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

Support

Representation ID: 6475

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

We agree that the Standard Method is the starting point for the Borough’s local plan housing requirement and that the eventual housing need figure will need to be informed by an updated Local Housing Needs Assessment. The allocation of land to provide a minimum of 12,500 new dwellings will also need to include additional land allocations to ensure choice and competition in the market for land and account for any fluctuations in the market. We consider this whole plan buffer should be at least 10% to meet these objectives in accordance with Paragraph 74 of the NPPF 2021. Based on the Standard Method alone, this buffer will require sufficient land allocations for 15,050 new dwellings. The application of this buffer is missing in the draft Local Plan and its absence means that appropriate levels of growth are not being fully tested and planned for in the various development strategy options. In establishing the Borough’s housing requirement, it is also important to recognise that the standard methodology represents the minimum number of homes that must be planned for. In addition, the Council will need to consider whether there are any unmet needs from neighbouring areas or whether there are scenarios that would lead to housing needs being higher than that established using the Standard Method. One such scenario is the high level of employment growth and investment being targeted in the area through the South East Midlands Strategic Economic Plan (SEMSEP) and Oxford-Cambridge Arc Economic Prospectus – both of which aim to double GVA by 2050. The government’s recent ‘Creating a vision for the Oxford-Cambridge Arc’, sets out a clear focus on making the most of the economic potential of the Arc by planning for sustainable growth to 2050 and beyond and creating a Spatial Framework that is ambitious, aspirational and unique to the Arc. To facilitate such growth the government has already invested in the East West Rail Project, connecting Oxford to Cambridge via Milton Keynes and Bedford and making it easier to connect businesses, research institutions and foster sustainable, economic growth. It is clear that housing delivery will need to keep apace with this economic growth. Will this be accounted for in the next iteration of the draft Local Plan (Regulation 19 stage) or will it will be subject to a separate strategic plan? Clarity on this essential in the interests of achieving the timetable set out in the Local Development Scheme.

Support

Representation ID: 6476

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Paragraph 74 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the plan period and to identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies. This should also include a buffer of a least 5%. 3. Even with a stepped trajectory, we expect the Council will need to significantly boost the number of small and medium housing site allocations in its new Local Plan to ensure a rolling five year housing supply. This is evident from the Council’s latest five year monitoring and forecast rates (Update to May 2019 report), which show much reduced delivery rates towards the latter half of the five year period: Year Estimated homes 2019/20 1343 2020/21 1198 2021/22 1007 2023/24 553 2024/25 442 4. Given the long lead in times for large scale settlements, we are of the view that further small and medium sized site allocations that do no rely on significant infrastructure delivery will be critical to the continuity of supply and the ability of the Council to meet its objectively assessed housing need. Additionally, even with allocation of strategic growth sites potentially delivering towards the latter half of the plan period (i.e. post 2030), there is still the need to allocate small and medium sites around existing settlements to provide choice and competition in the market and ensure flexibility in the housing trajectory in the event that, for instance, strategic site delivery is delayed (especially where the timing of significant infrastructure projects cannot be guaranteed).

