Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9755

Received: 27/07/2022

Respondent: De Merke Estates

Agent: Neame Sutton Limited

Legally compliant? No

Sound? No

Duty to co-operate? No

This section addresses the housing requirement and Spatial Strategy set out in Section 4 of the Pre-
Submission Plan.
Housing Requirement
2.2 The starting point in addressing the housing requirement is the Government's standard method (NPPF
2021, para.61). The National Planning Practice Guidance (NPPG, para.002, ID 2a-002-20190220) reiterates
that the standard method identifies the minimum, annual housing need figure, but does not provide the
housing requirement. Paragraph 61 of the NPPF (2021) goes on to state that, in addition to the local
housing need figure, any need that cannot be met within the neighbouring authorities, should also be
accounted for in establishing the housing requirement.
2.3 Being part of the Oxford to Cambridge Arc, Bedford is likely to experience the effects of significant
economic and infrastructure growth, such as an inward population migration and resultant higher housing
need. Coupled with this is the Duty to Cooperate Position Statements (April 2022), where all five of the
neighbouring districts (Central Bedfordshire Council; Huntingdonshire Council; Luton Council; Milton
Keynes Council; North Northamptonshire) acknowledge the likelihood of the need to provide an uplift in
housing requirements to meet the Arc, which will necessitate cooperation.
2.4 The Duty to Cooperate Position Statements document highlights that the neighbouring authorities have
not to date, had sight of the Pre-Submission Plan, and for the moment, the document simply identifies the
potential strategic, cross-boundary matters. Whilst there is evidence to suggest that the Council has been
engaging in Duty to Cooperate meetings, the Pre-Submission Plan and housing requirement remains
unadjusted, as the minimum, standard method figure (1,355 dwellings per annum).

Spatial Strategy
2.5 The Spatial Strategy is taking forward one of the four growth options previously considered by the Council
in the Regulation 18 Strategy Options and Draft Policies Local Plan (Option 2b). The growth locations are:
• Within the urban area.
• At strategic locations adjacent to the urban area.
• At new growth locations focused on the EWR/A421 transport corridor with the potential for railbased
growth, particularly in the south of the Bedford area and at a new settlement at Little
Barford.
2.6 The Council’s preferred strategy fails to take advantage of the opportunity presented by the EWR corridor
to the north of Bedford, particularly in Clapham. The corridor has been defined on the Key Diagram
(Fig.12) and the route to the west has been significantly advanced, therefore, it is evident that this railway
route will be delivered. Clapham benefits from excellent transport links and several services, yet its
expansion is not considered in the preferred growth option.
2.7 Given the likelihood of the EWR being delivered and the change in landscape that will occur as a result,
the Plan has failed to consider the option of further growth opportunities in the vicinity of the proposed
corridor. This is a failing of the Plan. Such an opportunity exists at Clapham, where the proposed route
will release land for development, which should have been explored by the Council.
TC1(S) Hierarchy of Town Centres – De Merke Estates agrees with the Settlement Hierarchy, where
Clapham is identified as a Key Service Centre. The Council has previously allocated 500 homes to
Clapham, recognising its locational sustainability.