Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9759

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As it stands the plan in our view is not sound on the following tests under paragraph 35 of the
National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
Whilst we agree that all homes should be delivered to a high standard and be of good quality, we also consider that space standards can, in some instances, have a negative impact by reducing customer choice and increasing affordability issues. Developers tend to provide entry-level one and two-bedroom properties which may not always meet the optional nationally described space standards, but which would be affordable for the number of required bedrooms.
Given that no evidence is presented with regard to the need for space standards, the policy is unjustified, and as such, unsound.

Object

Representation ID: 9760

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We consider the spatial strategy including site selections will not minimise the need to travel and hence fail to minimise carbon emissions from new development.
The location of some of the proposed allocations are not considered to be well related to existing urban areas and whilst new places of certain scale are able to become more self-sufficient over time depending on the mix of development and deliverability, there is uncertainty and risk over the means by which to achieve this. Some of the locations seem not to relate well to facilities within Bedford Town and Kempston and some will be reliant on
provision of East-West Rail which as our other representations have identified remains uncertain.
Land at Box End, West of Bedford performs well in accessibility and connectivity terms. The development will be designed to be a 20-minute community, where day-to-day facilities are accessible within 20-minutes by active travel. As the development will provide a mixed-use community, internalised based trips will be maximised.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are well related to Bedford Town and Kempston or can be largely self-sufficient in terms of the scale and mix of development.
These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
Paragraph 66 of the NPPF states that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply
and mix of sites, taking into account their availability, suitability and likely economic viability.
Bedford Borough Council is the strategic policy-making authority in this instance and we accept that the Council has undertaken a call for sites and has taken this into consideration in arriving at the proposed strategy and objectives but we consider there is a fundamental issue
over deliverability.
The policy does not include any target or means by which to assess performance against policy and hence it is not measurable and hence it is not achievable.

Object

Representation ID: 9761

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We consider there is insufficient evidence to demonstrate that the vision over the plan period is deliverable because of the proposed spatial strategy and site allocations.
The vision specifically mentions locations for new settlements and other development, but the strategy does not demonstrate deliverability of the sites proposed and it does not factor in sufficient flexibility for under-performance should the spatial strategy and site selection remain unchanged through the examination process.
We consider that to be found sound, the plan should be subject to main modifications in respect of a range of matters but for the purpose of this response to the vision and objectives we confine our comments to the need to review the evidence base and proposed spatial strategy and site allocations.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are deliverable. These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
Paragraph 66 of the NPPF states that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.
Bedford Borough Council is the strategic policy-making authority in this instance and we accept that the Council has undertaken a call for sites and taking this into consideration in arriving at the proposed strategy and objectives but we consider there is a fundamental issue over deliverability.
The spatial strategy is reliant upon further decisions to be made by other parties in respect of East-West Rail including fundamental considerations of the route west of Bedford Town, locations of stations and timing of subsequent stages for the planning for the development and delivery. The consultation on this local plan comes ahead of refinement of the detail of these extremely important matters and yet the local plan is not scheduled for submission for examination until January 2023. With this consultation comprising the plan for submission (Regulation 19), there would ordinarily not be any further opportunity for stakeholders to comment ahead of submission of the local plan (Regulation 22). As the spatial strategy and some of the proposed site allocations rely on delivery of East-West Rail this is a real point of vulnerability which should have been avoided by first having clarity on this ahead of consultation under Regulation 19.
The Infrastructure and Projects Authority, which is the Government’s centre of expertise for infrastructure and major projects, published its Annual Report on Major Projects 2021-22 on 20 July 2022. This has found that stages 2 and 3 of East West Rail appears to be unachievable.
In this report the East West Rail Connection Stage 2 and 3 which comprises predominantly upgrading of existing infrastructure (between Bletchley and Bedford) to allow services between Oxford and Bedford and East West Rail CS3 which involves building a new line, between Bedford and Cambridge, to extend the railway and facilitate services from Oxford to Cambridge, is identified as 'red' meaning that the successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability reassessed.
A copy of the report is available via: https://www.gov.uk/government/publications/infrastructure-and-projects-authority-annual-report-2022
Paragraph 2.4 states that remaining policies in the earlier Allocations and Designations Local Plan have been reviewed and, in the majority of cases, they remain fit for purpose and do not need to change at this time. Where is the assessment undertaken as referred to here and what is the position in respect of cases (seemingly being in the minority) which might not have been judged fit for purpose and so might need to be changed?
Paragraph 2.5 states that the development strategy to 2030 is already set, it is important that it is allowed to be delivered and for that reason the policies in this emerging local plan build on it, and in doing so, put in place a robust strategy for growth to 2040.
We do not agree with this statement because we consider the strategy proposed in this emerging local plan 2040 does not just ‘build upon’ the local plan 2030. The proposed strategy unlike the existing one identifies new settlements and new strategic-scale development based on East-West Rail over a period of some 15 years. The local plan 2030 adopted in January 2020 only covers the period to 2030 and has a focus on Bedford and Kempston, completing the then already started settlement at Wixams and village extensions including at Wootton, Stewartby and Shortstown.
There is not much, if any, scope for the local plan not already covered within the points at paragraph 2.6 and hence struggle to see why the new local plan seems to be proposed as a partial rather than a full review? In view of the proposed scope for the new local plan it seems appropriate to consider this replacing all existing development plan policy of relevance (acknowledging this will not include neighbourhood plans) and for the local plan to state what the development plan for Bedford Borough currently comprises.
There is an over reliance on larger sites within the plan and we question whether it is realistic to expect the quantum of potential delivery within the plan period.

