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

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 it does not even 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 see a higher housing target still in this area, reflective of Bedford’s central location within the arc.

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 continue ahead of adoption of ASF in place. Nonetheless, it would reasonable and appropriate for the Council to proceed with the preparation of a Plan that fully acknowledges the transformational growth anticipated in the Arc. The consultation document also acknowledges there will potentially be a need for a further early review of the Local Plan to response to the ASF, where necessary.

Paragraph 3.5 of the consultation document 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. Red Eagle Securities strongly objects to this suggestion as the level of housing need indicated by the Standard Method already exists now and is not currently being met given the much lower housing requirement in the Local Plan 2030.

Indeed, the Council purposely took advantage of the transitional arrangements when the 2012 Framework was first updated in 2018, in order to delay having to provide for the increased housing need required under the Standard Method in the Local Plan 2030, which is the primary reason this early review has been required. A stepped trajectory would further delay meeting a need that exists now with real consequences for those struggling to afford a suitable standard of living accommodation in the Borough. We noted in our representations submitted at the Issues and Options stage, that housing prices in Bedford Borough are circa 10 times average salaries, and further delaying seeking to meet housing need until later in the Plan period will do nothing to address the significant affordability issues faced by many in the Borough.

Red Eagle Securities is of the view there already exist both sustainable and deliverable options for growth within the Borough that can appropriately absorb the additional need arising as part of the LPR, thereby avoiding the need for a stepped trajectory. Indeed, paragraph 4.6 of the consultation document confirms that sites put forward through the Call for Sites could deliver far more homes than need to be allocated in the Plan.

Turning to the growth and spatial strategy options in the consultation document, all of the preferred emerging options have a degree of focus on the A421 transport corridor. The Draft Plan Strategy Options presents a bias that A421 transport-related growth should comprise the greatest proportion of growth within the Borough, due to the very limited range of options it presents.

Red Eagle Securities is concerned that the options have been dictated by the Sustainability Appraisal, which suggests that village-related components of growth perform more poorly, primarily due to the need to travel by private from these locations, but this ignores the seismic structural changes currently taking place in both the labour and housing markets as a consequence of the Covid-19 pandemic.

In the labour market many transitional office based sectors are seeing either a permanent shift to home working, or a hybrid approach, whereby personnel work from home for part of the working week, with resulting reduction in traditional journeys to work and reduced traffic. At the same time, the housing market has seen a substantial shift in demand away from towns and cities to properties in more rural locations, with great access to open space and countryside. It would be a significant failure if the LPR fails to respond to this.

There is now undoubtedly an opportunity to provide sustainable new housing in accessible villages such as Oakley, that is planned specifically to be suitable for home working. Sites such as Red Eagles Securities’ at Lovell Road, Oakley, would be ideally place to provide new homes in an accessible location, with good public transport links to Bedford, helping to meet the demand for housing in the Borough’s rural area. It would alsoy enable homes that are needed now to be delivered quickly avoiding the need for a stepped trajectory in the Plan.

The DSTP does not appear to acknowledge in particular the additional transport corridors outside the A421, such as the A6, to their fullest potential, instead considering these options in the context of “new settlements” only as opposed to further growth in the form of small or medium allocations at existing, sustainable locations, such as Oakley.

Pages 31 – 36 of the DSTP does identify potential highway constraints along the A6 to the north of Bedford, but this remains in the context of new settlements at Twinwoods and Colworth and it appears an assessment of the impact solely in the context of expanding existing settlements was not undertaken which could potentially mitigate the capacity concerns. The Bedford Borough Transport Model makes clear that the impact from new settlements is based on an increase of c. 5,895, whereas village related growth in locations already well served by existing corridors would experience far lower, more appropriate, levels of growth if included as part of a spatial strategy.

Red Eagle Securities is therefore of the view that any spatial strategy included in the next iteration of the LPR should seek to diversify growth across the Borough by incorporating elements of sub-options 2 and sub-options 3 complementing growth in the A421 corridor and on the edge of the urban area, with small and medium size allocations in sustainable villages such as Oakley. The diversification of a strategy in this manner would reduce the reliance on any one area of the Borough having to absorb and facilitate growth in the context of both the updated LHN and the incoming ASF.

It is unavoidable that this Council will need to examine more closely all options for sustainable growth as opposed to merely the best options for growth. Doing so would future-proof the Plan insomuch as is possible against the emerging requirements of the ASF at this current point in time to meet not only the minimum targets for housing growth until 2040 as per the LHN, but also the ASF in addition to boosting the supply of homes where possible in line with key objectives of national planning policy