Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9885

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

3.1 The Plan states that the result of the standard method is 1,335 new homes per annum between
2020 and 2040. The total for the plan period is 27,100 dwellings. Paragraph 4.7 states that after taking account of 14,824 dwellings committed, the new local plan will need to allocate land to provide a minimum of 12,276 new dwellings. The evidence base does not provide a critical assessment of the committed 14,824 dwellings and that will be necessary as the Plan is examined
as many may have lapsed or not be considered deliverable under the new definition in NPPF 2021.
3.2 Based on the latest affordability ratio we calculate the standard method figure to be Step 1 which is 985 dwellings per annum, with Step 2 increasing it to 1,369 dwellings.
3.3 Paragraph 7.3 of the Sustainability Appraisal Report states a higher growth figure should be considered of LHN plus 10%. It states:
“In considering reasonable alternatives for the amount of housing growth to be provided in the local plan, a lower figure than 12,276 dwellings (or no growth) is not a realistic option because of the National Planning Policy Framework requirement for local plans to meet assessed needs in accordance with the standard method. However this is a minimum number and a higher growth
figure has been considered for the purposes of sustainability appraisal testing although the Plan’s objective is to meet the Standard Methodology requirement. In the absence of any methodology for calculating a higher alternative figure, a 10% uplift to the local housing need assessment is proposed. This would give a requirement for 29,810 dwellings over the plan period. After commitments are deducted, 14,986 dwellings would need to be allocated.”
3.4 We endorse a buffer of at least 10%2, but it has not been carried forward into the Plan. Whilst we agree that there should be a minimum 10% flexibility, we consider there should be a buffer of 20% which is based on the Local Plans Expert Group report to the Communities Secretary and to the Minister of Housing and Planning in March 2016. The report recommends at paragraph 11.4 that the Framework should make clear that local plans should be required to demonstrate a five year land supply but also focus on ensuring a more effective supply of developable land for the medium to long term, plus make provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework.
3.5 As the plan moves forward a buffer of 20% is essential given that some of the growth is reliant on new settlements and significant extensions, made neighbourhood plans and from experience across the county issues arise on the timing of delivery on allocated sites. As we set out below it would also assist with the economic aims of the Arc and deliver much needed affordable homes in Bedford to meet a significant need.
Stepped Requirements
3.6 Paragraphs 4.25 to 4.27 of the Plan proposes a stepped requirement. It states:
“4.25 The significant increase in the housing requirement alongside the focus on new settlements and the infrastructure delivery challenges described above
mean 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 28 and the benefits for the local economy start to be felt.
4.26 Taking account of the infrastructure delivery challenges a stepped trajectory is proposed. The following policies set out the amount and timing of
the delivery of growth to meet identified needs.
4.27 In the years up to 2030 housing supply is provided by sites allocated in Local Plan 2030 and early delivery on additional sites allocated in Local Plan 2040. After 2030, once EWR and highway improvements have been completed, the strategic growth sites allocated in this plan will be able to deliver substantial growth. Furthermore, development on some other urban sites also becomes increasingly viable. Given that the higher development rates in the second half of the plan period are primarily related to the provision of major
infrastructure and strategic sites from 2030 onwards which is required to deliver them, there will be limited scope to bring forward sites to address any shortfall which may arise in the early years of the plan.”
3.7 A number of points arise.
3.8 Firstly, the proposed phasing is not consistent with real housing needs now and there is no evidence to suggest that the need will be less in the early years of the plan. Indeed, Policy 1 (Reviewing the Local Plan 2030) states:
“The plan review will secure levels of growth that accord with government policy and any growth deals that have been agreed. The planning and delivery of strategic growth will be aligned with the delivery of planned infrastructure schemes including the A421 expressway, Black Cat junction, East West Rail link and potentially the A1 realignment.”
3.9 The evidence and the need for this early review both demonstrate the highest levels of housing need being present now, due to persistent failure to meet housing needs in previous years and a very significant backlog of affordable housing.
3.10 Figure 42 and paragraph 5.18 of the ORS LHNA states:
“Based on a detailed review of both the past trends and current estimates our analysis has concluded that 2,119 households are currently living in unsuitable housing and are unable to afford their own housing. This assessment is based on the criteria set out in the PPG and avoids double counting as far as possible.”
3.11 The affordability ratios also demonstrate an increasing affordability issue in Bedford.
GRAPH IN ATTACHMENT
3.12 Meeting this need should not be delayed further by a stepped trajectory which would reduce supply against an increasing demand with the effect of higher house prices and worsening unaffordability.
3.13 Secondly, the proposed phased approach is contrary to paragraph 60 of the Framework, which
requires the Council to support the Government’s objective of ‘significantly boosting’ the supply of homes by bringing forward a sufficient amount and variety of land where it is needed. The origins of the current Framework can be found in the previous Government’s 2017 White Paper:
Fixing our Broken Housing Market, which made it very clear that the cause for the broken market is simple: for too long, not enough homes have been built. The current Government’s ambition is to increase the supply by 300,000 new homes annually which is, as explained in the current Government’s 2020 White Paper: Planning for the Future, a figure which far exceeds the cumulative targets in adopted development plans (187,000 homes per annum) and current delivery (241,000 homes were built in 2018/19). The messages are clear: there is a national housing crisis and boosting the supply of housing now is a critical objective for the Government.
3.14 There are three stepped requirements across the plan, with the first step continuing the existing outdated requirement of 970dpa and the second step barely increasing the requirement. Most of the unmet needs are pushed to the end of the plan period. The Plan is effectively proposing that unmet needs should not just persist for a longer period, but that they will continue to
accumulate for the first 5 years of the plan which when combined with the requirement in the adopted local plan will mean some 10 years of not meet the starting point for housing need in Bedford 3 . This is wholly unacceptable and clearly contrary to the national imperative to significantly boost supply. There is no other provision within national policy or guidance which supports the use of a stepped requirement nor any evidence to suggest the housing market is not capable of delivering significant growth required. If prospective purchasers or those in need of an affordable home are not provided with a home it will exacerbate the housing crisis and/or result in out migration.
3.15 Thirdly, at the Examination the Secretary of State can have no confidence that the higher levels of delivery in later years will ever be applied as a housing requirement. Paragraph 74 of the Framework states:
“Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old.”
3.16 Therefore, when the plan is more than five years old, housing land supply will be assessed against local housing need. On this point, footnote 39 of the Framework clarifies:
“Unless these strategic policies have been reviewed and found not to require updating. Where local housing need is used as the basis for assessing whether a five year supply of specific deliverable sites exists, it should be calculated using the standard method set out in national planning guidance.”
3.17 There is therefore no guarantee that the Council will ever apply the higher stepped housing requirement. Indeed, our experience is that LPAs with a planned housing requirement that is higher than local housing need will simply not undertake a ‘footnote 39 review’ or will determine through that review that the policies do not need updating. To name a few these include East Riding, Horsham, Ribble Valley, Hinkley & Bosworth, Cheshire East, Fylde and Wyre. For Bedford, this could mean prior to the higher stepped requirement in the later part of the LP2040, the LPA may decide to not undertake a ‘footnote 39 review’ so that housing land supply is calculated under the lower standard method. In the event of allocations not delivering as expected at that point, this approach would undermine the NPPF’s objective to allow sustainable windfall sites of all sizes to be brought in to meet needs.
3.18 The fourth is that the Stepped Trajectory Topic Paper (April 2022) and the Plan states that a reason
for the stepped trajectory is that “to support the level of growth required there will be a significant infrastructure need across social, environmental and physical infrastructure. It will require significant investment in health, education and the provision of other public services, as well as green spaces to support healthy lifestyles and transport infrastructure for all modes”. This is a consequence of the chosen development strategy and an alternative would be for extensions to existing settlements which can use the existing services and facilities. There is no evidence that existing settlements do not have the capacity to support new housing. As we set out under DS5(S) those existing communities should continue to have development so that those communities can maintain or improve their sustainability and are not fossilised.
3.19 Therefore, the requirement should not be reduced in the early years of the plan period. The proposed approach is contrary to national policy, in particular paragraph 60 of the Framework, and it is not an appropriate strategy based upon the evidence base. It would compound issues of housing under-delivery at a time when the backlog of needs should be being met as urgently as possible and contrary to the reasons for this early review. Instead of phasing the requirement,
the correct approach is to boost supply in the early years of the plan.
3.20 The allocation of additional sites which are deliverable in the short term could significantly boost supply in the early years of the plan, eradicating the need to employ phasing. Insufficient consideration has been given to this potential strategy through the preparation of the plan and in particular the selection of site allocations. Such small and medium sized sites which are not reliant on strategic infrastructure that can deliver early in the plan period as sustainable extensions to towns and villages. If a stepped requirement is required, then it should be based on a trajectory that factors in early delivery on small and medium sized sites and larger allocations which so not require that new infrastructure. The imperative should be to meet the housing needs sooner and any stepped requirement should be for new settlements only if they form part of the strategy going forward. The Plan should allocate land
for at least 1,369 dwellings per annum on adoption with monitoring provisions to allow for sites to be brought forward earlier if delivery does not keep pace with requirement. With a sufficient mix of the right sites housing completions in the recent past suggest that delivery in excess of 1,335 is achievable in the market with 1,350 dwellings and 1,359 dwellings being completed in 2017-18 and 2018-19 respectively which from the AMRs were from small sites through to large sites. This shows that a mix of sites is necessary to meet the standard method. Therefore, the Council needs to employ an appropriate strategy to deliver the housing needs that have existed for the last 4 years and going forward as set out by the standard method.

