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

These representations have been submitted by Pegasus Group on behalf of L&Q Estates.

Policy DQ1 seeks compliance with the Nationally Described Space Standards for all new homes as a minimum. The NPPF advises that policies may make use of the Nationally Described Space Standards where the need for an internal space standard can be justified.

The requirement for compliance with the Space Standards for all new development may impact on affordability and customer choice. It is important that that the Borough Council presents clear local evidence of need and impacts on viability to justify the inclusion of the policy in the plan.

Policy NE1 states that major development should provide an environmental net gain (in accordance with government policy). This requirement is supported particularly as no specific percentage required is given. This allows for flexibility in the policy to be in accordance with the latest government guidance. The Environment Bill sets out the Government's intention to provide for a two-year transitional period. The policy should therefore make reference to transitional arrangements.

The Council's Viability Assessment should provide a sufficiently robust assessment of the impacts of biodiversity net gain on housebuilding.

These representations have been submitted by Pegasus Group on behalf of L&Q Estates.

Policy SB1 sets out proposed requirements for self-build and custom house building, requiring new housing development to include a number of plots for self build and custom housebuilders depending on the overall size of the development. Under the Self Build and Custom Housebuilding Act 2015 and the NPPF, it is the Council's responsibility, not landowners or developers, to ensure sufficient permissions are granted to meet demand. The NPPG outlines ways Councils should consider supporting self and custom build housing through engagement with developers and encouraging them to consider self and custom build where they are interested.
The issue of self and custom build units on larger developments was a matter addressed by the Inspector examining the Blaby Part 2 Local Plan. In this case the Inspector noted that whilst the Self-Build and Custom Build Register may indicate an interest in this type of housing, it was not clear how this evidence translated into actual demand, with potential issues of double counting where individuals register with more than one Council. In proposing a Modification to the plan to remove the requirement for self-build housing on larger sites, the Inspector concluded that the requirement was not justified by the available evidence, there were potential viability issues and there may be negative consequences for the provision of affordable housing (paras 73-79, Inspector's Report, Blaby Part 2 Local Plan, 21st December 2018).

The Council does not have robust evidence that justifies the inclusion of this policy in the plan. Any evidence must be supported by a thorough viability and impact assessment.

This representation is submitted by Pegasus Group on behalf of L&Q Estates. We support the proposed visions as set out in Section 2 of the Consultation document. Please find enclosed our vision document for Wixams East (Site ID 3233) which provides more detail on how this site fits within the overall vision and objectives of the plan.

The significant work that has gone into delivering the four villages of Wixams has laid the foundation of a highly sustainable new community to the south of Bedford. Wixams east now offers the opportunity to build on these foundations by carefully expanding the settlement to accommodate further and much needed sustainable growth without undermining the urban design principle that underpin the Wixams success story.

Wixams East would support the vision for more accessible places. The site is located in close proximity to the scheduled Wixams Station which will provide direct connections to Bedford and other significant regional destinations. There are numerous local pedestrian and cycle links that provide access from the site to key local destinations, including the facilities and services at Wixams and employment opportunities. The A6 abuts the sites western boundary and provides a direct connection to Bedford and the strategy road network.

Development at Wixams East will be sensitively planned to complement the Borough's natural environments. We will protect and enhance the value of ecological and landscape features to deliver a net gain in biodiversity. Distinctive natural features will enable the create of new parks and spaces that will provide civic amenity and links into the surrounding countryside including a new linear park.

Wixams East will develop an environment that encourages health lifestyles and sustainable patterns of living. A new Neighbourhood Centre will comprise of local employment, working spaces, retail and leisure facilities and a new school. Significant movement routes will converge at this destination which will support active travel, reduce car dependency, and connect to Wixams.

Wixams East will support the Council's vision for Sustainability to be at the heart of new development. The new development will support the journey to net zero-carbon through the following 4 key contributor of our emissions
• Building and infrastructure design and performance;
• Connectivity;
• Energy supply; and
• Waste

Wixams East provides the opportunity to deliver the vision for the local plan by building up on the success of the well planned and high-quality development at Wixams which sets the standard for the rest of the development.

These representations have been submitted by Pegasus Group on behalf of L&Q Estates. L&Q Estates is promoting land to the East of Wixams (Site ID: 3233).

At paragraph 5.8 Wixams new settlement is identified as a potential key service centre as over the course of the Plan period, the planned town centre is expected to be constructed. We support this designation as a key service centre which demonstrates the success of the Wixams development as a sustainable location. Wixams East is in close proximity to the service centre would also be developed with connections into the planned service centre ensuring its continued vitality and viability as well as providing other local amenities at Wixams East.

Paragraph 3.1 sets out the housing requirement for the Borough across the plan period. Consideration needs to be given to the potential uplift in housing numbers because of "The Oxford-Cambridge Arc". It is acknowledged in Paragraph 1.7 that it is likely that there will be a significantly higher demand for homes within the Arc in response economic growth. The housing requirement figure of 1,275 dwellings should be a minimum requirement to prepare for the likely uplift in housing requirement as a result of the Arc.

