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

Support

Representation ID: 5659

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraph 1.5-1.7
Hallam Land Management supports the proposed Local Plan period of 2020-2040. Hallam considers that the period is most suitable for meeting a strategy that is enduring for accommodating growth across the Borough, in a way that meets the needs of the Borough and contributes effectively to growth ambitions of the Oxford Cambridge Arc. A longer-term plan period would allow the Borough Council to plan more appropriately for future strategic development allocations / locations which would in turn inform more strategic and longer-term infrastructure requirements.

Support

Representation ID: 5660

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management considers that the draft vision remains constrained by the absence of a single preferred strategy option which is needed to inform a vision that is more spatially relevant and provides a meaningful context for the emerging themes, and objectives, which themselves deserve to be more spatial in focus in focusing future growth.

As stated in Hallam’s Response to the Growth and Spatial Strategy Options, a preferred strategy is required that includes a combination of the wider options presented as alternatives. A single themed option based on the variants of Option 2, is unlikely to realise each of the opportunities for sustainable development and investment. Similarly, a single theme places additional risks in relation to delivery of homes and infrastructure – the prospect of which has been given secondary rather than primary consideration, were a single theme to be advanced as a preferred option. Maximising and not just meeting basic delivery aspirations should be a leading factor in the identification of the preferred option.

Spatial elements of the vision are initially focused on Bedford Town Centre. As a development strategy emerges, we would expect the vision and themes and objectives to be more spatially relevant in setting out the priorities for growth at more well-defined locations across the Borough to provide an appropriate context for the development strategy, and policies for the distribution of housing growth, employment and more detailed policies.

The focus on sustainable neighbourhoods implies sustainable developments in Bedford and Kempston and in village communities but is not reflected in the preferred variants of Option 2. In particular Hallam considers that a focus on Bedford and Kempston should embrace related settlements adjacent to the town. Such a focus needs to be more holistic and not just about design, but also supporting development with adequate infrastructure development. As such, Hallam considers that the Vision should be that by the end of the plan period, major strides will have been made to greatly enhance the sustainability, infrastructure and quality of life of existing communities through the opportunities delivered for sustainable development in and at existing communities. The focus should, therefore, be on the creation of sustainable communities be it through a balanced focus of growth at existing settlements as well as any major planned expansion or new settlements – i.e. not just sustainable developments, that as a main focus risks undermining achieving the true sustainability potential of existing communities. Nor is it appropriate or sustainable that existing settlements should be left behind.

Support

Representation ID: 5661

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraphs 3.1-3.7
Hallam Land Management supports the approach to the level of housing growth required, which as a “starting point” is set at 1,275 dwellings per annum and represents a significant uplift from the Local Plan 2030 requirement of 970 dwellings per annum.

Given the scale of uplift required, and significant challenges in terms of housing delivery, Hallam does not consider that a stepped trajectory would be appropriate. The example suggested in paragraph 3.5 - that the delivery target is 970 until 2030 then increased to 1,580 dwellings per annum, thereafter, equates to a significant uplift in housing delivery by 62% after 2030. It builds in the postponement of measures to meet immediate need, and it increases substantially the level of risk built into the plan since the effects of any underdelivery of stepped housing requirements on housing need would be greatly exacerbated. Hallam considers that delivery constrained to 970 dwellings in 2020-2030 would create a significant cumulative underbuild towards 2030 and is likely to undermine wider growth and planning objectives including those expected to emerge through the Oxford Cambridge Arc Spatial Framework. In this context Hallam considers that the housing trajectory is required to reflect an immediate uplift to the “starting point” of 1,275 and with a buffer. Such an approach will have implications for Spatial Strategy Options with an approach that is flexible and adaptable to change.

