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

The purpose of this representation, prepared on behalf of Landcrest Developments Ltd (“Landcrest”), is to respond to the Local Plan 2040 strategy options, together with commenting on the initial assessment of the land East of Oakley Road, Bromham in the Site Proforma (Site ID 521).

It demonstrates that in weighing up the emerging strategy options, the optimum approach for meeting housing need within the Borough should involve further growth at existing villages in accordance with the emerging Settlement Hierarchy, and that this is critical if the increased housing requirement derived from the Standard Methodology is to be met. This factors in the current Local Plan 2030 strategy directing the majority of planned growth toward the urban area, therefore supporting a more diversified approach to meeting housing need in the Borough for the period through to 2040 is considered most appropriate and sustainable.

Additional comment is provided in response to the site assessment work being undertaken by the Council and summarised on the Pro forma, although it is acknowledged this remains ongoing. This information directly addresses the potential effects of the Land East of Oakley Road, Bromham, in the context of the sustainability objectives of the Site Selection Methodology 2021.

Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document confirms that the starting point for the housing requirement in the Local Plan 2040 is a minimum of 1,275 dwelling completions a year, that being the Local Housing Need (LHN) calculated using the Standard Method.

Accordingly, the Council will need to allocate land to enable a minimum of 25,500 dwellings to be delivered in the period up to 2040. That is to meet just the LHN and does not even take into account the emerging strategy for the Oxford to Cambridge Arc, and the government’s ambition to deliver substantial growth in the region to capitalise on its economic potential, which could lead to a further increase in the housing delivery required.

It is acknowledged that the timetable set out in Policy 1 of the Local Plan 2030 does not align with the timetable for the publication of the Arc Spatial Framework (ASF), a consequence of the programme imposed by Policy 1. As such, the preparation of the Local Plan 2040 will have to progress in advance of adoption of the ASF. Nonetheless, it would be reasonable and expected for the Council to proceed with the preparation of a Plan that fully acknowledges the need for transformational levels of growth due to the need arising in the period up to 2040, arising from its central location within the Arc. The document also acknowledges there will potentially be a need for a further early review of the Local Plan to response to the ASF where necessary.

Paragraph 3.5 of the consultation advises that the Council is considering the possibility of a stepped trajectory as part of the Local Plan 2040 with the justification being that a number of infrastructure projects, such as improvements to the Black Cat junction and the delivery of East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Landcrest strongly objects to this approach on the basis that this level of housing need exists now and is not currently being met due to the much lower housing requirement in the adopted Local Plan.

Indeed, the Council has consciously used the transitional arrangements when the 2012 Framework was first superseded by the 2018 version, to avoid having to deliver the increased housing need under the Standard Method through the Local Plan 2030, which is the principal reason this early review of the Plan has been required. A stepped trajectory would only delay further meeting a need that exists presently, with real consequences for those struggling to afford a suitable standard of living accommodation in the Borough.

Landcrest is of the view there already exists sustainable and appropriate options for growth within the Borough, that can suitably provide for the additional need arising as part of the LPR, thereby avoiding any requirement for a stepped trajectory. Indeed, paragraph 4.6 of the consultation document confirms that the sites put forward through the Call for Sites total far more homes than need to be allocated in the Plan.

Turning to the preferred emerging growth and spatial strategy options in Section 3 of the consultation, these all have a degree of focus along the A421 transport corridor and the Draft Plan Strategy Options presents a bias that A421 transport-related growth should comprise the greatest proportions of growth within the Borough, due to the very limited range of alternative options it presented.

Landcrest is concerned that the options have been dictated by the draft Sustainability Appraisal, which suggests that village-related components of growth perform more poorly – primarily due to the need to travel by private car from these locations, but has not addressed the opportunity that future development in such locations would provide a dual opportunity for meeting housing need in addition to enhancing the public transport infrastructure to capitalize on transport corridors such as the A428 or A6 thereby reducing the need for private transport and enhancing the dependability and quality of public transport services.

However, the focus on transport-related growth primarily has revolved around the future East-West Rail and A421 and overlooked other noteworthy transport corridors such as the A6 and A428 which provides good access to well-established Key Services Centres, such as Bromham. Bromham is indeed acknowledged as one of the most sustainable settlements outside of the Bedford urban area, owing in no small part to its connectivity with Bedford.

The DSTP does not appear to acknowledge in particular these additional transport corridors to their fullest potential, instead considering these options in the context of “new settlements” as opposed to further growth to existing, sustainable locations, such as Bromham.

At paragraphs 3.19 – 3.21, the DSTP suggests that the option 2 strategies are the most sustainable, followed by the options 3 strategies. Both include an element of urban focus, with the former placing an additional emphasis on transport corridors and the latter upon key/rural service centres and new settlements.

As aforementioned, there are options for growth along transport corridors other than the A421 that would still constitute as sustainable solutions and would be considered more sustainable options than that falling under option 3. Specifically, north-based transport growth as an option has been entirely overlooked and instead growth in such locations is strictly considered in the context of village growth.

