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

Object

Representation ID: 8990

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated
in accordance with the Government’s Standard Method provides the starting point for
assessment of the number of homes to be provided through Plan-making. Positive Planmaking
should address those circumstances where it may be appropriate to make provision
for a higher number of new homes than indicated by the result of the Standard Method (with
a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at
ID: 2a-010-20201216.

It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the
calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary
to material considerations (including the Council’s own evidence base) that require more
detailed assessment before selecting options for the submission draft Plan and setting the
housing requirement in the Plan.

Reasoning
Paragraph 3.4 of the consultation document ‘Creating a Vision for the Oxford-Cambridge Arc’
refers to the importance of the role of the NPPF to deliver the economic pillar of objectives
for the corridor. In principle this reflects use of the Standard Method as the expected starting
point to identify housing needs within the Arc but further reflects observations in the initial
consultation and the role of the PPG that may necessitate delivery of higher levels of housing,
setting out considerations such as:
“developing an Economic Strategy, supported by strong economic evidence, to
identify the policies, locations and investment needed to deliver the Arc’s potential
for sustainable and green economic growth; and
• setting policies to make sure growth is felt by all communities and the Arc becomes
a better place to live and work for all, such as by providing more housing in the
right places, making sure people can move around by public transport and other
infrastructure, and enhancing the Arc’s natural capital”
The main implication of this component of the Arc Spatial Framework reflects circumstances
where the calculation of local housing need will not result in sufficient workers in the right
locations to achieve the full potential of sustainable patterns of economic development.

In relation to the Council’s evidence base there appear to be significant issues with their
assumptions for labour demand and labour supply techniques to forecast future changes in
jobs and the requirement for additional workers.

In-particular, the Council’s Employment Topic Paper:
• Does not use a range of economic forecasts (utilising only the East of England
Forecasting Model (EEFM2019) baseline scenario only)
• Does not consider a past take-up scenario for jobs growth and delivery of employment floorspace
• It is likely to significantly over-estimate the number of jobs associated with the increased working-age population based on the LHN (the Council’s employment
land scenarios set out no assumptions on economic activity rates or commuting -
the baseline EEFM assumptions are not dissimilar to LHN in terms of additional
dwellings and persons required to meet the jobs forecast).
• It takes no account of engagement with the LEP or forecast Spatial Framework
scenarios (that may result in a higher demand for labour)
Remedy
Failure to take account of these factors means that the Local Plan 2040 is more likely to
result in conflict with the emerging priorities of the Arc Spatial Framework and it is
recommended that a range of jobs-led scenarios are tested prior to determining the housing
requirement for the Local Plan 2040 and selecting an appropriate strategy.

Object

Representation ID: 8991

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s Preferred Option consultation proposals indicate that the purpose of updates
to the Local Plan following the requirements of the Review policy (Policy 1) are to outline a
development strategy to 2040 and meet national policy requirements for the delivery of
growth. This fails to fully reflect the reasons for first introducing the requirement for immediate
Review and in-particular the pattern and scale of housing growth necessary to achieve sound
outcomes for Plan-making (particularly with regards paragraphs 20 and 74 of the
NPPF2021).

Reasoning
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc
demonstrates poor affordability where development has not kept pace with need. That is
exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.

This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework
sets policies to enable housing needs to be met in full, including much-needed
affordable housing.

This sits alongside strategic decisions where direction will be provided by the Framework
e.g., implementation of East-West Rail, identification of Opportunity Areas and support for
the delivery of previously developed land.

What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach
providing for sustainable communities.

The Council’s Preferred Options consultation proposals would sustain a very substantial
shortfall against minimum annual local housing need until at least 2030. Due to only
considering a horizon to 2040 and as a result of likely timescales for the characteristics of
larger-scale development (including new settlements) it is furthermore highly likely a
significant shortfall against full development needs will persist until 2040 and beyond.

The Council’s proposed strategy offers no flexibility and choice to address the current and
persistent failure to meet needs in full. Our assessment indicates that current levels of
development are likely to become significantly constrained substantially before any of the
longer-term solutions proposed as part of the Preferred Options achieve significant delivery.
Realistic assumptions must also be made in relation to new larger-scale developments.

Object

Representation ID: 8995

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s consultation document considers the role for development allocations to be
identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the
context of updates to the development strategy explored via the Preferred Options.

These representations identify that the consultation fundamentally fails to assess the role
and ability of Neighbourhood Plans in meeting the requirements for sustainable development
(including housing delivery) in the period to 2030. The consultation proposals also provide
no clarity on the impact of meeting additional requirements for growth in terms of whether
the policies in ‘made’ Plans will remain in general conformity with the development strategy
nor how further allocations might be provided for in an effective and positively prepared
manner.

Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of
the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be
delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford and recently at Sharnbrook).

At paragraph 1.48 the Borough Council only provides vague indications of where further
engagement might take place with parish councils to meet additional requirements for growth
where a range of suitable sites are identified.

