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

Object

Representation ID: 8397

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

This section provides our formal consultation response in relation to the Issues and
Options and Growth Options Consultation. It sets out our response in relation to chapters
of the consultation that are of relevance in respect of the land that is being promoted at
Gibraltar Corner.
Level of Growth

Based on the ‘standard method’ the new Local Plan will need to identify sites to deliver
over 25,500 new homes to meet the Council’s housing needs for the period 2020 – 2040,
which equates to a delivery 1,275 dwellings per year . To maintain their housing trajectory,
the Council will need to identify a range of sites, so that this housing delivery rate can be
achieved. Currently, existing commitments total 13,000 dwellings which means the new
local plan will need to allocate land for a minimum (emphasis added) of 12,500 dwellings.

Effective housing delivery is essential for the social, economic and environmental
prosperity of the District and the wider spatial area of the Oxford – Cambridge Arc.
Accordingly, it is critical that the assessment of sites submitted through this Call for Sites
process is undertaken in a positive and aspirational manner (NPPF para 16) , and in
accordance with NPPF paragraph 69, allows the identification of a sufficient level of
deliverable and developable sites with sufficient flexibility to react to market trends and
economic changes.

The use of the standard method is supported, however, it is considered that the minimum
number of dwellings for the period to 2040 should be increased to 15,000 to allow the
inclusion of a 20% buffer to build in greater flexibility and more certainty that housing
delivery will actually be achieved. While currently housing delivery is meeting the adopted
local plan target, this only requires an annual requirement of 970 dwellings per year .
There will be a considerable uplift of 280 dwellings per year to meet the 1,275 dwellings
required for the new plan.

Based on planned population growth to 2040 the employment land requirement is
calculated to be 171 ha. The current supply in the Borough is 48 ha leaving the
requirement for a minimum (emphasis added) 123 ha to be allocated in the plan. As with
housing, it is considered equally important that a buffer of 20% should be applied to ensure
the provision of employment land keeps pace with demand, especially given the economic
importance of the Borough within the heart of the Oxford – Cambridge Arc. Accordingly,
it is therefore considered that the Plan should be seeking to allocate 148 ha of employment
land for the period to 2040.

Plan Period
While this consultation does not specifically seek views on the proposed plan period, it is
considered that a longer plan period would be more appropriate. National planning policy
requires a minimum 15 year plan period from adoption (emphasis added) and whilst the
current programme anticipates adoption in Winter 2023 it is a clearly established fact that
local plan preparation nearly always takes longer than anticipated at the outset.
Assuming the local plan is actually adopted at the beginning of 2024 this will only
establish a plan period of 16 years. Paragraph 22 of the NPPF requires a minimum 15
year period, however, the paragraph was also updated in the July 2021 version to suggest
that plans should have a vision of at least 30 years where new settlements or significant
extensions to existing villages and towns form part of the strategy for the area. Clearly,
as set out in the current four options, such developments are likely to form part of the
strategy and, as such, a longer plan period would seem more appropriate. Furthermore,
the nationally emerging Oxford – Cambridge Spatial Framework also seeks to guide
growth to 2050. Accordingly given the current early stage of plan preparation it is
considered that the Bedford Borough New Local Plan should adopt a plan period to 2050
as well.

Extending the plan period by a further 10 years will require further growth locations to be
identified including sites for a minimum additional 12,750 dwellings and a further 62
hectares of employment land. As referred to above, these would be minimum
requirements and a buffer should also be imposed, although given the extended length of
plan period a reduced buffer of 10% may be considered more reasonable. Adopting such
a strategy will allow the plan to consider a wider range of options and contain more
flexibility around delivery in the future. This will sensibly allow for the inclusion of new
settlements which, whilst slow to deliver, are likely to represent the most sustainable longterm
option for economic growth supported by a sufficient delivery of new homes. Such
flexibility will be essential to allow the District to maintain housing land supply at an
increased rate of 1,275 new homes per year over the plan period.

Support

Representation ID: 8398

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

The proposed vision and objectives set out in Section 2 (pages 11 & 12) are supported,
including the statement:
“Good design will help to improve quality of life and to create safer, vibrant and more
sustainable places, both in the urban area of Bedford and Kempston and in surrounding
village communities.”
However, it may need to be updated to better reflect the chosen growth strategy,
especially if that is to include the delivery of one or more new settlements around a new
East-West Railway Station.

