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

The Council proposes a plan period to 2040. As noted, this will differ from the plan period for the Oxford-Cambridge Arc Spatial Framework (Arc Framework) which is to 2050. Given the Local Plan will need to demonstrate its consistency with the Arc Framework when it becomes national policy in 2023 in order to be found ‘sound’, the Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan. It could seriously undermine the delivery of national policy if they are not reflected in the Development Plan for Bedford Borough. Whilst it is acknowledged this is challenging given both Plans are being prepared simultaneously, effective and on-going joint working is integral to a positively prepared and justified strategy.

In any event, national policy now requires Councils should set a vision that looks at least 30 years ahead when allocating new settlements or significant extensions to existing villages and towns (paragraph 22 of the NPPF). Given the nature of the options presented in this consultation, it would be prudent for the Council to decide now to revise its Plan period to 2050.

The scope of the Plan will need to consider the implications of the recent changes in national policy (NPPF July 2021), and the emerging content of the Arc Spatial Framework.

A Technical Note has been prepared by Jubb on behalf of Rainier Developments Limited, and is submitted by email separately.

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that rural population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
However, the key point here is that some villages are better related to Bedford town centre, the wider urban area, and have more sustainable travel options than other villages. To categorise all growth in the villages as having a major negative effect in relation to these SA objectives is inaccurate as some settlements are very close to the urban area with high levels of sustainable travel links to Bedford town centre, such as Bromham.
To put that point in context, Bromham is the largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre (circa 5km) than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and therefore was found sound by the Inspector. Hence, Bromham is inherently a very sustainable location to accommodate growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in the generation of strategy options at 3.12. It only appears in two options which are realistic (namely 3b and 3c which include development in and around the urban areas). Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options.
Again, the appraisal of these two options (3b and 3c) in the Draft SA is skewed by the assumption that all growth in the villages is in locations where there is a greater need to travel and which is more likely to be by car. The specific merits of Bromham as a location where the need to travel is reduced and where there are sustainable travel options are therefore not captured in the current draft of the SA, and this is a significant omission.
The Topic Paper concludes on these two options that they do not perform as strongly compared to others with reference to highway constraints on the A6 north of Bedford, the need to allow villages to assimilate already planned growth, and the loss of focus on EWR.
In response, Bromham as a location would not impact the A6 north of Bedford as traffic routes to Bedford and the M1 via the A4280, A428 and A422. This would therefore not be a constraint to growth at Bromham.
Planned growth at Bromham within the Neighbourhood Plan is likely to be delivered early in the Plan period, and thus there will be a lengthy period of time during the Plan period within which development could come forward. There is no evidence to suggest Bromham needs such a lengthy period of time to assimilate planned growth, nor that the benefit of any period would outweigh the need for Bromham to contribute to a sustainable pattern of development and meet needs arising from the urban area.
More fundamentally, however, this is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase in its housing requirement per annum and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change (particularly in the context of a higher housing requirement).
