Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10126

Received: 29/07/2022

Respondent: Bletsoes

Agent: Rosconn Strategic Land

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RSL are of the opinion the spatial strategy is unsound as it is not consistent with the requirements of national policy.
Paragraph 4.7 of the Draft Plan identifies the need to deliver 1,355 dwellings per annum, giving a total of 27,100 dwellings for the 20 year plan period between 2020-2040. Para 4.7 also states, taking into account of existing commitments, completions and an allowance of windfall, the residual housing figure is 12,276 dwellings to be allocated in this plan. RSL agree that the Council need to identify a minimum of 12,276 additional new homes up to 2040 based on the most recent revisions to the Government’s Standard Method calculation.
The Planning Practice Guidance (PPG) is clear that the standard method only calculates the “minimum annual housing need figure” and that “It does not produce a housing requirement figure.” (Reference: 2a-002-20190220). The PPG further clarifies that changing economic circumstances or other factors might have an impact on demographic behaviour and there are situations where it is appropriate to consider whether actual housing need is higher than the standard method indicates. These situations include but are not limited to growth strategies for the area where funding is in place to promote additional growth and where strategic infrastructure improvements are occurring that are likely to drive an increase in the homes needed locally (Reference: 2a-010-20201216).

It is, therefore, important to consider whether there is sufficient housing being provided in this plan to support the future economic growth of Bedford given the Borough’s prominence within the Arc Spatial Framework during the plan period. Despite the uncertainties regarding the Arc’s deliverability and the Government’s drive to deliver the Spatial Framework moving forward, the Council will need to consider the likely impacts of economic growth arising from such improvements on population growth and housing needs in Bedford.
RSL note that the proposed spatial strategy expects to deliver approximately 13,550 additional new homes within the plan period as set out in Policy DS5(S), which is an approximate 10% uplift beyond the Council’s housing requirement. This uplift is generally welcomed by RSL, however, to ensure that housing needs can be met and that any sudden changes in delivery expectations are compensated for, the Council should consider a more substantial buffer / uplift in supply. By increasing the supply at this stage to approximately 20% for example, it would provide more flexibility to offset for any potential under delivery and avoids the risk of having to make further amendments to the plan at a later date to include additional allocations.
The spatial strategy set out in the Draft Plan directs the further growth required to meet assessed needs to 2040 to locations that are currently accessible, or will become accessible during the plan period. Policy DS2(S) states the proposed growth locations will focus growth primarily within the urban area, followed by strategic locations adjacent to the urban area which contribute to the delivery of key green infrastructure projects. Furthermore, new growth locations are proposed to be focussed on the East West Rail (EWR) and the A421 transport corridors, particularly south of Bedford area and at a new settlement at Little Barford are proposed.
The above development strategy has omitted further growth in the Key Service Centres and Rural Service Centres, with no growth being directed in the north of the Borough. North of the Borough includes several highly sustainable settlements, including Key Service Centres of Bromham, Clapham, and Sharnbrook, and a selection of Rural Service Centres and smaller villages. RSL believe this undermines the long-term sustainability of the Key Service Centres and Rural Service Centres in this area.
Paragraph 4.27 states 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. The Bedford Infrastructure Delivery Plan (The Need for a Stepped Trajectory: Transport), forming part of the evidence base, also acknowledges the significant growth to the south of Bedford and a new settlement at Little Barford will require significant forms of new or enhanced transport infrastructure. The package of transport infrastructure to mitigate impacts on the highway network includes large schemes such as the EWR and Strategic Road Network (SRN) improvements, which are reliant on central government funding and processes such as Road Investment Strategy. The Delivery Plan also acknowledges that the transport infrastructure which is considered key to supporting growth is unlikely to be delivered in full before 2030. Chapter 4 of the Delivery Plan sets out when key transport infrastructure will be delivered, noting that the SRN improvements proposed to support growth would only be built out in the late 2020s or even early 2030s. The A421 Widening and A428 Back Cat to Caxton Gibbet schemes are ‘considered to be complex and therefore could face risks to their delivery timescales’. With regards to the EWR, the government has previously set out its commitment to complete the restoration of the rail link by 2030, with the Central Section of EWR the subject of consultation in 2021 and a Preferred Route Announcement due 2022.
