft vision to place the challenge of climate change and adapting to and mitigating against its effects -at the heart of new development. We agree with the draft vision’s focus on new multifunctional green spaces to complement the existing network of paths and green corridors. We consider such spaces should be integral to new residential developments wherever possible. It is considered the Vision should lead to a series of objectives which establish how the plan deals with the identified critical issues, which should include the requirement to respond to the significant need in the borough for new housing.

Form ID: 2168

I agree with this plan period

A shorter plan period eg to 2040 will allow the Local Plan to incorporate a vision which is aspirational but deliverable, in line with the requirements of NPPF paragraph 16. Looking beyond 2040 with the level of growth envisaged for the borough and wider Oxford to Cambridge arc is likely to be more challenging than with a shorter timeframe. The Issues and Options Consultation seeks views on a housing figure in the range of 800 –1,305 dwellings per annum. It identifies that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum and that the 800 figure represents an estimate of the possible figure were the standard methodology to be reviewed and based on the 2018-based population projections rather than the 2014-based figures. Taking into account existing commitments, the Issues and Options paper identifies that BBC may need to make new allocations to provide between 5,000 and 15,000 additional new dwellings over a plan period to 2040, depending on the Government’s formula. The consultation should identify a single figure rather than a range in order to meet objectively assessed need, as a minimum. Using current data it is possible to calculate housing need, based on the standard methodology set out in the 2019 NPPF. This utilises two separate data sets. The first is the household projections and second the affordability ratio of earnings to house prices. In this case, Government has set out that the 2014-based household projections should be used as the 2016-based ones do not reflect Government policy to increase housing supply. The latest population projections (2019) continue the trend of reducing population growth in England. It remains to be seen what Government response is to this data and this may have a future effect on the levels of growth. Guidance requires the use of projections for the start year (2020) and for ten years from that start date (in this case 2020). The projections set out a figure of 73,182 households in 2020 and 83,033 in 2030. This equates to a ten year household growth figure of 9,851 new homes required over the ten year period. This requires an average delivery of a minimum of 985.1 new homes per annum for the next ten years. The above figure has to be adjusted to reflect the level of affordability of housing in Bedford. The latest data shows that house prices are 9.82 times the average household income. As such, an upward adjustment has to be made to the demographic figure. Using this adjustment, the total number of new homes per annum required to address affordability increases to 1,343 new homes per annum. It is therefore considered the housing figures identified in the Issues and Options Paper of between 800 and 1,305 dwellings will need to be reviewed. A figure lower than the objectively assessed need would be unsound. Furthermore, given the specific strategic development context of the Borough within the Oxford -Cambridge Arc, this figure should be exceeded.

Form ID: 2169

Nothing chosen

In relation to the wider context of the Oxford -Cambridge Arc, there is a clear imperative to deliver more homes in sustainable locations as well meeting the general wider housing needs. The Government’s longterm ambition for the Arc is to see it as a driver for major economic growth, identifying it has having the potential to become an economic asset and for the benefit of local communities and the wider region. A major pillar of the Government’s strategy is to deliver sufficient, affordable, high quality homes to increase affordability and support growth in the Arc. The NPPF identifies that a supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as significant extensions to villages or towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. The ‘new settlement based growth’ option within the Issues and Options Consultation document has the potential to meet this objective. It proposes that Wixams would be expanded, which is supported. Wixams is designated as a Key Service Centre is the Local Plan and its role will grow as the settlement continues to be built out. The longer-term delivery development of Wixams as a New Town will see the delivery of a new town centre, strategic employment areas and a wide range of leisure and education uses alongside employment provision (eg Wilstead Industrial Park) and new transport infrastructure including the new Wixams railway station. These enhanced facilities are in place or committed and the expansion of Wixams would ensure future residents’ needs would be met without the need for wider travel. It is considered the logical expansion of Wixams is to the south given the constraints of the A6 to the east and B530 to the west. There are logical links to the suggested ‘rail growth’ option which notes the opportunity to extend the established settlement at Wixams, increasing access to the new Wixams Rail Station (Thameslink and a link into an enhanced station on the East-West rail line). It is considered therefore a combination of the two options would allow new residential development to assist in providing a critical mass to ensure best use is made of existing infrastructure and where necessary, providing enhancements to it. An example of such appropriate, achievable and deliverable development includes ‘Wixams End’ as identified in the recent Council Call for Sites submission during August 2020.

Form ID: 2170

As identified in the NPPF, larger residential developments including extensions to existing towns can support a sustainable community either with the development itself or in nearby larger towns to which there is good access. Whilst not exhaustive it is suggested the following infrastructure for new residential development is key to ensure new development is supported in a sustainable manner: • High quality public open space within and adjacent to new residential developments. • New highways infrastructure, including footpath and cycle connections in order to encourage genuinely sustainable growth which reduces the need to travel. • Opportunities for new public transport infrastructure. • Green infrastructure in the form of extensive planting and enhancements to existing landscape features in order to provide biodiversity and environmental net gain. It is considered site allocations should be carefully consider access to existing/committed infrastructure in the vicinity. This will provide the opportunity to increase viability of existing infrastructure and the potential to enhance facilities where there is a requirement.

Form ID: 2171

The Issues and Options Paper identifies that new developments are coming to market at Wilstead Industrial estate in Wixams and Bedford link Logistics Park, west of Wixams on the A421. Building on these committed employment areas, the expansion of Wixams should be a key focal point for new residential development.

Form ID: 2172

Maximising accessibility to rail stations on or with access to East -West rail will help capture these economic benefits. The new Wixams Railway station is noted as a priority for early provision in the adopted Local Plan (policy 90s). The sustainable expansion of Wixams to meet future housing needs will optimise the opportunities the new railway station offers.

Form ID: 2173

I agree

Further guidance is welcomed on how to respond to climate change and specifically expanding on policies within development plan documents which will give further clarity to applicants, developers and site promoters.

Form ID: 2174

Locating residential development close to existing established facilities will encourage sustainable travel such and walking and cycling and reduce reliance on car-based modes. Carefully designed larger residential developments can ‘design in’ tenets of sustainable movement from the outset which become integral to the design of schemes and contribute to making high quality places. The adopted Local Plan requires design codes to guide larger scale new residential developments which will assist with these aims (policy 29). Larger developments including extensions to existing settlements provide the necessary quantum of floorspace to ensure viability for significant public transport enhancements, where required. Integrated transport systems located close to where people live will provide a straightforward transition between modes - eg between bus and cycle routes – and which will further encourage sustainable means of travel.

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