Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10205

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Vision and Objectives of the Plan
2.4 The delivery of greener, more sustainable, more attractive, and prosperous places to live and work within the borough is supported and reflects the overarching goals of the National Planning Policy Framework for the delivery of development nationally. These are addressed throughout the themes and objectives of the plan showing clear recognition of their importance in ensuring the delivery of sustainable development to benefit local communities and their economies. Furthermore, the ‘Vision’ sets out a clear intention to enhance the sustainability of the borough in response to climate change, adapting and mitigating to its effect through various means. This is of growing importance in planning policy and presents clear acknowledgement of the issues and the council’s desire to employ a robust response through the themes and objectives that are set.
2.5 The value of protecting the open countryside through sensitive development is not disputed, local landscapes throughout the borough are of significant value, providing the setting for sporadic rural settlements surrounding the primary settlement of Bedford Town. It is agreed that appropriate development in rural locations is of value in supporting the delivery of much needed housing and employment and rural facilities and services, provided the intrinsic character and beauty of the countryside is respected.
2.6 The ‘Vision’ makes very bold statements about the delivery of infrastructure, and this must go further than to simply ‘support growth’, it must underpin the delivery of the spatial strategy, and be front-loaded so that without it the major strategic allocations do not make a head start and risk overloading the existing substandard network. Major residential development is “much needed” but it cannot be reliant on a strategy that places the burden and control over the delivery of infrastructure to outside stakeholders. Lessons from Wixams will tell us that the process of delivering new settlements takes much longer than at first considered and the delivery of key infrastructure must be implemented before work begins.
2.7 The ‘Vision’ stops short of locating development in the most sustainable locations on the edge of the urban area and the most sustainable rural settlements. This is a flawed approach. This is a new plan and whilst regard should be had the recently adopted plan, it must take its own steps to deliver dwellings in the most sustainable locations on the edge of the most sustainable settlements. Presently it does not do that.
2.8 In summary, the Vision and Objectives outlined are broadly supported if the applied spatial strategy delivers sustainable development throughout the borough in support of existing settlements, whilst acknowledging the importance of delivering infrastructure in advance of new development especially where it is sensitive to the impacts of development on countryside locations.

Object

Representation ID: 10206

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Spatial Strategy
2.9 Draft Policy DS2(S) sets out the spatial strategy, noting development will be focused within the urban area, at strategic locations adjacent to the urban area and at growth locations within the A421 and East West Rail corridor.
2.10 The Spatial Strategy outlines the delivery of development in the urban area through the redevelopment of previously developed land. Whilst the value of this is acknowledged in making effective use of the land, these sites are often challenging to deliver due to the high technical constraints that exist. Contamination, degraded land, ecological issues, legal and title constraints together with leaseholder concerns and the high cost of redevelopment often make these sites very difficult to develop, but moreover they cannot be relied upon to be developed in any fixed period. They are all classic windfall sites, or opportunity sites; but they are not suitable for allocation.
2.11 The allocation of these brownfield sites for redevelopment overlooks their potential to comprise windfall development throughout the plan period. Windfall sites are generally seen as tools in bolstering identified supply and addressing shortfalls in housing delivery but their allocation means that the Council can no longer fall back on these sites to cover under delivery. Their inclusion in the brownfield register (as they all should be) presents its own ‘commitment’ as a potential contribution to overall housing delivery numbers, but to allocate as well is an unsound basis for demonstrating the delivery of ‘new’ housing requirement for the Borough.
2.12 The Spatial Strategy also places significant reliance on the delivery of substantial isolated greenfield sites and new settlements. As outlined in the Stepped Trajectory Topic Paper (2022), that supports the emerging Local Plan, a range of assumptions are made in order facilitate the delivery of these settlements within the plan period. These comprise the delivery of substantial infrastructure projects on which the delivery of new settlements will be wholly reliant. Many of these infrastructure projects have been in the pipeline for a significant period of time and have experienced substantial delays in the past. Their timely implementation cannot be assured and yet the Council rely on this to happen. The reliance placed on the delivery of these strategic greenfield sites and new settlements for the delivery of homes through the Local Plan is considered to comprise significant risk and is highly likely to result in a shortfall throughout the plan period.
2.13 However, the real flaw in the planned spatial strategy is that the Council has not considered all reasonable alternatives and has not sought to identify sites in the most sustainable locations, such as on the edge of the Urban Area, or sustainable rural settlements. These sites have been overlooked in their assessment and we urge that this is reviewed.
2.14 This is the most sustainable location for growth. The Council must include these sites in advance of the identification of new settlement locations, especially where there is clear deliverability and cooperation with landowners and developers to pursue their development.
2.15 It is considered that the Spatial Strategy is flawed, overlooking sustainable locations for development in favour of uncertain new settlements and difficult brownfield sites that should be left as windfall opportunities. The Council has not looked closely at the preferred alternative site locations on the edge of sustainable settlements such as Milton Ernest, where this representation relates.