Should there be an uplift of Housing Requirement?
3.21 Paragraph 61 of the Framework states:
“To determine the minimum number of homes needed, strategic policies should be 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.”
3.22 Paragraph 2a-010 of the National Planning Practice Guidance (NPPG) states:
“When might it be appropriate to plan for a higher housing need figure than the standard method indicates?
The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities are encouraged to make as much use as possible of previously-developed or brownfield land, and therefore cities and urban centres, not only those subject to the cities and urban centres uplift may strive to plan for more home. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.”
3.23 As set out above, the minimum local housing need figure under the standard methodology is 1,369 new homes a year for the period 2020-2040. This is a total of 27,380 homes. After taking account of the existing commitments, the Plan seeks to make provision for 12,500 homes over the plan period to 2040. However, there should be a critical assessment of the supply undertaken to ensure that the Submission Plan allocates sufficient land to meet the housing requirement and that over-estimation of existing commitment delivery does not result in under-estimation of new allocations. That assessment has not been consulted upon prior to the Submission Plan being prepared. It will be for the Examination to critically assess the existing and new supply as a whole.
Arc Spatial Framework and East West Rail
3.24 As noted in paragraph 1.9 of the Plan, in February 2021 the Government published a policy paper entitled ‘Planning for sustainable growth in the Oxford-Cambridge Arc: an introduction to the spatial framework’. A consultation titled “Creating a vision for the Oxford-Cambridge Arc” ended on 12th October 2021. The consultation states that its purpose is:
“Creating a Vision for the Oxford-Cambridge Arc’, sets out the government’s first public consultation on the Oxford-Cambridge Arc Spatial Framework. We are seeking views to help us create a vision for the Oxford-Cambridge Arc Spatial Framework, and in doing so guide the future growth of the area to 2050.”
3.25 A number of points arise.
3.26 Paragraph 5.5 of the Arc Spatial Framework states:
5.5 We are concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.
And we have heard concerns about the quality and sustainability of new development.
3.27 Paragraph 5,7 states:
5.7 We will also seek to set policies to enable:
• new development to come forward at the scale and speed needed, in sustainable locations, with a focus on brownfield redevelopment;
• new development to support the recovery of nature, new green space that can be accessed by all, resilience to climate change, and protection of highly valued existing green space; and
• housing needs to be met in full, including much-needed affordable housing.
3.28 Paragraph 5.8 states:
“5.8 In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it.
This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself. The government will undertake additional Arc consultations on any specific proposals for such options as appropriate. The Spatial Framework will guide the future growth of the Arc to 2050, including on the question of new housing and infrastructure and will, as part of its development, take into consideration any significant new housing and infrastructure coming forward to meet the Arc‘s ambition.”
3.29 It is clear that the Arc Spatial Framework will impact on Bedford and the scale of housing. Bedford is at the heart of the Arc. Whilst it is too early to give significant weight to the Arc Spatial Framework as the emerging LP2040 is being prepared in parallel with it and “shares many of the overarching principles relating to economic growth and the natural environment”. The East West Rail is in progress and Stage 2 will extend the service from Oxford to Bedford. The full route to Cambridge is expected to be operational by 2030. This is included in the Vision (para 2.1). Given both the Arc and EWR, then planning for an additional 20% of housing not only provides the necessary flexibility required but will also provide homes to meet the economic ambitions of Bedford Borough.

