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

Object

Representation ID: 6625

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

The Draft Strategy Options were prepared ahead of the publication of the revised NPPF in July 2021, which introduced the requirement at Paragraph 22 for Local Plans which include new settlements or significant extensions to towns/villages, to be set within a vision which looks at least 30 years ahead. As the current aim is to plan to 2040, this requirement will not currently be met.
This policy requirement will apply to the Bedford Borough Local Plan review, given the options presented and it is therefore likely that the Council will need to undertake additional work to establish a longer-term vision within which the policies for the Local Plan 2040 can be set.
As is discussed in response to other aspects of the plan, given the constraints to development around the immediate edge of Bedford, combined with the level of development that will need to be accommodated in the Borough, the Council are rightly giving due consideration to a new settlement as part of the development strategy. This is likely to be combined with significant growth in the A421 corridor and around the southern stations. Given the key role that this corridor to the south of Bedford up to the A1 in the east will play in the period to 2040 and beyond, it is suggested that further visioning work may need to be undertaken specifically for this area to meet the requirements of the NPPF.
The revised Denybrook Vision Document accompanying these representations sets out the vision for delivery of the Denybrook proposal both up to and beyond the current plan review period of 2040. The vision is then underpinned in highway and access terms by the accompanying technical representations which sets out the approach to delivery up to and beyond the currently proposed Local Plan Review period to 2040.

Object

Representation ID: 6626

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

The Strategy Options consultation document sets out that the standard method figure for Bedford Borough is 1,275 dwellings per year or 25,500 dwellings in total. It goes on to state that after existing commitments are taken into account, the Local Plan 2040 needs to allocate land to provide an additional 12,500 new dwellings over the plan period. There are a number of considerations which suggest this figure should be higher.
Firstly, it needs to be recognised that the 25,500-home requirement is the minimum number of homes that need to be delivered over the plan period. To ensure this figure is delivered, there Local Plan will need to build in suitable flexibility and contingency in the land supply by way of over allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays.
An additional allowance of around 10%, which would equate to a further 2,550 homes, would be the minimum contingency that should be built into the land supply – the figure should be higher if there is a greater risk of slippage in the delivery of sites.
There is reference to choice and flexibility in paragraph 1.50 of the consultation document. However this simply relates to potential neighbourhood plans which should not be relied upon to deliver the Council’s housing requirements. Such neighbourhood plans are an unknown and it is essential that the Local Plan plans for in excess of the required 25,500 to ensure the minimum number of homes are delivered.
Secondly, it is unclear whether the allocations in emerging Neighbourhood Plans are included as commitments. There are a number of Neighbourhood Plans at examination with allocations to satisfy the requirements of the adopted Local Plan 2030. There is a chance that some of these Neighbourhood Plans will not be made which could add to the need for the Local Plan to plan for further additional growth – if two to be made are not, this would add 1,000 homes to the requirement, which may have implications for the proposed strategy.
Finally, the Local Plan should give greater consideration to the emerging aspirations for the Oxford to Cambridge Arc, where Bedford Borough sits in a key central area. To realise the economic benefits of the Arc it is likely that additional housing will be required above the Local Housing Need figure to support a growing working age population. Given Bedford’s central position with good access to both Milton Keynes and Cambridge, it is likely to be a key area of demand for housing. Therefore, it is suggested that the implications of this demand are explored further which may lead to the need for additional housing to be planned to avoid negative impacts on existing communities, including worsening affordability.
As set out in the accompanying Vision Document, Denybrook has the opportunity to deliver up to 4,000 new homes to 2040 and approximately 7,000 new homes and the associated infrastructure such and schools, health care and local centres in both cases.

