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

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

4.1

Representation ID: 8708

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

Representation Summary:

5.1 We set out below an overview of the site HSL are promoting for residential development in
Wootton for up to 81 homes.
Site Location and Description
5.2 The site is generally rectangular shape, on the edge of the western built-up area of Wootton,
which lies south west of Bedford. The site, as identified by the red line boundary, covers
approximately 6.5 hectares (ha) or 16 acres.
5.3 The northern edge of the site is defined by Hall End Road (also National Cycle Route 51) and the
John Bunyan Trail. There is a field access gate to the northeast corner of the site. From this
direction, the settlement of Wootton has recently been expanded towards the site with the
construction of 58 dwellings (Ref: 14/02939/MAF) (Allocation AD2) and is a prominent feature. An
allocation for a school extension is also located north east of the site on the opposite side of Hall
End Road and is yet to be implemented and extends the settlement edge outwards.
5.4 The eastern boundary runs alongside an unnamed road that provides access to Wootton Upper
School and commercial/ farm premises. The southern boundary is contiguous with Wootton
Wood, an area of ancient and semi-natural woodland. The western boundary is shared with an
adjacent field, laid to pasture. These boundaries are all formed from native hedgerow with a
combination of post and rail or post and wire fencing within.
Sustainable and Suitable Location
5.5 The village centre of Wootton is located approximately 900 metres to the east of the site. The
village benefits from many amenities including local convenience stores, pubs and restaurants,
several churches, a petrol station, pharmacy, public library and football club. The wider parts of
the village contain community services such as the village hall, memorial hall, play areas, skate
park and tennis courts.
5.6 In terms of transport links, bus services serve Wootton and can be accessed within a short walk of
the site. These services provide regular daily services to destinations such as Bedford, Milton
Keynes and other local villages, providing residents with the opportunity to access a wide range
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of employment, shopping, leisure and cultural opportunities without having to rely upon the
private car. The site location therefore would accord with NPPF §109.
5.7 The Environment Agency Flood Maps show the appraisal site lies entirely within Flood Zone 1
indicating it has a low probability of flooding and is suitable for residential uses.
5.8 The village of Wootton has a historic character, with buildings and monuments dating from as
early as the 14th Century. Wootton Church End Conservation Area is located approximately 250
metres to the east of the appraisal site and encompasses the Grade I listed Church of St. Mary
and several other listed buildings. These heritage assets are separated from the site by Wootton
Upper School and so development of the site would not have a negative impact upon their
setting. The westernmost part of the site is within an Archaeological Interest Site. The LPA also
agreed in the committee report (see EP4).
The Proposed Development
5.9 This proposal submitted to the LPA sought outline planning permission for the construction of up
to 81 dwellings with access. The final layout, scale, landscaping and appearance would be the
subject of a reserved matters application. The proposed illustrative site layout and Design and
Access Statement submitted with the application shows how the dwellings could be comfortably
accommodated on the site along with open space and the conserved and managed meadow.
These are enclosed as Appendix EP2.
5.10 All of the proposed dwellings within the site would be served by a single access road which would
be taken from Hall End Road. The main internal access road is shown and the precise details
would form part of the reserved matters application. Pedestrian and cycle connectivity can be
explored at the reserved matters stage.
5.11 The TA states that the proposed site is situated approximately 950m west of Wootton village
centre, and coupled with the site’s proximity to frequently serviced bus stops, cycle routes and
viability to access the nearest rail station, accessibility from the site is considered to be of a good
standard with opportunities to promote sustainable travel from the site. A Travel Plan was also
submitted with the application to help promote more sustainable choices of travel.
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The Application and Appeal
5.12 Following their consideration of the proposal, the professional officers of the Council concluded