Given that village growth itself would indicate a growth across a range of key and rural service centres, the “average” sustainability” impact of such a strategy overshadows the true cost of distributing development to the most sustainable settlements in the northern parts of the Borough well-connected to Bedford.

Pages 31 – 36 of the DSTP does identify potential highway constraints along the A6 to the north of Bedford, but this is in the context of new settlements at Twinwoods and Colworth and it appears an assessment of the impact solely in the context of expanding existing settlements was not undertaken which could potentially mitigate the capacity concerns. The Bedford Borough Transport Model makes clear that the impact from new settlements is based on an increase of c. 5,895 whereas village related growth in locations already well served by existing corridors would experience far lower, more appropriate, levels of growth if included as part of a spatial strategy – in line with the levels of growth distributed under Local Plan 2030.

It should also be noted that options 3b and / or 3c, which include an element of Landcrest’s preferred strategies for growth, already contain elements of the existing strategy from the Local Plan 2030. As such, and in light of potential concerns surrounding capacity of the A6 and indeed the A421 also – which in any event do not detract from the sustainability of Bromham, it being better related to the A428, a reasonable approach would be to diversify growth across the Borough by incorporating elements of sub-options 2 and sub-options 3. The diversification of a strategy in this manner would reduce the reliance on any one area of the Borough having to absorb and facilitate growth in the context of both the updated LHN and the incoming ASF.

It is unavoidable that this Council will need to examine more closely all options for sustainable growth as opposed to merely the best options for growth. Doing so would future-proof the Plan insomuch as is possible against the emerging requirements of the ASF at this current point in time to meet not only the minimum targets for housing growth until 2040 as per the LHN, but also the ASF in addition to boosting the supply of homes where possible in line with key objectives of national planning policy.

Other concerns raised within the DSTP in relation to the pros and cons of sub-option 3 growth (in terms of KSCs and RSCs) at paragraph 3.36 is that they would “support the creation of new businesses but with the proviso that this could lead in locational terms to a poorer relationship between where people live and work”.

In practical terms, this is a less of an issue than it ever has been in light of the Covid-19 pandemic. There is a strong desire from many to relocate to less intensified locations such as villages in the countryside given the massive increase in prominence in working from home in 2021. It is already apparent that consumer demand is leading to this being planned for in new developments, through the inclusion of home offices in dwellings and through the specification of technology such as broadband to facilitate it. Certainly, sub-options 3 do not detract from appropriate growth in the urban area and accordingly we should expect people to choose to settle where they consider is best for them in terms of where they live and where they work. This can only be achieved, however, if there is an appropriately diversified development strategy which provides plentiful options for growth across the Borough in differing locations

Taking the above together, therefore, Landcrest consider that the best approach for a development strategy for the period up to 2040 is one that genuinely champions the distribution of growth in locations that can appropriately support them in a sustainable fashion. This would require a diversified approach that incorporates true transport-based growth in and around the Bedford urban area together with growth at KSCs such as Bromham which remains the most sustainable settlement outside of Bedford proper. Indeed, it would provide a wider choice for future residents to live in rural locations given the rise of the working population that works from home, as well as unique opportunities for the continued revitalization of local economies at such locations. It would also ensure delivery of new housing that is needed now, avoiding the requirement for a stepped trajectory, which is not justified and would simply delay meeting a need that already exists.

Policy SB1 proposes a self-build and custom housing (SBCH) policy for new residential development proposals within the Borough which would be delivered as a fraction of the total number of units to be provided on site.

Landcrest is concerned that the inclusion of a policy with this specific kind of mechanism may have questionable success in delivering the appropriate levels of SBCH for the Borough’s citizens. Particularly, the policy is dependent on larger schemes in order to deliver sufficient levels of SBCH and indeed larger sites are well-known for their logistical difficulties in delivering units in a timely fashion as compared to smaller schemes. That aside, Landcrest would, in any case, question how much demand there would be for this type of housing as part of traditional volume house builder sites, and also raise the complications it inevitably creates around phasing, health and safety etc. There is then the question of whether appropriate numbers of SBCH can be delivered as and when needed during the plan period.

Furthermore, the figures required for contribution to SBCH on new schemes as per the tiers for contribution under Policy SB1 are on average lower than 10%. For schemes of 100+ this is by negotiation. Such low figures, and indeed uncertainty, for contributing to SBCH needs compounds on the ability of this Council to adequately provide SBCH in line with legal requirements.

Landcrest would support the inclusion of an alternate or additional policy for SBCH exception sites. These would function in effect similarly to rural exception sites and policies, for which there is already clear support for within the NPPF, but specifically address the need to provide sufficient levels of SBCH. The policy would be subject to of course appropriate criterion to prevent inappropriate development in inappropriate locations, but would nonetheless provide a unique opportunity and incentive for developers for bringing forward otherwise suitable sites for housing.