Support

Representation ID: 6627

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

Taylor Wimpey are generally supportive of the Council’s propose approach to allocation land for development, with the options focusing generally on Bedford, the transport corridors to the south of the town and the proposal for a new settlement(s).
The Development Strategy Topic Paper indicates that the A421 corridor, urban area and rail-based options set out at the Issues and Options stage were the most popular options for those who commented.
We also note that the SA process showed that the A421 corridor and rail-based growth options performed favorably against the new settlement options with only urban growth and urban edge growth performing better in sustainability terms. However, in general, the SA does not appear to indicate that there is a significant amount of difference in the sustainability of the options under consideration.
We consider that greater clarity is needed as to the realism of deliverability of a number of the strategy options still under consideration. Whilst we agree that the final strategy is likely to be a combination of each of the options, there appear to be a number of difficulties in delivering the numbers assumed from each area. Indeed, it is noted that at paragraph 3.11 of the Housing Topic Paper that the targets for the urban area are ‘deliberately ambitious’, which suggests that the 3,000 homes assumed for Bedford town may not be realistic.
Whilst growth in and around the urban area is clearly a sustainable option, particularly given Bedford is the main centre for services and facilities in the area, there are a number of constraints around the town (landscape, flood plain, potential coalescence to name three) which mean that development will be difficult in the area.
There may be small scale opportunities in the town, but the delivery of 1,500 homes will be a challenge as will finding suitable sites for a further 1,500 homes on the edge of Bedford – which is effectively limited to the north/north east of the town.
These constraints increase the importance of looking closely at the deliverability of the other options including the transport corridors and opportunities for new settlements.
Whilst we are supportive of the role of the A421 is supporting growth and development and considered that the quantum of growth in the corridor is realistic moving forward. However, we do have some concern regarding the ambition for up to 7,500 (alongside up to 80 hectares of employment land in the ‘rail based growth parishes’ to the south of Bedford, as is proposed in option 2a.
This level of residential growth does not appear to be realistic when consideration is given to the sites submitted in the area through the call for sites, which have been promoted for employment use. Even the lower level of growth in this area (5,500 homes) is likely to be undeliverable.
Given there are also capacity constraints with the delivery of significant development in and around Bedford town, this indicates that the options which require a new settlement should be looked at favorably. Whilst we suggest that the two settlement option (2c), which is at the expense of allocations in and around some of the existing settlements, is unlikely to be realistic given the impact this would have on the short term delivery of housing in the area, a single new settlement should form an integral part of the strategy.
A new settlement at Denybrook would complement the allocation of a range of small/medium sized sites around Bedford and other settlements in the A421 corridor, that would help to meet immediate housing need. Whilst we would expect a new settlement option to be built out by the end of the plan period (if not shortly afterwards), depending on its final capacity, such an allocation would fit with the revised expectations in the NPPF that allocations within an area with strategic scale growth should be set within a longer-term vision for the area. Therefore, whilst the delivery of a new settlement may extend beyond 2040, it is important that the expectations are set out now to allow wider plans – both short term and in the longer term to factor in the contribution it will make to housing and employment land supply, and on the infrastructure of the area.
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Object

Representation ID: 6628

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

It is noted that at this stage the proformas for each of the sites contain very limited information to allow a proper assessment and comparison of the sites. It is noted that the consultation document states at paragraph 4.3 that more information will be added when it becomes available.
It is essential that the Council commit to undertaking additional, more detailed assessment work to allow a robust assessment of the sites on a comparable basis.
This is particularly important for the new settlements where a significant amount of further work in additional to the high level assessments undertaken to date will need to be undertaken to understand their suitability for development and any mitigation that will be required if they are to form part of the strategy moving forward.
In this regard, Taylor Wimpey are keen to work closely with the Council on exploring further the exiting opportunity that is available at Denybrook and developing the evidence base to underpin its allocation in the Local Plan.

Support

Representation ID: 6629

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

Taylor Wimpey generally support the council recognising the climate change agenda and the need to make a positive change though the way development is delivered and designed. A new settlement proposal, such as Denybrook, provides the opportunity to create a self-sustaining community through the creation of walkable neighbourhoods where all such day to day amenities are delivered via the 15-minute neighbourhood principles. This can also be supported by the promotion of active travel corridors and the internalisation of job creation to reduce the reliance of the motor vehicle.
The accompanying Vision Document sets how this can be achieved and how Denybrook can make a positive contribution in the council’s agenda to become a net zero authority.

Object

Representation ID: 6630

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

Accompanying these representations are two notes prepared by TPA on behalf of Taylor Wimpey. Please refer to these documents to see Taylor Wimpey comments and position on these matters.