This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for
reviewing NDPs (which should encourage early review when strategic policies have
changed). That is an inevitable consequence of the Development Plan in Bedford given its
current failure to address levels of growth in accordance with the Standard Method. The
Borough Council’s own evidence indicates the strong likelihood of sites where early delivery
can be prioritised. This does not demand that meeting increased requirements for growth
should extend beyond 2030.

Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for
non-strategic allocations. Paragraph 29 confirms this must be within the context of
Neighbourhood Plans that do not promote less development than set out in adopted strategy
policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the
NPPF2021 outlines that strategic policies should set out a housing requirement for
designated neighbourhood areas which reflects the overall strategy for the pattern and scale
of development and any relevant allocations. This is an important distinction from the 2012
version of the Framework. However, the Council’s testing of options for the Local Plan 2040
rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service
Centres and Rural Service Centres.

This fundamentally fails to accord with the current requirements of national policy and
guidance and, importantly, has currently precluded the Council from considering ‘hybrid’
alternatives to the spatial strategy that would allow appropriate levels of sustainable
development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas

The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021.
Paragraph 66 sets out that strategic policies should also set out a housing requirement for
designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is
not justified and not positively prepared.

This is an important component of national policy and guidance in terms of seeking to avoid
conflict between existing and emerging Neighbourhood Plans and the strategic policies of
the Development Plan. This should form part of positive discussions between qualifying
bodies and the local planning authority, recognises the ability of Neighbourhood Plans to
sustain and increase housing delivery. Any indicative requirement figure would take into
consideration relevant policies such as an existing or emerging spatial strategy, alongside
the characteristics of the Neighbourhood Plan area and should minimise the risk of
Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID:
41-102-20190509).

The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential
requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at
the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall
against the government’s policy for calculating housing need, culminating in this
immediate review;
• The figures are applicable only in the context of a foreshortened plan period to
2030; and
• Figures are provided only for certain settlements, with no requirement indicated for
levels of the settlement hierarchy below Rural Service Centres (despite these
having been considered in earlier rounds of plan-making for the LP2030).

It follows that the process for calculation of any indicative requirement would therefore
materially and significantly exceed the evidence base for the LP2030 and the figures in Policy
4S. By extension this means that any evidence produced by groups preparing Plans (for
example assessments of local rural housing needs) whether relating to settlements listed in
Policy 4S or not) would need to be considered in the context of the overall result of the
Standard Method to 2040.

Any impacts upon the evidence based for emerging Neighbourhood Plans must be read
alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary
to review and update a Neighbourhood Plan’ and states in relation to the above issues:
“There is no requirement to review or update a Neighbourhood Plan. However, policies in a
Neighbourhood Plan may become out of date, for example if they conflict with policies in a
Local Plan covering the neighbourhood area that is adopted after the making of the
Neighbourhood Plan. In such cases, the more recent Plan policy takes precedence.”

Remedy
The solution to issues identified in these representations necessitates the Council complying
with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider
that a ‘hybrid’ development strategy must remain supported throughout the Plan period,
including recognition of the contribution that this would make towards the shortfall against
local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.

Without prejudice to any specific conclusions from this work this would support inclusion of
‘village-related’ development as a component of future growth. There may be scope to alter
the distribution of the housing requirement to Key Service Centres upwards or downwards
from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and
other potential benefits for development in these settlements relative to their overall potential
contribution to LHN.

Object

Representation ID: 8998

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section addresses two main themes. It firstly sets out the shortcomings of the Vision in
terms of reflecting comprehensive opportunities for sustainable development across the
Borough. Secondly, it addresses that while there are many positive aspects of outcomes
sought under the vision these will not be addressed as part of the strategy due to the
Council’s selected Preferred Options.
Reasoning

The draft Vision sets out:
“Well-planned growth supported by appropriate infrastructure and avoiding areas of high
flood risk will enable the creation of strong, safe and resilient local communities in
environments that facilitate healthy and independent living for all.”

This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options
omitting a significant number of the Borough's KSCs and RSCs from the spatial strategy and
do not seek to provide for the additional development required to secure balanced
communities.
The Vision further states:
“Rural communities will embrace appropriate development, in many instances through
the preparation of their own Neighbourhood Plans.”

This would imply a requirement for additional growth, which the preferred options exclude for
a significant number of centres. The draft Vision feels to address that it is part of the role of
the Local Plan review (and resulting updates) to address strategic priorities deferred as a
consequence of the Local Plan 2030 (for example expansion of primary healthcare and
secondary education). The Vision also fails to reflect that the proposed development strategy
is not looking to provide for any additional growth in rural areas as part of an uplift to meet
housing needs in full before 2030. This is a significant shortcoming of the strategy and
overlooks suitable and deliverable sites that could be prioritised now to meet these increased
needs alongside the delivery of other substantial benefits.

The Vision makes limited reference to specific benefits that the Local Plan 2040 will secure
in relation to the natural environment, including Country Parks north of Brickhill and west of
Bedford.

The Vision is artificially constrained as a result of the Council’s current position on Preferred
Options. There is no reason that other sustainable developments cannot achieve
complementary and significant advantages for Green Infrastructure provision (e.g., our
client’s proposals to provide a Riverside Park as part of the development opportunity at
Stoneyfields, Sharnbrook).