Object

Representation ID: 5662

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraphs 3.17, 3.10-3.16
Hallam Land Management objects to the preferred growth strategy options which are narrowly focussed on those variants of Option 2, and therefore also the decision to reject the alternatives or elements thereof presented in Option 1 and 3-7 and its variants. Hallam considers that a preferred strategy needs to be more reflective of a balanced and appropriately weighted approach in planning for sustainable development across the Borough and in this regard considers that a single preferred strategy must include an appropriate combination of the wider options presented with due weight given to those that can create a balanced and sustainable spatial strategy.
The variants of Option 2, although positive in focus towards Bedford and being aligned, broadly in the context of the anticipated Oxford Cambridge Arc Spatial Framework, notwithstanding the constraints of the A6 corridor, exclude opportunities for development at an appropriate scale to support existing communities. There are also doubts as to whether the most restrained variant – Option 2a would be able to provide sufficient capacity, in isolation, for growth, certainly around rail station locations provide opportunities for maximising sustainable accessibility to Bedford and along the East West Rail corridor.
No change is observed in the evidence base or the outcome of the existing plan – that existing well connected and well served settlements represent highly sustainable options for development. Specifically, the preferred strategy should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in East West Rail and connectivity to Bedford station – rail related potential is not limited to the south of the town and Bedford Station is as, or more, accessible from the north – more so with enhanced sustainable transport links, potentially including the A6 corridor as a focus for infrastructure investment (i.e. more frequent bus services and physical cycle links). The preferred strategy should not therefore rule out opportunities for continued development at Key Service Centres, particularly to the north of Bedford which is otherwise avoided by variants of Option 2 and is likely to rely on windfall development without any additional allocations. Such an approach will fail to realise sustainable investment in those existing communities and their infrastructure. Indeed, the opportunities that do exist to invest in sustainable transport, both for new and existing communities, to the north of Bedford, should be identified and supported through the transport and growth strategies of the plan. That the Council considers mitigation opportunities in the A6 corridor to be insufficient to support major scale development at Twinwoods or Sharnbrook, does not mean that there are not opportunities to be realised through lesser scale sites (than Twinwoods or Sharnbrook) in sustainable existing communities.
In this context, Hallam considers that a preferred strategy should combine elements of the wider discounted options (1 & 3-7) to best achieve the scale of growth that is likely to be required. Hallam considers that elements of discounted options have a part to play if the housing numbers are to be met in capacity terms and in securing an appropriate geography of opportunities and in helping meet the deliverability gap that is implied by stepped housing requirements and any allocations of large scale new communities or settlements. Hallam also considers that the preferred combination of options must be identified to enable a robust trajectory of delivery to come forward. In practice, Hallam have suggested that this will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. Of those locations identified for more strategic scale development along the A421 and East West Rail corridor, account should also be taken of cumulative delivery rates in the context of the scale of delivery being planned in Bedford Borough but also in Central Beds and other adjoining locations as part of the Oxford Cambridge Arc agenda. Some flexibility or tolerance may be required with anticipated delivery timescales. Such uncertainties and a requirement for contingencies translates into a more balanced focus that looks also towards the north of Bedford.
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Whilst considering that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford and therefore, emphasises for clarity, that this must extend beyond the 0.5 miles of the urban area boundary to include the most immediate neighbouring settlements that have significant potential to benefit from enhanced sustainable connections. An example in this context is Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). It becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. There are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the village.
The potential for Clapham to accommodate future growth and being well connected to Bedford, whilst being distinct as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham present the opportunity for the Borough Council to encapsulate a Greater Bedford option or element in its plan preparation and in due course in the plan strategy. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions but needs a comprehensive approach. A Greater Bedford element to the plan, including the urban areas and immediate settlements would reflect that ambition and provide a positive framework for investment and early delivery. .
The Development Options Topic Paper, in referring to the sustainability appraisal of the broad components of growth, considers the urban area component of the preferred options (including the rejected variants of Option 1, which would play a key role in a wider strategy) to perform best and then considers the adjoining urban area component to perform almost as well. In this context it follows, in Hallam’s view, that growth in immediate neighbouring settlements to the Bedford Urban Area such as Clapham are also capable of performing just as well as what is currently considered to be the adjoining urban areas with enhanced sustainable connections in the form of frequent public transport services and active travel routes. In this context a limit to identifying opportunities for growth to within 0.5 miles of the urban area boundary is considered arbitrary and not necessarily reflecting functional relationships. In practice existing settlements such as Clapham are arguably better located than sites in the immediate adjoining area, where patterns of existing development are likely to constrain opportunities for development that can fully exploit and enhance sustainable transport corridors. In Hallam’s view the definition of the adjoining area should be broadened to include the most immediate settlements that are able to be well connected though relatively modest infrastructure investment. In essence, this approach begins to reflect elements of Options 3b and 3c, 4, 6 and 7, insofar that the focus is extended to those smaller settlements that are immediately adjacent to Bedford and have the potential to benefit from enhanced sustainable connectivity.
An added benefit of securing an appropriate level of growth in those smaller settlements, particularly those adjacent to Bedford, would also be to support local services. Key Service Villages such as Clapham with additional development has the potential to support and enhance the offer of local services, including community facilities and local retail. These benefits are particularly important for people who do not have access to a car. A greater reliance of access to local services and facilities have been underpinned recently by the changes to working and living patterns arising through the Covid-19 pandemic.
Furthermore, a rationale in the current adopted development strategy is apportioning growth to Key Service Villages to support the provision of new Primary Schools with a scale of growth sufficient to support the delivery of 1 form of entry accommodation, is at odds with the Borough’s Council’s position (as set out in its paper for Education Provision for the Local Plan 2030) that new primary schools should by preference be for 2-3 forms of entry. It follows in this context that allocating further development to Key Service Villages would enable for the delivery of primary schools that are of an operationally efficient and preferable size (i.e. 2-3 forms of entry).
In identifying a Preferred Spatial Strategy Option, Hallam’s View is that this should be based on:
1. Embrace and include urban based growth and areas adjoining the Bedford urban area boundary including immediate neighbouring settlements (i.e. such as Clapham) that are or have the potential to be well connected to Bedford (therefore, partially reflecting Options 3b, 3c and Options 4 and 6) recognising also the contribution such elements can make before larger scale elements of the strategy
2. Medium to longer term infrastructure focused transport-oriented growth around existing and proposed East-West Rail Stations and key public transport routes or larger scale options (partially reflecting the variants of Options 2 and Options 4,5 & 6).
3. And, to a lesser extent, continue to focus more modest levels of growth at other Key Service Villages outside the Bedford catchment where development will further support local services and facilities to reduce the need to travel for day to day requirements and fully support the delivery of operationally efficient primary schools (as reflected in Options 3b and 3c and Options 4, 6 & 7).