Object

Representation ID: 9762

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We consider there is insufficient evidence to demonstrate that the vision over the plan period is deliverable because of the proposed spatial strategy and site allocations.
The starting point for the spatial strategy should be development at Bedford Town and Kempston, followed by locations which are accessible to these urban areas.
The strategic locations adjacent to the urban area under this policy cannot claim to be adjacent in the ordinary sense of the word, in that they are not next to or adjoin the urban area of Bedford Town and Kempston. Figure 5: South of Bedford Area needs to identify the urban area so that the proposed allocations can be seen properly in context. The Figure also needs to identify in the Key the various proposed allocations.
We consider that Policy DS2(S) Spatial Strategy should be subject to change from strategic locations adjacent to the urban area to strategic locations which are accessible to the urban area. This will entail a re-assessment of the evidence base including land availability, rightly bringing into consideration land at Box End, West of Bedford, which is being promoted by BDW Trading Limited for an exemplar sustainable urban extension of some 1,150 homes that meets or even exceeds policy requirements in relation to issues such as bio-diversity net gain, renewable energy etc.
The spatial strategy does not demonstrate deliverability of the sites proposed and it does not factor in sufficiently flexibility for under-performance should the spatial strategy and site selection remain unchanged through the examination process.
BDW Trading Limited includes Barratt Developments who are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022, this is a record 13th year in a row.
Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards large developer 2021. Barratt Developments have an enviable track-record of delivering sustainable development and high-quality place-making in Bedfordshire and beyond including at Wixams.
We consider that in order to be found sound the local plan should be subject to main modifications in respect of a range of matters. However, for the purpose of this response we confine our comments to the need to review the evidence base and proposed spatial strategy and site allocations.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are deliverable. These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
The spatial strategy is reliant upon further decisions to be made by other parties in respect of East-West Rail including fundamental considerations of the route west of Bedford Town, locations of stations and timing of subsequent stages for the planning for the development and delivery. The consultation on this local plan comes ahead of refinement of the detail of these extremely important matters and yet the local plan is not scheduled for submission for examination until January 2023. With this consultation comprising the plan for submission (Regulation 19) there would ordinately not be any further opportunity for stakeholders to comment ahead of submission of the local plan (Regulation 22). As the spatial strategy and some of the proposed site allocations rely on delivery of East-West Rail this is a real point of vulnerability which should have been avoided by first having clarity on this ahead of consultation under Regulation 19.
The Infrastructure and Projects Authority, which is the Government’s centre of expertise for infrastructure and major projects, published its Annual Report on Major Projects 2021-22 on 20 July 2022. This has found that stages 2 and 3 of East West Rail appears to be unachievable.
In this report the East West Rail Connection Stage 2 and 3 which comprises predominantly upgrading of existing infrastructure (between Bletchley and Bedford) to allow services between Oxford and Bedford and East West Rail CS3 which involves building a new line, between Bedford and Cambridge, to extend the railway and facilitate services from Oxford to Cambridge, is identified as 'red' meaning that the successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability reassessed.
A copy of the report is available via: https://www.gov.uk/government/publications/infrastructure-and-projects-authority-annual-report-2022
We question whether the number of dwellings identified for sites is achievable for example whether the potential dwelling yield at Little Barford and south of Bedford are achievable, which we summarise below.
Kempston Hardwick (HOU14)
• There is currently a pending planning application for employment on the site – Ref. 18/02940/EIA – Outline application with all matters reserved except access, for a commercial and industrial development providing up to 780,379 sqm of floorspace for B1, B2 and B8 uses and ancillary service uses (A1, A3, A4 & A5) and associated infrastructure including open space and landscaping.
• There are multiple land owners within the Kempston Hardwick allocation, meaning delivery could be delayed, complex and incoherent.
• The delivery of 3,800 units over the plan period is somewhat ambitious.
• The location of the allocation is based around the delivery of the East-West rail station, the location of which is uncertain at this moment in time.
Little Barford (HOU19)
• The delivery of 3,800 over the plan period is somewhat ambitious.
• There are potential cross-border issues to address as the Site sits on the edges of HDC and CCC.
• There are likely to be some potential capacity issues within the local highway network e.g. Black Cat roundabout.
• This site is based around the location of the East-West rail stations. At this moment in time, the locations of which are uncertain. This is a real point of vulnerability.
Land south of Wixams (HOU15)
• We would query where the projected dwelling yields are found in proposed policy terms

