Issues and Options

The draft vision is duly noted for wanting this Borough to become a greener, more sustainable and more attractive place to live. Matters such as climate chance appear to be at the heart of the vision to mitigate its effects through the inclusion of green infrastructure, energy efficiency, flood risk reduction and so on. Also notably included within the vision are the benefits brought about by the Ox-Cam Arc, which currently is derived from the progression of the East-West Rail. Furthermore, the consultation paper continues on to acknowledge the Arc is a key economic priority and the Government ambition for up to one million homes by 2050. The East-West Rail and the new expressway as part of this project are already coming into fruition; however, the paper raises questions about the progress of the Arc’s strategy for housing growth. It summarily dismisses the need for additional housing due to the Arc, stating “little progress has been made” on how the strategic growth will be delivered. In short, this plan focuses solely on Bedford Borough’s own growth requirement which is claims will be a significant challenge due to a potential “35% increase in the annual level of housing growth contained in the Local Plan 2030”. The matter of how many houses this plan should accommodate is covered in more detail later in this response; nonetheless, the inclusion of the benefits of the Arc and consideration as to how best to capture such benefits for the Borough residents remains a key question at this stage for this Review, surprisingly. Surely, if the infrastructure required for such growth is being implemented, then a spatial strategy itself is imminent for the Arc. This consultation itself acknowledge the need for appropriate infrastructure prior to accommodating significant growth. Yet, this Authority makes no attempt to query its citizens on what they believe should be a suitable vision in this respect. Certainly, even if accommodating a one third increase in the level of housing will be a challenge, surely this Council must now at least make attempts to help facilitate growth for when a strategy is realised. This is indeed the motivation and justification for the inclusion of Policy 1 within the currently adopted Plan. The examining Inspectors, as explained in the paper, set out that “there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible” (emphasis added). At best, this Authority should make full provision to accommodating further, projected growth given its fundamental location at the heart of the Arc. At worst, it should seek the views of its communities, residents and businesses on the matter as part of this, or any future, consultation to fully assuage whether this is truly unfeasible at this stage rather than irresponsibly dismiss planning for the Arc altogether.

Nothing chosen

The most crucial elements of growth to include as part of a spatial strategy going forward would be for increased levels of rural growth. To date, and as is proposed under some potentials options for growth, the Bedford and Kempston rural area has always been subject to significantly higher levels of housing growth with many settlements, including the sustainable Key Service Centres, receiving a very small proportion of planned growth under the previous plan (now superseded) and currently adopted plan. The implications for sustainability in this context are very clear, and indeed are listed within the pros and cons for the potential growth options. Urban based growth presents increasingly limited opportunities for developers to assist in meeting the objectives of sustainable development. Beyond high density schemes, very little alternatives exist to realise the level of growth that would be required as part of this Local Plan Review within the Bedford & Kempston rural area. This includes development on the urban fringe which in turn would encourage less sustainable transport methods as these would require significant further investment to facilitate a continued outward expand of the urban area. Urban based growth would equally starve more rural locations of much needed growth -housing or employment – while in turn risking the buildup of urban sprawl. Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Bromham which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future. In incorporating dispersed growth as part of a strategy, many rural communities such as Bromham would continue to be well-connected places without experiencing overdevelopment (as would be inevitable if Bedford & Kempston continued to receive a proportion of growth in line with that allocated currently/previously). Infrastructure equally would only require incremental improvements as compared to strategic level enhancements to facilitate a more spread out growth option which is more viable and has fewer impacts on the natural environment (in terms of air quality, visual impact, etc.). Some draft and adopted Neighbourhood Plans envisage that the (potential) sites for allocation will assist significantly in providing for a news school and / or expanded school capacity at existing institutes, for instance. This is one such approach that can help maintain and upgrade the existing levels of facilities and services, and subsequently the sustainability, of villages such as Bromham without giving rise to undue burden on local communities or the Council. Dispersing growth further allows for rural centres to retain and enhance their vitality and improve the quality of living in these areas in line with what they are capable of accommodating thereby securing a more vibrant Borough as compared to a single, densified urban area that rural communities become entirely dependent upon.

