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

Object

Representation ID: 7175

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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.”

Support

Representation ID: 7176

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

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.

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.

Support

Representation ID: 7177

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Neighbourhood Planning – Paragraphs 1.46 to 1.51
Neighbourhood Planning – Paragraphs 1.46 to 1.51

Please add your comments in the box below, and continue on an additional sheet if necessary.

It is noted that Neighbourhood Planning has been largely successful in Bedford Borough, and that discussions with the parishes are ongoing as to whether this remains a tool that communities wish to use to allocate new development in the next plan period. Our client raises no objection to this approach, and would welcome the opportunity to engage with the Parish Council on the benefits the site can offer. However, if this method of allocation is chosen going forward, it is important that a clear policy structure is created to define the level of growth to be allocated by each community. We would also argue that should those plans not come forward in a timely manner, such as within 3 years of the adoption of the Local Plan 2040, the policy should allow for sites to come forward adjoining the Settlement Policy Areas, therefore the allocation policy will be deemed out of date for that Parish/Settlement for the purposes of Development Control.

Object

Representation ID: 7178

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

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).

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, as well as consider the need for an uplift to be planned for as the Arc’s Spatial framework is prepared. The Council must therefore address this 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. If the Arc Spatial Framework requires a further uplift, this will again require another immediate review, we would therefore urge the Council to consider planning for longer term growth and avoid working to only the minimum requirements.

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 a stepped trajectory. This approach will undoubtedly compound the problem and will create a far greater burden on delivery between 2030 and 2040, it is also inconsistent with the objectives of the vision for the Arc.

Object

Representation ID: 7179

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Paragraph 3.5 infers that additional growth will not be delivered until infrastructure relating to the Black Cat junction and the East West section are complete. However, this is unrealistic and fails to meet the required need of the step change in delivery at the point of adoption. Growth needs to be planned for in a manner which starts to deliver at the point of adoption, and the strategy needs to deliver a range of sites in a range of locations to meet the need. Strategic Infrastructure development will progress at its own pace and will emerge in parallel with the delivery of new housing and employment opportunities.

Support

Representation ID: 7180

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Our client supports the strategies identified in Options 2a, 2b and 2d of the consultation, in which land in the southern Parishes, which includes Wootton could be identified for between 750 dwellings and 2000 dwellings. It is evident from the Call for Sites Proformas that there are several sites available across these Parishes that could make a meaningful contribution towards the delivery of these strategies.

It is further noted that the Sustainability Appraisal identifies Option 2a as the most sustainable option, and this proposes 2000 dwellings be identified in the Transport Corridor – South. If this Option, or indeed 2b or 2d, is eventually selected, our client wishes to put forward his site at the Chequers Public House, Wootton (Site 1503) as suitable site for allocation to meet this delivery.

Support

Representation ID: 7181

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Our client owns the Land at The Chequers Public House, Hall End Road, Wootton, which is being promoted through the Call For Sites Process, Site ID 1503. This site is available for up to 50 dwellings.

This site was originally allocated in the Regulation 14 version of the Wootton Neighbourhood Plan but was removed in the Regulation 16 Plan due to an overall reduction in housing numbers. There is clearly potential for further growth in Wootton and it is highly likely that some of the additional housing will be allocated to this part of the Borough, particularly as Wootton is within the preferred growth strategy options 2a, 2b, and 2d. We contend that our client’s land at The Chequers should be considered as a prime site and earmarked in any Plan going forward as it has already been identified as suitable for release by the Parish Council, and was only removed due to a near term reduction in housing numbers. If additional growth is identified for Wootton, then we would contend this should be the first site brought forward to meet that need.

Our client also owns the Land at Tinkers Corner, Keeley Lane, Wootton, which is being promoted through the Call For Sites Process, Site ID 1498. This site is available for up to 50 dwellings.

Part of this site has an allocation for residential development in the Draft Wootton Neighbourhood Plan. Our client confirms that they are fully supportive of releasing the land for this purpose, however, they would also like to highlight that there is more land available in this location which has already been assessed as being sustainable and suitable for new residential development. This would be also suitable for the further growth identified in this location in three of the preferred options - 2a, 2b, and 2d, and additional numbers could follow on from the development of the 15 dwellings allocated in the Neighbourhood Plan. Our client has already made such representations under the Regulation 16 stage consultation, and we would contend that in identifying the land, it would be logical and sensible to re-evaluate the capacity of identified sites, going forward, to look at where more efficient use of that land could minimise the release of additional land elsewhere.

Wootton, is a highly sustainable settlement and is recognised in the Bedford Borough Local Plan 2030 as a Key Service Centre. Within the village are a number of services accessible by foot including a primary school, a middle school, medical centre, two supermarkets, a post office, a church, and three public houses, as well as multiple employment opportunities. In addition to this there are several bus stops that offer services into Bedford. These sites are therefore both in a very sustainable rural location, and new development will contribute towards the long-term vitality of the settlement and viability of these services.

It is well recognised that villages and rural settlements such as this make for attractive locations for self-build plots. Table 12 of the Housing Strategy 2021-2026 shows that there are currently 82 registrants who have registered a preference for Self-Build housing in Wootton and the surrounding areas. These sites are also being promoted for self-build through the Call for Sites process and provides an opportunity to provide self-build plots in a location where they are required.

Finally, the Neighbourhood Plan process has worked well in Wootton and our client would be happy to continue to work with the Parish Council to deliver more land to meet future growth needs.

Object

Representation ID: 7182

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth 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, and a lack of sites where they are needed.