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

Object

Representation ID: 6067

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.2. The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or improved transport options etc. However, it is surprising that the Vision does not make any stronger statements on growth, where it will be located, or make a commitment to delivering the required number of new dwellings, and employment land as identified in the remainder of the Draft Plan.

3.3. Given the emerging focus on the delivery of the Oxford - Cambridge Arc as identified in the document, and the current consultation on priorities for the Spatial Framework, it seems a missed opportunity for the plan not to take a lead in setting out how it could play an important role in delivering the vision. The statement at paragraph 1.11 appears to read as “we will do what we have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

3.4. In particular it would seem sensible for the plan to make some provision for the possibility of an uplift in housing and employment growth that may emerge through the preparation of the Arc’s Spatial Framework. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”
Our emphasis

3.5. At paragraph 5.8 of the consultation, it adds:

“In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself.
Our emphasis


While it is acknowledged that the Local Plan review and the Spatial Framework will be prepared in parallel, it is clear that the emerging vision is targeting a more advanced and robust form of growth. Therefore, for the Plan to be “positively prepared”, we would contend that the Local Plan Review should allow for some uplift whether that be 10 or even 20%. If the Spatial Framework is adopted at the same time as the plan, there is likely to be the added pressure to consider another urgent review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and help towards reducing the burden going forward.

3.6. This important point is supported by updated guidance in the revised National Planning Policy Framework (2021); and, while it is accepted that this Consultation was developed in advance of the publication of the revised Framework, we must highlight that under paragraph 22 it states that where Local Plans are to include new settlements or significant extensions to towns and villages, then it should be set within a vision which looks at least 30 years ahead. As the transitional arrangements at paragraph 221 of Annex 1 confirm this applies to plans that have not reached Regulation 19 stage; then, no matter which strategy is chosen, the Bedford Local Plan 2040, must expand its “vision” to set out how it will accommodate growth beyond 2040 and deliver on the ambitions of the Arc.

Object

Representation ID: 6068

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.7. The current housing need requirements of 970 dwellings per annum were based on a previous housing needs methodology which was allowed to proceed on the basis that the Local Plan 2030 was submitted and examined under the procedures of a former version of the NPPF. The late adoption of the Plan, and the reduction of the plan period from 2035 to 2030, resulted in the Inspector imposing a requirement for the Council to undertake and submit a review of the Plan for examination within three years of its adoption, (Policy 1 – Reviewing The Local Plan 2030).

3.8. It is therefore explicit that the Council needs to consider the review in the context of an elevated housing requirement as set out in the Standard Methodology. The Council must therefore address this shortfall in this Review. If this is not adequately addressed throughout the earliest 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.

3.9. It has long been stated that there is need to deliver a step change in housing delivery, but this has never been more apparent than the comparison of the previous objectively assessed housing need, versus the need identified in the standard methodology. 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.

3.10. Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West Rail 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. There is an opportunity to accelerate development through the current allocated site at Great Barford west to ensure that there is sufficient supply of new homes into the new Local Plan period.

Object

Representation ID: 6069

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.11. We support the proposed growth along the A421 corridor. This accords with the Government’s strategy of delivering a growth corridor between Oxford and Cambridge which includes the building of one million high quality new homes, and over one million new jobs across the corridor by 2050, in order to maximise the areas economic potential.

3.12. However, although the four growth options being consulted upon all include the A421 corridor, only Option 2d includes the eastern parishes and fully explores the potential of this corridor and its settlements to accommodate growth. We contend that the eastern parishes should be included in the selected growth strategy otherwise an important part of the Oxford To Cambridge arc, namely the villages around the Black Cat interchange, will be left out. The eastern area of the corridor includes several sustainable settlements including Key Service Centres, all with good links onto the A421 and the A1. Allocations should be made across the entire corridor to ensure its economic potential is maximised.

3.13. We therefore raise objection to Growth Options 2a, 2b, and 2c as they have omitted a crucial part of the A421 corridor, and wish to elevate option 2d as the preferred option for growth to maximise the delivery of new homes through the sites allocated in the current local plan

3.14. In respect of those options reliant on the delivery of either one or two new settlements, our clients would argue that the Borough should be cautious in relying upon such a strategy to meet the required delivery rates for housing. As the Borough Council know from their experience with the Wixams, new settlements are difficult to deliver and take time to start making a contribution. New settlements can be part of the strategy, but a realistic view, a cautious view should be taken on the rate of growth these proposals can deliver, and plan accordingly.

