Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 10119

Received: 29/07/2022

Respondent: Office of the Police and Crime Commissioner for Bedfordshire

Agent: Bidwells

I write on behalf of my client the Police and Crime Commissioner for Bedfordshire in response to the Bedford Borough Council Regulation 19 Local Plan Consultation.
My client would like to express their support for the draft plan which includes the identification of their site ‘Land adjacent to Police Headquarters, Woburn Road, Kempston’ as allocation HOU8. My client confirms that this site remains available for development and is deliverable in the short to medium to term to support the ongoing requirement for homes in the area. In this representation I will identify key matters of note in the emerging plan and will seek to highlight areas which I consider require further attention.
It is evident in both the Development Strategy and Site Selection Topic Paper and the Sustainability Appraisal that, throughout the evolution of development strategy and consideration of different development options, growth in and around the urban area was considered to be the most sustainable development typology.
It is stated in the Development Strategy and Site Selection Topic Paper that:
‘In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area - 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.’
This approach is in keeping with the principle of sustainable development which is at the heart of the National Planning Policy Framework (NPPF) (2021).
Specifically, paragraph 11a of the NPPF states that: ‘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’ (emphasis added).
Paragraph 120d of the NPPF also states that planning policies should ‘promote and support the development of under-utilised land and buildings’ and paragraph 124 supports ‘development that makes efficient use of land’ drawing attention to ‘the availability and capacity of infrastructure and services’.
My client’s site is located within the urban area of Kempston, in close proximity to a wide range of services and public transport links, and represents a sustainable site option as per the above NPPF policies. The Call for Sites process has highlighted that there are a limited number of available sites within the urban area and it is therefore essential that the Council prioritise those sites which have been put forward as being available as allocations moving forward, where they can be considered suitable for development.
Site HOU8 is currently identified as an Urban Open Space under Local Plan Policy AD43, which is a policy constraint to development. This can be amended through the review of the Local Plan and we agree with the conclusion set out in the Call for Sites Assessment which states that ‘The site is suitable for development for residential and open space uses. Whilst it is designated as an urban open space, the reasons for its designation can be retained alongside development and the delivery of publicly accessible green space will be a significant benefit to the area.’
The site is also in public ownership and paragraph 121 of the NPPF states that ‘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’.
My client considers that the approach to identifying suitable development land in the urban area and the prioritisation of such sites as allocations has been properly evidenced and, in accordance with the requirements of paragraph 35 of the NPPF, represents a sound approach within the Local Plan.

Comment

Representation ID: 10120

Received: 29/07/2022

Respondent: Office of the Police and Crime Commissioner for Bedfordshire

Agent: Bidwells

General comments
Whilst agreeing that the allocation of site HOU8 is sound, I recognise that it is important that the development strategy as a whole is sound in order to ensure that development of my client’s site can be realised in the future. On this basis, I feel it prudent to note the below points in relation to the wider development strategy which I consider the Council need to be aware of moving forward:
• The average/peak delivery rates identified in the housing trajectory for large, strategic sites appear optimistic in a number of cases. Therefore, the level of housing that will be delivered in the plan period could be less than that expected by the Council. This reinforces the importance of allocating sites such as HOU8 but means that additional small-scale allocations may need to be proposed to underpin short term supply.
• Whilst the housing requirement is based on the Standard Method, I am uncertain if sufficient work has been undertaken to assess if a higher housing figure could be adopted. Again, this reinforces the need to maintain those site allocations proposed in the Plan but may necessitate additional allocations to make the Plan sound.
• It does not appear that there is a buffer in relation to land supply over and above the level needed to meet the current housing requirement. Again, this reinforces the need to maintain those sites currently proposed for allocation in the Plan but may also necessitate the allocation of other sites to
support overall delivery rates and make the Plan sound.