Object

Representation ID: 8399

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

Paragraph 3.5 of the draft options consultation document suggests that a stepped
trajectory approach could be followed, which would mean maintaining the existing supply
under the 2030 plan until 2030, and then increasing delivery thereafter for the remaining
10 years. This is not considered to be an appropriate strategy and would be clearly at
odds with the policy requirement set out in Policy 1 of the adopted plan, the whole purpose
of which was to recognise the need for increased housing delivery based on the
application of national planning policy. Furthermore, following such a strategy would not
only stifle potential economic growth, but will exacerbate housing affordability, which is
clearly acknowledged as a significant issue not only for Bedford Borough but also the
wider Oxford – Cambridge Arc.

Support

Representation ID: 8400

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

For the new local plan to meet the tests of soundness at examination it will be extremely
important for the growth strategy to be both deliverable and flexible without an
overreliance on strategic scale allocations such as new settlements. It is worth noting that
the St Albans Local Plan was withdrawn in November 2020 following a number of serious
concerns raised by the Inspectors which included an overreliance on a small number of
large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller
scale subareas. The Inspectors noted that a range of sites, including smaller and medium
sites, can provide benefits, in that they can be delivered more quickly without requiring
additional infrastructure, provide choice and flexibility in the housing market , and secure
affordable housing more immediately. They also referred to paragraph 68 (now paragraph
69) of the NPPF which indicates that small and medium-sized sites can make an important
contribution to meeting the housing requirement of an area and are often built out relatively
quickly.

The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local
Plan were similar. In that particular case, the Inspector considered it was highly ambitious
to rely on three new Garden communities (Easton Park, North Uttlesford and West of
Braintree) and not include a wider range of small and medium sized sites as advocated
by paragraph 68 of the NPPF.

Accordingly, it is considered the correct strategy for the emerging Local Plan 2020 – 2040
will be to avoid any short term reliance on strategic scale developments such as the new
settlements at either Wyboston or Little Barford and instead to include a significant and
extensive range of small and medium-size sites.

Paragraph 6.8 of the Strategy Options and Draft Policies consultation document indicates
that the new plan should provide three new business park sites, each of about 30 ha with
the remaining 63 ha of employment land allocated in smaller sites. However, it is noted
that potential employment sites are still being assessed. The employment sites will then
be identified to align with the preferred growth strategy. Again this suggests that a more
flexible strategy with a wider choice of potential site allocations should be followed.

The four growth strategy options are listed as follows:
Option 2a: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes.
Option 2b: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes, plus one new settlement.
Option 2c: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and, plus two new settlements.
Option 2d: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes, southern parishes and eastern parishes, plus one new
settlement.

It is noted that all four options will deliver the same amount of dwellings within the urban
area and adjoining the urban area (3,000 dwellings) along with 51 ha employment land.
It is assumed that the employment land provision will predominantly be made up of
existing commitments and therefore the sites for new business parks will need to be found
elsewhere. It is also noted that all four options include up to 80 ha of employment land
within the transport corridor, rail based growth. It is therefore considered that the extent
of employment land should be increased to 90 ha to allow for the identification of three
new business park sites of 30 ha each.

It is also noted that all four options aim to deliver a similar total number of dwellings, 12,500
or 13,085 if a new settlement at Little Barford is included. It is however considered that a
blended option should be the preferred choice, which is more aspirational, with the
potential to deliver a higher number of dwellings along with the maximum amount of
employment land to better reflect the national growth aspirations for the Arc.

In respect of the growth options, clearly the opportunities for accommodating any
significant further growth within the urban areas of Bedford and Kempston are limited,
having already been extended up to their boundaries with the A428. However, the urban
areas remain the focus for employment and retail activity and transport connectivity within
the Borough. It therefore seems logical and sustainable to identify opportunities for future
growth in close proximity to the urban areas, not only in the rail based transport corridor
around the five stations and A421, but also in the southern parishes where sites can be
identified close enough to the urban areas to allow active travel modes and the use of
public transport to be a realistic alternative.

The inclusion of Kempston Rural Parish as one of the transport related southern parishes
is therefore strongly supported and the site, the subject of this representation, is one such
location. The land at Gibraltar Corner is located only 600 m (0.3 miles) walk from
Kempston (at its nearest point). The road from Gibraltar Corner to Kempston has a
pavement on both sides and a dedicated cycle and pedestrian route exists under the A428
which provides very safe, quick and easy access to the Lidl supermarket and Kempston
High Street. The key service centre of Wootton is only 2 km to the south of the site and a
pavement exists along the full length of the road between the site and the cent re. Wootton
provides an alternative range of services and facilities.