3.15. In contrast urban and village extensions with one landowner and direct access to the existing highway network can deliver much quicker within the plan period, but are big enough to deliver new infrastructure in the form of schools and community facilities. Our client’s land in Great Barford offers that potential, is large enough to accommodate new strategic growth while having the land to deliver the necessary infrastructure. It can also build upon the current release of land at Great Barford West, as well as take advantage of the ability of the existing Primary School to accommodate expansion. A further 500 dwellings would take the education requirement at Primary level to a 3-form entry. We would argue there is sufficient capacity to achieve that and a 3 form entry primary school is of an appropriate size to deliver high quality education provision.

3.0 - Growth Option 2d
3.16. Of the selected growth options, our client’s support growth Option 2d which seeks to distribute growth along the entire A421 corridor. This option will contribute towards the Governments strategy of delivering a growth corridor between Oxford and Cambridge.

3.17. Great Barford is the largest settlement in the eastern parishes, and a Key Service Centre and it would therefore be logical that it be proportionally allocated the larger share of the identified growth.

3.18. We would also state that the quantum of development identified in option 2d is too low and would not fully utilise sustainable sites available within the eastern parishes, particular in Great Barford, where our client’s control land suitable for a further 500 dwellings or more and directly adjoining the high frequency bus route provided by the X5 linking between Milton Keynes, Bedford and Cambridge. Countryside have experience of procuring new bus services and routes through direct engagement with bus providers such as Stagecoach and First.

Support

Representation ID: 6070

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.25. We support the policy of creating a minimum of 8,642 net additional jobs up to 2040. A reasonable proportion of this growth should be facilitated along the A421 in line with the Governments objective of providing over a million jobs across the Oxford – Cambridge Arc by 2050.

3.26. Land West Of The Village Of Great Barford South Of The A421 (Site 878) has excellent links onto the A421. Small scale employment provision in this location would further enhance the sustainability of Great Barford as a Key Service Centre.

Object

Representation ID: 6071

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.27. The objective of this policy can only be delivered if there is a reasonable and proportionate distribution of growth along the corridor in desirable places where a need is identified on the Self Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of self build plots in and around the urban area. The Government’s objective in bringing in the self-build requirement was for that untapped part of the sector to start making a contribution towards housing delivery.

3.28. This means that self-build plots should be provided where they are wanted, and as the register shows a broad range of desirable locations, if the objectives of SB1 are to be realised, then a commensurate range of sites should be provided.

Object

Representation ID: 6072

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

4.1 The settlement of Great Barford was included in many of the options (2d, 3b, 3c, 4, 6, and 7) in the Issues And Options Consultation June 2020, with many of the options allocating 500 dwellings to the settlement in the next plan period; with option 2d identifying some growth to the area but no specifics.

4.2 As Great Barford is only now included in one of the four options being consulted upon – Option 2d, we must raise objection and highlight that the exclusion of strategic growth of Great Barford is a missed opportunity; and that the reasoning given in the sustainability appraisal for discounting this level of growth are considered superficial and indicate an underlying bias towards urban centric growth.

4.3 It is important to note that many of the options were not discounted due to issues with allocating growth to Great Barford itself, but because there are considered to be issues with the overall strategy in those particular options. For example, Option 7 was discounted because the required level of growth cannot be achieved. It is therefore crucial that Great Barford is not discounted as a suitable settlement for growth simply because it happened to be one element of an overall strategy in options which are considered to be less desirable. We would strongly contend that the sustainability credentials of Great Barford should be considered on its own individual merits.

4.4 Great Barford is a Key Service Centre and a sustainable settlement in a major strategic location on the Oxford To Cambridge Arc. It is an ideal location for delivering further strategic growth in this Local Plan Review. Countryside are delivering other strategic sites within the Oxford to Cambridge arc such as at Bourn airfield (3500 new homes) and have experience of working with a range of stakeholders to address cross boundary matters.