Theme 4 (Better Places) of the Council’s proposed Objectives for the Local Plan 2040 sets
out:
“Provide appropriate amounts and types of housing to meet the needs of the borough’s
urban and rural communities over the lifetime of the Plan making the housing stock more
adaptable and resilient
Achieve a borough where everybody has appropriate access to high quality health and
social care, as well as everyday essential services and community facilities where social
and cultural wellbeing are supported, enabling all residents to lead healthy and
independent lives.”

The principle of these objectives is supported but is reliant on flexibly supporting diverse
opportunities for development across the settlement hierarchy. There are a substantial number of centres where the level of development identified is insufficient to secure the opportunities identified.

Object

Representation ID: 9000

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section of our representations should be read alongside the standalone Review of the
Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review
support the Modifications in this part of the representations. This section also reinforces our
specific comments on the Council’s Preferred Strategy Options published in the main
consultation document.

These representations propose an alternative ‘hybrid’ spatial strategy. This is consistent with
the Council’s evidence base for the emerging Local Plan 2040; would overcome the
soundness issues identified with the Council’s Preferred Options; and would comprise an
appropriate strategy for the purposes of Paragraph 35(b) of the NPPF2021.

The ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’
growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of
their capacity to contribute towards sustainable development. The benefits of ‘village-related’
development do not suddenly materialise only where Key Service Centre and Rural Service
Centres are located in the A421 corridor and do not evaporate altogether outside of it.

The Council expressly recognised this in the evidence base for the current Development
Plan. In the current Preferred Options, it has taken an inconsistent approach to assessing
the effects of the ‘village-related’ development component by reaching different conclusions
for exactly the same settlements (in the ‘east’ and ‘south’ corridors) when they are assessed
as part of the Preferred Options as opposed to other strategy options (e.g., Option 3c).

The ‘hybrid’ option assigns the ‘village-related’ growth component only to those settlements
outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an
indicative distribution, have been retained at 500 units in Key Service Centres and 35 units
in Rural Service Centres albeit these are arbitrary figures and should be determined on a
case-by-case basis. Wixams has been excluded from the total for Key Service Centres
(reflecting its inclusion in the locations for rail-based growth). The only exception, taking
account of this, is an increase of 215 units in the distribution to Oakley based on our
recommendation for it to be reclassified as a Key Service Centre and growth east of Station
Road being specifically supported.
For the A421-based components of the strategy the total distribution to the ‘east’ corridor
parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d.

In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of largescale
strategic growth included in the strategy options. We have included the Council’s
minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and
New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic
timescales for development.

Including both components would comfortably exceed the minimum 12,500 units required
from additional allocations, with an appropriate buffer for flexibility and contingency
(particularly in terms of the prospects for meeting increased needs before 2030). There is no
reason higher quanta could not be included as part of an extended plan period. Equally, this
could allow some settlements to be excluded from further village-related growth albeit we
would not recommend this where Neighbourhood Plans being prepared have failed to
address important strategic priorities (as at Oakley and Sharnbrook, for example).

The ‘hybrid’ strategy based on these components are summarised in Table 1 below: (see attachment)

We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the
Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with
the standalone findings for growth components and the Council’s Options 2d and 3c, as well
as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable
development are enhanced. This is as a result of recognising that the potential negative
effects the Council assigns to village-related growth are incorrect and, in any event,
inaccurate because it ignores the location of some Key Service Centres and Rural Service
Centres within the A421 corridor. It also recognises that some the benefits of what is in reality
‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across
settlements elsewhere in the hierarchy. The results are summarised in Table 2 below: (see attachment)

Comments on the Strategy Options and Supporting Evidence
The section of the representations provides observations on the soundness of the Council’s
overall approach towards preparation of the Local Plan 2040 and identification of the strategic
priorities it is required to address. Comments specifically relate to Chapter 3 of the
consultation document. Issues relating to the ability of the Council’s approach to maintain a
rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped
trajectory) are dealt with separately in Section 6.

The preferred options for development, as set out in the Draft Local Plan, focus the allocation
of a minimum 12,500 units around the urban area of Bedford, the A421 and the A1 transport
corridors. This approach is unsound (not effective, not justified, not positively prepared and
not consistent with national policy) in creating an effective embargo on any further
consideration of village-related growth outside of these areas as part of the Council’s planmaking
process to prepare strategic policies or to necessitate the review of Neighbourhood
Plans that look forward only to 2030.
Reasoning

Whilst we are in support of parts of the Council’s ‘Preferred Options’ 2a-2d, insofar that they
recognise the potential for benefits from what is in-effect village-related growth at some Key
Service Centres (KSC) and Rural Service Centres (RSC), we note the absence of any
development being allocated to the northern parishes.

KSC’s and RSC’s outside of the ‘east’ and ‘south’ corridors are capable of delivering
development within the Plan period up to 2040 and addressing the significant increase in
housing need that must now be planned for. The evidence bases for emerging
Neighbourhood Plans and details of suitable sites being identified in the Call for Sites event
that Bedford Borough Council undertook in the Summer of 2020 are illustrative of this fact.

