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

The purpose of this statement, prepared on behalf of the Bedford River Valley Park (BRVP) Landowners comprised of, Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (“The BRVP Landowners”), is to respond to the Local Plan 2040 strategy options. Separate comments on the initial assessment proforma for the BRVP (Site ID 3245) have also been submitted.

It demonstrates that in weighing up the emerging strategy options, the optimum approach for meeting housing need within the Borough should involve a balanced approach, including growth along the A421 corridor and in the form of a new settlement at the BRVP, as enabling development for the consented water sports lake, as was outlined in detail in the BRVP Landowners Call for Sites submission and response to the previous consultation on Issues & Options (Summer 2020).

Such an approach is critical if the increased housing requirement derived from the Standard Method is to be achieved.
Additional information is provided in response to the site assessment work being undertaken by the Council, which remains ongoing, particularly the Site Assessment Proforma. This information directly addresses the potential effects with regards to the submitted site in the context of the sustainability objectives of the Site Selection Methodology 2021.

Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document confirms that the starting point for the housing requirement in the Local Plan 2040 is a minimum of 1,275 dwelling completions a year, that being the Local Housing Need (LHN) calculated using the Standard Method.

Accordingly, the Council will need to allocate land to enable a minimum of 25,500 dwellings to be delivered in the period up to 2040. That is just to meet the LHN and does not take into account the emerging Oxford to Cambridge Arc Spatial Framework (ASF), and the Government’s ambition to deliver substantial growth in the region to capitalise on its economic potential, which could lead to a further increase in the housing delivery required.

It is acknowledged that the timetable set out in Policy 1 of the Local Plan 2030 does not align with the timetable for the publication of the ASF, a consequence of the programme imposed by Policy 1. As such, the preparation of the Local Plan 2040 will have to progress in advance of the final ASF being in place. Nonetheless, it would reasonable and expected for the Council to proceed with the preparation of a Local Plan that fully acknowledges the emerging need for transformational levels of growth in the Borough in the period up to 2040, arising from its central location within the Arc. The document also recognises there will potentially be a need for a further early review of the Local Plan to respond to the ASF where necessary.

Paragraph 3.5 of the consultation advises that the Council is considering the possibility of a stepped trajectory as part of the Local Plan 2040 with the justification being that a number of infrastructure projects, such as improvements to the Black Cat junction and the delivery of East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Given that LHN exists now, the BRVP Landowners are of the view that a stepped approach in the delivery of the housing requirement should be avoided if at all possible, particularly when there already exist sustainable options for growth within the Borough, such as the BRVP Enabling Development, that can help meet the additional need arising as part of the LPR early in the plan period, thereby avoiding the need for a stepped trajectory.

Turning to the growth and spatial strategy options set out in Section 3 of the consultation document, whilst all of the preferred emerging options have a degree of focus along the A421 transport corridor, capitalising on the accessibility to the Bedford and Kempston urban area via such a link, only option 2d proposes new housing in the “eastern parishes” where BRVP is located, and even then only 750 dwellings are indicated within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston and a further 28 ha of employment land.

It is suggested that the capacity for new housing is currently underestimated, and more specifically, a new settlement comprising residential-led mixed-use development to provide the enabling development for the water sports lake at the BRVP, should be identified in the same way as the potential new settlements at Wyboston and Little Barford.

Whilst smaller in scale, nevertheless, the enabling development would still be substantive enough to warrant such identification as part of this growth option, and such transparency would be beneficial in providing certainty to assist the delivery of what would be a major leisure asset for the Borough, as was outlined in detail in the Call for Sites submission and Vision Document submitted on the Landowners’ behalf.

Equally, however, were the Council to take forward one of options 2a – c, or another option, there is also no reason why a new settlement comprising the residential-led mixed-use enabling development could not be included given its inherent merit as a standalone proposal.