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

Support

Representation ID: 7547

Received: 21/09/2021

Respondent: Luton Borough Council

Luton Council notes that the consultation document identifies that Bedford Borough Council must follow the standard method for calculating future housing requirements and that as a result of the government’s recent revisions to the standard method the figure for Bedford borough is 1,275 dwellings per year, giving a total of 25,500 dwellings from 2020 – 2040. Furthermore, it is acknowledged in the consultation document that this figure may change during the preparation of the Local Plan. As highlighted in our response to the Issues and Options consultation in September 2020, if the Bedford Local Plan does not meet its own housing need, Luton given its own constraints, will not be able to help to meet Bedford’s housing needs. The revised Local Plan will need to ensure that it is able to meet Bedford’s minimum annual housing requirement for the Plan period in accordance with Government guidance.
Luton Council intend to formally commence a review of the Luton Local Plan in due course once the issue of meeting our unmet housing need over the period 2011-2031 has been fully resolved. The adopted Central Bedfordshire Local Plan contains a commitment to deliver 7350 homes of Luton’s unmet need by 2031 and we await the Inspectors report into the North Hertfordshire Local Plan examination. For Luton Council and the Luton Local Plan review, key decisions such as the plan period, housing requirement, potential development capacity with in Luton etcetera have not currently been made. Unmet housing need from Luton for the period beyond 2031 could be an issue for the duty to co-operate (or its successor) which requires further consideration in this new round of local plans.

Support

Representation ID: 7548

Received: 21/09/2021

Respondent: Luton Borough Council

In relation to the level of employment growth and land, Luton Council notes that the consultation document identifies that taking account of planned population growth to 2040 and the currently available supply of land, the employment land to be allocated in the Local Plan for Bedford Borough is 123 hectares. As with housing need, Luton would be unable to provide additional employment land to support Bedford’s needs due to Luton’s own constraints.
Bedford and Luton Councils are within the Oxford to Cambridgeshire Arc and as such will need to continue to collaborate to maximise the areas potential within the Arc.

Object

Representation ID: 7549

Received: 21/09/2021

Respondent: Luton Borough Council

In our response to the Issues and Options consultation in September 2020 we raised concerns with regard to the sustainability of the option which provided housing growth along the A421. In particular we considered that development along the A421 would promote reliance on the private car and result in development that fails to meet national and local objectives to reduce climate change and improve air quality. We suggested that housing and employment delivery options that can be directly served by the rail network should be given significant priority.
We note that the consultation document identifies four emerging preferred growth strategy options (Options 2a, 2b, 2c and 2d), with housing development in the A421 transport corridor with rail based growth as part of all four options.
The Development Strategy Topic Paper (June 2021) that accompanies the consultation document summarises the sustainability appraisal testing of the reasonable alternatives, including the four emerging preferred growth strategy options. Paragraph 3.19 of the Development Strategy Topic Paper states:
‘In summary the sustainability appraisal shows that options 2a, 2b, 2c and 2d collectively are the best performing options. All four sub-options have an urban focus in common. However, option 2a performs better than the others because it concentrates most growth at the rail based location at Stewartby/ Kempston Hardwick (60% of total growth). This means that there is a high probability that public transport and cycling will be an attractive alternative to private car use for a significant proportion of total new growth.’
The assessment of Options 2a, 2b, 2c and 2d against the draft plan theme ‘2. More accessible’ in the table that follows Paragraph 3.23 of the Development Strategic Topic Paper repeats this view:
‘Although the need to travel is expected to rise, the high concentration of development near to rail stations and the use of bus facilities in the transport corridor are likely to encourage the use of public transport and cycling.’
However, the Bedford Borough Transport Model Local Plan Assessment has not tested the ‘long list’ of options (Options 1a through to 7), including the emerging preferred growth strategy options, but has instead to date only tested the potential locations for growth identified in the 2020 Issues and Options Consultation (Options Grey; Pink, Yellow and Brown; Red & Orange; Brown) and the new settlement options.
The table following Paragraph 3.31 in the Development Strategy Topic Paper identifies those options which, on the basis of the analysis to date through the sustainability appraisal, assessment against the local plan themes and the transport modelling work, perform the most strongly. One of the ‘Key strengths’ identified for Option 2a in the table is:
 ‘Potential for higher density development around rail hubs at Wixams (MML) and Stewartby and Kempston Hardwick (EWR) facilitating active travel modes and accessible neighbourhoods in proximity to new business park/ science park development’.
However, significant ‘Weaknesses and delivery challenges’ are also identified for Option 2a including:
 ‘The A421 is a key link and additional growth is a challenge to its capacity.
 Viability and land assembly challenges for urban land and timing of delivery in some cases dependent on EWR delivery.
 Delivery of new rail stations is proposed, but not yet confirmed.
 Lead in times for remediation of the Kempston Hardwick area and delivery of new rail stations mean that development in this part of the transport corridor will occur later in the plan period.’
Luton Council remains concerned that housing development along the A421 would not be sustainable unless it will be directly served by the rail network and the delivery challenges can be overcome. Detailed consideration should be given to these matters as part of the next steps in the technical work for the Local Plan’s preparation.