With respect of the KSC of Sharnbrook, this is evident in the circumstances for the
Neighbourhood Plan which the local planning authority and qualifying body (Sharnbrook
Parish Council) intends to put in place (following issue of the Examiner’s Report on 21 of July
2021). Sharnbrook as a settlement is identified in the adopted Development Plan as a KSC,
meaning that it has a good provision of services and facilities to facilitate development. The Neighbourhood Plan, covering only the period until 2030 in any event, does not provide for
development that is immediately adjacent or well-related to the existing Settlement Policy
Area boundary or that seeks to sustain and enhance the role of the settlement.

Furthermore, our client submitted substantial objections to the Neighbourhood Plan’s
proposed allocation at Hill Farm in terms of its sustainability and deliverability. The Hill Farm
and NDP allocation proposals would result in the removal of the Primary School currently
being provided in the KSC of Sharnbrook itself (it would relocate to Hill Farm). Our client’s
Stoneyfields scheme could lead to the re-provision of facilities in a highly sustainable
location, especially for existing Sharnbrook residents, amongst numerous benefits directly
related to the village it serves.
Remedy

Therefore, we would ask that Bedford Borough Council addresses their proposed
development strategy and seek to allocate development within the northern KSC and RSC,
where there is both demand for development and the available sites to aid in the delivery of
housing post 2030 or earlier. This could be achieved through allocating additional
development to the northern parishes (as part of flexibility and contingency) or redistributing
the minimum total of additional land to be allocated to address local housing need (and thus
addresses barriers to delivery of large-scale strategic growth within the Preferred Options).

Bedfordia generally support the approach the Council has taken to the Spatial Strategy
across the Authority area; recognising that housing and job growth can be accommodated
through a hierarchy of urban and rural communities.

Paragraph 3.10 of the Local Plan 2040, highlights that, as part of last year’s Issues and
Options consultation, the Council outlined six distribution options which could form part of
the strategy for growth. These were:
• Brown – Urban based growth
• Yellow – A421 based growth
• Pink – Rail based growth
• Orange – East-West rail northern station growth
• Grey – Dispersed growth
• Red – new settlement-based growth

The responses to the issues and options consultation indicated that there was broad
consensus favouring development focused on the existing urban areas and the A421
corridor, and possible new railway stations which might be delivered on the new East-West
Rail Line. This does not, however, provide justification to preclude the potential benefits of
dispersed growth altogether.
Reasoning
In conjunction with paragraphs 3.16 and 3.17 of the Local Plan 2040, an alternative ‘hybrid’
approach is required to provide for an appropriate strategy. This approach is consistent with
the criterion informing the spatial strategy under Policy 3S of the LP2030, supporting
proposals to deliver sustainable development and growth that enhances the vitality of the
Borough’s urban and rural communities. This specifically expects contributions towards the
objectives and policies of the Plan through (inter alia):
(iii) Strategic residential development in key service centres in association with
expanded education provision where necessary.
(iv) Limited development in rural service centres in line with existing and potential
capacity of infrastructure and services.
(v) Delivering the majority of rural growth through Neighbourhood Plans.

On the basis of the Council’s Preferred Options the Plan’s strategic policies would not
continue support for these components of a sustainable strategy beyond 2030. Moreover,
there is an existing conflict arising from the approach to Policy 3S, where Neighbourhood
Plans being prepared are likely to have addressed some but not all of an area’s priorities and
only in the context of the significantly lower OAN adopted in the LP2030. The Council’s
approach in the current Plan led to issues being deferred, rather than dealt with, meaning
that the Preferred Options only seek to compound this problem.

The Council’s Preferred Options must therefore be reconsidered and adapted to coincide
with ongoing support for those parts of the spatial strategy endorsed within Local Plan 2030
Policy 3S that the Council’s own evidence recognises as essential to securing contributions
towards sustainable development.

The annual requirement in the adopted Local Plan 2030 is 970 dwellings per year. The
minimum annual local housing need figure for the Local Plan 2040 represents a substantial increase to the adopted Plan and will bring with it considerable challenges.

Policy 3S was also in reality a ‘hybrid’ approach. The Council recognised it was unable to
make provision for even its own lower figure for objectively assessed needs without
diversification of the spatial strategy. The reasons for this primarily relate to issues that are
not new to this Plan-making process – namely the delivery of extant commitments on Town
Centre sites. The incorporation of new large-scale strategic options, which the Council was
unable to soundly introduce to the LP2030, adds to the number of locations where longer term
development timescales need to be considered but does not change the justification for
a flexible approach already recognised as sustainable.

As such, Bedfordia query the ability of Bedford Borough Council to deliver some 1,275 new
dwellings per annum, given the constraints Bedford faces and historic amount of growth that
has been accommodated to the south of the town, without sustaining a flexible approach.
Further growth should be directed KSCs, such as Sharnbrook, which demonstrate a good
level of facilities and perform an important role in facilitating strategic residential
development, considering the existing and potential capacity of infrastructure and services.
Remedy

As part of this approach the allocation of housing to any KSCs or RSCs needs to have regard
to the overall levels of increased housing need, and where appropriate the quantum adjusted
to reflect both settlement and site capacity.

