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

Object

Representation ID: 6064

Received: 09/09/2021

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

1.3 The Strategy Options document that is being consulted on was prepared ahead of the publication of the revised National Planning Policy Framework 2021 (NPPF). A requirement was introduced within Paragraph 22 of the revised NPPF for Local Plans proposing new settlements or urban extensions to towns/villages to be set within a vision which looks at least 30 years ahead. Paragraph 22 will apply to the Bedford Borough Local Plan based on the transitional arrangements that have been put in place and as a result, the Council will need to undertake additional work to establish a longer-term vision for the Local Plan 2040.

Object

Representation ID: 6065

Received: 09/09/2021

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

2.1 Chapter 3 of the consultation document identifies that given the predicted population growth up to 2040, 171 hectares of new employment land will be required. The current supply of employment land in the District sits at 48 hectares with this meaning that 123 hectares of land needs to be allocated within the Local Plan.The Local Plan should proactively seek to provide a buffer in the level of employment land to be required in order to allow a choice in the market and a differential in suitable sites to allow for the different requirements by the market. In this regard, although Chapter 3 stipulates that there is currently a shortfall of 123 hectares of land, the Council should look to allocate additional land to provide this buffer and to meet the wider requirements of different industries. For example, a buffer of 10% should be applied and therefore the plan should be looking to allocate 135 hectares of employment land to allow for this flexibility.
2.3 As a centrally located local authority in the Oxford to Cambridge Arc, Bedford Borough should ensure that the level of growth that is to be planned in the authority should be in line with wider aspirations for the area, with the employment areas additionally fulfilling the requirements set out in the Arc Vision. It is important that the employment areas that are proposed within the chosen strategy must be in close proximity to the strategic road network to allow easy access to the research and development hubs that have been constructed in both Oxford and Cambridge.
2.4 The amount of employment land that is to be allocated is affected in part by the following factors: the aspirations of the Oxford-Cambridge Arc should be considered alongside the requirements to provide different types of employment uses including B1 and B8 land uses and cross-boundary growth. These factors reflect the need to further increase the level of employment land to be allocated.
2.5 The inclusion of sites that are close to the boundary with the neighbouring authorities would additionally lead to the residents of these authorities coming into Bedford Borough thus boosting the economic growth of the Local Authority, without increasing the demand for residential dwellings in the authority.
2.6 Therefore, the employment requirement in the Local Plan 2040 needs to plan for flexibility and the broader long-term economic aspirations for growth in the area.

Object

Representation ID: 6066

Received: 09/09/2021

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

3.1 It is noted that The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for commenters were the urban area, the A421 corridor and rail-based locations. Further, the Sustainability Appraisal process identified that urban growth and urban edge growth are the most sustainable approach to new development.
3.2 The Call for Sites Extract shows a snippet of the sites that have been submitted for consideration by the Local Authority as potential development sites. A substantial number of these have been submitted for consideration as residential housing schemes as opposed to employment land. As flagged in Chapter 3 of the consultation document, the Council wishes to utilise both larger and smaller sites for use as employment sites, thus meaning a substantial number of sites would need to be allocated to meet the identified demands of employment land in the Borough. [Call for sites map inserted here.]
3.3 Of the sites that have been promoted thus far, it cannot be assumed that all the sites will be suitable and there may be constraints that limit what can be delivered, such as neighbouring uses, access, ecological considerations etc. This, therefore, makes it all the more essential that the Council give proper consideration to all the sites that have been put forward for development.
3.4 In a similar vein to the above, finding suitable sites for up to 51 hectares of employment (outlined in all options) on the edge of Bedford will be a challenge. Development on the edge of Bedford is realistically limited to the north/north-east of the town due to landscape, topography, flood plain constraints as well as the close proximity of the boundary of Bedford town to smaller settlements. Much of this land, whilst potentially suitable for residential development, aside from discrete parcels, is unlikely to be suitable for employment use.
3.5 Option 2d includes development in the eastern area of the A421 travel corridor which is supported by the clients as this provides a more flexible approach to development alongside not limiting this to a certain area of the Borough. It is, however, a concern that a number of the approaches are only limited to the south-western area of the District thus not utilising the important roles of the strategic transport links elsewhere and their associated roles, particularly for employment uses which rely on access to the strategic highway network. The close proximity of this site to the A421 and the A1 should be recognised within the site analysis that is to be undertaken, thus meaning that the site should be in a strong position for allocation.
3.6 In our view, for employment uses, given the relationship with the A1, the strategy outlined in Option 2d should be taken forward for further detailed consideration. It is important that there is a distinction made in the development of the strategy between the needs for employment uses and residential requirements. Whilst there is land with potential in the wider A421 corridor with the potential to accommodate both uses, from an employment perspective, the link to both the A421 and A1 sets option 2d apart.
3.7 We consider that a finer grain assessment of site availability and suitability should be undertaken to inform the development strategy. It is considered that this will identify a greater level of potential for growth along the whole of the A421 corridor. The whole of the A421 corridor should be looked at as one moving forward, with no arbitrary distinction between the eastern and southern parishes. This will allow a proper review of employment locations on a comparable basis and avoid suitable sites being missed out because they did not fall within the favoured growth area.
3.8 It can be noted, that the A421 has seen considerable growth in employment floorspace over recent years given its locality in both the Oxford to Cambridge Arc and the M1 corridor. In the future, it is predicted that this demand will remain, particularly for logistics given the ever-increasing emphasis on online sales alongside the significant investment in the A428 improvements.
3.9 The road improvements to the A428 / Black Cat roundabout and the East-West Rail are the key infrastructure investments in the area over the plan period and it is important that the opportunities associated with this significant investment are maximised. They will provide important connections between Oxford and Cambridge as well as linking to the wider train network. The village of Roxton is ideally located to maximise these opportunities and attract significant investment to the Borough.
3.10 This land is ideally located at the important interchange between the A428, A421 and the M1. In addition, it will be in close proximity to the East-West Rail. It is therefore considered that this site is ideally located for proposed employment land. this additionally supports the assertion in Paragraph 6.7 of the consultation document that outlines that sites should be well connected.
3.11 The proposed development at Roxton would not prohibit or curtail any of the planned infrastructure coming forward.
3.12 The inclusion of a new settlement in the strategy would present the opportunity to deliver new employment sites. However, there is a significant lead time associated with the development of new settlements, which would mean the release of employment land much later in the plan period with this potentially leading to a shortfall in the development of these employment areas in the short and medium-term stunting the growth of the Boroughs economy. This issue would be exacerbated should two new settlements be proposed within the plan.
3.13 If a new settlement is to be included in the strategy, the amount of employment land that they would deliver in the plan period should be realistic and sufficient, with other employment land also identified to meet immediate and medium-term demands. It is noted that the options currently assume the completion of either settlement option within the plan period. We would suggest that this is not a realistic assumption given the stage the plan is at and the lead-in time on matters such as land assembly, planning and infrastructure delivery.