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

Object

Representation ID: 6234

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Housing Needs
2.1 Paragraph 15 of the NPPF (2021) requires Local Plans to, inter alia, provide a
framework for addressing housing needs and other economic, social, and
environmental priorities.
2.2 Paragraph 16 states that Local Plans should be prepared with the objective of
contributing to sustainable development and be prepared positively in a manner
that is aspirational as well as deliverable.
2.3 The NPPF also requires (para 23) that the Strategic Policies of the Plan should
provide a clear strategy for bringing land forward to meet objectively assessed
needs in line with the presumption in favour of sustainable development (para
11), and, in doing so, allocating sufficient sites to deliver the strategic priorities of
the area.
2.4 National Policy therefore provides a clear, positive context with a clear
requirement to meet identified needs in an aspirational but deliverable fashion.
Importantly, the NPPF does not state that Plans should adopt a ‘do minimum’
approach; instead it promotes ambitious growth, where it is carried out in a
sustainable fashion.
2.5 Bedford Borough sits in a key location within a national area of strategic
importance, being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst
the timetable for the Local Plan does not align with that of the Arc Spatial
Framework, our client supports the approach being taken by BBC of
progressing the Local Plan in advance of the Arc Spatial Framework and
consider it is crucial that the Plan is adopted in a timely fashion.
2.6 The Local Plan 2030 was adopted on the basis of an early review and was
examined against the 2012 NPPF under transitional arrangements. The Local
Plan 2030, therefore, whilst being relatively “young” in Local Plan terms, is quite
outdated in terms of its approach to housing needs. The level of growth
identified and allocated in the Local Plan was based upon historic methods for
identifying housing need, and, therefore, suppresses housing need for a recently
adopted Plan.
2.7 The Local Plan 2040 must, therefore, address this issue in addition to
considering housing needs associated with the Arc.
2.8 The Local Plan 2030 was found sound on the basis of an average housing need
of 970 dwellings per annum (‘dpa’) across the period of 2015-2030.
2.9 The Standard Method requirement (para 3.2 of the Local Plan) meanwhile, finds
an average housing need of 1,275dpa, which the Local Plan applies across the
plan period of 2020 to 2040. There is, therefore, an overlap of some 10 years
between the two.
2.10 The Local Plan 2030 did not, therefore, meet the housing needs as now
identified based on the Standard Method. The Inspector’s Report into the 2030
Local Plan recognised (IR para 40) that if the Standard Method had been applied
in that instance, then the housing need figure of 1,280dpa would have applied.
2.11 The Standard Method has a cap which applies in instances where the strategic
policies for housing in a Local Plan have been adopted within the last 5 years1.
Whilst that is strictly correct in the case of BBC, as identified earlier in this
Statement, the spatial policies in the Local Plan 2030 effectively supressed
housing needs due to their consideration under the transitional arrangements.
2.12 There is a potential supressed need for the period 2015-2020 of some 1,550
homes (1280-970 = 310 x 5 years). It is contended, therefore, that the cap should
not apply in this instance as the spatial policies for housing need are effectively
out of date.
2.13 The Planning Practice Guidance is clear2 that the Standard Method identifies a
minimum annual housing need figure. It is not, therefore, a maximum target
and it is wholly appropriate to apply a higher housing need figure.
2.14 In this instance, whilst the housing targets for the Arc are currently unknown,
given the Plan runs until 2040, it would also be appropriate to include an uplift
to allow for additional housing to contribute to the Arc within the period.
2.15 The current strategy of deferring such a decision until the next review is not
a sound approach; it is not positively prepared planning for a spatial strategy
that will cover some 20 years. Even with a review in 5 years’ time (as is
suggested in the Local Plan), that would be close to the midpoint of the Local
Plan on the basis that this Local Plan is not likely to be adopted until 2024 (if
submission is in 2023). Moreover, the requirement is only that a Local Plan
Review is commenced in 5 years’ time, not completed, so any future review
would not be completed until after 2030.
2.16 This approach contrasts the approach taken by other authorities within the Arc,
including Oxfordshire who are currently consulting on a new Local Plan
(Oxfordshire Plan 2050) which specifically sets out that part of its purpose is to
influence and shape the emerging Arc Framework. Failure to positively plan for
the Arc now would reduce the Borough’s ability to influence the direction and
vision for the Arc through the Borough.
2.17 It is evident, therefore, that an uplift allowance in housing needs should be
included in this Local Plan to begin to accommodate future growth resulting
from the Arc. Given historic market trends and the scale of housing, an uplift of
10% (as a minimum) from the Standard Housing Method figure of 1,275dpa
would be reasonable at this time. This would lead to a new housing need of
1,403dpa (rounded). That equates to a total need of 28,050 homes across the
period 2020-2040.
2.18 In summary, therefore, the housing need figure in the Local Plan should be
increased to reflect the supressed supply in the Local Plan 2030, and future
growth from the Arc. A minimum increase of 10% should be applied, equating to
a minimum need of 28,050 homes.