In the case of Sharnbrook it remains appropriate to adopt a more comprehensive approach
to strategic residential development that is well-related to the village, providing benefits that
cannot be delivered through the allocation of a combination of smaller site options. The
decision of the Neighbourhood Plan to pursue in-effect new freestanding development at Hill
Farm (to be considered in the context of the wider settlement hierarchy) does not impinge on
the reasons to continue to support the justification for Policy 3S at Sharnbrook itself.

Object

Representation ID: 9004

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The opportunity for transformative change resulting from the delivery of East-West Rail within
Bedford Borough is not disputed. However, the Council’s own evidence demonstrates that
the level of rail-based growth at Kempston Hardwick/Stewartby and Wixams relied upon as
part of its Preferred Options is unsound. National Planning Practice Guidance ID: 68-020- 20190722 states that a pragmatic approach should be taken when considering the intended
phasing of sites, where the authority may need to provide a greater degree of certainty than
those in years 11-15 or beyond. The PPG expands on this by stating that where longer-term
sites are relied upon evidence must be available to demonstrate that they will come forward
within the timescales envisaged and at a rate sufficient to meet needs over the Plan period
(ID: 68-019-20190722).

While these sections of the PPG post-date the NPPF2012 it is the case that the Council has
historically failed entirely in setting out realistic timeframes for the development of complex
sites. These shortcomings have particularly affected Town Centre sites in the past, which the
Council will now unsuccessfully rely upon to sustain completions against the housing
requirement in the Local Plan 2030. We argued at the previous Local Plan Examination that
such sites should be identified as developable no earlier than the 11-15 year period.

These issues with existing sites will be compounded in the Council’s trajectory for the Local
Plan 2040 (meaning that even its proposed ‘stepped approach’ against a requirement of
970dpa to 2030 will not be effective). These representations further demonstrate the lack of
evidence to consider rail-based growth in the A421 corridor as developable any earlier than
years 11-15 of the Plan period (if not beyond) thus rendering the Council’s Preferred Options
entirely unsound.
Reasoning

The Council’s own Development Strategy Topic Paper identifies multiple risks to the railbased
component of growth in the A421 corridor, including:
• Delivery of new rail stations is proposed, but not yet confirmed.
• Lead in times for remediation of the Kempston Hardwick area and delivery of new
rail stations mean that development in this part of the transport corridor will occur
later in the plan period.
• Detailed analysis of context and density / storey heights to establish appropriate
place making for the rail based growth at Kempston Hardwick and Stewartby has
yet to be undertaken.
• The land at Kempston Hardwick is currently being promoted for employment
development.

These points confirm that the Council’s extremely wide range of potential quanta for the
development of rail-based growth are not currently informed by evidence of site-specific
opportunities assessed as suitable, available, or achievable. This means that there is no justification whatsoever for the levels of development summarised at paragraph 3.12 of the
Council’s Topic Paper:
“Transport corridor – rail based growth: land within the parishes of Kempston Hardwick,
Stewartby and Wixams. On the assumption that new rail stations will be delivered at
Wixams and Stewartby / Kempston Hardwick, ambitious growth is assumed at both
Wixams and Stewartby / Kempston Hardwick in the range of 1,500-3,000 dwellings at
Wixams and 2,500-5,000 dwellings at Stewartby / Kempston Hardwick by 2040. Within
the options two levels of development are tested: a lower option total figure of 5,500
dwellings (2,000 at Wixams and 3,500 at Stewartby / Kempston Hardwick) and a higher
option of 7,500 dwellings (3,000 at Wixams and 4,500 at Stewartby / Kempston
Hardwick)”

There is no evidence to indicate these totals as developable in the period to 2040. In the
absence of site-specific testing the Council can have no grounds to suggest how constraints
might be overcome, when infrastructure will be provided and whether the extremely high
levels of development required to meet these totals over a very short period between
sometime after 2030 and 2040 can be achieved.

The extent of this uncertainty is summarised in footnote 1 on pp.8 of the Development
Strategy Topic Paper:
“East West Rail are currently consulting on two options for the Marston Vale Line; one
which retains the current stations at Stewartby and Kempston Hardwick, and another
that replaces them with a new station (tentatively named “Stewartby Hardwick”) at
Broadmead Road. This component of growth is based on development around the new
or existing stations in conjunction with development around the new station at Wixams.
These stations could provide a focal point for higher density growth supported by the
sustainable travel options offered by new and enhanced rail services.”

The consultation referred to recently closed in June 2021 and final decisions on the ‘Concept’
for stations on the Marston Vale line are awaited. For the avoidance of doubt, the expected
timeframes set out in the most recent Consultation Document indicate that a Development
Consent Order may be obtained by 2024 and construction on the rail works may commence
in 2025. However, this does not provide a clear timetable for the delivery of individual projects
and upgrades. Stage 05 (‘Construction’) is summarised as follows:
“Once we’ve complied with any initial conditions or requirements included in the
Development Consent Order, the government will consider the full business case for the
Project to make the final decision to proceed. Following further conversations with the
public and stakeholders, can start to construct your new railway.”