The NPPF makes it clear at paragraph 60 it is important that a sufficient amount and variety of land can come forward and paragraph 69 sets out the benefits of small and medium sized sites and the importance to promote the development of a good mix of sites. Para 5.5 of the Delivery Plan notes that ‘large sites’ (sites with a capacity of at least 500 dwellings for housing) support 12,430 dwellings, meaning large sites support the delivery of ‘all but approximately 1,000 of the dwellings newly allocated’ in the Local Plan 2040. Table 5-2 sets out the relationship between a large site and the transport schemes. This table demonstrates that the implementation of a transport infrastructure scheme is judged to directly support a site’s delivery for 4 of the 7 ‘large sites’ allocated within the Local Plan 2040. For these sites, para 5.6 notes ‘it would be highly unlikely that a site would be able to come forward without the associated transport scheme being in place prior to or at the early phases of development’. These 4 sites account for delivering approximately 10,400 dwellings.
NPPF paragraph 16 notes plans should be positively prepared in a way that is aspirational but deliverable. Furthermore, paragraph 73, part d) requires local authorities to make a realistic assessment of likely rates of delivery with regards to larger scale development given the lead in times for such sites. RSL are concerned the Delivery Plan’s conclusions evidence that the strategy put forward by the Council is unsuitable given the high dependency of the proposed housing supply on large transport infrastructure projects delivering to schedule. The Delivery Plan acknowledges there is an inherent risk associated with delivery of large infrastructure projects, which needs be taken into account. Clearly, if there were to be a delay to the infrastructure projects outlined above, there is a significant risk the proposed housing allocations will not deliver sufficient housing to meet the minimum requirement within the plan period.
Overall, RSL considers the spatial strategy is contrary to national policy as set out above, specifically with regards to deliverability and variety of sites allocated and would fail the soundness tests set out in paragraph 35 of the NPPF.
RSL consider that more deliverable contingency sites should be identified in the Local Plan 2040 to offset the risk of under-delivery and to provide the flexibility to respond to changing circumstances. Neighbourhood Planning has successfully allocated or committed growth throughout Bedford Borough in line with the requirements set out in the Bedford Local Plan 2030. However, this Draft Plan consultation document does not, as per the previous draft Local Plan 2040, delegate any further growth to local communities through the creation of a Neighbourhood Plan, or indeed the review of an existing one.
RSL recognise that some Parish Council’s may be reluctant to consider further sizable allocations going forward to 2040. However, we would encourage the Borough Council to review the potential of the Key Service Centres capacity to deliver further growth, and to consider the opportunity to build upon the infrastructure being delivered / committed that existing allocations in Neighbourhood Plans will deliver in order to offset the risk of under-delivery of the proposed allocations as set out above.
For instance, further development can be delivered at Hill Farm in Sharnbrook, utilising the improved infrastructure and facilities associated with the Hill Farm Neighbourhood Plan housing allocation, and the remaining capacity of the Site of approximately 250 dwellings could make a meaningful contribution towards housing delivery in the next plan period.
The Site, as outlined in red below, is part of the site promoted via the Call for Sites process (Site 814). The majority of the farm, outlined in green below, has been allocated in the ‘made’ Sharnbrook Neighbourhood Plan under Policy S5 and is now subject to an Outline Planning Application (Reference 22/01037/MAO) submitted by Bellway and Redrow who intend to jointly build out the site. The description of development is as follows:
Outline application with all matters reserved except access, for the erection of up to 500 dwellings with associated landscaping, open space, vehicular access, pedestrian and cycle links and parking provision, and necessary supporting infrastructure including land for the provision of a primary school (2ha) and a community hub (0.2ha); land for formal and informal open space; drainage and service infrastructure works.

The residual land at Hill Farm, extends to circa 13.85 hectares and has the potential to deliver approximately an additional 250 dwellings. The remainder of the Site presents an opportunity to build upon the infrastructure that will be deliver by the development of the 500 dwellings. The location is considered as a sustainable extension to the village and will further support the aims of the Neighbourhood Plan.
One of the key benefits of this location is the high degree of accessibility to the wider road network, as well as strong connections and integration with existing public transport routes. The principal access point will be via the new roundabout on the A6 proposed as part of the Outline Planning Application, with secondary access points along Mill Lane and Templars Way. The Site would also benefit from access to new and upgraded footpaths and cycleways providing improved connectivity to the village centre; extensive public open space, and land for leisure facilities including sports pitches; land for a replacement primary school, small scale retail units, and a potential location for a new community building and/or a new doctors’ surgery.