Bus stops are located approximately 330 m to the south of the site and regular buses are
provided to Bedford, Wootton, Kempston, Bromham, Cranfield and Milton Keynes (Buses
53, 53A, A2 and C1). This also means there is convenient access to Bedford train station
(Buses 53 and C1) connecting Bedford to London and the wider south-east region. The
site is also located conveniently for connections to the wider highway network with easy
access to the A421 and A428.

Allowing growth in the southern rural parishes not only represents a sustainable location
for housing delivery close to the Borough’s main source of employment within the Bedford
urban area, but will also allow new homes to be provided in a high quality environment,
where future occupiers will also have opportunities to access the countryside for leisure
purposes, improving their health and well-being. Furthermore, development in these well
located parishes is less reliant on upgrades to infrastructure and will be deliverable early on in the plan period. It is therefore considered vital that the selected growth options
include the opportunity for growth in the southern parishes and especially Kempston
Rural.

Of the settlements within the Kempston Rural Parish, Gibraltar Corner benefits from being
located the closest to Kempston and therefore is a logical settlement within the Parish to
allocate for new growth.

In respect of the specific options we comment as follows:
Option 2a: Strongly Support – this option delivers the greatest range of sites
including small and medium-size sites, which will ensure that housing delivery, and
importantly affordable housing delivery can be maintained. However, it is considered
that the employment allocation should be increased to a minimum of 90 ha in the
transport corridor. This is also in line with the findings of the Development Topic Paper,
which concluded that the sustainability appraisal found option 2a to perform best out of
the four options as it concentrates most growth at the rail based locations at Stewartby
/ Kempston Hardwick, which means a high probability that public transport and cycling
will be an attractive alternative to the private car.
Option 2b: Support – this option delivers a range of sites including small and mediumsize
sites, which will help housing delivery, however the inclusion of a new settlement
presents a risk to delivery given the lead time associated with such development. The
housing numbers in the two transport corridors should therefore be increased to those
in option 2a. Accordingly, this is considered to be a more suitable option if the local
plan period is extended. It is also considered that the employment allocation should
be increased to a minimum of 90 ha in the transport corridor.
Option 2c: Strongly Object – this is the least flexible of all options and includes an
overreliance on new settlements. Furthermore, both settlements are in close proximity
to each other, and as such delivery is likely to be further delayed as a result of
competition in the local housing market. If this option were to be pursued it is
considered that the new plan would fail at examination for the reasons set out above,
having regard to the recent St Albans and Uttlesford Local Plan examples.
Option 2d: Neutral would support with appropriate modification – This option
delivers a range of sites including small and medium-size sites which will help housing
delivery, however the inclusion of a new settlement presents a risk to delivery given
the lead time associated with such development. The housing numbers in the two
transport corridors should therefore be increased to those in option 2a. Accordingly,
this is considered to be a more suitable option if the local plan period is extended. It
does however, provide sufficient employment land and a greater choice of locations for
new business parks.

Accordingly, we would recommend that the new local plan pursues a blended option
based on a mix of Options 2a and 2d as set out below, with a focus for approximately
2000 dwellings within the Southern Parishes. This will provide a sufficient range of sites
across the entire plan period without an overreliance on a new settlement being completed
by 2040. Such an option is more likely to be considered in line with Paragraph 22 of the NPPF, which requires plans to contain strategic policies which should look ahead over a
minimum 15 year period from adoption and, where larger scale developments such as
new settlements are proposed, policies are required to set out a vision that looks further
ahead at least 30 years to take into account the likely delivery timescales.
Proposed Option: Development in and around the urban area, plus A421
transport corridor with rail based growth parishes, southern parishes and east
parishes, plus one new settlement.
 Within the urban area (1,500 dwellings).
 Adjoining the urban area (1,500 dwellings), up to 51 ha employment.
 Transport corridor – rail based growth: land within the parishes of Kempston
Hardwick, Stewartby and Wixams (low option) (7,500 dwellings), up to 90 ha
employment.
 Transport corridor – south: land within the parishes of Cotton End, Elstow,
Kempston Rural, Shortstown, Wilstead and Wootton (2000 dwellings).
 Transport corridor – east: land within the parishes of Cardington, Cople, Great
Barford, Little Barford, Roxton, Willington and Wyboston (750 dwellings), up to 30
ha employment.
 New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings),
up to 20 ha employment.
 Total between 15,750 and 16,335 dwellings, up to 191 ha employment.

