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

Object

Representation ID: 6356

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

The standard method figure for Bedford Borough is set out in Chapter 3 of the consultation document at 1,275 dwellings per year (25,500 dwellings in total). With existing commitments taken into account, the plan will therefore need to allocate land to provide a minimum on 12,500 new dwellings.
However, it has not been made clear in what has been published whether the existing commitments that have been identified include the emerging Neighbourhood Plan allocations
(which are intended to satisfy the requirements of adopted Local Plan policy 4S). Should these be taken into account as commitments, the minimum level of growth that will need to be delivered in the Local Plan may need to increase should any of the emerging Neighbourhood Plans fail to come forward, fail at examination or not pass referendum.
It should also be stressed that the 25,500 housing requirement identified as part of the standard methodology is the minimum number of homes that need to be delivered over the plan period for the Bedford Local Plan 2040. There will need to be an additional allowance made in the allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays in order to ensure that this figure is delivered.
It is common practice to make an additional allowance of 10%, equating to land for 2,550 homes over the minimum, in order to ensure that there is an appropriate contingency in place for under delivery. At paragraph 1.50 of the published Draft Strategy Options Document there is reference to ‘choice and flexibility’, however this comment is only made in relation to the potential additional growth that could come forward via neighbourhood plans. As a result of this proposed approach, the amount of new homes delivered through neighbourhood plans is an unknown and therefore it is important to ensure the delivery of the minimum number of homes planned for in the Local Plan is in excess of the required 25,500 to allow for this.
Taylor Wimpey therefore consider that 28,050 homes (25,500 +10%) should be planned for rather than the 25,500 currently considered in each of the options that have been identified. This approach would also help to ensure that the requirements of paragraph 68 of the NPPF, which stipulates that council’s should plan for a deliverable supply of land for years 1-5 of the plan plus an appropriate buffer to be identified, will be met.

Housing Requirement
Additional land should be identified to provide a buffer beyond the base number identified in the standard methodology in order to create flexibility and contingency in the supply.

Where Neighborhood Plans have not come forward or have failed at examination, and therefore no development sites have been allocated as is required under the adopted Local Plan, the Local plan should allocate sites to meet this need.

Object

Representation ID: 6357

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Bedford Borough sits in a key central area of the Oxford to Cambridge Arc and as such the Council will need to ensure that the level of growth that is planned for is in line with wider aspirations for the area. For the economic benefits of the Arc are to be realised, it is likely that additional housing will be required to support a growing working age population. Should this housing not come forward alongside the anticipated economic growth, it may have knock on impacts for existing residents in terms of increased house prices and worsening affordability.
Therefore, Taylor Wimpey stress the need to plan for flexibility and contingency and for the broader long-term economic aspirations for growth in the area when setting the housing requirement for Bedford Borough.

The Government’s wider economic growth aspirations for the Oxford to Cambridge Arc and the potential uplift in housing need that this will result in should be thoroughly considered, and it is important to note in relation to this that the standard methodology housing requirement is a minimum figure.

Support

Representation ID: 6358

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey generally support the approach advocated in the Draft Strategy Options document which directs future growth being towards transport corridors, particularly the A421. The A421 is well related to Bedford as the area’s main service centre, is a key route through the Borough and connects Bedford Borough to the key centres of Milton Keynes and Cambridge.
The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for commenters were the A421 corridor, the urban area and rail-based locations.
The A421 corridor and rail-based growth options are also said to have performed favorably against the new settlement options as part of the Sustainability Appraisal process, with only urban growth and urban edge growth, unsurprisingly, performing better in sustainability terms.

Object

Representation ID: 6359

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey do not agree that option 2c, which intends to focus development on the urban area and create two new settlements in the east of the Borough, is a realistic option. Whilst acknowledging that there is scope for the inclusion of one new settlement in the emerging Local Plan, to include two new settlements at the expense of other options would be unsustainable and a highly risky strategy to deliver much needed homes in the short to medium term, particularly given the new NPPF paragraph 22 requirement for the strategy to be set within a 30 year, long-term vision.
Taylor Wimpey agrees that growth in and around the urban area is a sustainable option. However, given that Bedford is the main economic centre in the area and a built-up urban area, Taylor Wimpey question whether the 3,000 homes and an additional 51 hectares of employment land can be delivered in this location over the plan period. Indeed, there may be small scale opportunities for growth in the town, however, it will be a challenge to find land for an additional 1,500 homes over the plan period. In a similar vein, finding suitable sites for 1,500 home on the edge of Bedford will be a challenge. Development on the edge of Bedford is realistically limited to the north/north east of the town due to landscape, topography, flood plain constraints as well as the close proximity of the boundary of Bedford town to smaller settlements.
As a result of the above constraints in directing growth towards new settlements and the urban area, it is important to look closely at the development options for the A421 corridor and rail corridors, and establish these as an integral part of any future development strategy.