Object

Representation ID: 10207

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Amount and Timing of Housing Growth (DS3(S))
2.16 The plan covers a 20-year period from 2020-2040 and the spatial strategy deployed in this case sees development and delivery of much needed residential units delayed until the latter half of the plan period to facilitate the lengthy preparation, consultation, submission and consideration of planning applications and the delivery of infrastructure to support existing and future residents. Draft Policy DS3(3) sets out the delivery of housing throughout this period, identifying 9,700 units to be delivered in the first 10-year period and 17,000 to be delivered in the second 10-year period. This is a wholly unrealistic breakdown and places extreme pressure on the second half of the plan. On an annual basis the final ten years of the plan expects a rate of delivery that is nearly twice the previous ten years. Moreover, this has never been achieved in Bedford borough, historically.
2.17 As context, the Housing delivery test identified that in the past three years, Bedford has delivered 964, 1255, 1371, 1371, 1026, and 1203 dwellings per annum in the past 6 years respectively. Significantly below the expectation of 1,700 per annum per year over 10 years. There is a very strong likelihood that the delivery in the second half of the period will delay and reduce leaving a potential huge undersupply of homes.
2.18 Whilst the Council can demonstrate a 5-year housing land supply at this time, this stepped approach that sees housing unevenly distributed throughout the plan period may quickly lead to an under supply. The need for this plan to identify and allocate additional small and medium sites to deliver early homes within the plan period is essential to prevent later delays.
2.19 The STPP trajectory provides an overoptimistic estimation for the delivery of HOU14, HOU16 and Little Barford in particular. To consider that these are reliant on rail and road infrastructure delivery including East West Rail and the infamous A1 ‘Black cat’ roundabout works suggest that first completions are expected in 2030 is simply not realistic. That in year 1, each of those sites are proposed to deliver a minimum of 100 units in the first year is also unrealistic, even if they start on 1st April 2030. To suggest that they might achieve completions of 200 plus from year 2 reaching a staggering 600 units per annum in 2037 at Little Barford is without credibility. Wixams has only delivered around 180 per annum on average over its entire period of delivery.
2.20 It is worth noting that there are three major sites that are relying on the infrastructure being in place for completions to start on site in 2030, therefore it only takes one of those sites to fall-behind and the trajectory is quickly undermined. Although spreading the risk might be considered a benefit on one hand it also increases the risk of partial failure as there are three chances of that happening.
Reliance on outside bodies to deliver vital infrastructure
2.21 The Stepped Trajectory Topic Paper (April 2022) that supports this plan has sought to justify the approach applied to housing delivery in the draft Local Plan. This document notes that “development at the scale required by the Standard Method requires investment at a commensurate scale to unlock growth”. Whilst it is acknowledged that the Standard Method identifies high demand for housing and a comprehensive approach in response to this is required, it is considered that the provision of strategic greenfield development and two new settlements exacerbates this need for investment. Furthermore, if the logic is that large new settlements is an essential long-term solution to the high requirement, then pragmatically the delivery of those settlements should be phased over multiple Local Plans and not compressed into one. History shows that new settlements take more than 20 years to evolve and then complete and this significantly longer than the present plan timetable.
2.22 The STTP at para 2.2 identifies “in particular” both East West Rail and strategic highway improvements need to be delivered to successfully meet the trajectory proposed. These two constraints are extremely difficult to predict and rely on delivery outside of the control of Bedford Borough Council and the land promoters of the sites that rely on their delivery. To base 88% of all allocations in this plan on the delivery of further rail, road and other strategic investment, there needs to be an acknowledgement of the past and a trajectory that builds in flexibility and has a cautious approach to delivery.