Object

Representation ID: 9782

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
Policy DS3(S) provides insufficient explanation as to the proposed minimum number of new dwellings and it does not a clear or accurate explanation.
We consider that Policy DS3(S) is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The proposed policy does not demonstrate that it has satisfied paragraph 61 of the NPPF which requires strategic policies to determine the minimum number of homes needed, informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
Paragraph 4.7 of the emerging local plan states that as a result of the government’s recent revisions to the standard method, the housing figure for Bedford Borough is 1,355 dwellings per year, giving a total of 27,100 dwellings for the 20 year period from 2020 to 2040. The proposed policy is only to plan for this minimum, nothing more and hence there is no flexibility in this due to the absence of an appropriate buffer. We would expect to see a 10-15% buffer put in place, as this is often the accepted buffer for such matters. The strategy is not sound because it relies entirely on all of the strategic and non-strategic sites delivering within the plan period as envisaged, despite there being critical decisions yet to be made on masterplanning, infrastructure delivery, etc in the surrounding areas.
There is no explanation as to the options assessed for preparation of a local plan which includes a housing delivery figure above a minimum required under the standard method. Housing delivery in the Borough has already exceeded the annual minimum provision proposed under Policy DS3(S) in the periods 2020/21 to 2024/25 and 2025/26 to 2029/2030. Therefore this is a proposed local plan, which in respect of housing growth, shows a reduction in growth. It is a slowing-up in growth and this will be reflected in terms of investment including in infrastructure in comparison to recent delivery.
This is not a sound approach to take. Much is made of the Oxford-Cambridge Arc within the draft local plan but not when it comes to planning for the amount and timing for housing growth which seems to want to slow-up delivery and push it back later into the proposed plan period, by which time there would have to have been at least one further partial or full review of this emerging local plan.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. The proposed local plan includes new settlements but it does not look ahead over the longer timescale.
The policy and the plan overall does not provide for the paragraph 69 NPPF requirement for land to accommodate at least 10% of the housing requirement on sites no larger than one hectare or else shown through policy why there are strong reasons why this target cannot be achieved. We mention this because it is a matter for examination into the plan under the tests of soundness being consistent with national policy.
The table under Policy DS3(S) is not accurate in that the numbers within the rows do not add up to the total. This might be a typographical error but either way it needs to be accurate.
There is no justification given for the proposed stepped trajectory and insufficient explanation of a trajectory. Paragraph 74 of the NPPF requires strategic policies to include a trajectory illustrating the expected rate of housing delivery over the plan period, and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites. We consider it is appropriate to set out the anticipated rate of development for all proposed specific sites within the emerging local plan because without this the process is not transparent or measurable. This approach means they will not be meeting their housing need (including affordable housing) in the early years of the plan because of the stepped trajectory.

