Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10201

Received: 29/07/2022

Respondent: Bloor Homes

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Local Plan spatial strategy is underpinned by the aspiration of the Borough Council to deliver growth to meet its needs “…at the heart of the Oxford-Cambridge Arc…” This decision has influenced the spatial strategy set out in the submission Plan.

However, the Government’s Levelling–up and Regeneration Bill in May 2022 omits any reference to the OxCam Arc. Furthermore, the Infrastructure & Projects Authority annual report on major projects 2021-22 confirms that the successful delivery of East West Rail Connection Stage 2 & 3 appears to be unachievable and the project may need re-scoping and/or its overall viability reassessed.

The Council’s strategy for a large proportion of the proposed growth is rail based. Should the rail infrastructure including rail stations are unachievable then the new settlement housing allocations at Little Barford and Kempston Hardwick would seem undeliverable.

Without the benefit of a firm commitment from the Government to fund the East West Rail Connection Stage 2 & 3, the Local Plan and its proposed spatial strategy (Policy DS2(S) Spatial Strategy) will not deliver the required housing growth, including affordable, to 2040. The Local Plan is therefore not justified as it fails the test of soundness as set out in paragraph 35 of the National Planning Policy Framework 2021.

Object

Representation ID: 10202

Received: 29/07/2022

Respondent: Bloor Homes

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Even if the spatial strategy survives, the stepped trajectory set out in Policy DS3(S) has not been fully justified. The proposed spatial strategy relies upon the delivery of strategic scale allocation sites particularly but not exclusively between 2030-40, with insufficient contingency provided in the form of small and medium sized sites which can be brought forward without a dependency upon the delivery of major infrastructure.

The Local Plan makes insufficient provision as part of the uplift, especially between 2030-40, for increasing supply, choice and flexibility, in terms of allocating small and medium sized sites to the south of Bedford. Given the recent changes outlined above, the allocation and delivery of these type of sites becomes of greater importance.

Pararaph 1.31 Table 1 (page 10) confirms that 17 Neighbourhood Plans (NPs) have been made within the Borough and collectively include allocations for 2,381 dwellings during the 2020-2040 period. A total of 14 of the 17 NPs include allocations for residential development with allocations ranging in size from 11 units to 500 units. This table confirms that:

• four of the 14 NPs which include housing allocations are located to the north of Bedford and comprise allocations of 500 dwellings. These strategic scale allocations account for 84% of the 2,381 dwellings;

• only 2 of the 14 NPs relate to settlements which are located south of Bedford; and

• only 105 dwellings (4.4% of total NP allocations) are located to the south of Bedford

The above points highlight that there is a distinctive geographical imbalance which would result in a lack of small and medium sized sites to the south of Bedford allocated via NPs. The reliance upon NP allocations is not sufficient to ensure adequate supply, choice and flexibility.