The potential for residential development to occur in conjunction with the delivery of new stations as intended by the Council is likely to require a substantially longer lead-in
timeframe.
The Council has previously acknowledged that longer lead-in timeframes must be allowed
for as part of redevelopment of the Stewartby Brickworks (Policy 25) Development Plan
allocation as it exists in the LP2030. The Local Plan trajectory anticipates delivery of only (at
most) 100 units in 2029/30 before the end of the current Plan Period. The scheme is in effect
accepted as an 11-15 year developable site.

Application proposals under reference 18/03022/EIA (validated November 2018) benefit from
an Officer recommendation to grant planning permission subject to S106 agreement. In
practice, this does not alter any conclusions regarding the deliverability/developability of the
site and likely timescales. Discussions surrounding the draft S106 obligation would be
anticipated to be extensive. This is reflective of the constraints of the site and gaps in the
evidence base for the LP2030, notably:
• Around 19ha of the site falls within Flood Risk Zone 2. Furthermore, a small
proportion (around 1ha) is located within Flood Risk Zone 3a/3b.
• A requirement to confirm costs and timescales for the requisite link from the new
development across the railway could be achieved (notwithstanding ongoing
deliberations regarding East-West Rail). whilst Network Rail is identified as a key
stakeholder for preparation of the Council’s Infrastructure Delivery Plan (December
2018) no project associated with the rail crossing is identified, costed, or phased
over the course of the plan period.
• The Council’s Local Plan Viability Assessment (BNP Paribas, November 2017
(paragraph 6.16)) notes the requirement for significant investigations to assess onsite
constraints for this complex site, with a view to preparation of a development
brief, all prior to detailed viability work taking place.

It is our experience from monitoring the delivery of the nearby Wellingborough East Urban
Extension that the construction of crossings over rail lines can take significant periods of time
and are unpredictable.

The Officer Report in relation to the current position on securing a policy-compliant (and
CIL122-compliant) package of contributions towards the site’s ability to enhance use of railbased
transport states:
“Policy 25 iv. Sets out a need for enhancements to the existing railway station
environment including accessibility, provision of facilities and security. If the railway
station stays in its current location the increased permeability of the site will improve
connections from the village to the station. The Railway Station however does not fall
within the application site and is under review as part of the wider East West Rail scheme,
details of which are not confirmed at this time.”

Given this uncertainty we would anticipate it is highly likely that a S106 obligation may not
be entered into until these uncertainties are resolved or that otherwise it would be expected
that this would be subject to future Deeds of Variation or revisions to the scheme resulting in
delays to the delivery of housing.

The Council’s Preferred Options also identify a contribution of around 2,000-3,000 further
units to be allocated at Wixams, to correspond with eventual delivery of a further new station
as part of the wider scheme. These units will be additional to the remaining capacity identified
in the Bedford Local Plan 2030 trajectory and units to be delivered as part of committed
development in Central Bedfordshire’s Local Plan (which already includes a Southern
Extension to the scheme).

The longstanding issues with delivery of the Wixams New Station are illustrative of the
impacts upon rates of development likely to be experienced at Stewartby/Kempston
Hardwick. Evidence presented at LP2030 Examination demonstrated that the build-out rate
of Wixams within Bedford Borough has been 96 dwellings per annum over the 10-year period
to 2018. Development has since commenced in Central Bedfordshire, increasing the overall
build-rate but corresponding with a reduction of activity in Bedford Borough.

Delivery of the Station has been delayed by over 11 years with the project still not expected
to commence construction until 2023 at the earliest. Commissioning of a detailed design
scheme for the proposed station was able to progress earlier in 2021 contingent on the basis
of consultation on the proposed northern alignment of East-West Rail.
While any final decision is awaited on the outcome of the Bedford-Cambridge phase of East-
West Rail there remains a risk that the time-limited period for funding available from the lead
developers of the Wixams scheme will expire and result in the project not being delivered (or
requiring additional monies to address the shortfall in project costs).

In the context of the above delays and uncertainty and in the absence of a clear timeframe
for delivery of the station the Council’s Preferred Options present no site-specific evidence
of how the additional capacity at Wixams could be achieved over the Plan period and at an
appropriate build-out rate (in addition to the delivery of extant commitments).

The characteristics of any potential increase in allocations at Wixams also represents an
issue of cross-boundary strategic importance, given that the scheme is being delivered
across local planning authority boundaries and the requirement for partial review of the
Central Bedfordshire Local Plan 2015 to 2035. This could lead to any potential for additional
development being required to address the unmet needs of neighbouring authorities (or
affecting the administrative boundaries within which the most appropriate land should be
identified).
Remedy
These representations demonstrate that the rail-based growth component of the Council’s
Preferred Strategy Options requires substantial further refinement and site-specific testing.
This is likely to substantiate a significant reduction in assumptions regarding the potential for
development within the plan period, which can be effectively mitigated through pursuing a
‘hybrid’ strategy for development in sustainable locations across the Borough.