There is an opportunity for further growth of the wider site to build upon this infrastructure, contributing towards deliver. The Neighbourhood Plan allocated site will significantly enhance the sustainability of the location, and it is therefore considered entirely logical to examine the potential opportunity for further growth on the residual land at Hill Farm.
As per NPPF para 79, housing should be located where it will enhance or maintain the vitality of rural communities and planning policies should identify opportunities for villages to grow and thrive especially where this will support local services. To that end, the recently published Census 2021 data (June 2022) concludes a falling birth rate on top of an already falling proportion of children aged 0-14 (18.9% to 17.4%) will see a continued and increased fall in demand for primary and, consequently, secondary school places during the Plan period. This results in a situation whereby places at the local primary and secondary schools will be freed up to cover any increased demand as a result of new development. Thereby, additional development at Hill Farm will help the sustainability of local community facilities. Furthermore, the secondary school currently has good capacity and is supported by “out of catchment” pupil numbers coming from the Rushden area and Northamptonshire. However, with the addition of new school provision being delivered in the Rushden East Sustainable Urban Extension allocation, pupils will no longer have to travel to Sharnbrook from Northamptonshire; and as a result there will be sufficient provision at the secondary school to accommodate an increase in numbers as a result of additional development at Hill Farm.
One of the key reasons for Hill Farm’s allocation in the Neighbourhood Plan is its direct connectivity to the A6. This means that new housing and supporting infrastructure can be delivered, and accessed, without resulting in an adverse impact on the historic core of the village and its associated road network.

Object

Representation ID: 10127

Received: 29/07/2022

Respondent: Bletsoes

Agent: Rosconn Strategic Land

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

RSL are of the opinion Policy DS3(S) is unsound as it is not consistent with the requirements of national policy.
During the examination of the Local Plan 2030, the Inspector required the Council to undertake and submit a review of the Plan for examination within three years of its adoption on the basis that the current housing requirement of 970 dwellings per annum was based on the previous housing needs methodology, and not the Standard Methodology. Therefore, the Council needs to consider the review in the context of the elevated housing requirement as set out in the Standard Methodology. This version of the Draft Plan has retained the use of a stepped trajectory to deliver homes within the plan period up to 2040, whereby it is expected that 970 dwellings per annum (dpa) will be delivered in the period up to 2024/25, rising to 1050dpa up to 2029/30 and then to 1,700dpa up to 2039/40. The Council’s justification for the use of the stepped trajectory is in order to adapt to the significant increase in the annual housing requirement (from 970 dpa in the Local Plan 2030 to 1,355dpa which is an uplift of 40%) and the need to link growth to the completion of new infrastructure.
Paragraph 68-021-20190722 of the PPG states that using a stepped requirement must be evidenced by the policy maker and must not seek to unnecessarily delay meeting identified development needs. RSL are of the opinion the approach of pushing the majority of homes to be delivered towards the last 10 years of the plan period rather than seeking to address the uplift in housing need at the earliest opportunity in the plan period will undoubtedly create a far greater burden between 2030 and 2040 on the Borough. RSL note that the annual delivery of new homes as suggested in the proposed stepped trajectory will not exceed, or even equate to, the identified minimum annual requirement calculated by the Standard Method for the Borough until beyond 2030. The Council, therefore, are at risk of unnecessarily delaying meeting the identified development needs for the Borough, contrary to NPPF para 60.
As a consequence of this, the Council are not addressing the housing affordability issue in the Borough which exist now. According to the most recent affordability ratios published in March 2022, Bedford’s affordability ratio increased by 1.27, indicating affordability has significantly worsened in the year between 2020 (8.92) and 2021 (10.19). This is higher than England’s average ratio estimate that full-time employees could typically expect to spend their annual earnings on purchasing a home (9.1). RSL consider that the proposed stepped trajectory as currently outlined significantly risks affordability in the Borough worsening unnecessarily up to 2040. As such, in RSL’s opinion, the Council need to reconsider the stepped trajectory accordingly to not delay addressing the affordability issue.
Having adopted a spatial strategy that is not consistent with national policy (as set out in RSL’s response to Policy DS2(S)) it has resulted in the need for the Council to use a stepped trajectory which has the effect of delaying the delivery of housing for the first 17 years of the plan period. In the context of a housing crisis and housing affordability worsening, RSL consider the Plan fails to positively prepare for the area’s objectively assessed needs, provide sufficient justification that the strategy is appropriate, deliverable over the plan period and consistent with national policy as set out in paragraph 35 of the NPPF. As such, RSL consider the Plan unsound.