Census 2021
3.30 Paragraph 8 of the ORS Report states:
"The latest official figures from the 2018-based projections show 73.1 thousand households in 2022 and suggest that this will increase to 80.6 thousand households over the period to 2032 based on the 10-year migration trend variant scenario (Fig 1); a growth of 7.5 thousand, equivalent to 10.3%”.
3.31 Figure 58 of the LNHA also uses a starting point of 71,361 households as part of the housing need assessment. However, the 2021 Census figures are now available and for Bedford the total “Number of households with at least one usual resident” at 2021 is 74,900, some 1,800 more households than predicted by the 2018 household projections. This is a materially different starting point and that underestimation should not be carried forward. Rather, the migration trends should apply to the Census figure.

Affordable Homes
3.32 In the case of Bedford, paragraph 5.52 of the Local Housing Needs Assessment (LHNA) states that the affordable needs is 691 dwellings per annum which “represents a substantial proportion of the annual growth of 771 households per annum identified by the ONS 2018-based household projections for the LHN period 2020-2030 (10-year variant, Figure 33)”4. It represents 54% of the standard method figure. This is also a clear indication as to how much of Bedford Borough’s housing growth is (and will continue to be) unaffordable.
3.33 The Standard Method does not assess the affordable housing needs in each LPA area as the PPG5 confirms where it states:
“An affordability adjustment is applied as household growth on its own is insufficient as an indicator of future housing need because:
household formation is constrained to the supply of available properties – new households cannot form if there is nowhere for them to live; and people may want to live in an area in which they do not reside currently, for example to be near to work, but be unable to find appropriate accommodation that they can afford.
The affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes.” (our
emphasis)
3.34 Paragraph: 010 Reference ID: 2a-010-20190220 states:
“Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground;
There may, occasionally, also be situations where previous levels of housing delivery in an area, or previous assessments of need (such as a recently produced Strategic Housing Market Assessment) are significantly greater than the outcome from the standard method. Authorities will need to take this into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.” (our emphasis)
3.35 In the case of Bedford, Step 1 of the Standard Method is 985 dwellings per annum, with Step 2 increasing it to 1,369 dwellings. The affordability uplift is therefore 384 homes, which is significantly below the 691 affordable homes in the LHNA. This is because the affordability ratio as a long-term adjustment to house prices which can only be seen at the end of the plan period and is not meeting those 691 households in need per annum now and throughout the plan period. Therefore, we consider the Council should apply an uplift to meet affordable housing needs.
3.36 To conclude, our position is that the requirement should be treated as a minimum and a flexibility percentage should be considered and in the order of 20%. This would give a reasonable degree of security that should sites not deliver at the rates anticipated it will:
• Help ensure there is a robust five-year housing land supply;
• deliver a greater level of affordable housing in line with the LHNA; and,
• deliver homes to meet the economic ambition of the Arch Spatial Framework.

Comment

Representation ID: 9887

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

2. Plan Period
2.1 With regard to the plan period the Council will need to consider paragraph 22 of the Framework which was published after the start of the consultation. It states:
“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.”
2.2 The Plan sets out a significant level of development and new settlements and/or significant extensions to South Bedford. Given the scale of development, the strategy chosen, the stepped trajectory and ambitious annual delivery rates we consider the 400 dwellings that are shown to be post 2040 is an underestimate. We consider that the plan should be extended to 2050 if the
current proposed strategy involving new settlements is adopted.
2.3 A further point on why the plan period should be extended to 2050 is the consultation on the Arc Spatial Framework. Paragraphs 1.9 and 1.10 of the consultation paper for LP2040 states:
“1.15 In response to this, and in order to create a more joined up and legible process, some local authorities in the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. Government, however, has urged Councils in the Arc to carry on with plan-making and, in Bedford Borough’s case, the consequences of not doing so could be significant for the reasons relating to policies becoming “out of date” described above; so local plan work in Bedford Borough continued.
1.16 Whilst this local plan has emerged alongside rather than after the development of the Arc Spatial Framework, it shares many of the overarching principles relating to a focus on climate change, economic growth and the natural environment..”
2.4 We agree that LP2040 should progress and not be delayed by the Arc Spatial Framework, but we do question whether the two plans will be aligned on the key matters, one of which is the plan period with the Arc Spatial Framework planning to 2050 yet the LP2040 to 2040. This approach is different to other authorities within the Arc which are aligning emerging plans for the period up to 2050, such as West Northamptonshire.