Support

Representation ID: 5663

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam land Management considers that planning for the co-ordinated delivery of sites in and around the urban area and including the most immediate settlements such as Clapham, offers the potential to accommodate additional development that can support the co-ordinated improvement of existing infrastructure.
With much of the hard infrastructure in place Hallam envisages improvements involving enhancements to transport corridors into Bedford to the railway station to access East West Rail and the town centre to reinforce its vitality and vibrancy.
In the context of tackling climate change, locating new development in immediate settlements adjacent to Bedford offers the potential to create the critical mass necessary to support and enhance public transport services with increased frequencies to enable them to become modes of choice. Similarly, development can support investment in active travel infrastructure.
The co-ordinated growth of settlements within a ‘cycle-shed’ of Bedford, as a key part of the overall strategy provides an opportunity for capturing value from new developments alongside access to funding for sustainable transport infrastructure to invest in cycleways – including corridor improvements for continuous links (e.g. wider pavements, on road facilities). Such an approach would contribute significantly towards the England’s Economic Heartland’s Transport Strategy and align with Bedford Boroughs’ own transport principles – in terms of improving public transport networks and local connectivity and accessibility through active travel.
Hallam considers that the approach above further underpins the rationale (as argued by Hallam in its response to the Growth Strategy Options) for the Preferred Growth Option to include a Greater Bedford approach and as such modify the Bedford adjoining areas from an arbitrary limit of 0.5 miles from the urban area boundary to include the most immediate and well-connected adjacent settlements that would benefit from investment in public travel and active travel infrastructure.

Support

Representation ID: 5664

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Paragraphs 3.26 – 3.28
Housing on small sites, in the context of the National Planning Policy Framework and requirement for the Council to deliver 10% of the housing requirement on small sites no larger than one hectare, is linked by the Borough Council in 3.26 to windfall housing development.

The Borough Council’s proposed windfall allowance is based on monitoring of past windfall delivery rates during 2015-2020 which found that the number of dwellings built on small sites was consistently above 10% of the annual housing requirement. Whilst this is a logical approach for planning for development on small sites, Hallam Land Management has concerns about how the trend in windfall will continue spatially across the borough.