The Draft Sustainability Appraisal (dated June 2021) that supports the consultation document tests a higher growth option of a 10% uplift than the objectively assessment need of 12,500 homes as identified in the Local Housing Needs Assessment. In appraising the high growth option, paragraph 8.4 of the SA states that it was likely to perform more positively in relation to strong and balanced economy, promoting the vitality and viability of town centres and promoting good quality housing.

The Council’s decision to not pursue a higher growth strategy has not been adequately justified and it fails to recognise the benefits associated with a high growth option for both housing provision and economic growth. The Council has not investigated the potential for a growth scenario that would provide a better balance between the identified socio-economic benefits and potential environmental effects. The locally assessed housing need should take proper account of significant level of job that is expected because of the Arc.

Paragraph 3.5 suggests that a stepped housing trajectory approach is being considered which could mean the delivery target being kept to 970 dwelling per year until 2030 and increased to 1,580 dwellings per year for the rest of the plan period. This approach to the housing trajectory is not supported. This approach would not deliver the levels of housing that is required by the standards method of 1,275 dwellings per year for 10 years of the plan. This and the likelihood that the Arc will increase the housing requirement in the Borough could mean that there is a significant risk of creating a housing supply issue from the outset. It is important to ensure that the Plan is positively prepared and seeks to meet the areas objectively assessed needs. The Plan also needs to be justified to ensure the strategy is appropriate, based on proportionate evidence and takes account of reasonable alternatives.

The Draft Plan Strategy and Options and Draft Policies Consultation identifies 4 emerging preferred options for where development will be focused over the plan period. Wixams East would support the delivery of all 4 of these options. The sustainability appraisal shows that 2a performs better than the others because it concentrates most growth at rail-based locations at Stewartby/Kempston Hardwick. We are supportive of this conclusion. Options 2a is also not reliant on the creation of a new settlement which takes longer to deliver over the plan period due to the amount of infrastructure required from the outset.

L&Q Estates is promoting land to the East of Wixams which would support the delivery of Growth Strategy Option 2a. Please find enclosed our vision document for Wixams East (Site ID 3233) which provides more detail on how this site fits within the growth strategy.

Wixams East, whilst located within the Parish of Wilshamstead, is more spatially related to Wixams in terms of access to services and facilities. This site is therefore put forward as an extension to Wixams and would sit within the transport corridor - rail base growth villages in the growth strategy options.

Wixams East is proposed to accommodate 2,000 dwellings, a local centre and a new primary school. Access is proposed via two existing roundabouts along the A6. The proposed access strategy will also promote access to and from Wixams and the scheduled Wixams Station for all modes of transport with particular emphasis on walking and cycle. It is proposed that Wixams East will be an extension to Wixams and one community will be formed in the longer terms.

Wixams East will create new parks and spaces that will provide links to the surrounding countryside and provide extensive public open space. The most significant green infrastructure provision will be the creation of a new linear park. We will maximise the connection with the existing and new community to ensure that this regional park will be accessible via all modes of transport for the enjoyment for all. The linear park creates the opportunity to ensure long term biodiversity net gains through habitat enhancement and creation.

These representations have been submitted by Pegasus Group on behalf of L&Q Estates.

The Draft Sustainability Appraisal (dated June 2021) includes the sustainability appraisal framework in Appendix 1. This includes a series of assessment questions for each sustainability appraisal objective which is used to assess local plans policies and proposals.

The Sustainability Appraisal Framework should include quantifiable assessment questions in order for the SA to be able to assess the plan equally and fairly. For example, accessibility should be quantified in order to assess the SA objectives of air quality, climate change and transport. Without the specific quantifiable framework criteria, SA is at risk of being ambiguous in its assessment.

The health and wellbeing appraisal objection seeks to assess sites on whether they are close to open space and sports facilities. The appraisal objective should also promote active travel and other lifestyle changes in order to assess this objective.

In order to assess SA objective 11, minimise flood risk, the site assessment question should include the flood zone designation so that the SA can equally and fairly assess the Plan.

In order to assess SA objective13, the ability of sites to provide a cultural or social activity on site or whether it is possible to access a cultural or social activity by walk, cycling, bus or train should be considered.

In order to assess SA objective 14, promoting social cohesion, the ability of a site to design out crime and encourage social cohesion should be assessed

The transport sustainability appraisal objective is focused on reducing the need to travel and promote sustainable modes of transport. The site assessment questions do not adequately reflect the objective particularly as they include whether sites are able to connect with the highway network which is at odds with trying to reduce the need to travel. Accessibility should also be quantifiable in order to assess sites equally and fairly.

The development strategy focuses development in the urban areas, A421 corridor and possible new railway stations. The site assessment questions for transport should include consideration of a site's proximity to a nearby rail stations as it forms a part of the development strategy.