Object

Representation ID: 9896

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

5. Policy DS2(S) Spatial strategy and Policy DS5(S) Distribution of growth
5.1 Policy DS2(S) and Policy DS5(S) sets out the proposed distribution of growth. The key locations are:
• Within the urban area – 1,200
• Strategic locations adjacent to the urban area which contribute to delivering the
Forest of Marston Vale incorporating the Bedford Milton Keynes Waterway Park and
the Bedford River Valley Park – 1,500
• South of Bedford including new settlement 7,050
• Little Barford new settlement 3,800
• Some development will take place beyond the plan period – 400
• Remaining rural area / villages - Completion of sites previously allocated in local plans and neighbourhood plans
5.2 Paragraph 4.31 states:
“Policy DS5S sets out where growth will be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040. There will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres. No new allocations are made in these villages in the Local Plan 2040, although some Parish Councils may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs”.
5.3 We have a number of concerns with the strategy.
5.4 Our first concern is that the total supply from these sites in the plan period is 13,550. When added to the 14,824 dwellings committed, the total is 28,374 dwellings. At 4.7% this does not provide the necessary level of flexibility required in the SA of 10% to meet the requirement. Indeed, it is even lower than the 11% flexibility found acceptable by the examining Inspector in the LP2030.
5.5 Our second concern is that new settlements form part of the strategy. However, paragraph 2.5 of the Development Strategy Topic Paper states:
“The results are summarised in the Issues & Options Consultation - summary and responses document. The (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth options..
5.6 Therefore, the results of the Issues and Options showed that the options for new settlements and dispersed growth were most unpopular. Despite this, new settlements form the bulk of the strategy in the Plan. We questioned the merit in undertaking consultation at the Issues and Options when at that early stage in LP2040 no meaningful account has been given to the public responses and this has been carried forward in the Plan. Our overarching objection is that land adjacent to urban area and higher order sustainable large villages has been dismissed in favour of new settlements and unsustainable allocations (HOU13 and HOU16 for example).
5.7 Some of the proposed allocations have viability issues. For example, the Viability Study states:
“The two largest strategic sites (Little Barford and Kempston Hardwick) are identified as having challenging viability at current costs and values.”
5.8 As to the Development Strategy meeting affordable needs, the Viability Study states:
“Further, the Council’s policies build in an appropriate level of flexibility i.e. Policy DM1 (S) (Affordable Housing) is applied subject to viability and allowing for future reviews of viability as the development progresses.”
5.9 This shows that the Plan is predicated on viability issues being raised and less affordable housing delivered. As we set out under DS3 there is a significant and worsening affordability crisis in Bedford. If the Council are committed to meeting affordable housing needs, and the current strategy is adopted, there will need to be clear monitoring policies to ensure action can be taken as soon as possible to meet affordable needs if allocated sites do not deliver the required on-site affordable homes.
5.10 In the case of extensions to urban areas, paragraph 3.5 states:
“In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area - performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth. However, the adjoining the urban area component performed worse than the urban component in relation to maximising development on previously developed land. The risk of coalescence of rural settlements was also noted.”
5.11 In that context we consider that sites adjoining the urban area and which do not result in coalescence should have been allocated. In Section 7 we set out the merits of the land at Bromham Road, Biddenham (Site ID7432) which should have been allocated on that basis.
5.12 With regard to villages, paragraph 3.6 states:
“3.6 The worst performing component was the village related growth component. It was likely to have a more negative effect than the other components, particularly in relation to reducing carbon dioxide emissions, protecting water resources, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer positive effects than any of the other components of growth.”
5.13 As we set out at the Issues and Options stage, this conclusion must be read in the context that the Development Strategy Topic Paper6 which has a Village Related Growth Option were all based on over 4,000 new homes ranging from 28% to 41% of the total requirement. We do not advocate such a dispersal strategy but clearly recommend that there should be growth at Key Service Villages and Rural Service Centres.
5.14 We consider that the SA has not assessed reasonable alternatives and the options should have assessed a lower total percentage of the total requirement for the Village Related Growth Option and also distinguished between more sustainable Key Service Centres and less sustainable smaller villages, particularly for Wootton which is highly sustainable and lies close to Bedford town and close to Milton Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options for growth at Key Service Centres and Rural Service Centres should have been considered.
5.15 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note that these options state within the ‘parish area’ rather than within or adjacent to parish settlement. Paragraph 3.11 of the Development Strategy states that “development in parishes within the ‘Transport corridor”…. “will not necessarily adjoin existing villages but could be at new locations between a parish”. Development on the edge of existing settlements, and closer to services, are important factors and we consider that new homes would be better located adjacent to settlement boundaries of existing settlements as that is the most sustainable option. Land at Hall End Road, Wootton, which was recommended approval by officers for 81 dwellings, and was considered sustainable in a housing shortfall context, would be one such site adjacent to a Key Service Centre that could accommodate some growth. Land south of Bromham Road, Biddenham, immediately adjacent to the Bedford Urban Area boundary (the most sustainable area in the borough) would also be a logical option for up to 40 homes.
5.16 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby”. (our emphasis)
5.17 The fifth is that it is Intended that if the favoured strategy involves additional development in and around villages, that parish councils will be asked to allocate land in accordance with LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish should be given a housing requirement as required by paragraph 66 of the Framework which states:
“66. Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. Within this overall requirement, strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. Once the strategic policies have been adopted, these figures should not need retesting at the neighbourhood plan examination, unless there has been a significant change in circumstances that affects the requirement.” (our emphasis)
5.18 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban related growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include urban-related growth.
5.19 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs) and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated April 2022. At the time of the Draft Plan this report was not available as there was a “review underway” and was “not yet available for comment, but will be finalised in order to support the plan for submission (2022)”. We highlighted that it is important that this should be the subject of consultation prior to the Submission Plan being published so that any issues are considered prior to the spatial strategy evolving and reducing any potential objections to a key part of LP2040. Whilst it is part of the evidence base, any objections are to go before the Examination rather than being considered prior to Submission. This point applies with even greater force to the HELAA where factual errors or unchecked judgements have resulted in sites not being allocated. If these matters were picked up following consultation, then the evidence base would have been more robust. We examine issues with the HELAA in later sections.