Object

Representation ID: 6237

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Plan Period
2.19 Turning to the matter of Plan length AWG contend that the Plan Period should
run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan
and is not a sufficiently long enough extension to effect real change.
2.20 As the Council will be aware, strategic growth and development, along with
wide scale change, takes many years to deliver. Sites take a long time to plan
correctly and then commence delivery, and thus a longer Plan Period should be
allowed for.
2.21 Furthermore, by extending to 2050, this would bring the Plan in line with others
in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the
strategic and important role that Bedford Borough plays within the Arc, it would
represent ‘good planning’ and a holistic approach to align the Local Plan
Period with those other areas. The next review of the Local Plan would then
not need to extend the Plan Period, but instead revise housing and employment
growth to reflect the latest position as relevant at that time.

Object

Representation ID: 6239

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

3.1 The first statement contained within the Local Plan’s Vision (Chapter 2) rightly
sets an aim of tackling climate change and adapting to and mitigating its
effects being at the heart of new development in the Borough.
3.2 This is then reinforced, with Theme 1 (p.13) setting an objective to making
Bedford Borough a carbon neutral Borough. The draft Local Plan, however, does
not currently carry this commitment through in such a way as to suggest
meaningful action.
3.3 Firstly, the Local Plan does not include any proposed strategy or approach
concerning renewable energy development. If the Borough is serious about
becoming carbon neutral and tackling climate change, it is essential that the
Local Plan includes positive policies which encourage both renewable
energy developments, and net zero carbon developments, to come forward.
3.4 The NPPF is clear (Chapter 14 – para 152 in particular) that the planning system
should, inter alia, support renewable and low carbon energy and associated
infrastructure. Para 153 states that Plans should take a proactive approach to
mitigating and adapting to climate change.
3.5 Moreover, para 155 states that Plans should both provide a positive strategy for
energy from renewable and low carbon sources and consider identifying
suitable areas for such developments.
3.6 The Local Plan fails to tackle this issue. As currently drafted, it lacks any
meaningful proposals or aims in order to meet these requirements of national
policy.
3.7 In the same fashion that the Local Plan has considered issues and options
around future growth (scale, location, pattern etc), this iteration of the Local Plan
should have also included options proposing a positive strategy for energy from
renewable and low carbon sources, including potential locations.
3.8 It must encourage growth that comes forward where renewable energy
goes hand in hand with development proposals, with positive policies
encouraging such developments (be they as allocations and/or applications)
to be considered favourably. The NPPF makes particular reference (para 155 c)
to identifying opportunities for development to draw its energy supply from
decentralised, renewable or low carbon energy supply, and for co-locating heat
customers and suppliers.
3.9 Of particular concern is the lack of any focused evidence base document(s)
addressing these matters. The list of Local Plan 2040 Supporting documents
provided by the Council is absent any topic papers, studies or the like which
address these matters.
3.10 It is essential that BBC undertake such work as a matter of urgency to inform
the next stage of the Local Plan. AWG propose that the Local Plan will need to
include policies allocating sites for renewable energy, as well as allocating
strategic developments which could come forward alongside renewable
energy. The land West Park Farm, as set out later in these representations, is a proposed development that would be in accordance with such an approach as
advocated by the NPPF.