that planning permission should be granted and recommended this to the planning committee
on 28th October 2019. The application was deferred for a site visit and it was considered again on
the 25th November (Appendix EP3). The members of the Planning Committee voted to refuse the
application solely on highway grounds contrary to the advice of the planning and highway
officers.
5.13 The committee report sets out the detailed 22 planning considerations that were examined and
the planning officer was informed by statutory and non-statutory consultees and other
consultation letters during the determination period with the conclusion that permission should
be granted.
5.14 An appeal was submitted and determined. However, following a High Court challenge the
Inspector’s decision on the appeal dated 15 September 2020 was quashed and the Court has
ordered that the appeal be re-determined. The proposal has the following benefits:
• the delivery of open market housing to assist in boosting the supply of housing in
Bedford and can meet the 145 homes identified in the evidence base for the WNP as
well as borough housing needs;
• delivery of a medium sized site by HSL who have a proven track record of delivery
which would accord with the clear objective of the Government in paragraph 69 of
the Framework.
• the development accords with the spatial strategy as expressed in Policy 3S of the
Local Plan which identifies Wootton as a Key Service Centre which can accommodate
strategic residential development in a sustainable location.
• the proposed development helps to meet the objectives set out in the Bedford Green
Infrastructure Plan (2009) and the provision of open space to meet the needs of
existing and proposed residents and maintain a Green Corridor as required by saved
policy AD24.
• residential development at the site through the proposed scheme will result in an
improvement to the biodiversity value of the site and the net gain benefits to be
achieved and secured by the scheme outweigh the estimated loss of c. 3.1 hectares
of the neutral grassland at the CWS to achieve compliance with the paragraph 180(c)
of the Framework.
• the delivery of 30% affordable housing accords with Policy CP8 and would assist in
addressing the very significant and persistent shortfall in affordable housing delivery.
Paragraphs 4.23 to 4.30 of the Application Planning Statement confirm that there is a
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shortfall of 552 affordable homes since 2003 and the need going forward is 278
affordable homes per annum. There is also a need for 24 affordable homes as set out
in the Housing Needs Survey.
• highway works that will improve highway safety; and;
• a range of social and economic benefits and increase spending for local services and
facilities.
5.15 In the Site Assessment Pro-Formas June 2021 the subject site is Site ID 371. However the assessment
does not take account of the Officers Report to committee for the application and HSL sent an
email to the LPA on 2nd August 2021 setting out our comments which were noted in an email
dated 11th August 2021. The email exchange is Appendix EP4. The site is deliverable.
5.16 Our position is that the site can be delivered in full in the first five years of the plan period. This is
because the land is controlled by HSL, an experienced land promotion company complete with
its own housebuilding division. The site is controlled by a willing landowner, and there are no legal
or ownership issues that would prevent development. Appendix EP5 is a summary of the delivery
record of HSL in recent years. The Council can proceed in the confidence that the site is
deliverable and can be delivered in the first 5 years of the housing land supply and should be
allocated on that basis.
5.17 To conclude, with the need for further housing to meet the requirement to 2040 we request that
the site is proposed for allocation. We would welcome discussions with the LPA on what the site
can offer so that a deliverable site can be allocated to meet the housing needs in the first 5 years
of the plan period. HSL has a good track record in seeking to positively engage with communities
preparing neighbourhood plans as they have done with the Willington neighbourhood planning
group in Bedford on their land at Sandy Road. That NP is now at examination stage with HSL land
allocated for up to 50 dwellings to meet local needs alongside a range of community benefits
and HSL have a planning application pending. HSL undertook technical survey work to help
inform the NPG as they consulted with the community, which resulted in the allocation of the site
for development with the support of the local community and Parish Council.
5.18 This concludes our representations.