Object

Representation ID: 9783

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy and DS3(S) Amount and Timing of Housing Growth.
Policy DS3(S) provides insufficient explanation as to the proposed minimum number of new dwellings and it does not a clear or accurate explanation.
We consider that Policy DS3(S) is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The proposed policy does not provide an explanation of the individual sites forecasted for delivery or the overall amount. There is no clarity or transparency on the dwelling numbers. For example, there is a figure of 1,200 dwellings within the urban area but no break-down of
what is included within this. This means the reader has to look in detail at the individual sites being proposed to see if it is possible to work-out what the quantum is, although this is not possible for all of the sites.
There is no explanation of a buffer within the table under Policy DS3(S) i.e. where does any buffer sit and there is no statement that all of the dwellings are minimum.
There is no figure or break-down given for the remaining rural area/villages and not explanation of the development beyond the plan period. Development beyond the plan period should not be in a table which is meant to provide a breakdown of sites intended to deliver at least the minimum housing requirements within the 2040 plan period. The table within the policy is not user-friendly and it does not pass the tests of soundness under the NPPF.
We question whether the number of dwellings identified for sites is achievable for example whether the potential dwelling yield at Little Barford and south of Bedford are achievable. The potential delivery estimates within the table under Policy DS3(S) is ambitious at least and
possibly not deliverable. This is noted in further detail within the response to Policy DS2(S).

Object

Representation ID: 9784

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
We consider that Policy HOU12 is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The proposed policy is overly reliant on East-West Rail despite there being significant decisions yet to be made on this infrastructure proposal. By pushing ahead with this consultation prior to any definitive progress on East-West Rail there is danger that the spatial strategy including the approach to south of Bedford will unravel.
The locations of proposed sites do not relate well to one another in terms of accessibility and connectivity, and instead rely on higher order settlements such as Bedford, Kempston and Wixams. If the overarching strategy is based on East-West Rail connectivity, this only really relates to the sites with good accessibility to the stations, these being some of the western located sites.
We have explained in our response to the proposed vision, objectives and spatial strategy overall that we consider the tests of soundness have not been met. Land at Box End, west of Bedford is well related to the urban area of Bedford and Kempston and performs well in sustainability terms being to the south west within the broad area defined as ‘South of Bedford Area’ within Figure 5. This land is being promoted by BDW Trading Limited, which includes Barratt Developments, for sustainable and deliverable development. Masterplanning for the site includes land with potential for around 1,150 dwellings, a primary school and a community hub thereby creating a sense of community and potential for some trips to be internalised within the development.
Barratt Developments are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022 and previous years. Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards Large Developer 2021.
As the land at Box End performs so well but is inexplicitly omitted from the proposed sites within the South of Bedford Area, there is a vulnerability in the approach which is not sound.
We have concerns regarding he deliverability of the sites within the South Bedford area. The reasoning of which is contained within the response to Policy DS2(S).
We suggest a review of the evidence base and strategy which would lead to a need for more land for housing-led development including identification of land at Box End, west of Bedford.

Object

Representation ID: 9785

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
We consider that Policy HOU14 is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The proposed policy is overly reliant on East-West Rail despite there being significant decisions yet to be made on this infrastructure proposal. By pushing ahead with this consultation prior to any definitive progress on East-West Rail, there is danger that the spatial strategy including the approach to south of Bedford will unravel. Kempston Hardwick is reliant on two new train stations, which requires a significant amount of infrastructure delivery within a short timeframe. The timing of the delivery of these key pieces of infrastructure is uncertain.
The delivery of 3,800 units over the plan period to 2040 is ambitious when there are multiple land owners in play. Delivery could therefore be complex, delayed and incoherent.
There is currently a pending planning application for employment on the site – Ref. 18/02940/EIA – Outline application with all matters reserved except access, for a commercial and industrial development providing up to 780,379 sqm of floorspace for B1, B2 and B8 uses and ancillary service uses (A1, A3, A4 & A5) and associated infrastructure including open space and landscaping.
Barratt Developments are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022 and previous years. Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards Large Developer 2021.
As the land at Box End performs so well but is inexplicitly omitted from the proposed sites within the South of Bedford Area, there is a vulnerability in the approach which is not sound.
We suggest a review of the evidence base and strategy which would lead to a need for more land for housing-led development including identification of land at Box End, west of Bedford