Support

Representation ID: 8406

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

This representation has been prepared on behalf of our client, Axis Land Partnerships
Limited, in response to the Bedford Borough Council Local Plan 2040 July – September
2021 consultation in respect of the Strategic Options and Draft Policies and Site
Assessment Pro Formas. This submission is made in respect of Land to the East and
West of Home Road, Gibraltar Corner, Bedford (the Site).

The site, the subject of this representation, was put forward for consideration as part of
the 2020 ‘call for sites’ exercise and has now been assessed under site reference ID 1333.
It is being promoted on behalf of a single landowner, it extends to 21.80 ha and lies on
the northern side of Wood End Lane and Ibbett Close

(see map in attachment)

The following documents are also submitted in support of this representation and should
be read in conjunction with this statement:
 Site location plan – Promap;
 Ramsey Green at Gibraltar Corner Vision Document (September 2020) – Fabrik;
 Heritage Appraisal (August 2021) – JB Heritage Consulting Ltd;
 Preliminary Ecology Appraisal (August 2021) – Applied Ecology Ltd; and
 Preliminary Transport Strategy (August 2021) – Stantec.

This statement provides an overview and analysis in terms of housing delivery, having
regard to the National Planning Policy Framework 2021 (NPPF), past performance and
the need for the inclusion of a significant number of additional site allocations for the future
new Local Plan to successfully meet the tests of soundness. It has been split into two
main elements as follows:
1. Firstly, it considers the four growth options listed as Option 2a, 2b, 2c and 2d having
regard to the need to meet national policy requirements and in particular the
emerging spatial framework for growth in the Oxford-Cambridge Arc.
2. Secondly, it includes a review of the site assessment pro forma for the site which
demonstrates that the site is suitable for allocation and would make a positive and
sustainable contribution to the Borough’s required growth strategy.

Background
The current Bedford Borough Local Plan was adopted in January 2020 and covers a plan
period to 2030. It replaced the previous development plan which was made up of a
number of documents covering a plan period to 2021. However, due to national policy
changes to the way housing numbers are calculated, infrastructure upgrades and potential
strategic growth in the Oxford – Cambridge Arc, Policy 1 of the 2030 Local Plan committed
to the commencement of a review of the Local Plan within one year of adoption. The
review commenced in summer 2020 with an Issues and Options consultation and “call for
sites”.

It is worth noting that the eastern portion of the site previously formed part of a Local Plan
2035 Consultation Paper in 2017 and was identified as a preferred site for development
under reference number 146 (Home Road East) (please see below Figure 2). It formed
part of a preferred site for an estimated capacity of 500 homes on the edge of the urban
area. Figure 2 below does not include the entirety of the site as promoted within this
representation and also includes wider land that is outside of our clients control. The site,
now put forward (Figure 1 above), comprises the plots shown below as 146, 147 and 153.
In addition, the parcel of land adjacent to the north of plot 147 and 153 is included as well.

Figure 2: Appendix 5 of Bedford Borough Local Plan 2035 Consultation Document 2017 (see attachment)

A detailed description of the site and vision for its development is contained in the
accompanying vision document titled “Ramsey Green at Gilbraltar Corner” , which was
previously submitted in September 2020. The site is located within the Kempston rural
parish on the edge of the settlement of Gibraltar Corner. It extends to approximately 21.8
ha and could accommodate in the region of 450 new homes. It lies between the small
settlement of Gibraltar Corner and Green End to the north and is made up of land on the
eastern and western side of Home Road, from where the access can be obtained, along
with further vehicle access from Wood End Lane to the south. Pedestrian links can also
be provided to nearby public rights-of-way and Ibbett Close.

The site is located approximately 5 km south-west of Bedford town centre and only 2 km
from Kempston High Street. It benefits from good connections to Bedford and Kempston
by foot, bicycle and public transport. The village of Wootton, a key service centre, also
lies a short distance to the south. The regenerated woodlands of Buttons Ramsey and
the Kill lie immediately adjacent to the west and south of the site. The long distance
walking and cycling route of the John Bunyan Trail skirts the eastern edge and then
passes directly through the north-western corner of the site. These offer excellent outdoor
amenities and connectivity directly with nature.