Object

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

3.1

Representation ID: 8709

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

Representation Summary:

3.1 The consultation paper sets out the result of the standard method which is 1,275 new homes per
annum between 2020 and 2040 which means that after taking account of 13,000 dwellings
committed, the new local plan will need to allocate land to provide a minimum of 12,500 new
dwellings.
3.2 Paragraph 7.3 of the Sustainability Appraisal Report states a higher growth figure should be
considered of LHN plus 10%. It states:
“In considering reasonable alternatives for the amount of housing growth to be
provided in the local plan, a lower figure than 12,500 dwellings (or no growth)
is not a realistic option because of the National Planning Policy Framework
requirement for local plans to meet assessed needs in accordance with the
standard method. However this is a minimum number and a higher growth
figure should be considered for the purposes of sustainability appraisal testing.
In the absence of any methodology for calculating a higher alternative figure,
a 10% uplift to the local housing need assessment is proposed. This would give
a requirement for 1,403 dwellings per year and a total of 28,060 dwellings over
the plan period. After commitments are deducted, 15,060 dwellings would
need to be allocated.”
3.3 We endorse this need for a buffer of at least 10%, but it has not been carried forward into the
consultation paper and the options put forward. Whilst we agree that there should be a minimum
10% flexibility, we consider there should be a buffer of 20% which is based on the Local Plans
Expert Group report to the Communities Secretary and to the Minister of Housing and Planning in
March 2016. The report recommends at paragraph 11.4 that the Framework should make clear
that local plans should be required to demonstrate a five year land supply but also focus on
ensuring a more effective supply of developable land for the medium to long term, plus make
provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing
requirement, as far as is consistent with the policies set out in the Framework.
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3.4 As the plan moves forward a buffer of 20% is essential given that some of the growth is reliant on
made neighbourhood plans and from experience across the county issues arise on the timing of
delivery on allocated sites. As we set out below it would also assist with the economic aims of the
Arc and deliver much needed affordable homes in Bedford to meet a significant need.
Stepped Requirements
3.5 The Plan suggests that a stepped requirement is being considered. It states:
“Whilst more detailed work will be needed to determine this, we will consider
whether, given the significant investment in infrastructure which would be
necessary to deliver development in the borough at scale, a stepped trajectory
approach may be appropriate for this plan. This could mean, for example, that
the delivery target could be kept at 970 per year until 2030 and then increased
to 1,580 dwellings per year to make up the rest of the plan requirement over
the remaining 10 years. By 2030 the Black Cat Junction improvements will be
complete, the East West Rail section through Bedford Borough will be complete
(including new and re-modelled stations) and sufficient lead-in time will have
been available for strategic projects to be planned in detail, enabling these
higher numbers to be achieved. The forward planning will include
arrangements for new sustainable travel links, with the intention that these are
available from day one in order to embed and promote sustainable travel
choices.”
3.6 We are not against a stepped requirement given the scale of development and the timing of
infrastructure being delivered. However, we consider that the Council must consider the potential
for small and medium sized sites which are not reliant on strategic infrastructure that can deliver
early in the plan period as sustainable extensions to towns and villages rather than pursuing the
stepped requirement at this stage. If a stepped requirement is required, then it should be based
on a trajectory that factors in early delivery on small and medium sized sites and larger allocations
which so not require that new infrastructure. The imperative should be to meet the housing needs
sooner and any stepped requirement should be for new settlements only if they form part of the
strategy going forward. At this stage the presumption should be to plan for 1,275 dwellings per
annum on adoption with monitoring provisions to allow for sites to be brought forward earlier if
delivery does not keep pace with requirement. Housing completions in the recent past suggest
that delivery of 1,275 is achievable in the market with 1,350 dwellings and 1,359 dwellings being