Recognising comparable cases (Wixams)
2.23 One of the many rail infrastructure requirements is the new station at Wixams, apparently proposed to be operational by 2024. Assuming this is a correct estimation, and this will no doubt be tested at EiP, one only has to look at how the estimation for this being delivered have over time been delayed; from being an essential requirement and justification for the original designation of the Wixams new settlement, the station has become an afterthought, and will be delivered significantly later than expected. (see Wixams a pertinent case study overleaf – Figure 2).
2.24 This is the credibility of evidence that the Council needs to reflect upon as they build their trajectory and their basis for identifying strategic sites. Knowledge of the past flawed predictions should be taken as a warning to avoid future failure. Wixams is a case that demonstrates the difficulty of making predications on the delivery of key infrastructure that rely on outside control.
The STPP trajectory is flawed
2.25 In short, the trajectory lacks realism, both in terms of the start date for completions and the annual delivery and is therefore highly risky. Reliance on infrastructure provision that is itself reliant on outside bodies undermines the soundness of the trajectory. The STPP lacks realism and there is no recognition to the experiences of the past, such as Wixams, and failing to have regard to such an important understanding of the issues that are faced undermines the credibility and soundness of this plan.
A phased approach to delivery
3.9 As stated above, the council has sought to protect the settlements in the rural area where an existing NP exists. These NPs cover the period to 2030, therefore there is an opportunity to identify land in these communities post 2030. This can either be through a NP review or and for greater certainty we advocate that specific allocations are made in this plan as Post-2030 allocations. This is a phased approach that it is not uncommon, for example Rochford District Council in Essex applied a two phased approach with a policy that allowed the post-2021 sites. For flexibility these could also be brought forward early under certain triggers such as a lack of a five-year land supply.
3.10 The reason why this would work in Bedford Borough is that it would protect the delivery of the NPs and give time for the forward infrastructure delivery of other key strategic sites to make progress and come forward. These Post-2030 sites can then be identified for inclusion in any future LP or NP or be part of a process of delivering dwellings post-2030 alongside other strategic sites.
3.11 It should be noted also that the requirement for 2020-2040 is to deliver an annual 1355 dwellings per annum over the 20 year period (based on 27,100 homes in the period 2020-2040). This requirement begins at 2020 and is higher than the requirement set out in the adopted plan for the same year which is 970 per annum (based on 14,550 homes in the period 2015-30). This demonstrates that in the early years of this plan there is a significant uplift required (385 per annum) before the strategic sites contribute and the best location for this is in the Rural Areas. This should be read alongside the evidence that in 2020 the Housing Delivery Test demonstrated that the deliver was between 1026 and 1203 dwellings in 2020 and therefore the plan in 2020 is already underdelivering against a requirement of 1355 per annum.
3.12 The period 2030-2040 in this plan already looks like a daunting challenge and that period does not have any small to medium sites proposed and an opportunity is being missed to deliver sites that are capable of early releases of housing. This approach will allow a greater number and diversity of sites releasing housing across all of the Borough with all capable of contributing to land supply without the issues of an over concentration in one place.
3.13 If this site is not considered an acceptable site for the first ten years of this plan, as we believe it should be we would ask that it is considered as an inclusion in a phased strategy post 2030.

