Plan for submission evidence base

Comment

Representation ID: 10401

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

In particular, the Sustainability Appraisal testing of the ‘stepped approach’ is fundamentally flawed, with the justifications given for positive scores around items such as previously developed land (see SA Appendix 8 p. 113) being conjecture. The statement that the stepped approach would have a more beneficial effect on development on previously developed land is incorrect; sites which are previously developed land can come forward irrespective of the stepped approach and the SA does not identify any previously developed land south of Bedford that benefits from the new rail stations and links. Indeed, the allocations at locations such as the Wixams are not on previously developed land but greenfield land. The SA must, therefore, be re-run with a correct assessment of the stepped approach.
2.14 A correct assessment of the stepped approach in the SA would identify that there are risks with being reliant upon so much growth linked to strategic infrastructure outside of the control of developers and the Council. This would in turn mean that many of the benefits may not be realised, or realised later in the plan period, pushing housing delivery outside of the plan period.
This is particularly evident in this area, with the still awaited deliver of the Wixams rail station. That station was due to be completed in 2015 and is now timetabled for opening in 2024.
2.16 Instead, the Plan should take a more balanced approach, with a reduction in numbers on some of the strategic sites and the delivery of smaller strategic allocations which can come forward earlier and increase housing delivery in the period to 2030.
2.17 The Local Plan is not sound, as it is not justified or effective. To make the Plan sound the trajectory should be amended. Reflecting the fact that the Local Plan may not be adopted until 2023, and thus higher delivery in 2024 (compared to the Local Plan 2030), the trajectory should be as follows:
2020/21- 2023/24: 970dpa
2024/25 – 2039/40: 1,423dpa
2.18 Aligned with this, new allocations will be required, and a reduction in the number of dwellings on some strategic sites may be required. These matters are dealt with below.

Object

Representation ID: 10406

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our client’s position is that the approach taken to allocating sites and, in particular, the quantum of development allocated on certain sites is not justified nor consistent with national policy, for the following reasons.
3.2 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13, HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear understanding and expectation as to the quantum of development that the Plan is proposing in these locations.
3.3 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
3.4 What is not evident from the evidence base or the Local Plan, is the approximate developable areas and thus whether these are realistic densities. Upon examination of the Policies for each site, and the Figures in the Local Plan which accompany each, the only way to achieve all the Policy requirements, in particular the amount of open space and green infrastructure, it would necessitate very high densities on the majority of these sites (c. 50/60+ dph).
3.5 There is no evidence accompanying the Local Plan which justifies this approach; the HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which a high density would lead to, nor is there market evidence supporting housing demand for such a high quantum of small units in these locations.
3.6 This is likely to lead to future applications which either decrease the number of homes, resulting in unmet need (in terms of overall quantum and/or mix) and possibly non-delivery of key infrastructure. Alternatively, it may lead to non-delivery of green infrastructure due to pressures to deliver housing numbers.
3.7 The quantum for each allocation is not based on a proportionate or robust evidence base and are therefore not sound.
3.8 In order to make the Local Plan sound, additional allocations are therefore necessary to make up this shortfall in numbers. Doing so would have the further benefit of addressing the stepped trajectory shortcomings as set out in Section 2 of these representations.
3.9 The next section of these representations puts forward a case as to one such location for growth within the southern parishes, which would deliver growth in a sustainable location, close to East-West Rail and on a site which has erroneously been discounted from the site selection process.

4.0 Land to the north of Top End, Renhold
4.1 The land north of Top End, Renhold sits close to the centre of the settlement, some 14 minute walk from the Primary School. It is enclosed by woodland to the east, with housing to the south and west. It is identified on the drawings enclosed at Appendix 1. The land measures c.4ha and was submitted to BBC through the Call for Sites process in 2020. Enclosed at Appendix 2 is the Council’s most recent assessment of the site contained in the Site Assessment Pro Formas.
4.2 The land has previously been put forward for a residential development, with the Council’s assessment suggesting 25 homes. The site is in sole ownership and can be brought forward in different phases to reflect local housing needs. The enclosed Plans at Appendix 1 show the different approaches which can be taken to delivery of the site.
4.3 The Council’s assessment of the site confirms it is in a sustainable location, being only 200m from the nearest bus stop and a short walk to the primary school (scoring
positively in both regards).
4.4 Indeed, the proforma assessment does not identify any constraints to the development of the site, other than those which can be adequately mitigated against as part of any proposals.
4.5 The site is being promoted for residential development, which could include self-build homes. There is an identified need within the Borough for self-build homes, and a lack of specific allocations within the Plan for this. The site could provide an important contribution to meeting this identified need in accordance with national policy.
4.6 A full and thorough assessment of the site, carried out in accordance with the full evidence base and the proposals as put forward on behalf of the landowner, would find that the site should be allocated. The Local Plan is, therefore, unsound as it is not justified. The Local Plan should be modified to allocate the land to the north of Top End, Renhold, for housing including self-build homes. This is necessary to both respond to the evidence base, and to help contribute to the shortfall of housing that will result from the correct assessment and planning of the other south of Bedford sites, as set out in Section 3 of these representations. Moreover, as a non-strategic site the land is not reliant upon larger infrastructure. It can, therefore, come forward early in the plan period and help to deliver homes within the first 5 years. This would further boost the trajectory position and the Council’s housing land supply, an important benefit.
4.8 The Site is in a single ownership, is available and is deliverable, being actively promoted by the landowner. It is not reliant upon any third parties and would be capable of “consuming its own smoke” in terms of infrastructure. The Site could, therefore, be delivered early within the plan period.
4.9 The location both within Renhold, but a reasonable distance from Bedford, enhances the sustainability of the Site, which could deliver a widened footpath on the frontage as noted by the Council in the proforma. The homes would therefore be in an excellent location by providing opportunities for people to live and work locally and reduce reliance upon the private car.

Highways and Access
4.10 The Site proforma (site ref 431) finds that the site would likely not cause significant issues in highway terms.
4.11 It also highlights the proximity (200m) to the nearest bus stops, and does not raise any concerns regarding access. The site benefits from a direct frontage to Top End Road and sufficient land to create a satisfactory access, with appropriate visibility splays.

Heritage
4.12 Whilst there are three Grade II listed buildings near to the site, these would not be unduly harmed by development here and could be screened through an appropriately designed and landscaped scheme.
4.13 There is, therefore, no reason to find that the Site should be excluded on heritage grounds. This is in direct contrast to other allocated sites, in particular HOU13 with several heritage assets (not just buildings but features such as ridge and furrow) identified as requiring mitigation within the Policy wording.

Summary
4.14 The land to the north of Top End, Renhold, is being actively promoted for residential development, including self-build homes to meet identified local needs.
4.15 The Local Plan evidence base finds that this location is a logical and appropriate location for development; The Site would accord with the emerging development strategy for BBC and would deliver housing in a sustainable location, as advocated in the NPPF.
4.16 The land north of Top End, Renhold should therefore be allocated for residential development within the Local Plan.