4.5 Option 2d in the consultation is the only option which includes all of the A421 corridor on the Oxford To Cambridge Arc. Given the Government’s objectives for the arc and the strategic importance of this location, and the fact that Great Barford is the most sustainable settlement in the eastern parishes, it is considered crucial that it be included in the final strategy taken forward

Object

Representation ID: 6074

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

5.1 We raise objection to the contents of the Sustainability Appraisal. The framework for considering sustainability is well established, and we do not raise objection to the general scope of the appraisal. However, it is felt that there is an underlying bias towards urban centric growth, which discounts further growth in the Key Service Centres and smaller sustainable villages.

5.2 The four options in Option 2 are described in the consultation as primarily an urban centric set of options focused on growth in and around the urban area, and rail connection points. We would argue this approach is far too simplistic and omits an opportunity to enhance the sustainability of Key Service Centres through the provision of additional services and employment opportunities. It also ignores the potential to build upon the community-led ambitions of the many Neighbourhood Plans that have been prepared in the Borough

5.3 We would comment that at paragraph 8.10, the Council comment on merits of growth around rail hubs and yet ignore to a large extent the value of the bus network with high frequency bus services being a far more flexible and viable option to providing an alternative to the car. The delivery of housing growth along the high frequency bus network, such as that served by the X5, has the knock on benefit of supporting improvements to services and wider improvements to sustainability across a broader range of settlements.

5.4 An enhanced population along the bus network increases passenger numbers which enables improvements to those existing services to be more viable. By enhancing the network as a whole, you can better serve smaller settlements and improve their sustainability as a consequence. We would highlight again that Countryside has significant experience of procuring additional bus services through their developments in collaboration with local services and ensuring they become viable.

5.5 We would also highlight that sustainable development needs to plan for the longer term. The private motor vehicle/car is considered to have a harmful effect on the environment, contributing to rising CO2 levels and poor air quality. As a consequence, the language of sustainability talks about “reducing the reliance on the private motor vehicle”. However, as we progress forward in carbon neutral/zero emissions vehicles, this notion will be out of date. The Government has brought forward it’s ban on the sale of new petrol and diesel cars to 2030, with all new cars and vans required to deliver zero emissions from the tailpipe from 2035. The car industry has also reacted with many car manufacturers already committed to being fully electric by 2035. As well as the largest manufacturers such as Volkswagen Group committed to their vehicles being carbon neutral at the point of manufacture.

5.6 With the move towards more environmentally friendly forms of private transport which are driven and supported by the ever-growing energy provision coming from renewable sources, the impact of the private motor vehicle will change, and will be part of a range of sustainable transport options.

5.7 We would also raise objection to the very narrow view that somehow sustainability can only be achieved by one model of growth, with a focus on what is new, being located in only a select few locations; and that somehow everything else is not sustainable, nor could ever be altered to being sustainable. In our view it ignores the wider objective of enhancing the sustainability of existing settlements of all sizes, and fails to support the long-term vitality and viability of those existing settlements and the services and facilities they rely upon.

5.8 It also assumes that travel patterns will continue to grow along the same trajectory, but our collective experiences through the Covid19 pandemic have accelerated the trend of home working supported by advancements in technology. As demonstrated by the pandemic, a large portion of the economy can continue to function without the need to travel, and to some extent has opened people up to embracing technology and minimise their need to travel to communicate. All development needs to consider, that going forward, a greater proportion of people will be working from home or in localised hubs without need to travel long distances. That degree of flexibility is already coming in in the form of communal work spaces, and hot desking etc. Therefore, the provision of high-speed broadband to all new developments, as well as supporting enhancements to the existing network, is essential in delivering sustainable growth.

5.9 We would therefore conclude, by arguing that the sustainability credentials of the settlement of Great Barford should be assessed independently, and the opportunities for growth in the settlement fully considered in light of its sustainability credentials. It is self-evident that Great Barford occupies a sustainable location, served by A421 at the junction with the A1, and is supported by high frequency public transport links via the X5 and 27 bus services. The settlement is independently accessible from the major road network, and within short distance of a major employment area on the eastern edge of Bedford, with existing pedestrian and cycle connections into the town. We believe that the allocation of development at Great Barford would meet many of the sustainability objectives the Council are arguing in support of options 2a – 2d, and as such would question why strategic growth here has been discounted.
Countryside takes its responsibilities as a sustainable developer very seriously and have a number of strategies to ensure we meet these objectives and continue to monitor progress (sustainability approach document attached at Appendix A).