Object

Representation ID: 6240

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

3.11 The Sustainability Appraisal (‘the SA’) should also be updated to reflect this
requirement. The climate crisis is a significant, national issue and the SA
methodology must be amended to provide greater weighting to matters
relating to climate change and energy.

Object

Representation ID: 6241

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

4.1 The previous Issues and Options consultation outlined six potential approaches
to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based
growth.
4.2 These six options have now been progressed and as set out in the Local Plan
and Development Strategy Topic Paper (June 2021); BBC now seek views on
four ‘preferred options’ to meet the (proposed) level of growth set out in the
Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes and southern parishes;
2. Option 2b: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes and southern parishes, plus one new
settlement;
3. Option 2c: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes, plus two new settlements;
4. Option 2d: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes, southern parishes, and eastern
parishes, plus one new settlement;
4.4 The four options put forward share many common components. In all but one
option (Option 2c), growth is proposed to the south of Bedford, including the
southern parishes. The only option that omits this approach is Option 2c, which
instead proposes the delivery of two new settlements.
4.5 Firstly, Option 2c is not considered a sound approach. As has been
evidenced3, the development of large sites (2,000+ dwellings) takes many years.
The average time quoted from validation of the first planning application to the
first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. The
lead in period to starting on site for new settlements is many years, being further
complicated by matters such as creating the necessary utility infrastructure for a
new settlement.
4.6 The same report also finds that the average annual build-out rate for a scheme
of 2000+ dwellings is 160dpa.
4.7 Working on the basis of a plan led system, any application for a new settlement
would, in theory, not be validated until after the Local Plan is adopted, thus 2024
at the earliest. This means that any new settlement is unlikely to begin
delivering homes until 2032 at the earliest. The proposed new settlements are
3,085 dwellings at Little Barford, and 2,500 dwellings at Wyboston. Little Barford
would take 19.3 years to build out at that rate (almost the entire Plan duration),
and Little Barford 15.6 years.
4.8 If the Plan period runs until 2040, both new settlements would only deliver, at
best, half of their housing numbers within the Plan Period.
4.9 The approach set out in Option 2c would not, therefore, meet the Borough’s
housing needs within the Plan Period and should be discounted as a result.
4.10 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d,
albeit the effect of only having one new settlement would lessen the delivery
issues.
4.11 The option which has the greatest likelihood of delivering growth within the
Plan period, as required by national policy, is Option 2a. This option would
focus growth in the south along the major transport corridors of the A421, A6
and railway line, and in turn would focus development in the most sustainable
locations.
4.12 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the
best performing option. It also finds Option 2c to be the worst performing of
these 4 options, and that is without considering the issue of delivery as set out
above.
4.13 AWG strongly argue that Option 2a should be the preferred Option for growth
that is taken forward in the Local Plan. Option 2a is the best performing of the
various growth options as shown by the evidence base.
4.14 The next section of these representations puts forward a case as to one such
location for growth within the southern parishes, which would deliver growth in
accordance with Option 2a (in fact according with 3 of the 4 development
options).

Support

Representation ID: 8573

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

1.1 These representations have been prepared on behalf of Arnold White Group (‘AWG’) in response to the public consultation on Bedford Borough Council’s (‘BBC’) Local Plan 2040 – Draft Plan, Strategy Options and Draft Policies Consultation (‘the Local Plan’).
1.2 AWG are a landowner and strategic land promoter,
owning and controlling significant areas of land within Bedford Borough. These representations are made having particular regard to a 96ha area of land at Broadmead, Marston Vale, north of Stewartby. This land forms part of the wider 222ha ‘Bedford Business Park’ being promoted by Cloud Wing UK Ltd (‘Cloud Wing’).
1.3 A Site Location Plan identifying the extent of land (hereafter referred to as ‘the Site’) is enclosed at Appendix 1.
1.4 The Site has previously been submitted to BBC as part of the Call for Sites process, and AWG has been active participants in every stage of the Local Plan 2030, as well as the 2020 consultation on the Local Plan 2040.
1.5 The response to this consultation considers the key issues of job growth; strategic locations for growth; climate change; and, as an overall point, the relationship of the Local Plan to the Arc Spatial Framework and Government’s proposed planning reforms.
1.6 This response also includes further information in relation to the land at Bedford Business Park, with the enclosed illustrative Masterplan (Appendix 2) demonstrating how the land would deliver substantial employment and economic opportunities in accordance with national policy.