completed in 2017-18 and 2018-19 respectively.
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Should there be an uplift of Housing Requirement?
3.7 Paragraph 61 of the Framework states:
“To determine the minimum number of homes needed, strategic policies should
be informed by a local housing need assessment, conducted using the
standard method in national planning guidance – unless exceptional
circumstances justify an alternative approach which also reflects current and
future demographic trends and market signals. In addition to the local housing
need figure, any needs that cannot be met within neighbouring areas should
also be taken into account in establishing the amount of housing to be planned
for.”
3.8 Paragraph 2a-010 of the National Planning Practice Guidance (NPPG) states:
“When might it be appropriate to plan for a higher housing need figure than the
standard method indicates?
The government is committed to ensuring that more homes are built and
supports ambitious authorities who want to plan for growth. The standard
method for assessing local housing need provides a minimum starting point in
determining the number of homes needed in an area. It does not attempt to
predict the impact that future government policies, changing economic
circumstances or other factors might have on demographic behaviour.
Therefore, there will be circumstances where it is appropriate to consider
whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much
of the overall need can be accommodated (and then translated into a
housing requirement figure for the strategic policies in the plan). Circumstances
where this may be appropriate include, but are not limited to situations where
increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities are encouraged to make
as much use as possible of previously-developed or brownfield land, and
therefore cities and urban centres, not only those subject to the cities and
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urban centres uplift may strive to plan for more home. Authorities will need to
take this into account when considering whether it is appropriate to plan for a
higher level of need than the standard model suggests.”
3.9 As set out above, the minimum local housing need figure under the standard methodology is
1,275 new homes a year for the period 2020-2040. This is a total of 25,500 homes. After taking
account of the existing commitments, the Plan seeks to make provision for 12,500 homes over the
plan period to 2040. However, there should be a critical assessment of the supply undertaken to
ensure that the Submission Plan allocates sufficient land to meet the housing requirement and
that over-estimation of existing commitment delivery does not result in under-estimation of new
allocations. That assessment should be consulted upon prior to the Submission Plan being
prepared and consulted upon.
Arc Spatial Framework
3.10 As noted in paragraph 1.8 of the consultation document, in February 2021 the Government
published a policy paper entitled ‘Planning for sustainable growth in the Oxford-Cambridge Arc:
an introduction to the spatial framework’. They are now consulting on “Creating a vision for the
Oxford-Cambridge Arc” which ends on 12th October 2021. The consultation states that its
purpose is:
“Creating a Vision for the Oxford-Cambridge Arc’, sets out the government’s
first public consultation on the Oxford-Cambridge Arc Spatial Framework. We
are seeking views to help us create a vision for the Oxford-Cambridge Arc
Spatial Framework, and in doing so guide the future growth of the area to
2050.”
3.11 A number of points arise.
3.12 Paragraph 5.5 of the Arc Spatial Framework states:
5.5 We are concerned about the affordability and availability of housing in the
Arc, and what this will mean for the Arc’s communities, economy and
environment. Development of new homes is already happening in the Arc, but
in the main centres this has not kept up with need. We also know people are
being priced out of the area, increasing the need to make more polluting
journeys for work and leisure, and making home ownership less likely for many.
And we have heard concerns about the quality and sustainability of new
development.
3.13 Paragraph 5,7 states:
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5.7 We will also seek to set policies to enable:
• new development to come forward at the scale and speed needed, in
sustainable locations, with a focus on brownfield redevelopment;
• new development to support the recovery of nature, new green space that can
be accessed by all, resilience to climate change, and protection of highly valued
existing green space; and
• housing needs to be met in full, including much-needed affordable housing.
3.14 Paragraph 5.8 states:
“5.8 In parallel to the development of the Spatial Framework, the government