Support

Representation ID: 6477

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

General approach 1. 2. 3. 4. 5. 6. The general strategy running through all four development options is supported in terms of the need to distribute growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Each of the options do however present varying concentrations of growth within these categories with resulting positive and negative outcomes. We have provided a detailed commentary on each below. Urban Centre and Edge A total of 3,000 homes are proposed within and adjoining Bedford Town Centre with 1,500 homes specifically targeted in the urban area alone. This seems an overly ambitious level of growth for the urban area given the limited land available, the presence of several heritage and environmental constraints and pressures to safeguard land for critical infrastructure such as Bedford Hospital. We would question how the delivery of this number of homes would protect the character of the town given the likely density required to reach this target and the high levels of traffic and congestion already experienced in the town. There will be viability and land assembly challenges for urban land and substantial development has already taken place on the edge of Bedford. Whilst residential development has a place in town centres, there also needs to be an appropriate balance between residential growth and employment/retail/leisure offerings. This is to ensure the vitality of the town centre and its recovery post pandemic. A detailed analysis of the town’s context and capacity for further density/storey heights needs to be carried out before such an option is considered sustainable and achievable. New settlements Paragraph 73 of the NPPF requires LPAs to identify suitable locations for large scale development where this can help to meet identified needs in a sustainable way. This should include: • considering the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains; • ensuring that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access; • set clear expectations for the quality of the places to be created and how this can be maintained (such as by following Garden City principles); and ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed and beautiful homes to meet the needs of different groups in the community; • make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development corporations); and • consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size. Taking into account the above points, it is clear that the advantage of the proposed new settlement at Little Barford is that it would benefit from direct access to the new East West Rail station that is proposed southwards of St Neots. Several of the proposed routing options for the railway line will however 5 constrain the site to an extent. In contrast, a new settlement at Wyboston, given its remoteness from existing urban areas, would have greater reliance on the use of private cars and fewer opportunities to promote active travel and create viable public transport services. This concern is supported by the transport evidence prepared by Aecom on behalf of the Borough Council. 7. 8. 9. 10. 11. 12. 13. Paragraph 73 of the NPPF states that large scale development should be supported by the necessary infrastructure and facilities to include a genuine choice of transport modes. Given the sustainable transport interventions needed to ensure climate change actions are met, delivering a new settlement the equivalent size of a new town in this location cannot be the preference. Furthermore, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another giving rise to concerns around delivery rates as well as significant pressure on existing road infrastructure. Rail based growth parishes The development strategy options include rail based growth at land within the parishes of Kempston Hardwick, Stewartby and Wixams ranging between 3,915 - 7,500 dwellings and 80ha of employment. Currently, the Stewartby and Kempston Hardwick large site promotions include mainly employment development with current applications submitted by Cloud Wing for a 780,379sqm business park and 1,000 new homes at Stewartby. The draft Local Plan development options run contrary to these current land promotions and lack accompanying evidence of deliverability, viability and capacity testing. Delivery of a new railway station and the closure of the exiting Kempston Hardwick and Stewartby stations also affects the masterplanning of the area and could give rise to potentially long lead in times in combination with the extensive remediation works required and off-site highway junction improvements. The principle of development in this location is understood but we would question how much reliance can be placed on the medium-high growth level scenarios delivering within the proposed plan period and how accurately this level of growth can be set out in the Council’s housing trajectory in the absence of evidence concerning lead-in times, infrastructure requirements, remediation works and costs, financial viability testing, masterplaning/capacity testing etc. We would suggest that growth at Stewartby is only capable of delivering post 2035 given the considerable challenges faced with making the site acceptable for development. The principle of further growth at Wixams is also understood although this should be re-categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario and included in the rail based growth parishes to acknowledge the strategic presence of Wixams and focus sustainable growth, investment and infrastructure towards it in a holistic manner rather than invite piecemeal delivery on the edges of Wilstead. Southern parishes Development in the Borough’s southern parishes that surround the A421 has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. This follows paragraphs 68 and 79 of the NPPF and the requirement to promote sustainable development in rural areas where it will enhance or maintain the vitality of rural communities and, more generally, the need to identify a sufficient supply and mix of housing sites. Options 2a, 2b and 2d include potential for 750-2000 dwellings to be delivered within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton. Option 2a includes the higher range (up to 2000) and if distributed equally between these villages would amount to approximately 333 homes each. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability, providing more day-to-day services and facilities and higher levels of self-containment. 6 For this reason, these settlements have potential to accommodate higher levels of growth especially where sites are located within reasonable travel distances of Bedford’s Town Centre and major employment areas, and benefit from existing sustainable travel infrastructure such as cycle/walking routes and bus services. 14. Certain land promotions within the southern parishes present obvious coalescence issues with surrounding villages, which is particularly notable between Gibraltar Corner (see site 636 – land at Gibraltar Corner) and Cotton End (see site 1332 – land at Manor Farm). The Council will need to consider such issues within its site assessments but also be alive to the opportunities presented by other land promotions that present appropriate land for villages to grow especially where this can be comprehensively masterplanned with sufficient land to deliver open space, biodiversity net gain (including Forest of Marston Vale targets), space for recreation, new/enhanced green connections and additional facilities and services. 15. Shortstown is already defined in the current Local Plan 2030 as a ‘Key Service Centre’ comprising a good range of services and facilities and being well connected to the town centre by public transport and cycling. It is approximately a 20 minute cycle and 20 minute bus ride from Bedford Town Centre and railway station and also benefits from close access to the A421 for wider transport connections. As a Key Service Centre, it has the capacity to support further sustainable development. The land promotion at College Farm (Site 1513) includes provision of a new primary school to support housing growth and increase local education capacity in the area. College Farm is also strategically well placed to create important walking and cycling connections to Shocott Spring to the south, Bumpy Lane to the north and the John Bunyan Trail to the west. This would have significant health and wellbeing benefits for the local and wider area. 16. Development at Cardington Sheds (Site 1338) would provide another sustainable location for housing growth in Shortstown, linking into recent development to the east of the settlement. It also creates a unique opportunity to deliver a ‘Heritage Park’ that celebrates the history of RAF Cardington. This would feature public art, educational features, high quality landscaping and play/informal open areas. Further health and wellbeing benefits would be delivered by the introduction of new recreation routes through the site, linking to the A600 (with onward connection to a new primary school at College Farm) and surrounding countryside. 17. Both land promotions would complement rather than compete with the larger potential growth sites, providing Bedford Borough Council with a mix of housing sites and a continuous housing supply throughout the plan period. They can deliver early on in the plan period and deliver growth in a sustainable way that benefits existing and new residents via the provision of new education, recreation and sports facilities, new footpath and cycle connections and a net gain in biodiversity and woodland/tree planting. Eastern parishes 18. 19. Option 2d includes potential growth for 750 dwellings and up to 28ha of employment land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston. The scale and nature of development at either Little Barford or Wyboston will depend on which is chosen as a strategic location for large scale growth. As such, the remaining villages will need to be assessed in terms of their capacity for further growth, their levels of sustainability and local character. The offer of land promotions in this area ranges significantly and does not necessarily present obvious sustainable choices for growth such as Site 878 (Land west of Great Barford south of the A421). At 2,350 houses, this site will be disproportionately large in relation to the size of Great Barford with significant transport implications and the potential to cause very high harm to both heritage and local character. Site 1355 (Trinity College Farm - North and West Off Roxton Road) for 200 dwellings is, for instance, very poorly related to any existing settlement and unlikely to foster sustainable travel movements and integration with the existing community. The level of growth in the eastern parishes will therefore be partly tempered by the offer of land promotions put forward and their levels of sustainability. Their distance further away from key urban areas like Bedford and St Neots compared to the southern parishes means that in allocation terms, overall growth numbers should be lower. 7 Summary 20. We are in broad agreement with the overarching strategy that directs growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Delivering 3,000 homes towards the urban area and adjoining urban area could be overly ambitious for the reasons we have set out above and requires further analysis of the town’s context and capacity to accommodate density/storey heights before such an option is considered sustainable and achievable. 21. In terms of new settlements, Little Barford scores more highly than Wyboston as a sustainable location as it will benefit from the new East West Rail station and a genuine choice of travel modes. However, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another and concerns around delivery rates and infrastructure capacity, and therefore Option 2c is less favourable and more risky from a strategic point of view. 22. Rail based growth is set at high levels within Options 2a, 2b and 2d with up to 5,500 or 7,500 homes being targeted at Kempton Hardiwck, Stewartby and Wixams. The principle of development at Stewartby and Kempston Hardwick is understood but too much reliance appears to be placed on high growth scenarios in these locations with the likelihood that both deliver too late on in the plan period. Further evidence will be required to demonstrate deliverability and viability in this location particularly given the extent of land remediation required and the likely S106 contributions sought in relation to highway mitigation, education and community infrastructure. 23. The principle of further growth at Wixams is understood as well but would be better categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario. 24. Growth within the eastern parishes is presented in Option 2d but we would suggest growth is better directed towards the southern parishes (as in Options 2a) in order to meet sustainability objectives. Development in the Borough’s southern parishes has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability and, for this reason, these settlements have potential to accommodate higher levels of growth. 25. Not all land promotions within the southern parishes present sustainable choices and further assessment will be required to rule out sites that lead to coalescence between villages or relate poorly to existing settlements in terms of size or location. At the same time, the assessments will need to take into account land promotions that provide opportunities to expand existing settlements, giving sufficient weighting to those sites that can deliver early on in the plan period and align with the draft Local Plan objectives to be greener, more sustainable and create strong, safe and resilient local communities.