Additional growth at Bromham of up to 345 dwellings (reflecting the capacity of Site ID 757 as discussed below) need not detract from a focus on EWR given the scale of housing need to be met across the Borough.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs.
Furthermore, and more fundamentally, it is requested that the Council reconsider the role of Bromham given its location on the edge of the urban area, its proximity to the town centre and Bedford train station, and its sustainability credentials. The scale of growth that could be accommodated at Bromham need not challenge or threaten a strategy focussed on the urban area and rail based growth, but complement it in identifying deliverable sites in a sustainable location that can boost supply to meet the higher housing requirement.
For the avoidance of doubt, these representations are not suggesting all Key Service Centres should accommodate further growth of 500 dwellings as assessed in the Options. Our representations are that deliverable sites in sustainable locations around villages near the urban area, should contribute to boosting supply in the early part of the Plan period to meet the new housing requirement. Bromham is unique given its close relationship to the urban area of Bedford and the town centre and train station, and there is a strong case for this settlement to form part of the final preferred strategy (either recognised on its own, or recognised as part of the wider urban area).
Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy.
The site adjoins the settlement boundary, and is enclosed by built development (existing and committed) on two sides to the east and south, and by the road network (Northampton Road and A428) to the north and west. Built development also exists at Chestnut Avenue to the north of Northampton Road.
Its development would therefore be restricted by physical features, and would represent a logical rounding off of the settlement within the confines of the built form and complimenting the committed site to the south at Beauchamp Park. The site was previously identified as a ‘preferred site’ and considered as a reserve site by the Parish Council in its preparation of its Neighbourhood Plan. It is fair to say that the site is recognised as the next logical allocation for residential development in the settlement.
There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning. Taking these into account, the site has capacity for approximately 345 dwellings.
The development of the site would clearly make an important contribution to housing supply, including affordable housing at 30% (circa 100 dwellings). This is significant given it has been resolved that the undetermined outline planning application (19/01904/MAO) at Beauchamp Park will only provide 15% affordable housing, resulting in a shortfall of supply (circa 60 affordable dwellings) against the level expected to be delivered to meet the significant affordable need within the area during the Plan period. There are other environmental benefits, including biodiversity net gain and an extension to the Bromham Heritage Trail through new areas of open space. There will also be economic benefits in terms of jobs generated from the construction phase, and an increased population supporting the viability of services and facilities within Bromham, and nearby Bedford.
The site benefits from good access by sustainable modes of travel to facilities within the village as demonstrated previously within the Vision Document, as well as nearby Bedford. There is capacity within those facilities, particularly the local school which at present is 3 Form Entry but has the capacity to expand to 4 forms of entry as explained in the Neighbourhood Plan and agreed with the Local Education Authority. There is therefore capacity to accommodate additional spaces to meet demand arising from the development of Site ID 757 within the local school which is the preference of the Parish Council.
Separate representations have been made in response to the Site Assessment Consultation on Site ID 757.