Object

Representation ID: 10208

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Distribution of Growth (DS5(S))
2.26 Through application of the Standard Method for calculating housing need, a total of 27,100 new homes are required in the borough over the plan period 2020-2040. The Local Plan Review, therefore, needs to facilitate the provision of a further 12,275 residential units through allocations beyond those previously allocated in the Local Plan 2030, adopted in July 2021, and Neighbourhood Plans. This comprises a total increase of 40% in comparison to the housing growth outlined in the Local Plan 2030.
2.27 Draft Policy DS5(S) of the emerging Local Plan 2040 sets out proposals for a total of 13,550 residential units through proposed allocations in line with the Spatial Strategy, resulting in an over delivery of 1,274 units throughout the plan period. The over provision outlined implies shortfalls in delivery with the identified approach are already anticipated and this does add some flexibility, but it is unclear what this is based on. Nonetheless, 1,274 units will not be sufficient in overcoming the potentially significant delays in the delivery of new settlement because of identified risks pertaining to infrastructure delivery and delays in the planning process.
2.28 The draft Policy also refers to the remaining rural areas and villages, however, identifies no additional residential land in these locations. As such, it is not considered relevant to note this within the policy as it does not relate to the distribution of growth as set out in the emerging Local Plan.
[see attachment for Wixams a pertinent case study – Figure 2]
3.0 A Flawed Approach to the Rural Area
3.1 Although reference is made to the role of the rural area in the Spatial Strategy, no formal allocations are made for further development in these locations, other than by reference to new settlements and the two strategic sites at Gibraltar Corner and Willington/Cople. Draft Policy DS2(S) states that development in rural areas will comprise the completion of allocations outlined in the Local Plan 2030 and Neighbourhood Plans. No further development is proposed in these areas as part of the emerging plan. Not only is this a missed opportunity it fails to recognise that the review is intended to apply up to date housing figures from the revised housing needs assessment under the standard methodology and that this applies to 2020 - 2040; not just post 2030. Fundamentally the Council’s position is a political one and affords too much protection to existing communities, at the cost of a misconceived approach to sustainable deliverable development. This needs to be reassessed before the plan is tested at an Examination in Public, because there is a serious risk that the plan is found to be unsound.
3.2 To add to this point, there is no recognition in the plan that the Neighbourhood plans are only projected to 2030 and therefore there is no reason given as to why allocations in the rural areas cannot be identified for post 2030, through a phased approach to delivery. This concept is discussed below.
3.3 The Vision and Objectives seek to promote sustainable growth, and this should be similar to the concept in previous Local Plans in Bedford as the context of the Borough has not changed. It remains a Town and Country Borough with a principle Urban Area and a range of settlements that have different levels of facilities that dictates in a clear hierarchy which are the most sustainable locations for growth.
3.4 The Settlement Hierarchy Addendum (2022) supports the emerging Local Plan 2040. The addendum notes that the Key Service Centres and Rural Service Centres identified to deliver growth as set out in the Local Plan 2030, will not change. The Settlement Hierarchy confirms that 6 settlements in the administrative area comprise Key Service Centres. Most of them have allocated around 500 dwellings to be developed in the plan to 2030, all through Neighbourhood Plans. Only Wilstead with zero dwellings and Wootton with 105 dwellings are lower. Wilstead is affected by the role of Wixams whilst Wootton is arguably underprovided given its scale.
3.5 Based on the Standard Method for calculating housing need a total of 27,100 new homes are required in the borough over the whole plan period 2020-2040, therefore only 7.8% of housing allocated through the Local Plan 2030, Neighbourhood Plans and the emerging Local Plan 2040 is to be delivered in some of the most sustainable settlements in the borough. Yet allocations in these rural areas would be immediately sustainable, would not be subject to significant infrastructure projects and could be delivered quickly to provide housing in response to current housing need.
3.6 The same conclusion can be drawn for Rural Service Centres in the borough, of which there are 10. Whilst it is acknowledged that these settlements are smaller, the settlement hierarchy confirms they still score reasonably high on the rankings. They have good road and public transport links and reasonable levels of service provision. Milton Ernest is the 12th most sustainable rural settlement in the Borough and yet it has an allocation of 25 dwellings through a Neighbourhood Plan, amounting to just over 1.25 dwellings to be delivered per annum over the entire plan period. This is a significantly underprovided for the local need of Milton Ernest as well as its important role in the Borough as a whole.
3.7 More recognition of the importance of rural settlements in meeting housing need over the entire 20-year period is required in this plan. The strategy proposed places emphasis on the use of large strategic sites located in isolated countryside locations, in some cases near to or adjacent to settlements that are in the lower rural settlements and are simply not sustainable.
3.8 The allocation of housing on the edges of existing sustainable rural settlements presents a multitude of benefits both to the settlement and the borough through ensuring quick delivery of housing contributing to housing supply and bolstering the sustainable nature and vitality of smaller settlements in the borough. National Policy recognises this stating “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly.”