Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10438

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HOU12 states that the Council will prepare a strategic place making framework to guide development across the policy area which will be adopted as a Supplementary Planning Document.
The six matters that Policy HOU12 intends to build upon in the SPD include:
a) Landscape, natural capital and green infrastructure;
b) Internal and external connectivity and active and low carbon travel;
c) Environmental regeneration and remediation;
d) Strategic master planning and placemaking principles;
e) Approaches to governance and stewardship of community assets; and,
f) Infrastructure delivery in accordance with the Council’s Infrastructure Delivery Plan.
National planning guidance (008 Reference ID: 61-008-20190315) states that “supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance
on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan.”
In the case of Policy HOU12, the six matters of focus for the SPD include landscape, connectivity, environmental regeneration, placemaking principles, governance and infrastructure delivery. These are all relatively broad topics that are already guided by the Borough’s general development management policies or separate strategy-making bodies in the area (e.g. Internal Drainage Board). Examples of such policies and strategies are provided below:
• Forest of Marston Vale (Policy 36S and SPD),
• Bedford to Milton Keynes Waterway Park (Policy AD27)
• Placemaking and Design Principles (Policies 28S and 29)
• Environmental Net Gain (Policy DM7)
• Green Infrastructure, Landscape Character, Landscaping in New Development (Policies 35S, 37 and 38)
• Minerals and Waste Restoration (Policy 48)
• Pollution, Disturbance and Contaminated Land (Policy 47S)
• Water Resources and Flood Risk (Policy 50S, 92)
• Resources and Climate Change (Policy DS1[S])
• Impact of transport on people, place and environment (Policy 88)
• Marston Vale Surface Water Plan (IDB)
There is potential here for the SPD to duplicate what is largely covered already in other policies or strategies governing the area but if more innovative or ambitious targets are sought, these should be presented upfront in Policy HOU12 to ensure they meet national planning policy requirements and are tested at examination stage. This is particularly important given the large number of potential development sites affected by this strategic place making framework.
The South of Bedford area covers a large area of the Borough including eight parishes. All of the site specific policies for this area require applications to be accompanied by design codes that accord with the proposed SPD. As the SPD covers such a significant area and number of sites, its preparation and adoption will likely be complex and time consuming. This could hold up several development sites, threatening not only the timely delivery of development but also a significant amount of the Borough’s housing supply and new infrastructure. To avoid this situation, we would recommend that any specific policy objectives and guidance for the South of Bedford be written into Policy HOU12 and not left to an SPD.

Object

Representation ID: 10439

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HOU17 criterion (i) requires preparation of a masterplan and design code to be completed prior to and submitted with any planning application and to accord with the South of Bedford strategic framework. This framework will be detailed further in an SPD and as there is no indication as to when this SPD will be adopted there is a real risk that development in the South of Bedford area will be held up. Site-specific design codes could take several months to develop and if there is a delay in the South of Bedford SPD this could push back submission of applications and housing delivery substantially. We therefore suggest that the policy is more flexible and allows design codes to come forward either as part of an outline application or prior to the submission of the first reserved matters application, as is experienced in other local authority areas.
With respect to HOU17(i), we acknowledge the merits of consultation with the Met Office to ensure the proposals minimise or mitigate any adverse effects on relevant sensitive receptors. The Met Office in this case is a non-statutory consultee, by virtue of it being a neighbouring occupier. It should be noted that the Met Office’s Cardington facility is not a formally safeguarded site as defined by the following Directions that make provisions for such sensitive sites:
• Town and Country Planning (Safeguarded Meteorological Sites) (England) Direction 2014
•
• Town and Country Planning (Safeguarded aerodromes, technical sites, meteorological technical sites and military explosives storage areas) (Scotland) Direction 2016
The facility does not appear on the corresponding Safeguarded Zones Map on the Met Office website (https://www.metoffice.gov.uk/services/business-industry/energy/safeguarding) and therefore it is understood not to benefit from any additional planning protection.
It is therefore important that the consultation process undertaken is proportionate to the status of the Met Office facility and that the delivery of College Farm is not unduly delayed.
Paragraph 4.88 of Policy HOU17 states that “Land at College Farm, Shortstown offers the opportunity for sustainable residential development which will also contribute to the wider South of Bedford area allowing sustainable transport and green infrastructure linkages with Wixams to the west and beyond, including to the Wixams and Stewartby Hardwick railway stations. The proposals will complement the existing development at Shortstown and provide additional facilities including a new Primary School.”
There is no mention in the policy of the need for any other additional facilities that might serve new residents and we think this should be addressed in the policy.
We have progressed our early plans for the site in consultation with the local community and following a public consultation in May this year respondents made clear that there is a desire for more services and facilities across Shortstown to meet the needs of the growing population. Aside from more education and healthcare provision, respondents at our public consultation event highlighted the following elements of infrastructure for enhancement across Shortstown in the future:
a) food store
b) pub or eatery
c) more frequent bus services
d) coffee shop & takeaway
e) gym
With a growing population, we consider there to be clear need for an additional local centre at the College Farm site, which is accounted for in our masterplanning. Currently, the draft policy does not include such provision within the development, which is a missed opportunity to balance the needs of the area and deliver more sustainable development in accordance with Chapter 8 of the NPPF (Promoting healthy and safe communities).
Criterion (xvi) requires “delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change.” There are no specific targets suggested as part of this objective and therefore we would question its relevance to the policy and whether it is required in light of other similar policies in the draft Plan, such as Policy DS1(S) Resources and Climate Change.

