Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9645

Received: 29/07/2022

Respondent: Thakeham

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Thakeham agree with the general approach to the spatial strategy for Bedford, especially the aim to deliver sustainable development and make Bedford a net zero carbon emissions borough. We also support the identification of the A421 as a growth location for new development.
However, we are concerned about the soundness of a key element of the strategy, namely the creation of a new settlement at Little Barford, which is based on delivery of new major infrastructure projects being delivered in order to bring forward this settlement.
The first of these is the A428 upgrade works, which would need to provide a new junction to provide road access into the site. However, within the DCO now in place, there is no provision for such a junction and therefore a new junction couldn’t be constructed until after the A428 upgrade works are complete in 2026.
The second is the reliance on East West Rail to reduce car travel. Whilst we understand that the East West Rail line between Oxford and Milton Keynes is already under construction, there are still consultations ongoing as to the preferred route of the line from Bedford to Cambridge, and no definitive site has been identified for a new station. Indeed, there is currently no timeframe as to when and where the East West Rail line between Bedford and Cambridge will commence, let alone be complete and in use.
Whilst there is currently no certainty about the East West Rail line here, nor any viable road access to the site, the suggested new settlement at Little Barford cannot be considered to be a sustainable location for development, making the current policy a contradiction that could result in the Plan being found unsound.
In addition to the unsustainable location, we believe that the suggested numbers of units to be delivered at Little Barford over the plan period are not feasible. The plan suggests the Little Barford site will deliver at least 4,000 new homes overall of which 3,800 will be built within the current plan period.
The promotors own representations to the Council states that only 3,085 dwellings will be built by 2040, which assumes that the site starts delivering houses in 2026. However, this timeframe will not be feasible for the following reasons:
1. The upgrade works to A428 necessary for access, are not due to be completed until 2026, and the DCO does not currently include any junction works to facilitate the site;
2. The East West Rail route and station locations have yet to be identified, let alone surveyed and DCO applications prepared; and
3. Policy HOU19 states that a supplementary planning document will need to be produced ahead of submission of the planning application. This won’t be possible until the Transport and Works Act Order is in place for East West Rail.
In light of the above, it is likely to be 2030 before planning permission were even granted, meaning the first dwellings would not be complete until 2032 at the earliest.
Accordingly, to ensure a robust land supply position can be maintained throughout the plan period, as well as delivering sustainable development, it is suggested that the alternative location of Wyboston is considered as a more sustainable alternative, given its proximity to the A421 corridor and it is not dependent on the delivery of East West Rail to ensure delivery of sustainable development.

Comment

Representation ID: 9646

Received: 29/07/2022

Respondent: Thakeham

Thakeham supports the inclusion of 30% affordable housing requirement for sites of 10 or more residential dwellings. Thakeham delivers policy compliant affordable housing across all our sites, are pepper-potted around the development rather than clustered and ensure these are built to the same standard as our market housing. Our developments in Bedford would be no different.

Comment

Representation ID: 9647

Received: 29/07/2022

Respondent: Thakeham

Thakeham supports the Council’s policy to include self-build, and acknowledges the number of units provided in development over 100+ is by negotiation. However, as is the case across the country, any specific amount of self-build should be evidenced by demand in the area, rather than an arbitrary number based on the scale of development proposed.
Thakeham supports the Council’s inclusion of a deadline for marketing plots for self-build after which they would be released from the self-build policy requirement. However, we believe that 12 months is too long, as land would remain fallow for the entire marketing period, plus the time then taken to obtain planning permission for conversion to alternative housing or uses.

Comment

Representation ID: 9648

Received: 29/07/2022

Respondent: Thakeham

Thakeham welcomes the inclusion of an environmental net gain policy. Thakeham seeks to deliver biodiversity net gain across all our sites and from 2025 20% biodiversity net gain (an increase on the government’s mandated 10% minimum), and our developments in Bedford would be no different.