5.20 One of our specific interests is Wootton which is one of the 8 Key Service Centres. In the settlement hierarchy paper, it is one of the most sustainable settlements in the borough. Policy 4S of the LP2030 sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169 dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000 dwellings should be located at Key Service Centres of which Wootton is one. The policy then continues when it states:
“it will be necessary to identify sites to meet the following levels of development, generally in and around defined Settlement Policy Area boundaries. Other than in Roxton, all sites will be allocated in Neighbourhood Development Plans. In rural service centres allocations may exceed 50 dwellings where specific local justification is set out in Neighbourhood Plans demonstrating that it would be appropriate in terms of the scale, structure, form and character of the settlement and the capacity of local infrastructure”
5.21 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there is no specific requirement proposed for Wootton. This was explained in the 2017 version of the LP2030 because Wootton had expanded in recent years. This should not be seen as further development at Wootton not being appropriate; rather it confirms its suitability and capacity as a location for growth. We consider that going forward Wootton should be identified as a location for growth and given a specific requirement. This should be at least 500 dwellings as set out in Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030 and form part of the committed 13,000 dwellings. These settlements could get less or as was the case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have a specific requirement of at least 500 dwellings especially due to its sustainability credentials and its close relationship to Bedford town. If there is a concern about the effects of recent development in Wootton, which in our view do not stand up to scrutiny, there is no reason why the Council cannot suggest a requirement to Wootton to be delivered
later in the plan period.
5.22 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that development should not occur.”
5.23 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed within site specific policies W3 to W6. Development in excess of this figure will only be permitted where the proposal relates to a site within the SPA in accordance with Policy W1.”
5.24 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale of development in the WNDP, with 73% of respondents strongly agreeing/agreeing with the allocation of sites sufficient to accommodate a total of 145 residential units within the plan period, on the basis of need ascertained by the Housing Needs Survey. This survey aimed to assess the need of local people for either affordable housing or market housing in Wootton, at the time when it was envisaged that the Bedford Borough Local Plan would cover the period to 2035. The quantum of development has been marginally reduced in response to further resident feedback and to reflect the reduced Local Plan period to 2030.”
5.25 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the 105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of the existing residents of Wootton and it takes no account of the newly forming households and the increase in households in the plan period across Bedford Borough that the standard method calculates. This is a particularly important point as the LP2040 consultation confirms that capacity within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet needs of which Wootton can play an important role. However, it demonstrates a continuing need for new housing in Wootton which LP2040 should plan to meet.
5.26 Paragraph 4.12 of the Education Paper states that “Wootton has expanded significantly in recent years and development is soon to commence on land south of Fields Rd. Initially it was thought that there may be scope for some additional capacity in local schools later in the plan period but updated school numbers show that this is unlikely to be the case”. This is not evidenced in that document, yet the IDP states that there is a surplus of 328 places (Figure 48ID). Are these surplus places being taken up by the less sustainable allocations such as HOU13 and HOU16? For example, HOU13 requires a secondary school contribution which demonstrates there is capacity to expand existing schools. Therefore, we have significant reservations on the evidence base and how it has been used to prepare the Plan.
5.27 This was a matter assessed by the Examiner for the Neighbourhood Plan. Paragraphs 4.16 to 4.18 state:
“4.16 Up to 105 dwellings are proposed in policy W2 but it is made clear that this figure could be exceeded on suitable sites within the Settlement Policy Area, subject to the requirements of Policy W1 being met. This approach is based on the findings of the Housing Needs Survey (2017) and is supported by a majority of the local community. I am aware that Wootton is defined within the Bedford Local Plan as a ‘key service centre’ and on my visit I noted the wide range of community facilities and services available. However, I also saw that there has been significant development in the area over recent years and I consider that the Parish Council has adequately justified the reduction in housing numbers from 145 (as set out in policy W2 of the Pre-Submission version of the WNDP document – September 2020) to 105. This reduction is based primarily on resident feedback during consultation on the pre-submission version of the Plan and to reflect the reduced Bedford Borough Local Plan period from 2035 to 2030.
4.17 I note that some local residents questioned the need for more housing in the village and suggested that Wootton has ‘reached the limit’12. However, the housing figure is based on the Housing Needs Survey (2017) and NPPF section 5 confirms that it is the Government’s objective to significantly boost the supply of homes. Paragraph 11 of the NPPF confirms that a sustainable pattern of development should be promoted. I consider that the wide range of community facilities and services that are available in Wootton contribute significantly to its credentials as a sustainable location for development.
4.18 Conversely it was suggested that in order to ‘boost the supply of homes’ 13 more housing should be allocated, and for example, it was suggested that there should be an allocation at the Chequers Public House14. On current evidence I am satisfied that the Parish Council has satisfactorily justified its approach15, but circumstances may change with the adoption of the Bedford Local Plan Review (scheduled for 2023) and that is one of the reasons I am recommending that the WNDP is reviewed every two years (see paragraph 4.56).”
5.28 Paragraph 4.10 referred to the out of date nature of the housing needs and proposed an early review. It states:
“4.10 The Parish Council has based its housing requirement on the 2017 Housing Needs Survey (with a reduction to take into account the reduced Local Plan Period from 2035 to 2030). The Borough Council has not objected to this approach and bearing in mind I am recommending review of the WNDP every 2 years (see paragraph 4.56), I am satisfied that, at this time, sufficient land has been identified for housing development in the village.”
5.29 Therefore, the Plan is wrong to suggest that sites are not required in Wootton given the dwellings delivered to date and commitments. The Examiner proposing an early review confirms that housing needs need to reassessed to meet current and future needs.
5.30 It is clear that the housing needs of the area will not
be met the most sustainable village as set out in Appendix 3 of the Settlement Hierarchy with Addendum which scores Wootton as the highest of the 80 settlements assessed. The Plan needs to be altered to identify a specific requirement for Wootton.