Support

Representation ID: 6478

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

The principle of seeking biodiversity net gain is supported and is expected to be mandated nationally through the government’s Environment Bill if accepted by government and turned into an Act. The policy text also accounts for circumstances where net gain on site may be particularly challenging and instead requires enhancement or creation of off-site habitats. Further consideration does however need to be given to scenarios where landowners do not own sufficient off-site land and may need to consider contributions through biodiversity obligations or credits though financial payments as a last resort. We are uncertain what ’environmental net gain’ means in the context of this policy and if this requires more than ecological net gain measures. Paragraph 8 of the NPPF already defines the environmental objectives of sustainable development as protecting and enhancing our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. Environmental net gain could therefore encompass several features leading to confusion in the interpretation and application of this policy and ultimately its soundness. The main focus of the policy appears to be on biodiversity and therefore we think the policy wording should be more closely aligned with this aspiration and replace ‘environmental net gain’ with ‘biodiversity net gain’. If the Council’s ambition is to secure greater levels of green infrastructure or green corridors to boost natural capital in the Borough, we would suggest this is best set out in a separate strategic policy, which is informed by a Green Infrastructure Study to identify areas of deficiency and opportunity. As this is a Borough-wide issue it requires a more planned, joined-up approach underpinned by evidence to maximise opportunities to improve the natural capital of the area, rather than relying on individual site appraisals that risk a more piecemeal, uncoordinated approach.

