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

Object

Representation ID: 3557

Received: 11/08/2021

Respondent: Brown & Co Barfords

Growth and spatial strategy options:
Paragraph 3.5 on page 16 of the Local Plan 2040 – Draft Plan Strategy Options and Draft Policies
Consultation sets out a stepped trajectory with a delivery target of 970 dwellings per year until 2030 and
this is proposed to increase to 1,580 dwelling per year to make up the rest of the plan requirement over the
remaining 10 years. Leaving 1580 dwellings per year from 2030 onwards is a significant number of
dwellings to achieve even with the Black Cat junction improvement, and East West rail anticipated to be
completed and consider this to be undeliverable.

Paragraph 68 of the NPPF 2021 sets out through strategic policy making planning policies should identify
a supply of specific, deliverable sites for years one to five of the plan period; and specific, developable sites
or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan. Therefore, a
more reasonable stepped trajectory should be applied to ensure an effective and sound plan as set out in
policy 35 of the National Planning Policy Framework (NPPF) 2021.

Object

Representation ID: 3558

Received: 11/08/2021

Respondent: Brown & Co Barfords

Housing development on small sites:
Paragraph 3.26 on page 25 sets out in relation to housing development on small sites which is required by the National Planning Policy Framework to deliver 10% of its housing requirement on small sites (sites no
larger than one hectare) it is agreed this will create diversity in the type of site that will be developed across
the borough and maintain the Council’s 5-year housing land supply. It is acknowledged by the Council that
larger sites can have a significant lead in time before development commences.

Object

Representation ID: 3559

Received: 11/08/2021

Respondent: Brown & Co Barfords

Paragraph 3.27, page 25 sets out at 31 March 2020, 24.1% of housing supply was on small sites which
notes the importance of small sites. Paragraph 3.28 sets out the Local Plan to 2040 will not allocate small
sites. However, paragraph 68 of the NPPF 2021 sets out small and medium sized sites can make an
important contribution to meeting the housing requirement of an area and are often built-out relatively
quickly. To promote the development of a good mix of sites local planning authorities should identify,
through the development plan land to accommodate at least 10% of their housing requirement on sites no
larger than on hectare and therefore there is a requirement to allocate small sites with windfall sites in
addition.
The Local Plan should provide a range of housing sites, both small and large scale to enable flexibility and
competition in the market. Therefore, small sites should be allocated as part of the Local Plan to 2040 such
as the sites at Pertenhall as without small sites the Plan would not be consistent with national policy and
therefore cannot be deemed sound as set out in paragraph 35 of the NPPF 2021.

Support

Representation ID: 3561

Received: 11/08/2021

Respondent: Brown & Co Barfords

Self-build and custom housebuilding:
The sites put forward also provide the opportunity for self-build and custom build homes. Paragraph 7.11
on page 42 rightly sets out in determining planning applications will take into account demand shown by
both parts of the register.

Policy SB1 – Self-build and custom housebuilding on page 43 and 44 sets out a strategy to incorporate
self-build homes within sites dependent on the number of homes created. Clients who wish to undertake
self-build and custom housebuilding seek larger plots of land which are not significantly constrained by
neighbouring dwellings. Therefore, allocating these types of houses within developments means large land
values are required for the plots which will result in the marketing of the plots and ultimately market
dwellings, therefore leaving a shortfall in self-build plots. It is considered a better solution to secure these
types of dwellings would be to allocate self-build sites on the edge of villages such as the sites put forward
on the land at Pertenhall where a Design Code can set out parameters to achieve well-designed homes
and secure successful self-build and custom housebuilding.

Object

Representation ID: 3562

Received: 11/08/2021

Respondent: Brown & Co Barfords

Development Strategy Topic Paper June 2021
Paragraph 3.7 on page 6 sets out village related growth is likely to have a more negative effect than the
other options for growth in relation to reducing carbon dioxide emissions, protecting water resources, and
reducing the need to travel and promoting sustainable modes of travel.

The National Planning Policy Framework 2021 sets out in paragraph 78 that 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 nearby villages. The sites at Pertenhall have good access to Kimbolton Road
(B660) and development in this location will support St Peter’s Church and the Village Hall, it will also
support the Primary School in the village of Riseley which is only four miles away.

Therefore, it is considered there should be development in and around the urban area, A421 transport
corridors, rail-based growth, and growth around villages, particularly those without a Neighborhood Plan
such as Pertenhall to enable the village to grow and thrive.

Support

Representation ID: 6400

Received: 13/09/2021

Respondent: Brown & Co Barfords

Agent: Brown & Co Barfords

Bedford holds a significant position within the OxCambs Arc. Given the planned population growth to 2040, together with the proposed East West Rail and upgrade to the A428 from the Black Cat Roundabout, both Wyboston and Little Barford (Option 2c) appear to rational locations for the location of a sustainable new settlement and employment allocation. Such locations are supported as they will provide suitable access to the key transport nodes centered around the convergence of the A1/ A428 and also East West Rail and the existing East Coast Mainline.