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

Object

Representation ID: 9016

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

In summary, our review of the Local Plan consultation finds that there are a number of areas of the 2040 Local Plan and its evidence base that need further consideration, in some instances due to the changes to the NPPF which were published after the consultation had launched. The three key issues are summarised below:
1 Duty to cooperate - It is not clear that BBC is currently cooperating effectively with HDC in assessing the cross-boundary impacts of the proposed new settlements at Little Barford and Wyboston, which is not in compliance with the NPPF and the duty to cooperate at paragraph 24. The Council needs to show that it is engaging with HDC to determine that the new settlements are deliverable and that they are based on effective joint working across the local authority boundaries. This evidence is also needed to provide communities and other stakeholders with a transparent picture of how they have collaborated.
2 Highways modelling and unlocking the north of Bedford - development of any strategic site north of Bedford appears to have effectively been ruled out on highway capacity grounds. Vectos considers the approach BBC has taken to its 2040 Local Plan site selection using the Predict & Provide approach to traffic capacity that ignores mobility as a whole in line with leading transport guidance is incorrect. It is not policy compliant in the context of the Climate Emergency declared by BBC, the Department for Transport paper – Decarbonising Transport published in July 2021 nor the NPPF, paragraph 7, 11a and 73). This ‘business as usual’ approach is unlikely to be compatible with a 30-year vision (outlined in 3. below) which properly embraces all the changes to sustainable transport that are a realistic prospect over that extended timeframe.
3 Visioning and future housing needs – the introduction of paragraph 22 of the NPPF 2021 provides the Council with the chance to look ahead and plan for the longer term. Although the Council is still without specific housing growth figures to plan for over that period, there is already evidence to suggest needs in excess of the Standard Method to c.45% and the Oxfordshire Plan is already seeking to deliver more than the Standard Method in it’s part of the Arc. A visioning exercise needs to be undertaken to 2050 which as well as increasing housing needs, also considers the very recent changes and expectations of sustainable transportation and active travel in the future across the Arc. The assessment of TwinWoods should be revisited in light of its potential to form part of this vision.
TwinWoods
5.2 In transport modelling terms, TwinWoods has not been considered as a new self-sustaining town, but instead as only additional housing whose residents are attracted to Bedford and beyond. This is an outdated view of development, not reflective of what is proposed at TwinWoods which has embraced the provision of everything communities need in 20-minute neighbourhoods, reducing the need for individual travel. For this reason, the BBC modelling results are not an appropriate basis on which to make determinative planning decisions which would fix directions of growth and represent an effective moratorium on any growth north of Bedford.
5.3 In the context of the 30-year visioning exercise required, combined with the emergence of the OxCam Spatial Framework, which itself is looking c.30 years ahead, Bedford Borough cannot afford to disregard any development to the north of Bedford for future decades on the basis of transport evidence which utilises out of date methods which do not adhere to national planning policy or the decarbonisation agenda, including BBC’s own declaration of a Climate Emergency.
TwinWoods represents a strong opportunity to create a new sustainable settlement capable of providing a significant number of homes to meet Bedford’s long-term housing needs beyond the plan period. It is deliverable, with all of the land in control of the two promoters, and it would involve the re-development of a partial brownfield site. TwinWoods also has the potential to link growth with the East-West rail route as part of a self-contained sustainable settlement, providing its own jobs, services, shops and local connections to Bedford. The previous consultation responses and supporting evidence documents that we have provided, including a detailed Feasibility Report, demonstrates that TwinWoods is a viable scheme that would support the aspirations of the NPPF.