Support

Representation ID: 6479

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

1. 2. 3. 4. 5. 6. 7. 8. The number of self-build plots required through Policy SB1 relative to the number of dwellings at a given site is too high relative to the evidence of demand demonstrated through the evidence base, particularly in the case of the explicit and anticipated requirements suggested for larger developments, particularly the evidence base leaves a large degree of uncertainty about demand. The ‘Self-build and Custom Housebuilding Guidance’ states in paragraph 11 that “Local planning authorities should use the demand data from the registers in their area, supported as necessary by additional data from secondary sources (as outlined in the housing and economic development needs guidance), to understand and consider future need for this type of housing in their area”. The “Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding Report of Findings April 2021” document within the evidence base states that “the current assumed supply of self-build and custom housebuilding is currently measured only by those properties with permission for a single dwelling. In practice it is likely that at least some properties on sites with more than one dwelling will also fall within the definition of being self-build and custom housebuilding.” Therefore by its own admission, the evidence base document is of limited accuracy in terms of the demand for self-build plots and the number of plots available. Measuring need in this way does not take into account how many permissions for single dwellings have been built out and it is also unclear “how many households from the register have been able to access these plots because the information is not recorded”. Furthermore, paragraph 1.20 of the same evidence base document also states that “Bedford Borough Council is currently providing sufficient single dwelling plots to comply with its requirement to meet the needs of those on Part 1 of its own self-build and custom housebuilding register. This has been achieved without any designated policy requirement for either allocated sites for serviced plots, or a requirement for a proportion of plots on larger sites to be made available”. This draws into question the justification for Policy SB1 being so specific in stating plot numbers relative to the size of a given scheme when sufficient provision is already being achieved without such a policy. The requirements are relatively high when compared to the size of the developments specified. For example, a requirement of 2 self and custom build plots on a 10 dwelling sites equates to 20% provision, and a requirement of 7 self and custom build plots on a 90 dwelling site equates approximately to 8% provision. This when typically many local plans require roughly 5% provision or are negotiated on a case by case basis based on evidence of need. This also represents an unbalance in how much provision is sought based on the scale of a site, when there is no evidence to support such an approach. Furthermore, there is a fundamental question as to whether the provision of self-build plots on all allocations actually meets the desires and aspirations of self-builders, who often want to deliver a house on a standalone plot or with increased external space, which would not be available when delivered as part of a large site. In addition, there are issues in terms of phasing, delivery and health and safety implications from such an approach. Therefore, given the commentary provided through the evidence base and the admitted need for more information to be gathered, we consider that a Policy in the form of SB1, requiring specific numbers of plots to be self-build on developments of various scales, is not justified by the evidence base. Such an unjustified approach may lead to unnecessary delays and uncertainty to the delivery of dwellings across the district in potentially requiring relatively large proportions of self and custom build plots which may not be taken up as such. It is therefore suggested that the policy be amended to make an allowance for small exception sites to be delivered on land adjacent to settlement boundaries, which has been done successfully in other Districts, such as South Northamptonshire (as was, now West Northamptonshire). If there is to be an allowance on large sites in addition to the above then we would suggest that this is set at up to 3% 10 provision to be negotiated on a case by case basis if there is a lower level of need identified. This will help to facilitate the speedy delivery of new dwellings across the borough and accounts for the identified need for the evidence base to be further developed. 9. Additional point for Policy SB1: “Proposals for single self or custom build sites immediately adjoining the confines of settlements will normally be permitted where they help to meet demand as demonstrated by Part 1 of the council’s Self and Custom Housebuilding Register and are compliant with other policies of this plan.” 10. Revised wording to Point ‘I’ of Policy SB1 is suggested below: “The Council will require applications for new housing development to make up to 5% of the plots available on site as serviced self or custom build plots, subject to negotiation based on evidence of identified local need.”

Support

Representation ID: 6480

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

1. We have reviewed the Council’s assessment of Land west and south of Shortstown (College Farm) and would like to add the following additional information to aid further understanding of the site’s potential for allocation (see overleaf). We also enclose an updated Vision Document and additional Technical Documents to those submitted in our previous response to the Reg 18 Issues and Options Consultation.
[See also Site Proforma for site: 1513]