Object

Representation ID: 8575

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

2.1 Paragraph 16 states that Local Plans should be prepared with the objective of contributing to sustainable development and be prepared positively in a manner
that is aspirational as well as deliverable.
2.2 The NPPF also requires (para 23) that the Strategic Policies of the Plan should provide a clear strategy for bringing land forward to meet objectively assessed needs in line with the presumption in favour of sustainable development (para 11), and, in doing so, allocating sufficient sites to deliver the strategic priorities of the area.
2.3 National Policy therefore provides a clear, positive context with a clear requirement to meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes ambitious growth, where it is carried out in a sustainable fashion.
2.4 Bedford Borough sits in a key location within a national area of strategic importance, being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst the timetable for the Local Plan does not align with that of the Arc Spatial Framework, our client supports the approach being taken by BBC of progressing the Local Plan in advance of the Arc Spatial Framework and consider it is crucial that the Plan is adopted in a timely fashion.
2.5 Representations put forward by Cloud Wing provide a detailed explanation of the national, sub-regional and local context for employment needs. AWG, having reviewed those representations, fully support the case put forward by Cloud Wing in their representations and do not seek to replicate those arguments here.
2.6 The Cloud Wing submission is based upon up-to-date market evidence at all scales (national, sub-regional and local) and, crucially, demonstrate that the
targets for employment growth in the Local Plan significantly fall short of what is required to meet identified and future needs in the Borough.
2.7 AWG consider that the employment needs proposed in the Draft Local Plan 2040 do not fully capture recent economic trends nor consider the wider national and sub-regional context of significant economic growth planned within the region or the Arc.
2.8 Bedford Borough sits at the heart of the Arc, whilst the A421 and East-West Rail are key movement corridors through the Arc and wider sub-region. Whilst it is acknowledged that the Arc Spatial Framework is currently lagging behind the timetable for BBC’s Local Plan, sufficient knowledge and evidence for the ambition and scale of growth to be delivered in the Arc exists.
2.9 The current strategy of deferring decisions on housing and employment growth until the next Local Plan review is not a sound approach; it is not positively prepared planning for a spatial strategy that will cover some 20 years. Even with a review in 5 years’ time (as is suggested in the Local Plan), that would be close to the midpoint of the Local Plan on the basis that this Local Plan is not likely to be adopted until 2024 (if submission is in 2023). Moreover, the requirement is only that a Local Plan Review is commenced in 5 years’ time, not
completed, so any future review would not be completed until after 2030.
2.10 This approach contrasts the approach taken by other authorities within the Arc, including Oxfordshire who are currently consulting on a new Local Plan (Oxfordshire Plan 2050) which specifically sets out that part of its purpose is to influence and shape the emerging Arc Framework. Failure to positively plan for
the Arc now would reduce the Borough’s ability to influence the direction and vision for the Arc through the Borough.
2.11 As a result, the approach set out in the Draft Local Plan significantly underestimates the scale of economic development needed and envisaged within the wider sub-region. It also risks Bedford losing out on the substantial benefits associated with this growth to other parts of the Arc. The Council's evidence, therefore, needs to be updated including to reflect recent trends
and market signals and align with the wider ambitions for the sub-region.
2.12 Within this context any employment land requirement should clearly be set as a minimum rather than a ceiling on employment-generating development in
the Borough. BBC should adopt a similar approach to Central Bedfordshire Council (‘CBC’) in their recently adopted Local Plan. In the case of CBC, who share many similar characteristics with BBC in terms of employment market and needs, the Local Plan allocated a significant quantum of strategic employment land over and above the identified needs, as the Council (accepted by the Local Plan Inspectors) acknowledged that future employment growth is diverging from historic market trends, and that there is a chronic undersupply issue.
2.13 Whilst CBC had initially suggested this could be put to a future Local Plan Review, they took the positive approach of planning for these needs now, recognising the significant economic boost that will bring. It is crucial that BBC adopt a similarly positive approach in the Local Plan and do not progress a ‘do minimum’ strategy.
2.14 The Local Plan should also have regard to the changing nature of jobs within the employment market and the evidence base is presently misleading in this regard. The Employment Land Supply incorrectly asserts that the logistics sector does not generate highly skilled jobs. Whilst that may have been the case 10-15 years prior, modern logistics operations employ many highly skilled workers, and this is only set to increase in the future with further automation and robotics.
2.15 Furthermore, many logistics buildings now incorporate large areas of office within them, meaning that they also deliver E Class (former B1) jobs that would otherwise not come forward.
2.16 The Local Plan strategy fails to adequately recognise the difference in employment development and needs versus housing needs. Employment development is generally driven by demand from actual occupiers. It is important to note that there needs to be a range of unit sizes available to meet demand as it arises from occupiers who will have different requirements according to the nature and size of their businesses.
2.17 Occupiers’ need for new facilities is generally immediate because it arises from the demands of their businesses. Businesses are rarely able to plan accurately more than 12 months in advance, where delivery of new employment, even on allocated land, can take 18 months to deliver. Accordingly, there need to be employment sites identified well in advance which are capable of meeting need as it emerges. As a result, there needs to be a “surplus” of allocated land against identified needs to ensure there are sufficient sites available which can meet a range of demands quickly.
2.18 This in turn provides the opportunity to meet market demand in a sustainable, planned fashion, i.e. through a Local Plan, rather than through ad hoc planning applications on unallocated sites because the Local Plan has not provided sufficient employment land.
2.19 The Draft Local Plan recognises the strategic importance of the A421 rail-based growth corridor in unlocking and delivering growth in the area. However, it fails to recognise the unique opportunity presented by the Bedford Business Park in this location, instead contemplating the allocation of smaller, piecemeal business parks and other small employment sites. This approach does not appear to be soundly based and would not be capable of delivering the scale of investment or diversity of economic growth that could be delivered by Bedford Business Park.
2.20 The Bedford Business Park (and in particular the land at Broadmead) is considered in more detail in Section 5 of these representations.

