Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9875

Received: 28/07/2022

Respondent: Taylor Wimpey

Our main area of concern is in relation to the approach that has underpinned the development strategy set out in Policy DS(2) and the potential implications that this will have.
As part of their proposed development strategy, the Council have attempted to focus new housing within the existing urban area of Bedford and this is in keeping with the principle of sustainable development as stipulated in the National Planning Policy Framework (NPPF) (2021). However, as evidenced by the Call for Sites process, there are a limited number of available sites within the urban area and the Council have therefore attempted to identify sustainable locations for residential growth elsewhere, in particular, through the provision of large, strategic allocations.
Whilst Taylor Wimpey recognise that large, strategic sites have a key role to play in a development strategy, we consider that the growth strategy proposed by Bedford Borough Council places an over reliance on large allocations. This is to the extent that there are four new large settlements or significant urban extensions proposed as part of the Local Plan Development Strategy: Shortstown, Kempston Hardwick, Gibraltar Corner and Little Barford and no small/medium sized sites, aside from existing commitments. This will have a significant impact on the ability of the Plan to support the delivery of homes in a timely manner.
The focus on large settlements/urban extensions will have a detrimental impact on the ability of the Council to meet housing requirements in the short to medium term, even with a stepped trajectory (discussed further below). This to the extent that, we don’t believe that the Council will be able to demonstrate a deliverable five-year housing land supply on adoption of the plan and potentially beyond.
Proposing allocations in the more sustainable villages in the 2040 Review would have gone a long way in terms of bolstering the short-medium term housing land supply position, which is currently lacking.
The methodology and evidence underpinning the decision to exclude the villages is poorly justified in both the Sustainability Appraisal and the Development Strategy and Site Selection Topic Paper.
The topic paper states that when considering development options: ‘The worst performing component is the village related growth component. It is 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 is likely to have fewer positive effects than any of the other components of growth.’
However, the assessment criteria used prior to the Regulation 18 consultation process requires scrutiny. Whilst it is important to give consideration to the key areas of ‘Greener’, ‘More Accessible’, ‘More Prosperous’ and ‘Better Places’, the key practical matter of the deliverability of the strategy as a whole and issues that might result from opting for different options e.g. land assembly, viability, timescales, deliverability, previously developed land, site-specific benefits, infrastructure, etc appears to have been ignored. Had these matters been considered in more detail it is likely that additional growth in villages would have been seen as a more favourable option. Following the Regulation 18 consultation, a secondary round of work to support the development strategy was undertaken, however this also neglected the majority of these key considerations.
Linked to the above, the Council have failed to plan for 10% of their housing requirement being delivered on sites of 1ha or less as per the requirement of paragraph 69 of the NPPF. The Council, in their Small Sites Topic Paper, state that they consider that they will deliver well in excess of what is required by the NPPF through windfall development and neighbourhood plans, however the approach taken is not consistent with the NPPF which states that this provision should be identified in either the local plan or in a brownfield register. The purpose of this national policy is to provide the certainty through an allocation in a local plan.
Additionally, as is touched on further below, in our view, the anticipated delivery rates attached to the large allocations conflicts with typical rates for comparable sites. We consider that the Council have been overoptimistic in terms of the output rate of sites both in terms of average and peak delivery rates. For example, at both Kempston Hardwick and Little Barford, over the final 10 years of the plan, it is stated that these sites will deliver on average 380 dwellings a year and have a peak delivery rate of 600 homes between 2037/38-2039/40. The justification for these delivery rates is not provided and they appear high compared to evidence from similar scale schemes elsewhere (see Lichfields’ Start to Finish report 2nd edition Feb 2020 for a comparison). The housing trajectory should be amended to reflect evidence on delivery rates. When this adjustment is made, the Council will find that forecast housing delivery will fall short of that which is required to meet the housing requirement., meaning the development strategy set out in policy DS2 is unsound.
Ultimately, it is clear that no real consideration was given as to whether the villages in Bedford Borough can or should form part of the development strategy. Given the issues associated with the development strategy identified above we consider that, as proposed, it cannot be relied upon to deliver the identified housing requirement and is therefore unsound in its current form. This can only be remedied through the consideration of a more dispersed pattern of growth an allocations in sustainable rural settlements, such as Wilstead and Willington.