The site is located in a sustainable location, approximately 0.25 kilometres to the west of
the A428, 1.43km from its connection to the A421 to the south, providing connections to
the wider highway network including the M1 Motorway (London to Leeds), the A6 (Luton
to Carlisle) and A1 (London to Edinburgh). There are two bus stops located on Ridge
Road (approximately 300 metres) to the south of the site, providing regular bus services
Monday – Friday on the number 53 bus to Bedford, Kempston and Wootton, the A2 bus
to Kempston, Bromham, Cranfield and Milton Keynes and the C1 bus to Bedford, Marston Moretaine, Kempston, Wootton, Cranfield, Cranfield University, Newport Pagnell and
Milton Keynes. The nearest railway station to the site is Kempston Hardwick, located
approximately 3.9 kilometres to the south on the Marston Vale Rail Line, providing an
hourly service to nearby Bletchley and Bedford.

In terms of constraints, the site is relatively unconstrained, being located within Flood Zone
1 and is therefore not at risk of flooding. A comprehensive landscape buffer could be
provided to the north to ensure no impact on the setting of the three Grade II Listed
Buildings located to the north of the site (see accompanying Heritage Appraisal), whilst
also contributing towards the Forest of Marston Vale.

Support

Representation ID: 8407

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

on
cross-boundary strategic matters that have been dealt with rather than deferred, as
evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable
development in accordance with the policies in this Framework and other
statements of national planning policy (emphasis added), where relevant.
2.5 These tests need to be applied in a proportionate way to ensure they are consistent with
strategic relevant policies for the area.
2.6 The NPPF notes that:
Significant development should be focused on locations which are or can be made
sustainable, through limiting the need to travel and offering a genuine choice of transport
modes. This can help to reduce congestion and emissions, and improve air quality and
public health (paragraph 105).
9
2.7 It advises that, when assessing sites that may be allocated, or specific applications for
development:
(a) appropriate opportunities to promote sustainable transport modes can be – or have
been – taken up, given the type of development and its location;
(b) safe and suitable access to the site can be achieved for all users;
(c) the design of streets, parking areas, other transport elements and the content of
associated standards reflects current national guidance, including the National
Design Guide and the National Model Design Code: and
(d) any significant impacts from the development on the transport network (in terms of
capacity and congestion), or on highway safety, can be cost effectively mitigated to
an acceptable degree (paragraph 110).
2.8 NPPF further advises (at paragraph 112) that, for development proposals, priority should
be given first to pedestrian and cycle movements, and second – so far as possible – to
facilitating access to high-quality public transport. However, it also recognises (at
paragraph 105) that opportunities to maximise sustainable transport solutions will vary
between urban and rural areas, and this should be taken into account in both plan-making
and decision-making.
2.9 In respect of heritage matters Paragraph 189 notes that:
“These assets are an irreplaceable resource, and should be conserved in a manner
appropriate to their significance, so that they can be enjoyed for their contribution to the
quality of life of existing and future generations.”
2.10 Paragraph 202 goes on to state:
“Where a development proposal will lead to less than substantial harm to the significance
of a designated heritage asset, this harm should be weighed against the public benefits
(emphasis added) of the proposal including, where appropriate, securing its optimum
viable use.”
Oxford-Cambridge Arc Spatial Framework
2.11 In July 2021 the Government published a consultation document which set out how they
intend to develop a Spatial Framework for the Oxford – Cambridge Arc. The spatial
framework is intended to provide a vision for the Arc to guide future growth in the area to
2050. To ensure that sustainability is embedded in the spatial framework the consultation
also includes a scoping report in respect of the sustainability appraisal. The Arc covers
the county council areas of Oxfordshire, Buckinghamshire, Bedfordshire,
Northamptonshire and Cambridgeshire. Once approved the spatial framework will form
national planning policy and transport policy for the Arc and local planning and local
transport authorities must have regard to it when preparing local transport and local
development plans and policies. It will also be a material consideration in the
determination of planning applications in the area. This will be the first regional planning
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policy document to be prepared since the abolition of regional plans which signals the
importance that the Government attributes to the Arc.
2.12 The Arc is a national economic priority area which the Government believes has the
potential to be one of the most prosperous, innovative and sustainable economic areas in
the world, and can make a major contribution to national economic recovery following on
from the impact of COVID-19.
2.13 It is intended that the framework will facilitate better planning for economic growth,
supported by new homes and infrastructure, and deliver more sustainable results. It is
intended that it will inform development plans.
2.14 The current consultation closes on 12th October 2021 following which a vision and issues
and options consultation will be published in spring 2022. The finalised spatial framework
will be published for consultation in autumn 2022 with implementation of the final
Framework shortly after.