Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9509

Received: 27/07/2022

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

1.1. CPC considers Policy DS3(S) Amount and timing of housing growth to be unsound as it is unjustified and ineffective as set out below.
Oxford-Cambridge ‘Joint Declaration’
1.2. Policy DS3(S) states that the Local Plan will make provision for a ‘minimum of 27,100 dwellings’ between 2020 and 2040. This equates to an average of 1,355 dwellings over the plan period. This is an increase of 385 dwellings on average per annum (a 40% increase) compared with the adopted Local Plan 2030 which has a requirement of 14,550 dwellings between 2015-2030 (970 dwellings per annum average).
1.3. Whilst paragraph 4.7 of the Local Plan explains that the housing requirement is a result of the Council following Government policy and guidance on housing requirements namely the Standard Method, the Council first states in the Local Plan that the 40% increase in housing is a result of the ‘Oxford-Cambridge Joint Declaration’1:
“…the Council will make provision for significantly more homes as described in the Arc joint declaration. It will do this as a result of government’s new standard method for calculating housing need, which it will deliver in full, and which results in an uplift of 40% when compared to the locally-calculated housing growth planned for in the Local Plan 2030, and by allocating sites that will continue to build out beyond the 2040 plan end date.”
1.4. However, there have been a number of rumours that the Arc may no longer be going ahead. This could also be evidenced by its absence in the Levelling Up and Regeneration White Paper2 and the Levelling Up and Regeneration Bill.
1.5. There are a number of local media and trade press stories on this including an article in the Cambridge Independent (27th April 2022)4 which states:
1 The Oxford-Cambridge Arc – Government ambition and joint declaration between Government and local
partners (2019)
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/799993/O
xCam_Arc_Ambition.pdf
2 Levelling Up and Regeneration White Paper (February 2022)
https://www.gov.uk/government/publications/levelling-up-the-united-kingdom
3 Levelling Up and Regeneration Bill (11th May 2022) https://publications.parliament.uk/pa/bills/cbill/58-
03/0006/220006.pdf
4Oxford-Cambridge Arc confusion: Has the project really been ‘flushed down the toilet’? Cambridge Independent
(27th April 2022) https://www.cambridgeindependent.co.uk/news/oxford-cambridge-arc-confusion-has-theproject-
really-been-9251669/

“One of the partners in the Arc’s development, Robbie Owen, head of infrastructure planning and government affairs and Pinsent Masons, said his understanding was that the spatial framework would no longer be going ahead.”
“Cllr Herbert (Cambridge City Council) also said East West Rail could be at risk, but said he hoped the different partners in the Arc discussions would continue to
work together.”
1.6. For BBC to base its housing requirement figure on a Joint Declaration for a project that appears to be in serious doubt could result in a Local Plan with an increase of 40% housing without the accompanying strategic infrastructure required to support the housing.

Object

Representation ID: 9510

Received: 27/07/2022

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Stepped Approach to Housing Requirements
1.7. CPC notes that there are, what appear to be, multiple miscalculations in Policy DS3(S):
• Under the column 2025/26-2029/30 it states that the total number of dwellings for this period is 4,850 and that the dwellings per annum equates to 1,050.
However, 2025/26-2029/30 equates to 5 years. 4,850 divided by 5 = 970.
Therefore, BBC appears to have overestimated the number of dwellings per annum for the period 2025/26-2029/30 by 80 dwellings per annum. 80 dwellings
X 5 years (2025/26-2029/30) = 400 dwellings. BBC, it appears, has overestimated
the total number of dwellings in the policy by 400 dwellings.
• The totals of the three columns in the ‘stepped housing requirement’ table does not equate to 27,100 dwellings. 4,850 dwellings + 4,850 dwellings + 17,000 dwellings = 26,700 dwellings. Therefore, BBC has underestimated 400 dwellings somewhere in its calculations.
• It is noted that Policy DS5(S) Distribution of growth states that 400 dwellings will “take place beyond the plan period”, however this does not assist in understanding the miscalculations in Policy DS3(S) as outlined above. (Policy DS3(S) table pasted in original rep)
1.8. It is concerning that there is a shortfall of 400 dwellings in BBC’s calculations set out in the Local Plan which is hopefully a ‘typo’ or that the intended approach has not been communicated clearly so that this can be easily corrected and robustly explained by BBC.