is also exploring options to speed up new housing and infrastructure
development in the Arc to help meet its ambitions, where evidence supports it.
This includes examining (and where appropriate, developing) the case for new
and/or expanded settlements in the Arc, including options informed by possible
East West Rail stations between Bedford and Cambridge and growth options
at Cambridge itself. The government will undertake additional Arc
consultations on any specific proposals for such options as appropriate. The
Spatial Framework will guide the future growth of the Arc to 2050, including on
the question of new housing and infrastructure and will, as part of its
development, take into consideration any significant new housing and
infrastructure coming forward to meet the Arc‘s ambition.”
3.15 It is clear that the Arc Spatial Framework will impact on Bedford and the scale of housing. It is too
early to give significant weight to the Arc Spatial Framework but as the emerging LP2040 is being
prepared in parallel with it and “shares many of the overarching principles relating to economic
growth and the natural environment”, then planning for an additional 20% of housing not only
provides the necessary flexibility required but will also provide homes to meet the economic
ambitions of the Arc Spatial Framework.
Affordable Homes
3.16 In the case of Bedford, paragraph 5.52 of the Local Housing Needs Assessment (LHNA) states that
the affordable needs is 691 dwellings per annum which “represents a substantial proportion of
the annual growth of 771 households per annum identified by the ONS 2018-based household
projections for the LHN period 2020-2030 (10-year variant, Figure 33)”1. It represents 54% of the
standard method figure.
1 Paragraph 5.53 of the LHNA
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3.17 The Standard Method does not assess the affordable housing needs in each LPA area as the
PPG2 confirms where it states:
“An affordability adjustment is applied as household growth on its own is
insufficient as an indicator of future housing need because:
household formation is constrained to the supply of available properties –
new households cannot form if there is nowhere for them to live; and
people may want to live in an area in which they do not reside currently, for
example to be near to work, but be unable to find appropriate
accommodation that they can afford.
The affordability adjustment is applied in order to ensure that the standard
method for assessing local housing need responds to price signals and is
consistent with the policy objective of significantly boosting the supply of
homes. The specific adjustment in this guidance is set at a level to ensure that
minimum annual housing need starts to address the affordability of homes.” (our
emphasis)
3.18 Paragraph: 010 Reference ID: 2a-010-20190220 states:
“Circumstances where this may be appropriate include, but are not limited to
situations where increases in housing need are likely to exceed past trends
because of:
• growth strategies for the area that are likely to be deliverable, for
example where funding is in place to promote and facilitate additional
growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase
in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring
authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing
delivery in an area, or previous assessments of need (such as a recentlyproduced
Strategic Housing Market Assessment) are significantly greater than
the outcome from the standard method. Authorities will need to take this into
account when considering whether it is appropriate to plan for a higher level of
need than the standard model suggests.” (our emphasis)
3.19 In the case of Bedford, Step 1 of the Standard Method is 980 dwellings per annum, with Step 2
increasing it to 1,275 dwellings. The affordability uplift is therefore 295 homes, which is significantly
2 Paragraph: 006 Reference ID: 2a-006-20190220
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below the 691 affordable homes in the LHNA. This is because the affordability ratio as a long-term
adjustment to house prices which can only be seen at the end of the plan period and is not
meeting those 691 households in need per annum now and throughout the plan period.
Therefore, we consider the Council should apply an uplift to meet affordable housing needs.
3.20 To conclude, our position is that the requirement should be treated as a minimum and a flexibility
percentage should be considered and in the order of 20%. This would give a reasonable degree
of security that should sites not deliver at the rates anticipated it will:
• Help ensure there is a robust five-year housing land supply;
• deliver a greater level of affordable housing in line with the LHNA;
• deliver homes to meet the economic ambition of the Arch Spatial Framework.