Object

Representation ID: 9006

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

“Given the highway constraints on the A6 north of Bedford (including both new settlements
KSCs and RSCs), the need to allow villages already planning development to assimilate
that growth, the more dispersed nature of the distribution of growth and the loss of focus on
EWR, these options do not perform as strongly.”

The Council’s claims regarding the level of impact generated by any level of development at
Key Service Centres and Rural Service Centres are not justified. The Council primarily relies on evidence of other components comprising part of these strategy options (particularly
‘New Settlements’ on the A6) as generating a significant element the highways impact on the
highways network.

The assumed impact arising from village-related growth specifically results from the first
stage of testing undertaking in the AECOM Transport Model. Paragraph 1.2.2 of the
Summary Report explains that this was only considered as part of testing of four general
development scenarios, relating to the ‘grey’ (dispersed) option providing no focus upon
strategic growth locations within the corridor:
“this scenario includes all sites identified as part of the Local Plan 2040 call for sites
consultation with the size of the proposed developments scaled uniformly to ensure that the
overall growth in the borough is considered to be in the likely range of the new Local Plan
housing and employment targets.”

This approach to testing bears very little relationship with the Council’s subsequent testing
of strategy options where the opportunity to focus some growth on the urban area and A421
corridor is not disputed. Levels of growth required to be tested under the ‘dispersed’ scenario
are materially higher than the relatively limited proportion of ‘village-related’ growth in Option
3c not otherwise associated with ‘east’ and ‘south’ corridor parishes. Moreover, the AECOM
testing of the ‘dispersed’ scenario has the same flaws as the Council’s testing of ‘villagerelated’
growth in the strategy options by opting for a ‘uniform’ or ‘one-size fits all’ approach
to levels of development at individual settlements. This overlooks where site-specific or
settlement-specific justification for site selection could reduce impact on the highway
network.
Upon beginning the process for identifying strategy options the Council has acknowledged
the need for subsequent Transport Modelling. This is set out at paragraph 1.4.1 of the
AECOM Summary Paper and includes additional testing of ‘New Settlement’ options on the
A6.
Our client has instructed Transport Consultants SDD to undertake a ‘Review of “Bedford
Borough Transport Model’, including the specific assessment of impact of New Settlements
on the A6. A copy is enclosed at Appendix 7.

The findings of the Review confirm:
• Beyond levels of committed growth to 2030 in the ‘reference case’ the AECOM
scenarios are based upon different levels of growth at Twinwoods and Colworth
only, and whether each / both sites are brought forward.
• No sensitivity testing has been undertaken whereby the two new settlements at
Colworth and Twinwoods do not come forward, and instead housing growth
development at other existing villages across Bedford Borough.
• There is no justification provided within the report as to why the focus of
assessment has been focused on the development at Colworth / Twinwoods only,
as opposed to assessing potential levels of ‘village-related’ growth in accordance
with Option 3c north of Bedford from a highways capacity perspective
• No assessment is provided of the dumbbell roundabouts off the A6 in the vicinity
of Oakley, nor the junctions with Highfield Road further north along the A6
• There is not specific testing of impacts and changes to the network resulting from
the deferral of site allocations to Neighbourhood Plans – specifically the need for
a new roundabout on the A6 required as part of the proposed Hill Farm
development.

It follows from the above that the Council’s conclusions for strategy options in the
Development Strategy Topic Paper and reasons for the selection of Preferred Options at
Paragraph 3.12 of the Consultation Document are not justified and not consistent with
national policy.

The Council has not only failed to justify that the impact of Option 3c on the highway network
would be severe but failed to begin preparation of Transport Modelling that would in any way
allow it to test a ‘hybrid’ approach to development in providing for an appropriate strategy.
The requirement for further testing is significant in terms of ensuring further site-specific and
settlement-specific testing of options maximises the potential to achieve benefits for the
highway network in accordance with paragraph 110 of the NPPF2021, for example:
• Assessing the opportunities to relieve congestion at Station Road, Oakley
associated with Lincroft Academy through provision of a new dedicated access
together with supporting sustainably located residential development within easy
walking distance of Primary and Secondary education in the village
• Promoting growth adjacent and well-related to the Sharnbrook Settlement Policy
Area, facilitating opportunities for the delivery of new and accessible services and
facilities (including a Primary School) within walking distance from existing
residents of the village in order to sustain and enhance its role.

This section of our representations (and supporting information at Appendix 6) confirms the
requirement to undertake further detailed testing of a ‘hybrid’ strategy option including an
accurate assessment of potential impacts on the highway network.

Object

Representation ID: 9008

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

This section of the representations should be read alongside the separate Delivery
Assessment included at Appendix 5. This addresses the ability of the Council approach to
maintain a rolling five year supply of deliverable sites (including as part of its proposed use
of a ‘stepped trajectory and upon proposed adoption of the Local Plan 2040). The Delivery
Assessment also illustrates that the Council is unable to demonstrate a five year supply of
deliverable sites based on its own published position (at a base date of 1 April 2019) or when
this is rolled forward to 1 April 2021.