Whilst windfall development is likely to continue, Hallam is concerned that opportunities for development in smaller settlements will become more constrained as existing opportunities on brownfield and infill sites are developed which leads to concerns on how smaller settlements can continue to accommodate modest levels of growth to support existing community facilities.

In Hallam’s view, whilst windfall will continue to contribute to housing supply, the overall amount is likely to be increasingly composed of changes of use allowed under permitted development rights and be more focused in Bedford. Increasingly limited opportunities outside the Bedford Urban Area supports a rational for allowing for planned provision, certainly in the Key Service Villages if they are to fully support the adequate provision of education, wider services and sustainable transport.

Support

Representation ID: 5665

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

In response to the invitation to submit sites that could be available to meet Bedford Borough’s growth needs, Hallam Land Management submitted two sites at Clapham Village including East of Clapham and North of Clapham (Site ID: 975 & 976). Hallam has reviewed the Site Assessments that have been carried out on the sites submitted by Hallam, being both Site 975: East of Clapham and Site 976: North of Clapham as set out in the ‘Site Assessment Pro Forma’ (Bedford Borough Council - Site Assessment Pro Formas (oc2.uk)) and is submitting separate comments, as requested to update and augment the assessment of Site 975. Hallam is also submitting comments on a separate site in Clapham (Site ID: 3234).
These are attached to these representations

Object

Representation ID: 5666

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management objects to the proposed Policy for Essential local shops and public houses and their change of use.

The approach is not consistent with national policy and no specific justification for it, that is consistent with national policy, is provided. Equally, what constitutes an essential service or facility is also not explained nor easily done – which types of shops – foodstore, nailbar etc.

If the policy is to preclude a congregation of hot food or similar retail elements, then it should say that.
In the absence of the justifications set out above, Hallam suggest that the policy is deleted and not pursued.
Were the policy to be retained, Hallam considers that the requirements of ii) should only apply to be consistent with paragraph 5.28 if there are no alternative facilities, with regard to i), within 1,000 metres or that a broad range of facilities is available. We believe the requirements for ii) should only applying when i) cannot be met. Otherwise, Hallam considers the requirements of ii) would be too onerous if alternative essential services are available within the 1,000 metres distance threshold. That definition should also be widened to address the breath of services in communities rather than simply distance which is arbitrary.

Hallam also considers criterion iii) to be vague in terms of ‘similar uses’ and would welcome clarity on this term. Without such clarification the objective of iii), appears to overlap with the objectives of Policy TC9 which seeks to guard against the impacts of concentrating similar, albeit “Town centre uses”. Hallam in this context questions whether iii) is necessary. Should it be so, then Hallam would also request the criterion to clarify that test it to be applied to the proposed use.

Equally even if uses are viable, there are planning and other justifications, that would permit alternative uses or purposes and the loss of such a facility as a result of wider benefits achieved. This should be recognised in any policy.

In context of the above concerns, Hallam therefore request a change in the wording of the policy, if contrary to Hallam’s view it is to be retained, which as such should be read as:

Policy TC8 – Essential local shops and public houses – changes of use
The Council will only grant planning permission for the change of use of essential local shops within Class F2 or public houses to other uses when:
i. There is an alternative facility within 1000 metres providing a similar service or a range of facilities available within a relevant definition of community; [and] or
ii. The applicant can demonstrate to the satisfaction of the Council that the current (or last) use is no longer economically viable (including in appropriate circumstances financial information); this can best be demonstrated by providing evidence that the property has been actively and appropriately marketed; or
iii. that the change of use of the facility is acceptable in planning terms and/or meets wider community of planning objectives.

The proposed use must [would] not lead to the concentration of similar uses whose cumulative impact would be to the detriment of environmental quality, amenity or parking, or would increase the risk of anti-social behaviour.

Note: Remove the words in [Square Brackets].

Object

Representation ID: 5667

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management considers that the proposed Policy for Residential Space Standards set out in Policy DQ1, whilst welcome, deserves expansion to encourage new developments to embrace the changes to working patterns with a housing offer that can facilitate choices to work from home, reflecting changes to working patterns arising through the Covid-19 pandemic. Offering a wider choice of homes that make provision for working from home would be beneficial in further reducing the need to travel and increasing support for local services and facilities.