Comment

Representation ID: 9876

Received: 28/07/2022

Respondent: Taylor Wimpey

In terms of the amount of housing, we have a concern that the Council are relying on the standard method housing figure as the housing requirement without considering in more detail if a higher target would be appropriate.
The PPG at several points, including paragraph 10 (reference ID: 2a-010-20201216) is clear that the standard method provides the minimum starting point for determining how many homes are needed in an area – it does not set the requirement. It lists a number of circumstances where housing need in the future may be higher than the standard method indicates, including where there are strategic infrastructure improvements that are likely to drive an increase in the demand for homes. This is the exact situation in Bedford with East West Rail and the highway improvements to the east of Bedford, which will massively improve access to Cambridge.
The Sustainability Appraisal does briefly consider alternative numbers, immediately ruling out a lower number. When discussing a higher alternative housing figure it states: ‘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.’
This matter is then revisited at Section 9.2 of the Sustainability Appraisal where it briefly states that the Council have adopted the Government’s Standard Methodology housing figure. The decision not to use a higher alternative housing requirement is justified on that basis that:
“A higher level of growth that exceeds housing needs would result in a number of negative effects on sustainability appraisal objectives which exceed the benefit of the identified positive effects. Such higher growth is not a reasonable option. It would not be deliverable and would not be supported by the Council because of the lack of evidence to show that a higher level of growth is required and the perceived negative effects on existing communities and the environment. A growth option which meets the assessed housing need for growth (including a buffer) is the only reasonable option.”
We contend that this is insufficient analysis to consider if a higher requirement could be appropriate and that this needs to be revisited for the Plan to be sound.
The use of a stepped trajectory as proposed is consistent with the National Planning Practice Guidance (reference ID: 68-021-20190722). However, this should only be on the basis on the relationship with planned infrastructure and should not unduly delay the delivery of housing to meet local needs, as is made clear in the PPG.
We have a concern that the stepped approach set out in DS3 will conflict with this requirement by unnecessarily delaying the delivery of homes. As is set out in our comments on policy DS5 below, to rely solely on existing commitments in the rural area and villages is a fundamental error of the plan is it negates the important contribution the small and medium sized sites in the larger villages can make to meeting short term housing need without a need for significant infrastructure investment. Therefore, whilst we agree that a stepped trajectory may be capable of being justified in the Plan, the way it is currently drafted is unsound as it unnecessarily delays the delivery of housing.