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that rural population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
However, the key point here is that some villages are better related to Bedford town centre, the wider urban area, and have more sustainable travel options than other villages. To categorise all growth in the villages as having a major negative effect in relation to these SA objectives is inaccurate as some settlements are very close to the urban area with high levels of sustainable travel links to Bedford town centre, such as Bromham.
To put that point in context, Bromham is the largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre (circa 5km) than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and therefore was found sound by the Inspector. Hence, Bromham is inherently a very sustainable location to accommodate growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in the generation of strategy options at 3.12. It only appears in two options which are realistic (namely 3b and 3c which include development in and around the urban areas). Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options.
Again, the appraisal of these two options (3b and 3c) in the Draft SA is skewed by the assumption that all growth in the villages is in locations where there is a greater need to travel and which is more likely to be by car. The specific merits of Bromham as a location where the need to travel is reduced and where there are sustainable travel options are therefore not captured in the current draft of the SA, and this is a significant omission.
The Topic Paper concludes on these two options that they do not perform as strongly compared to others with reference to highway constraints on the A6 north of Bedford, the need to allow villages to assimilate already planned growth, and the loss of focus on EWR.
In response, Bromham as a location would not impact the A6 north of Bedford as traffic routes to Bedford and the M1 via the A4280, A428 and A422. This would therefore not be a constraint to growth at Bromham.
Planned growth at Bromham within the Neighbourhood Plan is likely to be delivered early in the Plan period, and thus there will be a lengthy period of time during the Plan period within which development could come forward. There is no evidence to suggest Bromham needs such a lengthy period of time to assimilate planned growth, nor that the benefit of any period would outweigh the need for Bromham to contribute to a sustainable pattern of development and meet needs arising from the urban area.
More fundamentally, however, this is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase in its housing requirement per annum and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change (particularly in the context of a higher housing requirement).
Additional growth at Bromham of up to 345 dwellings (reflecting the capacity of Site ID 757 as discussed below) need not detract from a focus on EWR given the scale of housing need to be met across the Borough.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs.
Furthermore, and more fundamentally, it is requested that the Council reconsider the role of Bromham given its location on the edge of the urban area, its proximity to the town centre and Bedford train station, and its sustainability credentials. The scale of growth that could be accommodated at Bromham need not challenge or threaten a strategy focussed on the urban area and rail based growth, but complement it in identifying deliverable sites in a sustainable location that can boost supply to meet the higher housing requirement.
For the avoidance of doubt, these representations are not suggesting all Key Service Centres should accommodate further growth of 500 dwellings as assessed in the Options. Our representations are that deliverable sites in sustainable locations around villages near the urban area, should contribute to boosting supply in the early part of the Plan period to meet the new housing requirement. Bromham is unique given its close relationship to the urban area of Bedford and the town centre and train station, and there is a strong case for this settlement to form part of the final preferred strategy (either recognised on its own, or recognised as part of the wider urban area).
Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy.
The site adjoins the settlement boundary, and is enclosed by built development (existing and committed) on two sides to the east and south, and by the road network (Northampton Road and A428) to the north and west. Built development also exists at Chestnut Avenue to the north of Northampton Road.
Its development would therefore be restricted by physical features, and would represent a logical rounding off of the settlement within the confines of the built form and complimenting the committed site to the south at Beauchamp Park. The site was previously identified as a ‘preferred site’ and considered as a reserve site by the Parish Council in its preparation of its Neighbourhood Plan. It is fair to say that the site is recognised as the next logical allocation for residential development in the settlement.
There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning. Taking these into account, the site has capacity for approximately 345 dwellings.
The development of the site would clearly make an important contribution to housing supply, including affordable housing at 30% (circa 100 dwellings). This is significant given it has been resolved that the undetermined outline planning application (19/01904/MAO) at Beauchamp Park will only provide 15% affordable housing, resulting in a shortfall of supply (circa 60 affordable dwellings) against the level expected to be delivered to meet the significant affordable need within the area during the Plan period. There are other environmental benefits, including biodiversity net gain and an extension to the Bromham Heritage Trail through new areas of open space. There will also be economic benefits in terms of jobs generated from the construction phase, and an increased population supporting the viability of services and facilities within Bromham, and nearby Bedford.
The site benefits from good access by sustainable modes of travel to facilities within the village as demonstrated previously within the Vision Document, as well as nearby Bedford. There is capacity within those facilities, particularly the local school which at present is 3 Form Entry but has the capacity to expand to 4 forms of entry as explained in the Neighbourhood Plan and agreed with the Local Education Authority. There is therefore capacity to accommodate additional spaces to meet demand arising from the development of Site ID 757 within the local school which is the preference of the Parish Council.
Separate representations have been made in response to the Site Assessment Consultation on Site ID 757.

