Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 10142

Received: 29/07/2022

Respondent: Axis Land Partnership

Agent: Strutt and Parker

1. INTRODUCTION

1.1 This representation has been prepared by Strutt & Parker on behalf of Axis Land Partnerships (“Axis) in response to the current Regulation 19 consultation on the emerging Bedford Borough Local Plan 2040: Plan for submission consultation.

1.2 Strutt & Parker on behalf of Axis, have been promoting land at Gibraltar Corner as part of the emerging Local Plan and this representation should be read in conjunction with earlier representations made. This representation responds to relevant policies in the plan, having regard to land at Gibraltar Corner, which has obtained an allocation for a residential development and provision of the delivery of open space and green infrastructure improvements under policy HOU13 of the emerging Local Plan.

1.3 As set out within previous representations Axis are promoting the land to the north of Wood End Lane and to the east of Home Road. The land on the south side of Wood End Lane and Home Close are being promoted separately by the Crown Estate.

1.4 The allocation HOU13 is shown in Figure 1 below:
SEE ATTACHMENT
1.5 This representation provides a response in relation to key policies within the plan in turn. For the reasons explained further within Section 2 of this report, Axis as promoters of the site fully support the proposed allocation as set out in Policy HOU13. In accordance with the requirements of the consultation, it is considered that the plan in its current form is legally compliant, sounds and complies with the duty to co-operate.

1.6 Section 2 of this representation seeks to assess the soundness of this allocation having regard to tests set out within national policy.
2. REVIEW OF KEY POLICIES

2.1 The tests of soundness are set out in Paragraph 35 of the National Planning Policy Framework (2021). According to Paragraph 35, plans are ‘sound’ if they are:

a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

2.2 This section provides a response in relation to key policies within the plan as follows:

Policy DS2(S) Spatial Strategy

2.3 Policy DS2 (S) Spatial Strategy of the Bedford Borough Local Plan 2040 sets out the Strategic locations proposed for growth as part of the emerging Local Plan.

2.4 This includes an allocation on land at Gibraltar Corner, Kempston Rural, under policy HOU13. The wording set out within policy DS2(S) is considered to be sound and Axis fully support the key objective of delivering sustainable development and working towards a net zero carbon emissions borough. The allocation of land at Gibraltar Corner is considered to be fully aligned with the objectives set out within policy DS2(S) and the proposed allocation, given its proximity to Bedford and Kempston will assist maintaining and enhancing Bedford and Kempston as a vibrant location as identified in policy DS2(S).

Policy DS3(S) Amount and Timing of Housing Growth

2.5 The proposed quantum of housing growth as set out in policy DS3(S) is supported, which appears to be positively prepared and seeking to meet Bedford BC objectively assessed housing needs.

Policy DS5(S) Distribution of Growth

2.6 The proposed distribution of growth is supported and policy DS5(S) is considered to be both justified and effective.

2.7 The proposed allocation of 1,500 dwellings within strategic locations adjacent to the urban area, are considered to be particularly important to the Distribution of Growth Strategy. It is noted that a large quantum of the proposed growth relates to new settlements to the South of Bedford and Little Barford. Whilst no objection is raised to either allocation, the delivery of both sites will require the provision for significant infrastructure, which is likely to mean that they will not come forward within the immediate term. The allocation of the smaller and medium sized sites such as Gibraltar Corner is therefore imperative to maintain a consistent delivery of housing, as required by paragraph 74 of the NPPF.

Policy HOU13- Land at Gibraltar Corner, Kempston Rural

2.8 Land at Gibraltar Corner, Kempston Rural will be developed for a mix of residential uses and open space including the delivery of strategic green infrastructure improvements.

2.9 A response to each of the policy requirements is set out below:
SEE ATTACHMENT

2.10 Overall the allocation of the site under policy HOU13 is fully supported by Axis. The site is fully deliverable in planning terms and offers an appropriate location for strategic growth. It is considered to be sound in planning terms and retention of the allocation is important to ensure that the Local Plan is positively prepared, justified, effective and in accordance with national policy. It is requested that the minor adjustments to the policy as set out above are made in order for the policy wording to be effective as required by national policy.