Object

Representation ID: 8576

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

2.21 Turning to the matter of Plan length AWG contend that the Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change.
2.22 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for.
2.23 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas. The next review of the Local Plan would then not need to extend the Plan Period, but instead revise housing and employment growth to reflect the latest position as relevant at that time.

Object

Representation ID: 8577

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

3.1 The first statement contained within the Local Plan’s Vision (Chapter 2) rightly sets an aim of tackling climate change and adapting to and mitigating its effects being at the heart of new development in the Borough.
3.2 This is then reinforced, with Theme 1 (p.13) setting an objective to making Bedford Borough a carbon neutral Borough. The draft Local Plan, however, does not currently carry this commitment through in such a way as to suggest meaningful action.
3.3 Firstly, the Local Plan does not include any proposed strategy or approach concerning renewable energy development. If the Borough is serious about becoming carbon neutral and tackling climate change, it is essential that the Local Plan includes positive policies which encourage both renewable energy developments, and net zero carbon developments, to come forward.
3.4 The NPPF is clear (Chapter 14 – para 152 in particular) that the planning system should, inter alia, support renewable and low carbon energy and associated infrastructure. Para 153 states that Plans should take a proactive approach to mitigating and adapting to climate change.
3.5 Moreover, para 155 states that Plans should both provide a positive strategy for energy from renewable and low carbon sources and consider identifying suitable areas for such developments.
3.6 The Local Plan fails to tackle this issue. As currently drafted, it lacks any meaningful proposals or aims in order to meet these requirements of national policy.
3.7 In the same fashion that the Local Plan has considered issues and options around future growth (scale, location, pattern etc), this iteration of the Local Plan should have also included options proposing a positive strategy for energy from renewable and low carbon sources, including potential locations.
3.8 It must also encourage growth that comes forward where renewable energy goes hand in hand with development proposals, with positive policies encouraging such developments (be they as allocations and/or applications) to be considered favourably. The NPPF makes particular reference (para 155 c) to identifying opportunities for development to draw its energy supply from decentralised, renewable, or low carbon energy supply, and for co-locating heat customers and suppliers.
3.9 Of particular concern is the lack of any focused evidence base document(s) addressing these matters. The list of Local Plan 2040 Supporting documents provided by the Council is absent any topic papers, studies or the like which address these matters.
3.10 It is essential that BBC undertake such work as a matter of urgency to inform the next stage of the Local Plan. AWG propose that the Local Plan will need to
include policies allocating sites for renewable energy, as well as allocating strategic developments which could come forward alongside renewable energy.
3.11 The Sustainability Appraisal (‘the SA’) should also be updated to reflect this requirement. The climate crisis is a significant, national issue and the SA methodology must be amended to provide greater weighting to matters relating to climate change and energy.