Public services and sustainable transport infrastructure will remain the most significant required that will enable the Borough to achieve the requisite levels of growth. In dispersing growth across the Borough, facilities and services as schools, doctors, etc., are more readily secured incrementally in locations that can sustain them via developer contributions in a manner that does not overwhelm the communities that need such infrastructure. As aforementioned, the Settlement Hierarchy Background Paper notes several rural settlements as containing an already appreciable level of sustainability in this context, and as such it would not be remiss to continue to expand on and improve existing provisions in areas capable of supporting them further. One key way to enhancing sustainable transport connectivity would be improve links to the major transport hubs within the Borough – at present, and in the future to thereby including the East-Wail Rail, such that the benefits of greater connectivity to places such as Oxford and Cambridge are better captured across the Borough instead of being centralized to strictly where the East-West Rail station will be. Doing so would present people and communities with the opportunity of living in vibrant, rural communities with exceptional employment opportunities not only limited to the Bedford and Kempston Urban area but to also include the wider, regional destinations. The major rural settlements of the Borough contain a reasonably integrated transport network across the Borough with the urban area, and as such reduces the need for strategic level new or improved infrastructure. It therefore makes sound planning sense to look towards further significant development in locations such as Bromham, which itself is strategically located south of the nearby A6 and adjoins the A428 on its southern boundary. The village, therefore, maintains strong transport links via public highways and sustainable transport methods enabling access to towns of Bedford, Northampton, Milton Keynes, Luton and Wellingborough. All five have excellent rail connections to London, the south east, Birmingham, Nottingham and the north east. Thus, the dispersal option is an element of growth that can combined with others – such a growth focused on key transport corridors – to overcome the need for further significant infrastructure.

Currently, policy inhibits any housing growth beyond in the rural area which is not planned for as part of Neighbourhood Plans. Together, the implementation of a Settlement Policy Area which restricts rural growth and the increasingly limited options for growth within the Bedford and Kempston urban area lead to situation wherein currently adopted policies, unintentionally or otherwise, fail to sufficiently accommodate growth in a manner that is commensurate with Paragraph 170 of the NPPF. Paragraph 170(a) states that Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Paragraph 170(b) requires that those policies and decisions recognize the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. The terminology used above is very clear in that non-valued landscapes should not be protected and instead be recognized. A number of policies across the country which have come into conflict with the NPPF for blanket protection of the countryside have been ruled inconsistent with Paragraph 170(b) for this reason. Whilst this many not be the case here, it is evident nonetheless, that the scope within which one can bring forward development to enhance the vitality and wellbeing of local communities is extremely limited despite the sustainability credential of some of the more major rural settlements in the Borough. Certainly, windfall sites should they come forward never intend to compete with allocated / Neighbourhood Plan sites. They provide housing growth in addition the minimum levels of growth that the Borough must deliver and, where they constitute sustainable development, they often fall foul of very technical considerations such as Settlement Policy Area. Whilst relevant for considering when specific policies (such as Policy 7S) may come in to play for applications and proposals, it has had the inadvertent consequence of severely restricting levels of growth that may be in line with Paragraph 170(b), but will fail to completely account for other policies, to include that of Paragraphs 77 and 78 on rural growth which do not specify that an identified need (as set out in Policy 7S0 is required to ensure rural vitality. This is particularly so when this Council must duly take account the planned levels of growth for the Borough due to revisions in Standard Methodology; issues with affordability; the Ox-Cam Arc; and even the specific context within with this Government views proposals that boost the supply of housing even when authorities demonstrate a 5YHLS. These are all matters expanded on below.