Object

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

3.10

Representation ID: 8710

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

Representation Summary:

4.2 Our first concern is that none of the four options deliver LHN+10% (15,060 dwellings). The Table in
7.14 of the draft SA shows that whilst two (Options 3a and 6) come closer to meeting that
requirement by delivering 14,480 dwellings it is still not meeting LHN+10%.
4.3 Our second concern is that new settlements form part of the strategy in 3 of the 4 options.
However, paragraph 2.6 of the Development Strategy Topic Paper states:
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“The results are reported in full in the Issues & Options Consultation - summary
and responses document and the key point was that the (brown) urban,
(yellow) A421 and (pink) rail-based growth development locations were the
most strongly supported and were twice as likely to be selected as suitable
locations for growth as dispersed and new settlement based growth.
4.4 Therefore, the results of the Issues and Options showed that the options for new settlements and
dispersed growth were most unpopular. Despite this, they formed part of 9 of the 13 options in
the draft SA, and 3 of 4 preferred options in the consultation paper. We question the merit in
undertaking consultation at the Issues and Options when at this early stage in LP2040 no
meaningful account has been given to the public responses.
4.5 The third is that paragraph 3.11 recognises that urban growth comes with deliverability issues and
significant investment and the level of development in each of the 4 options for the urban area
are a constant. In that context paragraph 3.6 is clear where it states that:
“the urban area and adjoining urban area perform the best, particularly
because of reducing carbon emissions and reducing travel”.
4.6 Therefore, development in and adjacent to urban areas performs best, yet paragraph 3.7 states:
“The worst performing component was the village related growth component.
It was likely to have a more negative effect than the other components,
particularly in relation to reducing carbon dioxide emissions, protecting water
resources, and reducing the need to travel and promoting sustainable modes
of travel. It was likely to have fewer positive effects than any of the other
components of growth.”
4.7 This conclusion must be read in the context that the Development Strategy Topic Paper which
has a Village Related Growth Option were all based on over 4,000 new homes ranging from 29%
to 47% of the total requirement. We do not advocate such a dispersal strategy but clearly
recommend that there should be growth at Key Service Villages and Rural Service Centres.
4.8 Therefore the options should have assessed a lower total percentage of the total requirement for
the Village Related Growth Option and also distinguished between Key Service Centres and
smaller villages, particularly for Wootton which lies close to Bedford town and close to Milton
Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options/s for
growth at Key Service Centres and Rural Service Centres should have been considered.
4.9 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain
parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note
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that these options state within the parish area rather than within or adjacent to parish settlement.
Paragraph 3.12 states that “development in parishes within the ‘Transport corridor”…. “will not
necessarily adjoin existing villages but could be at new locations between a
parish”. Development on the edge of existing settlements, and closer to services, are important
factors and we consider that the Plan needs to clarify development within a Parish should be
located adjacent to settlement boundaries of existing settlements as that is the most sustainable
option.
4.10 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the
achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be
located where it will enhance or maintain the vitality of rural communities. Planning
policies should identify opportunities for villages to grow and thrive, especially where
this will support local services. Where there are groups of smaller settlements,
development in one village may support services in a village nearby”. (our emphasis)
4.11 The fifth concern is that the LHN Assessment has been published but there has been no
assessment of housing market areas and commuting patterns to help inform strategy and
location of growth. Generally, Bedford borough has a strong geographical association with
Milton Keynes to the south-west and Central Bedfordshire to the south. This was recognised in the
SHMA (2018) where Bedford is within the Milton Keynes HMA and a commuting association with
Central Bedfordshire. This context should inform the location for new growth in a sustainable
way. Instead, the preferred options appear to focus growth with new settlements in the northeast
of the borough which the SHMA (2018) suggested was closer/within the Huntingdon HMA. We
are concerned that this approach may exacerbate unsustainable travel patterns particularly
where housing growth in more remote parts of the borough may force residents to take longer
journeys into Bedford town for jobs. Higher-order settlements closer to Bedford town should be
prioritised for housing growth in preference to more remote areas.
4.12 The sixth is that it is Intended that if the favoured strategy involves additional development in and
around villages, that parish councils will be asked to allocate land in accordance with
LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish
should be given a housing requirement as required by paragraph 66 of the Framework which
states:
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“66. Strategic policy-making authorities should establish a housing requirement
figure for their whole area, which shows the extent to which their identified