Object

Representation ID: 8578

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

4.1 The previous Issues and Options consultation outlined six potential approaches to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based growth.
4.2 These six options have now been progressed and as set out in the Local Plan and Development Strategy Topic Paper (June 2021); BBC now seek views on four ‘preferred options’ to meet the (proposed) level of growth set out in the Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes and southern parishes;
2. Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes and southern parishes, plus one new settlement;
3. Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, plus two new settlements;
4. Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes, and eastern parishes, plus one new settlement;
4.4 All four proposed options include development along the A421 transport corridor, and rail-based growth in the south of the Borough. It is of note that the map alongside each image fails to recognise the proposed new East-West rail station that would be located north of Stewartby (potentially alongside Bedford Business Park). This station would further justify the choice to progress a growth option focused on the A421 and rail corridor.
4.5 AWG supports the proposed strategy of growth along the A421 and rail corridor. However, AWG consider that each of the proposed options fail to identify
sufficient land to meet the employment needs of the Borough (as set out in Section 2 of these representations and in the Cloud Wing representations).
4.6 The Development Strategy Topic Paper states (para 3.13) that 123ha is proposed to be allocated to 2040, based on the Employment Land Study. For the reasons
set out in Section 2, that figure is not considered to be sound and needs to be increased. This would, in turn, result in a requirement for the proposed Development Options (and the final selected Option) to identify further areas for employment growth.
4.7 As well as an insufficient quantum of employment land, AWG contend that 3 of the 4 options may result in insufficient delivery within the Plan period. Firstly, Option 2c is not considered a sound approach. As has been evidenced1, the development of large sites (2,000+ dwellings) takes many years. The average time quoted from validation of the first planning application to the first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. Whilst this relates to dwellings, Option 2c proposes up to 20ha of employment as part of a new settlement. It is reasonable to assume that the 20ha would come forward as part of a holistic approach to a new settlement. The employment could, therefore, be constrained by the delivery of the new housing and associated infrastructure demands.
4.8 The same report also finds that the average annual build-out rate for a scheme of 2000+ dwellings is 160dpa.
4.9 Working on the basis of a plan led system, any application for a new settlement would, in theory, not be validated until after the Local Plan is adopted, thus 2024 at the earliest. This means that any new settlement is unlikely to begin delivering homes until 2032 at the earliest, and potentially employment land until a similar time.
4.10 The approach set out in Option 2c may not meet the Borough’s employment needs in the short term and could result in employment delivery beyond the plan period and should be discounted as a result.
4.11 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d, with the same quantum of employment proposed for one settlement (as opposed to two in the case of Option 2c).
4.12 The option which has the greatest likelihood of delivering growth within the Plan period, as required by national policy, is Option 2a. This option would focus growth in the south along the major transport corridors of the A421, A6 and railway line, and in turn would focus development in the most sustainable locations.
4.13 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the best performing option. It also finds Option 2c to be the worst performing of these 4 options, and that is without considering the issue of delivery as set out above.
4.14 Whilst Option 2a is the best of the options put forward, for the reasons set out in Section 2 of these representations, the proposed level of growth in Option 2a is not sufficient to meet the identified needs for the Borough.
4.15 A new Development Option is therefore required which meets the identified growth needs and, in particular, the opportunity presented by Bedford Business Park to maximise growth in the A421 rail-based growth corridor. This Option would then be the favoured one to progress in the Local Plan, being for some 222ha of employment growth in this location.
4.16 The next section of these representations puts forward a case as to why the land at Broadmead, and in turn the Bedford Business Park, would deliver growth in accordance with the Development Strategy outlined above (in fact according with 4 of the 4 development options).