Object

Representation ID: 9897

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

5. Policy DS2(S) Spatial strategy and Policy DS5(S) Distribution of growth
5.1 Policy DS2(S) and Policy DS5(S) sets out the proposed distribution of growth. The key locations are:
• Within the urban area – 1,200
• Strategic locations adjacent to the urban area which contribute to delivering the
Forest of Marston Vale incorporating the Bedford Milton Keynes Waterway Park and
the Bedford River Valley Park – 1,500
• South of Bedford including new settlement 7,050
• Little Barford new settlement 3,800
• Some development will take place beyond the plan period – 400
• Remaining rural area / villages - Completion of sites previously allocated in local plans and neighbourhood plans
5.2 Paragraph 4.31 states:
“Policy DS5S sets out where growth will be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040. There will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres. No new allocations are made in these villages in the Local Plan 2040, although some Parish Councils may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs”.
5.3 We have a number of concerns with the strategy.
5.4 Our first concern is that the total supply from these sites in the plan period is 13,550. When added to the 14,824 dwellings committed, the total is 28,374 dwellings. At 4.7% this does not provide the necessary level of flexibility required in the SA of 10% to meet the requirement. Indeed, it is even lower than the 11% flexibility found acceptable by the examining Inspector in the LP2030.
5.5 Our second concern is that new settlements form part of the strategy. However, paragraph 2.5 of the Development Strategy Topic Paper states:
“The results are summarised in the Issues & Options Consultation - summary and responses document. The (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth options..
5.6 Therefore, the results of the Issues and Options showed that the options for new settlements and dispersed growth were most unpopular. Despite this, new settlements form the bulk of the strategy in the Plan. We questioned the merit in undertaking consultation at the Issues and Options when at that early stage in LP2040 no meaningful account has been given to the public responses and this has been carried forward in the Plan. Our overarching objection is that land adjacent to urban area and higher order sustainable large villages has been dismissed in favour of new settlements and unsustainable allocations (HOU13 and HOU16 for example).
5.7 Some of the proposed allocations have viability issues. For example, the Viability Study states:
“The two largest strategic sites (Little Barford and Kempston Hardwick) are identified as having challenging viability at current costs and values.”
5.8 As to the Development Strategy meeting affordable needs, the Viability Study states:
“Further, the Council’s policies build in an appropriate level of flexibility i.e. Policy DM1 (S) (Affordable Housing) is applied subject to viability and allowing for future reviews of viability as the development progresses.”
5.9 This shows that the Plan is predicated on viability issues being raised and less affordable housing delivered. As we set out under DS3 there is a significant and worsening affordability crisis in Bedford. If the Council are committed to meeting affordable housing needs, and the current strategy is adopted, there will need to be clear monitoring policies to ensure action can be taken as soon as possible to meet affordable needs if allocated sites do not deliver the required on-site affordable homes.
5.10 In the case of extensions to urban areas, paragraph 3.5 states:
“In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area - performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth. However, the adjoining the urban area component performed worse than the urban component in relation to maximising development on previously developed land. The risk of coalescence of rural settlements was also noted.”
5.11 In that context we consider that sites adjoining the urban area and which do not result in coalescence should have been allocated. In Section 7 we set out the merits of the land at Bromham Road, Biddenham (Site ID7432) which should have been allocated on that basis.
5.12 With regard to villages, paragraph 3.6 states:
“3.6 The worst performing component was the village related growth component. It was likely to have a more negative effect than the other components, particularly in relation to reducing carbon dioxide emissions, protecting water resources, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer positive effects than any of the other components of growth.”
5.13 As we set out at the Issues and Options stage, this conclusion must be read in the context that the Development Strategy Topic Paper6 which has a Village Related Growth Option were all based on over 4,000 new homes ranging from 28% to 41% of the total requirement. We do not advocate such a dispersal strategy but clearly recommend that there should be growth at Key Service Villages and Rural Service Centres.
5.14 We consider that the SA has not assessed reasonable alternatives and the options should have assessed a lower total percentage of the total requirement for the Village Related Growth Option and also distinguished between more sustainable Key Service Centres and less sustainable smaller villages, particularly for Wootton which is highly sustainable and lies close to Bedford town and close to Milton Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options for growth at Key Service Centres and Rural Service Centres should have been considered.
5.15 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note that these options state within the ‘parish area’ rather than within or adjacent to parish settlement. Paragraph 3.11 of the Development Strategy states that “development in parishes within the ‘Transport corridor”…. “will not necessarily adjoin existing villages but could be at new locations between a parish”. Development on the edge of existing settlements, and closer to services, are important factors and we consider that new homes would be better located adjacent to settlement boundaries of existing settlements as that is the most sustainable option. Land at Hall End Road, Wootton, which was recommended approval by officers for 81 dwellings, and was considered sustainable in a housing shortfall context, would be one such site adjacent to a Key Service Centre that could accommodate some growth. Land south of Bromham Road, Biddenham, immediately adjacent to the Bedford Urban Area boundary (the most sustainable area in the borough) would also be a logical option for up to 40 homes.
5.16 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby”. (our emphasis)
5.17 The fifth is that it is Intended that if the favoured strategy involves additional development in and around villages, that parish councils will be asked to allocate land in accordance with LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish should be given a housing requirement as required by paragraph 66 of the Framework which states:
“66. Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. Within this overall requirement, strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. Once the strategic policies have been adopted, these figures should not need retesting at the neighbourhood plan examination, unless there has been a significant change in circumstances that affects the requirement.” (our emphasis)
5.18 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban related growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include urban-related growth.
5.19 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs) and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated April 2022. At the time of the Draft Plan this report was not available as there was a “review underway” and was “not yet available for comment, but will be finalised in order to support the plan for submission (2022)”. We highlighted that it is important that this should be the subject of consultation prior to the Submission Plan being published so that any issues are considered prior to the spatial strategy evolving and reducing any potential objections to a key part of LP2040. Whilst it is part of the evidence base, any objections are to go before the Examination rather than being considered prior to Submission. This point applies with even greater force to the HELAA where factual errors or unchecked judgements have resulted in sites not being allocated. If these matters were picked up following consultation, then the evidence base would have been more robust. We examine issues with the HELAA in later sections.