In the context of the need to boost housing supply in light of the increased housing requirement (circa 33% increase per annum), the Council should in this Plan proceed with making allocations in order to speed up delivery and ensure the housing need (including affordable) is met as soon as possible. Awaiting Neighbourhood Plans to be reviewed or prepared would add unnecessary delay which may adversely affect the trajectory and five year housing land supply (against the higher housing requirement).
This would be particularly relevant in areas where there is an obvious and logical choice of site to be selected for allocation, such as at land south of Northampton Road, Bromham (ID 757). Paragraph 1.48 states that in the scenario where the strategy involves additional development in and around villages and there is a genuine choice of site available, the Council will ask if a Parish Council would like to select the sites in a review of their Neighbourhood Plan. In the case of Bromham, we query whether there is a genuine choice of available sites. The Local Plan should identify and allocate deliverable sites in and around settlements now, particularly where there is no genuine choice of alternative sites.
Furthermore, Site ID 757 (formerly Site 43) has been previously referred to in an email from the Chair of the Parish Council (dated 23 January 2020) as the natural progression for future development in Bromham and had the backing of the Parish Council for a reserve site.

As the consultation acknowledges, the figure of 1,275 dwellings per year is the Local Housing Need and is the starting point. It is also the minimum number of homes needed in accordance with national policy (paragraph 61). The Council need to consider whether a higher figure is necessary in order to address the worsening issue of affordability (with average house prices 8.4 times average earnings), or in order to respond to unmet needs that may arise from neighbouring areas or from the Greater London authorities.
However, more fundamentally, it needs to consider whether delivering the bare minimum number of homes is sufficient to match the intention for Bedford Borough to be at the heart of a national economic priority area as set out within the Oxford-Cambridge Arc Spatial Framework. In order to become one of the most prosperous, innovative and sustainable economic areas in the world, and make a major contribution to national economic recovery, the area will require labour and those people will require affordable homes unless unsustainable patterns of commuting are to prevail. The economic potential of the Arc will not be achieved, or not achieved in a sustainable way, by providing the minimum number of homes needed.
In this regard, it is questioned whether the forecast growth in jobs of 13,200 over the plan period within the LHNA (using the 2019 EEFM data) is now accurate in light of the Government’s intended strategy. The Council should review the LHNA and its anticipated job growth to assess whether there is a need to uplift the local housing need to meet the future needs of jobs and workers.
Further, the planned investment in East-West Rail, in addition to the proposed investment in sustainable infrastructure within the Arc Spatial Framework, similarly provides a strong case for a higher housing need figure than the standard method in order to satisfy the future demand that it will drive for people to live in and around Bedford. Support for a higher figure in this context is set out within the NPPG (Paragraph: 010 Reference ID: 2a-010-20201216).

The Council will need to demonstrate in its evidence base that existing commitments can be delivered within the plan period, and these will also need to be set out within the proposed trajectory as indicated to be provided at paragraph 3.4. The trajectory will of course need to be realistic as required by national policy (NPPF paragraph 73), and should have regard to the evidence from Start to Finish Two (Lichfields Feb 2020).

The Council need to consider the social and economic consequences of a stepped trajectory, namely the impact of unmet housing needs arising within the Borough over the first half of the plan period (i.e. 2020 to 2030). If suitable and deliverable sites are available now in sustainable locations, they should be allocated and the strategy amended to avoid or minimise the need for a stepped trajectory. Housing needs are arising now, and they should be met as soon as possible.
As set out at paragraph 1.2 of the Development Strategy Topic Paper, the increased requirement applies from 2020 and the provision made within the adopted Plan needs to be ‘topped up’. Sites that accord with the adopted strategy, such as at Bromham where the adopted strategy supports a minimum of 500 dwellings, should be allocated to come forward in the period to 2030 to avoid the need for a stepped trajectory.
Given the negative consequences for the economy and population, any such policy will need to be clearly justified in order to be found sound. On the basis of the evidence and the availability of suitable and deliverable sites in sustainable locations (such as at Bromham), it is considered such a policy unlikely to be found sound.

These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
Finally, none of the emerging preferred options allocate any growth to Bromham. Bromham is largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy therefore allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and thus was found sound by the Inspector. Bromham is inherently a very sustainable location to accommodate further growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in any of the preferred options. The northern boundary as currently drawn for the southern parishes within 2a, 2b, and 2d is the A428, and yet Bromham to the immediate north of the A428 is as well related to the urban area and would contribute in the same way to a sustainable pattern of development.
As with the point made above, it is acknowledged that Bromham has existing commitments which will deliver housing within the early part of the Plan period. However, Bromham is a sustainable location for growth given its relationship to the urban area and should therefore play a role in meeting the higher housing needs of the Borough (boosting supply in the early part of the Plan period to meet the higher requirement and avoid stepping the trajectory).
This is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase per annum in its housing requirement and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change.
Bromham has capacity to accommodate more development. As noted under representations made at paragraph 1.28, land south of Northampton Road, Bromham (Site ID 757) is a suitable and deliverable site, and could complement existing commitments to the south at Beauchamp Park. That site is already well advanced in the planning process and likely to come forward early in the Plan period.
In determining the best growth strategy, we encourage the Council to reconsider its approach to Bromham and include it as a discreet addition to its preferred strategy, and allow for further growth over the Plan period. Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy in this context.