Object

Representation ID: 9512

Received: 27/07/2022

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5(S) fails to set out full extent of growth
2.2. Paragraph 4.31 of the Local Plan states that Policy DS5(S) “…sets out where growth will be located”. However, the policy presents an incomplete picture of the quantum and location of growth that the Local Plan makes provision for between 2020-2040.
2.3. For example, the overall quantum of housing that the policy makes provision for is 13,550 dwellings. This is only 50% of the 27,100 dwellings that Policy DS3(S) sets as the housing requirement figure. This provides a lack of clarity about the location and quantum of all the growth that is being planned through this Local Plan. BBC should not assume that users of the Local Plan have up to date knowledge of the remaining allocations from the
2030 Local Plan and that the assumptions about the housing BBC considers will come forward during the 2040 plan period should be clearly set out in this policy.
No inclusion of small sites
2.4. The policy should clearly set out the number and location of ‘small site’ dwellings it has identified through the development plan and brownfield register in order to comply with paragraph 69 of the NPPF. This requirement of the NPPF is that the LPA must identify at least 10% of its housing requirement on sites no larger than one hectare, unless it can show that there are strong reasons why this 10% target cannot be achieved.
No inclusion of windfall allowance:
2.5. BBC’s ‘Stepped Trajectory Topic Paper’ (April 2022), includes provision for a total windfall allowance of 2,630 from 2021-2040. This is an important component of BBC’s housing supply, yet it is not set out anywhere in policy within the Local Plan. CPC considers that
the windfall allowance should be set out within Policy DS5(S) to ensure soundness.
Urban Area Supply is Inadequate
2.6. At the heart of the NPPF is a presumption in favour of sustainable development5. Plans and decision should apply a presumption in favour of sustainable development. The NPPF explains what this means for plan-making with making effective use of land in urban areas at the heart of mitigating climate change stating that (our emphasis added):
“all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects”6
2.7. Section 11 of the NPPF is called ‘Making effective use of land’. There are a number of important requirements set out in this section of the NPPF for plan-makers including the following:
• “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land”7
• “give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”8
• “promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is
constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure)”9
• “Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.”10
2.8. Given that the NPPF places such great weight and emphasis on the need to make the most effective use of previously developed land and land within settlements it is surprising how little the Local Plan and its evidence have to say about how the Council intends to comply with the NPPF as part of its plan-making.
2.9. BBC’s Development Strategy Topic Paper explains that one of the five ‘components of growth’ it has tested is ‘within the urban area (sites within the urban area boundary)’.
BBC explains that the Sustainability Appraisal (SA) concluded that the ‘within the urban area’ component performed the best of all of the potential components:
“In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area component performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and
access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of
land within the urban area could act as a constraint on business growth.
5 NPPF (2021) paragraph 11
6 NPPF (2021) paragraph 11
7 NPPF (2021) paragraph 119
8 NPPF (2021) paragraph 120
9 NPPF (2021) paragraph 120
10 NPPF (2021) paragraph 121
2.10. Regarding the ‘urban component of growth’ BBC explains that given that it performs most strongly “the assumption for the urban and adjoining areas is “deliberately ambitious” explaining that: “Development at scale in some parts of the urban area will be challenging and will require comprehensively master planned proposals and may require land assembly powers and significant investment in the infrastructure necessary
in order to deliver the development”11.
2.11. In the following section of the Development Strategy Topic Paper it summarises the development assumptions for options generation with ‘sites within urban area’ showing 1,500 dwellings. How is the assumption of 1,500 dwellings in the urban considered by
BBC to be “deliberately ambitious”?
2.12. Referring to the ‘Stepped Trajectory Topic Paper’ it sets out in Appendix 1 the ‘Urban’ sites that are new allocations in the Local Plan. The total amount of development capacity assumed for these sites is 1,178 over the plan period which falls considerably short of
the 1,500 dwelling assumption made by BBC in determining the amount of urban land that can be delivered in the Local Plan through Policy DS5(S).
(Figure 2.1 is extract from the Stepped Trajectory paper - the urban rows / sites section of the spreadsheet)
2.13. In relation to employment land that is potentially available for alternative uses (housing), the Local Plan makes no provision for this as a potential source of housing over the life of the Local Plan. This is despite the Council’s Employment Land Study (2022) identifying 15 employment sites within the Bedford / Kempston Urban Area as sites that should be ‘Monitored and Managed’ according to the Study. ‘Monitor and Manage’ is defined in the Study as “sites that may not continue to meet the needs of businesses in future”12.
2.14. The total land area of these sites is 65.77 hectares of land which should be at the very least tested for potential release for housing and to determine the potential capacity for housing on these sites should they become available. BBC should also include a policy in its Local Plan setting out how it will ‘monitor and manage’ these employment sites and under what circumstances it would permit the release of employment sites for housing.
11 Development Strategy Topic Paper (May 2022) paragraph 3.11
12 Bedford Employment Land Study (May 2022) paragraph 6.6
(figure 2.2 is an extract from Employment Land Study page 40)
Sites Adjacent to the Urban Area
2.15. The Sustainability Appraisal states that it has decided that “in most instances” sites adjoining the edge of the urban area should not be part of the local plan. This is due to the gap between the town and surrounding villages being too narrow. Whilst this may indeed be the case, CPC considers that such an approach which rejects more growth at the edge of the town in favour of selecting a ‘new settlement’ strategy requires greater evidence and justification than what BBC has presented to support its preferred development strategy.
“The Council has decided that sites adjoining the edge of the urban area in most instances should not be part of the local plan strategy because, in many locations, the gap between the edge of the town and villages surrounding it is very narrow and the strategic expansion of the urban area in recent years has already reduced that separation”13
13 Sustainability Appraisal paragraph 9.9