5.20 One of our specific interests is Wootton which is one of the 8 Key Service Centres. In the settlement hierarchy paper, it is one of the most sustainable settlements in the borough. Policy 4S of the LP2030 sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169 dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000 dwellings should be located at Key Service Centres of which Wootton is one. The policy then continues when it states:
“it will be necessary to identify sites to meet the following levels of development, generally in and around defined Settlement Policy Area boundaries. Other than in Roxton, all sites will be allocated in Neighbourhood Development Plans. In rural service centres allocations may exceed 50 dwellings where specific local justification is set out in Neighbourhood Plans demonstrating that it would be appropriate in terms of the scale, structure, form and character of the settlement and the capacity of local infrastructure”
5.21 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there is no specific requirement proposed for Wootton. This was explained in the 2017 version of the LP2030 because Wootton had expanded in recent years. This should not be seen as further development at Wootton not being appropriate; rather it confirms its suitability and capacity as a location for growth. We consider that going forward Wootton should be identified as a location for growth and given a specific requirement. This should be at least 500 dwellings as set out in Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030 and form part of the committed 13,000 dwellings. These settlements could get less or as was the case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have a specific requirement of at least 500 dwellings especially due to its sustainability credentials and its close relationship to Bedford town. If there is a concern about the effects of recent development in Wootton, which in our view do not stand up to scrutiny, there is no reason why the Council cannot suggest a requirement to Wootton to be delivered
later in the plan period.
5.22 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that development should not occur.”
5.23 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed within site specific policies W3 to W6. Development in excess of this figure will only be permitted where the proposal relates to a site within the SPA in accordance with Policy W1.”
5.24 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale of development in the WNDP, with 73% of respondents strongly agreeing/agreeing with the allocation of sites sufficient to accommodate a total of 145 residential units within the plan period, on the basis of need ascertained by the Housing Needs Survey. This survey aimed to assess the need of local people for either affordable housing or market housing in Wootton, at the time when it was envisaged that the Bedford Borough Local Plan would cover the period to 2035. The quantum of development has been marginally reduced in response to further resident feedback and to reflect the reduced Local Plan period to 2030.”
5.25 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the 105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of the existing residents of Wootton and it takes no account of the newly forming households and the increase in households in the plan period across Bedford Borough that the standard method calculates. This is a particularly important point as the LP2040 consultation confirms that capacity within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet needs of which Wootton can play an important role. However, it demonstrates a continuing need for new housing in Wootton which LP2040 should plan to meet.
5.26 Paragraph 4.12 of the Education Paper states that “Wootton has expanded significantly in recent years and development is soon to commence on land south of Fields Rd. Initially it was thought that there may be scope for some additional capacity in local schools later in the plan period but updated school numbers show that this is unlikely to be the case”. This is not evidenced in that document, yet the IDP states that there is a surplus of 328 places (Figure 48ID). Are these surplus places being taken up by the less sustainable allocations such as HOU13 and HOU16? For example, HOU13 requires a secondary school contribution which demonstrates there is capacity to expand existing schools. Therefore, we have significant reservations on the evidence base and how it has been used to prepare the Plan.
5.27 This was a matter assessed by the Examiner for the Neighbourhood Plan. Paragraphs 4.16 to 4.18 state:
“4.16 Up to 105 dwellings are proposed in policy W2 but it is made clear that this figure could be exceeded on suitable sites within the Settlement Policy Area, subject to the requirements of Policy W1 being met. This approach is based on the findings of the Housing Needs Survey (2017) and is supported by a majority of the local community. I am aware that Wootton is defined within the Bedford Local Plan as a ‘key service centre’ and on my visit I noted the wide range of community facilities and services available. However, I also saw that there has been significant development in the area over recent years and I consider that the Parish Council has adequately justified the reduction in housing numbers from 145 (as set out in policy W2 of the Pre-Submission version of the WNDP document – September 2020) to 105. This reduction is based primarily on resident feedback during consultation on the pre-submission version of the Plan and to reflect the reduced Bedford Borough Local Plan period from 2035 to 2030.
4.17 I note that some local residents questioned the need for more housing in the village and suggested that Wootton has ‘reached the limit’12. However, the housing figure is based on the Housing Needs Survey (2017) and NPPF section 5 confirms that it is the Government’s objective to significantly boost the supply of homes. Paragraph 11 of the NPPF confirms that a sustainable pattern of development should be promoted. I consider that the wide range of community facilities and services that are available in Wootton contribute significantly to its credentials as a sustainable location for development.
4.18 Conversely it was suggested that in order to ‘boost the supply of homes’ 13 more housing should be allocated, and for example, it was suggested that there should be an allocation at the Chequers Public House14. On current evidence I am satisfied that the Parish Council has satisfactorily justified its approach15, but circumstances may change with the adoption of the Bedford Local Plan Review (scheduled for 2023) and that is one of the reasons I am recommending that the WNDP is reviewed every two years (see paragraph 4.56).”
5.28 Paragraph 4.10 referred to the out of date nature of the housing needs and proposed an early review. It states:
“4.10 The Parish Council has based its housing requirement on the 2017 Housing Needs Survey (with a reduction to take into account the reduced Local Plan Period from 2035 to 2030). The Borough Council has not objected to this approach and bearing in mind I am recommending review of the WNDP every 2 years (see paragraph 4.56), I am satisfied that, at this time, sufficient land has been identified for housing development in the village.”
5.29 Therefore, the Plan is wrong to suggest that sites are not required in Wootton given the dwellings delivered to date and commitments. The Examiner proposing an early review confirms that housing needs need to reassessed to meet current and future needs.
5.30 It is clear that the housing needs of the area will not
be met the most sustainable village as set out in Appendix 3 of the Settlement Hierarchy with Addendum which scores Wootton as the highest of the 80 settlements assessed. The Plan needs to be altered to identify a specific requirement for Wootton.