In summary, the Council’s proposed approach to managing the delivery of housing over the
Plan period is unsound. The Council indicates a proposed 20-year Plan period (2020 to 2040)
for the Local Plan Review. The Local Plan Review must meet minimum annual local housing
need calculated in accordance with the standard method. Planning Practice Guidance ID:
68-031-20190722 answers the question ‘how can past shortfalls in housing completions
against planned requirements be addressed’? and states:
“Where the Standard Method for assessing local housing need is used as the starting point
in forming the planned requirement for housing, Step 2 of the Standard Method factors in
past under-delivery as part of the affordability ratio, so there is no requirement to
specifically address under-delivery separately when establishing the minimum annual local
housing need figure. Under-delivery may need to be considered where the Plan being
prepared is part way through its proposed Plan period, and delivery falls below the housing
requirement level set out in the emerging relevant strategic policies for housing.”

Based on the emerging proposals the performance of delivery in the period 2020 to 2023 will
be relevant to assessing the soundness of the Local Plan 2040. Performance for this period
will therefore be substantially informed by the Council’s current evidence of deliverable
supply against the Local Plan 2030 housing trajectory (and extant consents).

The Council’s Preferred Options consultation proposals also indicate that it is likely to rely on
a ‘stepped trajectory’ for the Plan period to 2030 (retaining an annual requirement of 970
dwellings per annum). The Preferred Options principally rely on large-scale strategic sites
with limited prospects for delivery within five years from adoption (2023 to 2028). The
Council’s supply for this period will therefore also substantially be informed by the Local Plan
2030 trajectory (and characteristics of sites identified in Neighbourhood Plans).

The evidence for sites identified in the Local Plan 2030 trajectory, as of 1 April 2021, reviewed
in the separate Delivery Assessment, demonstrates that these do not achieve an early
prioritisation of housing delivery. This reflects issued raised throughout the Local Plan 2030
Examination relating to constraints to viability and availability of the sites identified,
particularly within the Town Centre.

Regarding Town Centre sites identified in the Local Plan 2030 and the associated
longstanding delays to development there is no mention of a Development Corporation in
either the Council’s consultation document or consultation on a Vision for the Oxford-
Cambridge Spatial Framework. The Council has previously indicated that this may be the
route to unlocking sites and overcoming barriers to development for which there is currently
no clear solution.

In these circumstances the Council’s proposals to pursue a stepped trajectory are contrary
to national policy and guidance. PPG ID: 68-021-20190722 answers the question ‘when is a
stepped requirement appropriate for plan-making’? and sets out:
“A stepped housing requirement may be appropriate where there is to be a significant
change in the level of housing requirement between emerging and previous policies
and / or where strategic sites will have a phased delivery or are likely to be delivered later
in the plan period. Strategic policy-makers will need to identify the stepped requirement in
strategic housing policy, and to set out evidence to support this approach, and not seek to
unnecessarily delay meeting identified development needs. Stepped requirements
will need to ensure that planned housing requirements are met fully within the plan
period. In reviewing and revising policies, strategic policy-makers should ensure there is
not continued delay in meeting identified development needs.
Where there is evidence to support a prioritisation of sites, local authorities may
wish to identify priority sites which can be delivered earlier in the plan period, such
as those on brownfield land and where there is supporting infrastructure in place e.g.,
transport hubs. These sites will provide additional flexibility and more certainty that
authorities will be able to demonstrate a sufficient supply of deliverable sites against the
housing requirement.” (SPRU emphasis)

There are four key issues to highlight with the Council’s proposed use of a stepped trajectory:
• The change in housing requirement cannot be considered significant. The Council was
fully aware of these circumstances when the Local Plan 2030 was adopted with the
requirement for early review. Planning for a difference in the annual requirement of
around 305 dwellings per annum (LHN of 1275 vs OAN of 970) is a relatively modest
change in the context of a recently adopted Local Plan that should maintain a minimum
rolling supply against the OAN figure
• The Local Plan 2030 unnecessarily sought to delay meeting needs in accordance with the government’s latest policy. Pursuing a stepped trajectory simply perpetuates that
problem
• The current Local Plan 2030 housing trajectory provides for no flexibility or certainty
(particularly given issues with Neighbourhood Plans and Town Centre sites). The
Council’s Preferred Options provide no resolution to this.
• The use of a stepped trajectory will not ensure needs are met in full. There will be a
substantial shortfall against the stepped requirement of 970dpa to 2030 (based on the
latest information regarding supply). A reliance on large-scale strategic sites beyond
2030, for which there is a poor record of success in the borough in terms of timescales
and rates of delivery, does not provide a reasonable prospect of development in
accordance with PPG ID: 68-019-20190722)

Those issues relating to the current Local Plan 2030 mean that there is no prospect
whatsoever that extant commitments and allocations alone would allow the Council to
demonstrate a five year supply of deliverable sites based on the calculation of minimum
annual local housing need upon adoption of the Local Plan 2030.
Our analysis demonstrates that the Council’s proposed approach to rely on a stepped
trajectory is also flawed. This will not achieve a five year supply of deliverable sites upon
adoption of the Local Plan 2040 without significant support to prioritise the early delivery of
additional sites.