Object

Representation ID: 10440

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criterion (iii) of Policy HOU17 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. Criterion (iv) requires submission of a transport assessment including measures to mitigate the impact of development on the local and strategic route network and to maximise opportunities for sustainable travel including provision of a mobility hub (criterion v).
Linked to this site specific policy, is strategic Policy DS3(S), which explains that housing provision across the plan period will need to be “stepped”; continuing at the same rate as it is for Local Plan 2030 for the first five years, with more significant growth post-2030 once critical infrastructure is delivered – in particular transport infrastructure. We have provided a detailed overview of the transport evidence that accompanies the Draft Plan in Appendix A of these representations.
Firstly, the Council should look to ensure that it seeks to meet housing needs consistently across the plan period and not unnecessarily pushing back housing delivery through the use of a stepped trajectory, as outlined in paragraph 68-021of PPG. The use of a stepped trajectory should be a last resort and preference should be given to meeting needs more consistently across the plan period where sustainable.
The Council has identified that development of the Site at College Farm would be directly supported by the proposed improvements to the junction of A421/A600, which includes the introduction of traffic signals on the northbound approach of A600 leading towards the southern roundabout of the dumbbell junction. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 at that junction, we are of the opinion that a ‘Monitor and Manage’ approach should be adopted, in conjunction with the wider and more extensive improvements to widen A421 between A421/A6 and A421/A603 Cambridge Road.
The implementation of an improvement to the junction of A421/A600 should not prejudice either the commencement or the full occupation of dwellings on the Site. The adoption of a ‘Monitor and Manage’ approach would therefore be consistent with the current views of both National Highways and BBC, and any future highway scheme to improve the junction should be assessed as part of the more extensive proposal by National Highways to widen A421.
For the above reason, there is opportunity for College Farm to come forward earlier than anticipated in the Council’s stepped trajectory under Policy DS3(S) and this would go some way to addressing the shortfall in housing supply in the earlier plan period. Currently, the trajectory shows the first homes on College Farm occurring in 2028 due to the timing and need for upfront transport interventions on the A600/A421. We would argue that new homes could be delivered as early as 2025 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

Object

Representation ID: 10441

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criterion (iii) of Policy HOU17 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. Criterion (iv) requires submission of a transport assessment including measures to mitigate the impact of development on the local and strategic route network and to maximise opportunities for sustainable travel including provision of a mobility hub (criterion v).
Linked to this site specific policy, is strategic Policy DS3(S), which explains that housing provision across the plan period will need to be “stepped”; continuing at the same rate as it is for Local Plan 2030 for the first five years, with more significant growth post-2030 once critical infrastructure is delivered – in particular transport infrastructure. We have provided a detailed overview of the transport evidence that accompanies the Draft Plan in Appendix A of these representations.
Firstly, the Council should look to ensure that it seeks to meet housing needs consistently across the plan period and not unnecessarily pushing back housing delivery through the use of
a stepped trajectory, as outlined in paragraph 68-021of PPG. The use of a stepped trajectory should be a last resort and preference should be given to meeting needs more consistently across the plan period where sustainable.
The Council has identified that development of the Site at College Farm would be directly supported by the proposed improvements to the junction of A421/A600, which includes the introduction of traffic signals on the northbound approach of A600 leading towards the southern roundabout of the dumbbell junction. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 at that junction, we are of the opinion that a ‘Monitor and Manage’ approach should be adopted, in conjunction with the wider and more extensive improvements to widen A421 between A421/A6 and A421/A603 Cambridge Road.
The implementation of an improvement to the junction of A421/A600 should not prejudice either the commencement or the full occupation of dwellings on the Site. The adoption of a ‘Monitor and Manage’ approach would therefore be consistent with the current views of both National Highways and BBC, and any future highway scheme to improve the junction should be assessed as part of the more extensive proposal by National Highways to widen A421.
For the above reason, there is opportunity for College Farm to come forward earlier than anticipated in the Council’s stepped trajectory under Policy DS3(S) and this would go some way to addressing the shortfall in housing supply in the earlier plan period. Currently, the trajectory shows the first homes on College Farm occurring in 2028 due to the timing and need for upfront transport interventions on the A600/A421. We would argue that new homes could be delivered as early as 2025 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

Object

Representation ID: 10442

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We note the requirement for a 50% discount to be applied to First Homes which is above the
minimum 30% discount set out in national planning guidance. Whilst national policy does allow for the discount to be increased above 30%, we do not believe that the Borough Wide Viability study demonstrates a clear position that this approach to First Homes is viable. In fact, regarding affordable housing as a whole there are potential concerns regarding several sites and the ability to deliver the 30% of the whole mix.
In the absence of compelling evidence to justify a 50% discount, and instead putting the onus on developers through Policy DM2(S) regarding viability, the approach taken is unsound. We instead suggest that the First Homes discount is reduced to 30% of open market value which is consistent with national planning guidance.

Object

Representation ID: 10443

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM3(S) (Housing Mix) requires all developments of 20 dwellings or more to provide a minimum of 4% of all market housing and 6% of affordable housing to Category 3 standards. However, it does not clarify if such housing should be ‘wheelchair adaptable’ or ‘wheelchair accessible’ as both types exist under this standard.
We would expect application of Category 3 ‘wheelchair adaptable’ standards to apply to market homes and ‘wheelchair accessible’ standards to apply to affordable homes where the council is responsible for nominating the person who lives in that house.