Object

Representation ID: 9898

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU12 South of Bedford area
5.31 We have significant reservations on how land has been allocated in the south of Bedford area where priority has been given to new settlements and extensions to less sustainable settlements, with such extensions likely to more than double the size of the existing communities. This has been chosen over extensions to more sustainable settlements for example Wootton. It is clear that HOU13 and HOU14 will rely on Wootton for services and facilities but journeys are likely to be by car. Extensions to Wootton would promote shorter journeys by alternative means such as by foot and cycle.

Object

Representation ID: 9899

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

HOU13 Land at Gibraltar Corner, Kempston Rural
5.32 Notwithstanding the Plan has proposed an allocation of land surrounding Gibraltar Corner, Kempston Rural which is a small residential estate west of the A6. We object to HOU13 as it is proposing significant development in this isolated location which is clearly not as sustainable as an extension to Wootton or adjoining the Bedford urban area. In the Settlement Hierarchy it is a Group 4 settlement (the lowest category) scoring a total of 8, which is for bus services. It did not score for any other service or facility. Policy HOU13 sets out requirements for development but as can be seen by criteria iv, v, vii residents will rely on vehicular connections to more sustainable locations, including Wootton and Biddenham. It is not a new settlement but a larger residential estate in the open countryside. With a need for houses in the area as established by HOU13 and HOU14, then Wootton would be the most sustainable location to deliver some of this need.

Object

Representation ID: 9900

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

HOU13 Land at Gibraltar Corner, Kempston Rural
5.32 Notwithstanding the Plan has proposed an allocation of land surrounding Gibraltar Corner, Kempston Rural which is a small residential estate west of the A6. We object to HOU13 as it is proposing significant development in this isolated location which is clearly not as sustainable as an extension to Wootton or adjoining the Bedford urban area. In the Settlement Hierarchy it is a Group 4 settlement (the lowest category) scoring a total of 8, which is for bus services. It did not score for any other service or facility. Policy HOU13 sets out requirements for development but as can be seen by criteria iv, v, vii residents will rely on vehicular connections to more sustainable locations, including Wootton and Biddenham. It is not a new settlement but a larger residential estate in the open countryside. With a need for houses in the area as established by HOU13 and HOU14, then Wootton would be the most sustainable location to deliver some of this need.

Object

Representation ID: 9901

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU15 Land south of Wixams and Policy HOU16 Land at East Wixams
5.33 The site is located to the east of the A6 and the existing Wixams development. Figure 8 shows this to be a disparate allocation of three residential parcels one of which (HOU15) is a logical extension to the village. The other two parcels (HOU16) are on the opposite side to the A6 and the largest parcel is a standalone development. In the Settlement Hierarchy Wixams scores 55 points whereas Wootton scores 92 points. Despite this clear difference Wootton has not been allocated. As with HOU13 residents will rely on vehicular connections to more sustainable locations.
5.34 The spatial strategy and distribution of development in the Plan requires a fundamental change and greater concentration of sites adjacent to existing settlements. At present Policy DS5(S) is not justified when utilising the evidence base, is not in accordance with national policy and is not effective in delivering housing needs in the most sustainable locations.

Object

Representation ID: 9902

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU15 Land south of Wixams and Policy HOU16 Land at East Wixams
5.33 The site is located to the east of the A6 and the existing Wixams development. Figure 8 shows this to be a disparate allocation of three residential parcels one of which (HOU15) is a logical extension to the village. The other two parcels (HOU16) are on the opposite side to the A6 and the largest parcel is a standalone development. In the Settlement Hierarchy Wixams scores 55 points whereas Wootton scores 92 points. Despite this clear difference Wootton has not been allocated. As with HOU13 residents will rely on vehicular connections to more sustainable locations.
5.34 The spatial strategy and distribution of development in the Plan requires a fundamental change and greater concentration of sites adjacent to existing settlements. At present Policy DS5(S) is not justified when utilising the evidence base, is not in accordance with national policy and is not effective in delivering housing needs in the most sustainable locations.