Comment

Representation ID: 9877

Received: 28/07/2022

Respondent: Taylor Wimpey

Policy DS5(S) sets out how the level of growth set out in policy DS3 will be distributed across Bedford Borough. Notwithstanding the points made above about the housing requirement and the overall development strategy, we have particular concerns about the distribution of growth.
The main issue is that the distribution does not appear to factor in any buffer on the supply side. The inclusion of a 10% buffer, as a minimum, should be factored into the supply of housing in order to act as a contingency for under-delivery on identified sites. This is a fairly standard approach taken with Local Plans in order to ensure that housing targets are met and that plans have flexibility built in. This would help to ensure that the requirements of paragraph 68 of the National Planning Policy Framework (NPPF) (2021), which stipulates that council’s should plan for a deliverable supply of land for years 1-5 of the plan plus an appropriate buffer to be identified, will be achieved.
Given the reliance on strategic scale sites, it is suggested that a larger buffer may be appropriate given the risk to the delivery of homes that is associated with a limited supply of large sites.
As noted above, we have a fundamental concern that by not allocating any development to sustainable rural settlements, such as Wilstead and Willington, the ability of the plan to meet its housing need in a timely manner is unduly affected. In considering the strategy in the adopted Local Plan, it was deemed appropriate and sustainable to focus growth on certain settlements. The proposed approach goes away from this without a proper justification and our view is that to be sound, further consideration needs to be given to the role that settlements such as Wilstead and Willington pay in the Local Plan.
Site Assessment Process
We would also like to re-iterate our concerns, as expressed in our Regulation 18 representation prepared by Bidwells, regarding the shortcomings of the Council’s Call for Sites Assessment Process which fed into the development strategy.
The site assessment forms lack any detailed assessment and have not been underpinned by a review of all the evidence available to the Council; colleagues in other departments (such as heritage, highways, etc.) do not appear to have been consulted as part of this process, including the development management team. When looking at the assessment of our own sites in both Wilstead and Willington, the information stated conflicts with information provided by ourselves and the conclusions reached by Council Officers on recent planning applications (on important matters such as previously developed land, heritage, etc). These forms also do not consider the potential benefits that sites could offer which should be a consideration in the suitability and sustainability of sites.
Given our aforementioned concerns in relation to the development strategy, we are concerned that a large number of sites were discarded on the basis of their conflict with the development strategy as part of this assessment process. The site assessment work should feed into the formulation of a development strategy - it should be a two-way process. However, from the Sustainability Appraisal and Topic Paper, it instead seems that the site assessment work was undertaken in a bubble and the information was only used to fit an independently developed strategy.
General Compilation
The Council have failed to properly collate previous planning policies into a single, clear planning document and instead simply save policies from previous Development Plan documents.
The emerging development plan comprises policies from the document itself (Local Plan 2040), the Local Plan 2002, Bedfordshire and Luton Minerals and Waste Local Plan 2005, the Allocations and Designations Local Plan 2013 and the Local Plan 2030.
Paragraph 16 of the NPPF is clear that plans should ‘contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals’, as well as ‘be accessible through the use of digital tools to assist public involvement and policy presentation’.
With how the plan is currently drafted, the requirements of paragraph 16 have not been met in that this document is not accessible to the public; relevant information is spread over six development plan documents and an individual will have to find a table included in an Appendix to understand what policy to apply. The plan is not accessible and it therefore conflicts with national policy.

Object

Representation ID: 10229

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to the identification of Little Barford as a new settlement under para x. of DS2(S) as it is not deliverable or developable within the 2040 Plan period. It is reliant on key rail infrastructure that does not even exist and is unlikely to be so by 2030.
Please see attached representations ….specifically paragraph 2.9, section 3, paragraphs 3.1-3.28, paragraph 5.6 bullet 4, section 6, Appendices A, B, C for the detailed reasons.

Object

Representation ID: 10230

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to policy DS3(S) stepped trajectory in so far as it relates to 2030 onwards and the reliance it places on delivery from Little Barford. The Delivery rates anticipated in the Stepped Trajectory Topic Paper are unrealistic and not achievable, irrespective of the uncertainty over the delivery of the EWR.
Please see attached representations…specifically paragraph 2.6, section 3 paragraphs 3.1-3.28, paragraph 5.6 bullet 4, section 6, Appendices A, B, C.

Object

Representation ID: 10231

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to Policy DS5(S) in so far as it identifies 3,800 dwellings to be provided at Little
Barford. Little Barford is undeliverable and undevelopable within the 2400 plan period as it is
reliant on the delivery of key rail infrastructure which does not currently exist, and is unlikely to
by 2030.
Please see attached representations…specifically section 3 paragraphs 3.1-3.28, para 5.6
bullet 4, section 6, Appendices A, B,C.

Object

Representation ID: 10232

Received: 29/07/2022

Respondent: Taylor Wimpey

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? No

TW object to the allocation of Little Barford under policy HOU19. The site is undeliverable and undevelopable in the 2040 Plan period, as it is reliant on key rail infrastructure which does not even exist and is unlikely to by 2030. The site has considerable environmental and physical constraints in any event, and further, until the route of the EWR is consented, it is impossible to masterplan the site to determine whether or not the required 4,000 (3,800 in the plan period) can actually be realised within the allocation. In addition, severance and connectivity is severely compromised resulting in serious concerns as to whether a cohesive, well planned, well connected community can actually be achieved on the site.
Please see attached representations…specifically section 3 paragraphs 3.1-3.28, paragraph 5.6 bullet 4, section 6, Appendices A,B,C.