Bedford Borough Local Plan 2040 Plan for Submission

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.

Paragraph 4.77 Growth locations on the EWR / A421 transport corridor and with the potential for rail-based growth

Paragraph 4.77 includes the overarching vision of the south of Bedford Strategic policy area.
The role played by the expansion of Wixams is supported. L&Q Estates is promoting land to the East of Wixams which would support the delivery of the south of Bedford Strategy Policy Area. Wixams East is proposed to accommodate at least 1,800 dwellings, a local centre and a new primary school. Access is proposed via two existing roundabouts along the A6. The proposed access strategy will also promote access to and from Wixams and the scheduled Wixams Station for all modes of transport with particular emphasis on walking and cycle. It is proposed that Wixams East will be an extension to Wixams and one community will be formed in the longer term.

Wixams East will create new parks and spaces that will provide links to the surrounding countryside and provide extensive public open space. The most significant green infrastructure provision will be the creation of a new linear park. We will maximise the connection with the existing and new community to ensure that this regional park will be accessible via all modes of transport for the enjoyment for all. The linear park creates the opportunity to ensure long term biodiversity net gains through habitat enhancement and creation.

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.

Paragraph 2.0 Vision and Objectives

The Submission Draft Plan's vision is set out at paragraph 2.1 and states that new settlements at Little Barford and Kempston Hardwick will play a primary role in delivering housing to 2040 and beyond as well as development at Stewartby Brickworks.

The Vision does not refer to the important role played by The South of Bedford Strategic policy area including the completion and expansion of Wixams, in helping to deliver the housing requirements over the plan period. Policy DS5 (S) Distribution of Growth, indicates that the South of Bedford will provide for 7,050 new homes up to 2040. This represents an important contribution to meeting future housing needs.

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.

Paragraph 4.7 Housing

Paragraph 4.7 sets out the housing requirement for the Borough across the plan period. Consideration needs to be given to the potential uplift in housing numbers because of "The Oxford-Cambridge Arc". It is acknowledged in Paragraph 1.7 that to achieve the Arc's full economic potential, this would demand collective determination over the long-term to deliver homes across the Arc of the right quality and in the right places to meet its needs; also, that this might include the expansion of existing as well as the development of new settlements.

The housing requirement figure of 12,276 across the plan period is supported but it is recommended that this housing requirement is considered as a minimum requirement to ensure flexibility in the development of the plan and to prepare for the likely uplift in housing requirement as a result of the Arc or other future long term growth ambitions of the region.

The Draft Sustainability Appraisal (dated June 2021) that supports the consultation document tests a higher growth option of a 10% uplift than the objectively assessment need of 12,500 homes as identified in the Local Housing Needs Assessment. In appraising the high growth option, the SA comments at paragraph 8.4 that it was likely to perform more positively in relation to strong and balance economy, promoting the vitality and viability of town centres and promoting good quality housing.

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.
Policy DM5 sets out proposed requirements for self-build and custom house building, requiring new housing development to include a number of plots for self-build and custom housebuilders depending on the overall size of the development. Under the Self Build and Custom Housebuilding Act 2015 and the NPPF, it is the Council's responsibility, not landowners or developers, to ensure sufficient permissions are granted to meet demand. The NPPG outlines ways Councils should consider supporting self and custom build housing through engagement with developers and encouraging them to consider self and custom build where they are interested.
The issue of self and custom build units on larger developments was a matter addressed by the Inspector examining the Blaby Part 2 Local Plan. In this case the Inspector noted that whilst the Self-Build and Custom Build Register may indicate an interest in this type of housing, it was not clear how this evidence translated into actual demand, with potential issues of double counting where individuals register with more than one Council. In proposing a Modification to the plan to remove the requirement for self-build housing on larger sites, the Inspector concluded that the requirement was not justified by the available evidence, there were potential viability issues and there may be negative consequences for the provision of affordable housing (paras 73-79, Inspector's Report, Blaby Part 2 Local Plan, 21st December 2018).
The Council does not have robust evidence that justifies the inclusion of this policy in the plan. There is a concern that as currently proposed this policy will not assist in boosting the supply of housing and may even limit the deliverability of some sites and homes. There is also no evidence to confirm that large scale developments are a preferred location for self-build plots. Any evidence must be supported by a thorough viability and impact assessment. There is always a danger of gaps in the street scene, or unfinished properties, by including self-build plots into development proposals and this needs to be avoided to ensure cohesive and consistent developments.

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.
Policy DM6 requires all new dwellings to conform to nationally described space standards as a minimum.
If the Borough Council wishes to adopt the optional nationally described space standards, then this should only be done in accordance with the National Planning Policy Framework (NPPF) (para 130f & Footnote 49). Footnote 49 of the NPPF states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”. The NPPF states that policies should be underpinned by relevant and up to date evidence which should be adequate, proportionate, and focused tightly on supporting and justifying the policies concerned (para 31). The Borough Council has not provided any evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in the Local Plan.
There is also no evidence to show that the Borough Council has considered the impacts on need, viability, and timing before introducing the nationally describe space standards.
The requirement for compliance with the Space Standards for all new development may impact on affordability and customer choice. It is important that that the Borough Council presents clear local evidence of need and impacts on viability to justify the inclusion of the policy in the plan.