The Local Plan Review fails to adequately consider this Borough’s Local Housing Need as derived from the Standard Method, which in any event is undergoing consultation for proposed changes to its methodology in line with increased levels of planned growth by central Government, in addition to the full implications of the Oxford-Cambridge Arc. This is prior to accounting in any way for the Government objective of significantly boosting the supply homes as per paragraph 59 of the NPPF. Presently, the standard method falls short of meeting the 300,000 dpa which the Government has said should be the national annual housing target. The target of building 300,000 homes a year on average in the UK was and remains the founding principle of the Government’s ‘Standard Method’ which was implemented as part of the revised National Planning Policy Framework. This was an effort to standardize house-building targets across the country in an effort to genuinely address the housing needs of real people in real need now. This is now being addressed by the government going forward as evidenced in the White Paper “Planning for the Future” and “Changes to the Current Planning System” which expressly sets out that the government will review the formula for calculating Local Housing Need such that it corresponds to instead to a 337,000 dpa figure (twice the average level of growth in this country). No doubt this Authority is fully considering the implications of the White Paper and revisions to the SM, and as a matter of course will duly consider whether there will be a need to transfer over toward a new form of development plan that considers the predefined “growth, renewal and protection” areas envisaged for new Local Plans in future. Nonetheless, and question that is relevant here and now is that the SM revisions invariably means LPAs across the country will need to deliver more housing against future LHN than what it is identified as at present, including Bedford Borough. This is against the context that Bedford currently faces increasing house prices and increasing monthly rents all set against a backdrop where rates of development has fallen below planned levels. In respect of house prices, the average house price paid in Bedford is £300,477. When compared to an average income of £29,411, an average priced home in Bedford costs 10 times more than an average household earns, meaning affordability is a significant barrier to many people wishing to acquire a suitable home. The lower quartile house price ratio stands at a similarly staggering 10.61 times household income and means that many people at the lower end of the market are pushed into the private rented sector, often with poorer living conditions and insecure tenancies. This situation is fundamentally against Government ambitions to make housing more affordable for everyone, which is why affordability remains a key adjustment factor in the Standard Method, and against ever increasing house prices (despite even the consequences of the current pandemic) it is only reasonably expected that the Council’s LHN will continue to increase in future years due to this factor alone. Coupled with the need to accommodate for future growth as part of the Oxford-Cambridge Arc, which itself aspires to up to a million homes are delivered in the Arc by 2050. Most of the arc is free from constraints like Green Belt, AONB or European protected habitats. Housing delivery on a much larger scale will be planned for in this area. The delivery of new homes in this area is a matter to which significant weight should be attached given this vision for growth by Government and it is unacceptable to this Council to be seeking to meet need as low as potentially “800” homes per year on the basis that the Ox-Cam Arc-wide spatial strategy not being agreed. The East-Wail Rail is progressing in a timely fashion such that this Council is intending to give consideration how to best capture the economic benefits of it under this Review. This in itself is evidence enough that despite there being no clear government guidance at present on what is intended for the Arc in terms of housing, these are expected in the very near future and most certainly within the proposed plan period. Current housing targets are at 970 dwellings per annum, shooting to well above 1,000 dpa benchmark due to the Standard Method alone. The supposition that this Council need not plan for a housing figure over and above its own requirement is nonsensical against the above context, and when viewed in the additional context of paragraph 59 of the NPPF. Para 59 sets out ambition for the significant boosting of the supply of homes in this country – an objective which can only be achieved once the minimum levels of growth has been accommodated for. It is an ambition that is further reflected in a recent appeal decision taken by the Secretary of State relating to Land Off Audlem Road / Broadley Lane, Stapeley, Nantwitch (ref: APP/R0660/A/13/2197532), and Land off Peter De Stapeleigh Way, Nantwich (ref: APP/R0660/A/13/2197529). Within the decision letter (DL) at DL28, the SoS accords significant weight to the benefit of delivering new market housing thereby significantly boosting the supply of homes as per paragraph 59 of the NPPF. This is notably in the context of the relevant LPA being able to demonstrate a deliverable five-year supply of housing land. This local authority is also once such authority that claims to have a five-year housing supply of land. Yet, it will flounder and fail to secure even the minimum levels of housing growth over the proposed plan period until 2040 unless it duly accounts for the increasing unaffordability of housing that is explicitly due to such low planned levels of growth, the Ox-Cam Arc, the objective of boosting the supply of homes, and the overall incoming revision to national policy which revises national housebuilding targets to double the average housebuilding rate in the country. Plainly, these are all matters that relevant now and must be accounted for as part of this review.