housing need (and any needs that cannot be met within neighbouring areas)
can be met over the plan period. Within this overall requirement, strategic
policies should also set out a housing requirement for designated
neighbourhood areas which reflects the overall strategy for the pattern and
scale of development and any relevant allocations. Once the strategic policies
have been adopted, these figures should not need retesting at the
neighbourhood plan examination, unless there has been a significant change
in circumstances that affects the requirement.” (our emphasis)
4.13 In light of the above we answer paragraph 3.17 which asks:
“If you think that there are other strategies we should be considering, please let
us know. These may be ones set out in the Development Strategy Topic Paper
or completely different alternatives.”
4.14 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban
growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include
urban growth.
4.15 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs)
and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated September
2018 although we note that there is a “review underway” and is one of the documents “not yet
available for comment, but will be finalised in order to support the plan for submission (2022)”. It
is important that this is the subject of consultation prior to the Submission Plan being published so
that any issues are considered prior to the spatial strategy evolving and reducing any potential
objections to a key part of LP2040.
4.16 Our specific interest is Wootton which is one of the 8 Key Service Centres. Policy 4S of the LP2030
sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169
dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000
dwellings should be located at Key Service Centres of which Wootton is one. The policy then
continues when it states:
“it will be necessary to identify sites to meet the following levels of development,
generally in and around defined Settlement Policy Area boundaries. Other than
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in Roxton, all sites will be allocated in Neighbourhood Development Plans. In
rural service centres allocations may exceed 50 dwellings where specific local
justification is set out in Neighbourhood Plans demonstrating that it would be
appropriate in terms of the scale, structure, form and character of the
settlement and the capacity of local infrastructure”
4.17 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there
is no specific requirement proposed for Wootton. This was explained in the 2017 version of the
LP2030 because Wootton had expanded in recent years. This should not be seen as further
development at Wootton not being appropriate; rather it confirms its suitability and capacity as
a location for growth. We consider that going forward Wootton should be identified as a location
for growth and given a specific requirement. This should be at least 500 dwellings as set out in
Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also
required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030
and form part of the committed 13,000 dwellings. These settlements could get less or as was the
case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have
a specific requirement of at least 500 dwellings especially due to its sustainability credentials and
its close relationship to Bedford town.
4.18 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of
Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that
development should not occur.”
4.19 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed
within site specific policies W3 to W6. Development in excess of this figure will
only be permitted where the proposal relates to a site within the SPA in
accordance with Policy W1.”
4.20 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton
Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale
of development in the WNDP, with 73% of respondents strongly
agreeing/agreeing with the allocation of sites sufficient to accommodate a
total of 145 residential units within the plan period, on the basis of need
ascertained by the Housing Needs Survey. This survey aimed to assess the need
of local people for either affordable housing or market housing in Wootton, at
the time when it was envisaged that the Bedford Borough Local Plan would
Bedford Local Plan 2040 – Draft Plan Strategy Options and Draft Policies Consultation
Representations for Hollins Strategic Land LLP
September 2021
14
cover the period to 2035. The quantum of development has been marginally
reduced in response to further resident feedback and to reflect the reduced
Local Plan period to 2030.”
4.21 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the
105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of
the existing residents of Wootton and it takes no account of the newly forming households and
the increase in households in the plan period across Bedford that the standard method
calculates. This is a particularly important point as the LP2040 consultation confirms that capacity
within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet
needs of which Wootton can play an important role. However, it demonstrates a continuing
need for new housing in Wootton which LP2040 should plan to meet.
4.22 To conclude, there should be changes to the Spatial Options and we propose:
• A greater level of housing to be planned for of LHN+20%;
• Greater recognition of the housing market areas and extensions to existing established
settlements with closer relationships to Bedford town should be prioritised;
• Clarity that extensions to Key Service Centres and other sustainable villages form part
of the strategy. This may be a refinement of the transport corridor criteria or a specific
requirement as set out in part iv and v of Policy 4S of LP2030; and,
• Each neighbourhood plan area to have a requirement set out. For Wootton we
consider at least 500 dwellings.

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