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

Support

Representation ID: 7159

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

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: 7160

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

“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.

Object

Representation ID: 7161

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

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: 7162

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

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: 7163

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

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.

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.

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.

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.

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.

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, particularly in Great Barford, where our client’s control land suitable for a further 92 dwellings, within easy access of a major junction onto the A421, and close to the high frequency bus route provided by the X5 linking between Milton Keynes, Bedford and Cambridge.

Support

Representation ID: 7164

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

Our client supports the proposed development at Land West Of The Village Of Great Barford South Of The A421 which is being promoted through the Call For Sites process (Site 878) by Countryside Properties (UK) Limited. This site has the opportunity to act as an expansion of Land At Great Barford West which has an allocation for 500 dwellings in the Draft Neighbourhood Plan under Policy H1, and can build upon the infrastructure that will be delivered as part of the development of that site.

Our client would also like to draw attention to his land off New Road, Great Barford, which is being promoted through the Call For Sites process under Site ID 684. The site is available for up to 92 dwellings.

The Neighbourhood Plan was focussed on delivering a block of land to accommodate 500 units in a suitable location within the village to meet the required allocation. The New Road site was discounted as the Great Barford West site was seen as preferable. However, the New Road site remains a viable and deliverable option for further growth in the village. Should the strategy emerge and include further growth in Great Barford, and if the Borough Council, or the Parish support additional growth going forward to 2040, but wish to examine an alternative to land to the west, our client would highlight that the land at New Road remains available for allocation.

This is a very deliverable site on the edge of the village which could provide a smaller amount of growth. The site is within preferred strategy Option 2d, as Great Barford forms part of the eastern parishes of the Borough. Great Barford has excellent connectivity to the A421 transport corridor which is expected to see large levels of growth over the coming years.

Great Barford, is a highly sustainable settlement and is recognised in the Bedford Borough Local Plan 2030 as a Key Service Centre. The site is within walking distance of numerous services including a primary school, medical centre, a convenience store, takeaway, a post office, a church, and a public house, as well as multiple employment opportunities. In addition to this there are several bus stops that offer services into Bedford and St Neots, as well as the X5 service linking between Milton Keynes, Bedford and Cambridge. The site is therefore in a very sustainable rural location, and development of this site will contribute towards the long-term vitality of the settlement and viability of these services.

The site is on the edge village, surrounded by existing development, and can be developed to assimilate into the village without having a significant impact on the wider landscape.

Object

Representation ID: 7165

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

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.

Support

Representation ID: 7169

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

None of the preferred growth option include any particular focus on leisure and tourism, and the Plan does not contain much commentary about the potential tourism development can offer for supporting a diverse local economy, bringing employment and benefits to the wider town. Our clients land known as Great Barford Lakes (Site 744) provides an opportunity for a leisure use driven by tourism which comprises of a hotel and lodges based around water-based recreation on the lake, and the River Great Ouse. The site is located close to the A21 junction outside Great Barford.
Pre-application discussions were held many years ago on the potential of a speculative application. The reason this did not move forward was the perceived risks involved in progressing a planning application with no clear policy support for tourism application. Hotel provision is defined as a “town centre use”, and yet it is evident that hotel provision must address locational needs and desires to attract customers.

As the Town Centre policy framework is rather narrow in scope, we would encourage the Council to consider a broader economic vision, within the context of the Oxford-Cambridge Arc. With economic and population growth will come the commensurate increase in leisure and recreation; as well as drawing in consumers and visitors from outside the Arc. We believe the emerging growth options should therefore include for tourism related development, or preferably consider allocating leisure and tourism opportunity sites.

Support

Representation ID: 7170

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

Our client controls the Land at Great Barford Lake, Great Barford, which is being promoted through the Call For Sites Process, Site ID 744. The site has the opportunity to provide a comprehensive leisure and tourism facility based around the lake. An allocation on this site will make a positive contribution towards the Borough’s economic diversity and development.

The site is located within the Eastern Parishes of the borough, and therefore falls within preferred Option 2d of the Strategy Options. In addition to this, its location within the east of the borough means that the site has good connections to the A421 Growth Corridor, which is expected to see growth over the coming years.

Support

Representation ID: 7171

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

Policy TC9 refers to hotels as a Town Centre use which they predominantly are but this does not mean that hotel provision in a rural area should not be considered for rural tourism and the contribution this can make to the economic development of the Borough should be recognised.

Some positive thought needs to be placed on the opportunities for out of town hotels to benefit rural tourism and support leisure and recreational uses in these areas.