Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Support

Representation ID: 8071

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Paragraph 1.7 notes that ‘The Oxford to Cambridge Arc Government Ambition’ document is currently silent on the number of new homes that are expected to be delivered by individual authorities within the arc.

This is of course correct, however, what is also very clear is that the Government expects authorities in the arc to provide a step change in housing delivery. The Governments ‘Introduction to Spatial Framework for the Arc’ as published in February 2021 places particular emphasis on seeking to address the lack of affordability of housing in the arc resulting from historic delivery which has not met demand. (Paragraph 1.21)

Paragraph 2.10 of the same document advises that the Government intends to plan for housing growth in the Arc, to ensure it is a great and affordable place to live and work. It also states that where local authorities plan for growth in their areas the Government will support this with funding for necessary infrastructure.

It is considered that the Plan to 2040 should include some kind of housing uplift to respond to the Boroughs position within the arc.

If a position is taken that as no precise numbers are yet known the plan cannot make any provision for growth associated with the arc it is likely to become quickly out of date and may again need a further review very quickly after adoption.

Building in an uplift at this stage even if some uncertainty remains provides flexibility and would represent positive planning for the arc.

Support

Representation ID: 8072

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages.

This is a process that can work if the Parish’s act reasonably quickly following indication of an initial intention to prepare a neighbourhood plan (NP).

However, whilst some Parish Councils have taken forward NP’s others have not and some have stalled such that sites in the rural areas have not come forward as hoped leaving some villages with little or no growth over the plan period.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes clear that if an NP has not been prepared and made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village will be held to be out of date and applications for new development close to or adjoining boundaries would then benefit from a presumption in favour of sustainable development.

Paragraph 1.49 then notes that the Council will not expect NP’s to allocate strategic scale sites and this will be done in the Borough Local Plan.

The definition of a ‘strategic site’ is not provided. It is considered that the Borough Plan should consider allocations within Parish areas on sites over 50 units where these fit with the overall development strategy.

This would again assist in ensuring that the NP process does not prevent larger sustainable sites coming forward due to delays with the NP process.

Object

Representation ID: 8073

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate upon how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc by the end of the Plan period.

Policy 1 (Reviewing The Local Plan 2030) of the Local Plan 2030 states that the review will secure levels of growth that accord with government policy and any growth deals that have been agreed.

Whilst as noted in our comments in response to paragraph 1.7 of the draft plan, it is accepted that there are no finalised figures for housing growth at this stage, it is important that some form of uplift is included to provide flexibility and forward planning in a positive manner and in anticipation that additional housing will be required.

If the plan simply takes the view that it cannot consider additional growth at this stage or until firm figures are released it will fail in this regard and will require further early review.

Object

Representation ID: 8074

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The current housing need requirements of 970 dwellings per annum wase based on the previous housing needs assessment that proceeded on the basis that the Local Plan 2030 was submitted and examined under the procedures of the NPPF 2012.

The reduction of the plan period from 2035 to 2030 as a result of the lack of deliverability of the Colworth New Settlement and the fact that the plan did not sufficiently address growth associated with the arc led the Inspectors who examined the Plan to include a requirement for a review.

It is therefore clear that the Council needs to consider the review in the context of an elevated housing requirement based upon the Standard Methodology.

If this housing step change is not adequately addressed in the early stages of the plan period, then there is danger that there will be a shortfall to meet demand, along with the commensurate need for affordable housing.

This uplift in housing numbers, as well as employment land provision, needs to be targeted from the point of adoption, and not, as has been implied in the text, pushed back five years via stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040.

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption.

Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Object

Representation ID: 8075

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

1. Notwithstanding our comments on the overall housing and employment numbers proposed in the plan and the need to add an uplift associated with the Oxford to Cambridge Arc strategy, it is considered that the preferred spatial strategy (Options 2a, b, c, and d) have significant merit subject to the following qualifications.

2. Firstly, the strategy proposes development of 1,500 dwellings within the urban area.

3. Clearly there is merit in re-using urban sites and locating new homes close to key infrastructure, shops and services. However, concern is raised as to the deliverability of the levels of growth proposed.

4. The evidence base so far provided does not clearly demonstrate where the 1,500 homes would be accommodated within the urban area within the proposed plan period.

5. Urban sites are often constrained by existing uses, including commercial operations, car parks, supermarkets, government buildings etc. and / or have complicated ownerships and sitting tenants such that delivery is slow and uncertain.

6. As the Council will be aware a number of urban sites were previously identified as opportunity sites or ‘Areas of Change’ in the Town Centre Area Action Plan and so highlighted for potential development back in 2008. The majority of these have still not come forward some 13 years later.

7. There is also concern regarding the viability of urban sites to come due to higher existing use values but more specifically to come forward whilst delivering a full policy compliant level of affordable housing.

8. Subject to the level of certainty and viability assessment that the Council can place on the Urban Area sites it is submitted that the figure should be reduced to approximately 1,000 rather than 1,500 with the balance (500) being added to the ‘Adjoining the Urban Area’ category where sites are less constrained and very clearly deliverable.

9. Turning to the proposed ‘Adjoining the Urban Area’ category, it is assumed that any sites within Parishes adjoining the urban edge would qualify for consideration.

10. That is, sites for example in Renhold could be allocated as part of the 1,500 figures, it is not simply sites within the southern Parish’s which adjoin the urban area, that is a separate category. If that is a correct interpretation then this approach is supported.

11. All of the Option 2 spatial strategies include reference to the “A421 transport corridor with rail based growth parishes and southern parishes”.

12. The reference to the A421 transport corridor suggests that development close to the A421 would be favoured. This approach obviously has great merit as the A421 provides excellent linkages to the west and east and is also central to the Oxford to Cambridge arc.

13. However, the Transport Corridor options included in the list beneath the title seem to then reference only parishes south of the A421. This appears to ignore for example Renhold and its sustainable location close to a major junction onto the A421 (unless Renhold is considered to fall within the ‘Adjoining the Urban Area’ category as highlighted above).

14. Notwithstanding this it is considered that the corridor strategy should properly consider sites well related to the A421 but not necessarily only the southern parishes.

15. Of all of the Spatial Options the sustainability appraisal considers Option 2a the most sustainable.

16. This excludes new settlements. Whilst new settlements can be important in delivering new infrastructure, they are also prone to delay and uncertainty over delivery rates.

17. It was the proposal for the Colworth new settlement falling away which ultimately resulted in an unsatisfactory local plan to 2030 and a need for early review. Concern would again be raised as to the realistic deliverability of a new settlement option.

Conclusion
18. The Howbury Hall Estate broadly agrees with the Council’s assessment of the differing Spatial Development Strategy Options

19. Notwithstanding this general support, concern is raised in respect of what could be an over-reliance upon uncertain urban sites.

20. Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it whilst exhibiting far fewer viability / deliverability issues and as outline we submit should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

21. Our clients land on the east side of Bedford at Howbury Hall Estate is available and deliverable as set out in the Call for Sites submissions (Site 765) and in further representations now made in respect of the Call for Sites Assessment Proformas.