Object

Representation ID: 6360

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey is encouraged to see that growth in the A421 corridor is included within three of the four options presented in the paper (for which commentary on the fourth option which focuses growth on two new settlements is discussed in more detail below), as well as rail-based growth being included in all four options identified.
However, Taylor Wimpey do still have some outstanding concerns about the detail behind Options 2a, 2b and 2d (the three options which contain growth in the A421 corridor); this primarily focuses on the level of growth directed to the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period and the deliverability of 5,500-7,000 homes in the rail corridor. These are discussed in more detail below.

Rail related growth
Whilst in principle Taylor Wimpey support growth in the rail corridor to the south of Bedford, there are a number of key matters in relation to the approach taken to this growth by the Council which requires further consideration.
Firstly, it is unclear how it will be possible to deliver the scale of growth proposed by the Council (50% of the housing requirement). An extract of the Call for Sites map has been overlaid with the rail related growth area identified in Options 2a - 2d and is included at Figure 1 below. As can be seen from Figure 1, there are a limited number of sites which have been put forward to the Council as being available in this area – with the majority of the large sites that have been put forward having been identified for potential employment use.
Secondly, the justification for the extent of the catchment area for these rail station locations has not been properly elaborated on. Additional opportunities may be available on the periphery of this area, in settlements such as Wilstead, which could contribute to delivery (which is currently classed as being in the A421 corridor). Wilstead is a settlement with a range of services and is in easy commuting distance of Wixams including via sustainable modes of transport such as cycling. It is in close enough proximity to Wixams that a local gap is currently included within adopted policy in order to separate the two settlements.
Without expanding the catchment area for the rail-related growth, combined with concerns about the ability to delivery 3,000 in and around the urban area, further emphasis should be placed on the role of land in the A421 corridor within the development strategy, with a particular focus on those settlements, such as Wilstead, which can be classed as lying in both.

Delivery in New Settlements
Taylor Wimpey recognise that there is a role for a new settlement as part of the development strategy,
As previously noted, the NPPF 2021 includes the new provision that new settlements will need to present a long term, 30 year vision and a new settlement will therefore present the opportunity to deliver new homes later in the Local Plan period.
However, there will be a significant lead in time with any new settlement, with completions not likely to be realised until well into the Local Plan period. An over reliance on new settlements to meet housing need would therefore be a detriment to meeting housing requirements in the short to medium term, particularly when there appear to be sufficient suitable and deliverable sites available to meet the need in a timely manner. This issue would then be further exacerbated in a strategy which relies on the creation of two new settlements.
If a new settlement is to be included in the strategy, which would be a reasonable approach given the challenges in the area, the number of homes to be delivered in the plan period should be realistic. It is noted that the options currently assume the completion of either settlement option within the plan period. This is not a realistic assumption given the stage the plan is at and the lead in time on matters such as land assembly, planning and infrastructure delivery.
The Council will need to ensure that the residual requirement that has been identified above in the earlier plan period is picked up through the development strategy. Given the constraints with other elements of the strategy, emphasis should be placed on the importance of the A421 corridor to deliver growth and the wider catchment area around key rail locations and the approach taken in Option 2c reconsidered.

The Apportionment to the Southern Parishes
Aside from option 2c (the two-settlement option), which has been addressed above, each of the options include an element of growth in the A421 transport corridor. This level of growth varies from 1,500 dwellings in option 2b and 2d to 2,000 dwellings in option 2a. Taylor Wimpey consider that these options significantly downplay the potential of the area to deliver additional housing numbers and note that there is a need to rely on sites in this location given the issues identified above.
Figure 1(below), an extract of the Call For Sites map, identifies that there are a number Key Service Centres located within this corridor such as Wilstead (where Taylor Wimpey are promoting land), as well as Wootton, Wixams, Shortstown and Great Barford. These settlements are highly sustainable and have the ability to provide additional sites beyond the housing apportionment currently stated. In the adopted Local Plan, Key Service Centres were seen as suitable for 500 dwellings, and indeed higher level of growth in some locations were assessed early in the process as being appropriate.
There are also other larger settlements in the corridor that could take growth, such as Willington (where Taylor Wimpey have land interest) which have been excluded from the A421 Corridor, despite being in the same transport corridor as the likes of Wootton, Wilstead, Cotton End and Shortstown (which are included in three of the options). From a review of the evidence it is not clear why this is the case.
No justification has been given as to why the options limit potential growth to 2,000 dwellings and therefore this comes across as an arbitrary number that is not underpinned by the necessary evidence. This is particularly noticeable when the issues raised above with the other options are taken into account.
A finer grain assessment of site availability and suitability should be undertaken to inform the development strategy. Taylor Wimpey consider that this will identify a greater level of potential for growth in the A421 corridor.
The whole of the A421 corridor should be looked at as one moving forward, with no arbitrary distinction between the eastern and southern parishes. This will allow a proper review of all settlements and sites on a comparable basis and avoid suitable sites being missed out.