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16. L & Q Estates Ltd supports the proposed allocation East of Wixams as it represents a sustainable and deliverable development that will make an important contribution to meeting housing needs over the plan period.
The following sections set out our comments on relevant sections and policies in the plan.
Policy HOU16 Land at East Wixams
Policy HOU16 allocates land at East Wixams for residential, community and open spaces uses. The scale of housing is not specifically included in the policy. For clarity, it would be helpful if the allocations policies identified the scale of housing proposed and that these figures represent a minimum provision.
Wixams East is proposed to accommodate at least 1,800 dwellings, and associated infrastructure. Access is proposed via two existing roundabouts along the A6. The proposed access strategy will also promote access to and from Wixams and the scheduled Wixams Station for all modes of transport with particular emphasis on walking and cycling. It is proposed that Wixams East will be an extension to Wixams and one community will be formed in the longer terms.
Policy HOU16 states that the development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan. The Infrastructure Delivery Plan at Table 5-2 states that the A421 widening to 3 lanes between A6, and Carrington Road (A603 junction) would need to be delivered before this site allocation comes forward. The Infrastructure Delivery plan states at paragraph 2.6 that with the growth included in the current adopted Local Plan, in 2030 the A421/A6 and A521/A603 junctions are operating over capacity. However, it is not clear how much of the growth allocated in the adopted Local Plan 2030 has been developed. The infrastructure delivery plan assumes that all the allocations have been developed which may not be the case. Whilst L & Q Estates is supportive of delivering infrastructure that is required by the development, the restriction on Land East of Wixams from being delivered until the transport improvements are in place is not justified. It is possible that land to the East of Wixams could come forward before some allocations identified in the Local Plan 2030, helping to support the delivery of housing to meet requirements. Therefore, whether a contribution is required to fund infrastructure improvements or whether infrastructure improvements need to take place ahead of the development of the allocation should be determined through the development of the comprehensive transport assessments as part of the development management process. The policy already appropriately sets out the requirement for a full Transport Assessments as part of any applications, which is supported.
Policy HOU16 states that the development will include:
• provision of two 2.4 ha serviced sites to accommodate two 2 form entry primary schools to include early years’ provision.
• Provision of an 11 ha serviced site to accommodate a nine-form entry secondary school to include sixth form provision;
• financial contribution towards secondary school provision;
The Local Plan 2030 – Education Implications (2030) with Addendum (2022) indicates the potential education needs arising from new development and includes broad costs for the provision of new schools.
At this stage it appears that the Local Plan is seeking primary and secondary school places more than what would be reasonably justified to meet the needs of the East of Wixams housing allocation. It is possible that Wixams East has been identified to meet the additional needs of other proposed allocations. This has not been justified or supported by sufficient evidence. If this is the case, it would be necessary for other allocated sites to contribute proportionately to the cost of the additional land, the lost opportunity cost of the land and building work and the relevant policies amended to make this requirement for contributions clear. The development of the land at Wixams East should only be required to mitigate the impacts arising from this development alone. It is unjustifiable to impose additional infrastructure burden on this site to mitigate impacts arising from development proposals elsewhere.
For primary schools, The Education Implications paper provides for new pupil product ratio for primary pupils of six pupils per year group per hundred dwellings. This is given as " a 1 form entry school for 500 dwellings, a 2-form entry school for 1,000 dwellings and a 3-form entry school for 1,500 dwellings.”
The Local Plan is seeking approximately 0.4FE primary school places more than what is require by the proposed East of Wixams allocation. Whilst the need for some flexibility across the area is understood, with the Wixams East site proposed for 1,800 dwellings, no more than 3.6FEof primary provision is warranted to meet its needs. One 2FE primary school is supported. A further 2FE should be planned for, but with only 1.6 FE of the land and construction costs funded by the development and the remainder met by one of the other local developments. Alternatively, the provision of one 4FE primary school on the site could benefit from economies of scale in its construction and running and still meet the educational requirements of East of Wixams. Such an approach is being undertaken for the remaining education provision in the existing Wixams settlement.
The Education Implications Paper, states that a 2FE site is expected to be provided at 2.4ha, including sufficient space for early years provision. This is considered high, as DfE Guidance provides for a 2FE site to be scaled at between 1.6ha and 2ha. The Local Plan and Education Implications paper has, therefore, opted for the maximum size and then increased the requirement by 0.4ha for early years. This is not justified as there is no indication as to how this level of requirement has been reached, either in terms of pupil numbers or in terms of the space breakdown. For the Wixams East site, each of the 2FE sites should be containable within a 2ha site. If the provision of the 4FE approach is adopted then the site area required reduces to 3.39ha as demonstrated on the Wixams town centre school that is currently being planned for. There is no justification for requirement of 4.8ha for primary education provision at the East of Wixams.
For Secondary school provision, Wixams East is requested to provide a 9FE entry school with sixth form which is 5.4FE more than the needs created by the allocation. It is clearly anticipated that this new school is intended to meet the needs of other allocation in the area. However, at 9FE, our evidence suggests that it exceeds the overall requirement for the area by 1.8FE. a requirement of 3.6FE (at 4.14 ha) is supported. A further 3.6FE should be funded by other developments and contribute proportionately to the cost of the additional land, the lost opportunity cost of the land and building work and the final 0.8ha to meeting any additional needs up to 8FE should be funded by the Education Authority. The indication of a 9FE with sixth at an 11ha site size is considered excessive. A site of between 8.1ha and 10.1 has (including sixth form) is the range recommended by the DfE for an 8FE school. There is no evidence to support the provision of more than the minimum. Additionally, there is no rational justification as to why Wixams East needs to be burdened with the provision of a secondary school whilst other allocations in the area do not. This is an unduly onerous and inequitable requirement.