Neighbourhood Plans
It is noted that there are a number of emerging Neighbourhood Plans which seek to address the housing need requirements identified for certain villages in Policy 4S of the Local Plan 2030.
If a Neighbourhood Plan is made ahead of the adoption of the Local Plan 2040, this should not influence the strategy included in the emerging plan.
The emerging Local Plan should revisit the level of growth apportioned to each settlement as part of a review of the growth strategy for the area and allocations should be made in settlements, such as Wilstead and Willington, in order to ensure that the housing needs for Bedford Borough are met.

Location for Growth
− There is a concern that the assumed delivery of the settlement options may be being overstated.
● The assumed capacity of the urban area/urban fringe and the rail focused options to deliver the stated level of development should be reviewed.
● The two-settlement option is not a robust or sustainable approach to meeting housing need.
− A focus for growth within the A421 corridor is supported by Taylor Wimpey and it is asserted that there is a need to increase the level of development focused along the A421 corridor due to the constraints which effect other options. It is noted that the Council have created an unjustified split in the parishes along the A421 corridor and that a more appropriate approach would be to look at the area as a whole and identify the most appropriate available sites.

Object

Representation ID: 6361

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Whilst Taylor Wimpey have not reviewed all of the site assessments published by the Council, the general conclusions drawn and the approach to assessing the suitability of sites for development is concerning.
The site assessment forms have not been underpinned by a detailed review of the evidence available to the Council. Taylor Wimpey’s site at Wilstead (referred to as ID819) has previously been promoted for development and a planning application has been progressed (ref:
20/01666/MAO). However, none of the technical work or statutory consultee responses to this application are referenced in the form. For example, the Heritage Team and the Ecology Team both responded to the application, but the forms state that there is ‘uncertain or insufficient information’ or that there is the potential to cause harm. Another illustration of this is Environmental Health; the site assessment form states ‘A6 road noise’, however as part of the recent application Environmental Health responded that the proposed mitigation measures included as part of the proposal were acceptable and therefore no objection was offered in relation to the application. Similarly, Taylor Wimpey’s site at Willington (referred to as ID855) has previously been promoted for development and a detailed Vision Document was submitted providing a significant amount of evidence in relation to the site opportunities and constraints. None of this background information appears to have informed the site assessment forms published online.
The site assessment forms also lack any detailed assessment. For example, in relation to Wilstead, at 9a in the assessment form the Council have stated that ‘The site is not previously developed land as defined in the NPPF’. This is a simplistic response which does not properly represent the planning history of this site. The site was previously used as a camp site associated with Briar Bank Park to the north, and the remains of an amenity block building can be seen at the centre of the site, along with the access road and associated underground drainage system. The site is not a pure green field site. Linked to this, 9b which focuses on best and most versatile agricultural land, states that ‘The classification of the site is not known or it is not clear whether is classified as grade 3a or 3b’. The site is not used as agricultural land and has not been used as such for a long time due to the historic camping use; significant work would be required to bring this site back into agricultural use. Before any site selection process is undertaken, each site should be properly reviewed by members of the policy team.
The site assessment forms do not allow for a consideration of the potential planning benefits that sites may offer. For example, in relation to Willington, it is proposed that 10ha of this site is delivered as public open space and this should be given significant weight in the decision making process.
Moving forward, the assessment of sites should be more thorough and refer to the evidence base used and referenced in submitted representations to justify decisions. Other plans have been brought down in recent years because of a lack of transparency in the assessment process which was considered to undermine the conclusions made. All sites should be assessed on a fair and equitable basis, utilising the available evidence, which does not currently appear to be the case.

Site Assessment Process
The site assessment process needs to be made robust through the use of all available evidence when considering of site suitability.