Bedford Borough Local Plan 2040 Plan for Submission

The purpose of this statement, prepared on behalf of Landcrest Developments Ltd (“Landcrest”), is to respond to the Local Plan 2040: Plan for Submission. Whilst Landcrest broadly support the vision and objectives for the Borough, there are areas of concern that may indicate the plan has not been positively prepared, justified or is effective as per paragraph 35 of the NPPF. These matters include the primary strategy of delivering new residential development in order to meet the new local housing need target of the LP2040 – particularly those proposed at Little Barford and Kempston Hardwick.
Such a strategy presents a multi-pronged aspect of understating the consequences of such a vision in the context of spatial development and temporal development within the borough. The matter is considered in further detail below as part of the representations on the spatial strategy-specific policies.
With regards to the other elements of the vision and objectives for LP2040, as set out above there is otherwise broad support. The development of the East West Rail will go a long way in providing connectivity, investment and growth across the borough and to other locations beyond thereby having a positive compounding effect in terms of its planning gain when considered in the context of benefits local growth. However, recent comments from the Transport Secretary indicate that the project should be cancelled, and accordingly there is no contingency or measures within the plan to accommodate for a potentially radical shift in how transport infrastructure in and across the borough will be utilised. In terms of environmental sustainability, Landcrest also share values on the role played by green infrastructure that aims to complement the natural environment whilst simultaneously creating vibrant, sustainable neighbourhoods.

The spatial strategy is clear at the outset that Bedford is at the heart of the Oxford – Cambridge Arc, and this in part has directed an approach in the spatial strategy to take advantage of existing and future strategic infrastructure such as the A421 and the East West Rail corridor to deliver sustainable development within the borough.
Landcrest consider, however, that the spatial strategy does not fully reflect the full potential for sustainable growth across the borough in accordance with overarching aims of the Oxford-Cambridge, or one that would capitalise on true potential of the existing and future transport corridors. This is evident as the strategy seeks to deliver growth primarily within / around the urban area, and at new settlements. It is clear that more rural locations, including key service centres many of which, such as Bromham, are well served by strategic transport corridors which would perfectly complement additional capacity provided by the East West Rail, have been overlooked in terms of their true growth potential.
To this end, the spatial strategy is not considered appropriate as it is overly reliant on the new settlement proposals to the South of Bedford and at New Barford as evidenced the be the distribution of growth in Policy DS5(s): Distribution of Growth. Key Service Centres’ potential growth have only been given due consideration in terms of their potential for sustainable growth as part of Neighbourhood Plans. The previous development plan that preceded the LP2030 introduced a moratorium on rural growth that quashed the vitality and potential at critical location across the borough. Whilst since then a relatively modest attempt at growth was planned as part of Neighbourhoods Plans, which themselves derive allocation sites and figures from LP2030 and not any higher, represent “one and done” approach to strategically reviewing sustainable rural locations for growth. It should be borne in mind that targets set out within the LP2030 – that of allocation figures distributed across the various rural areas and indeed the housing target as a whole – have always been identified as a minimum and not a maximum. For this authority to then formulate strategy that seeks to achieve the bear minimum in sustainable and planned growth in its rural heartlands gives little confidence that the plan has been positively prepared to meet the wide range of needs of local residents.
The matter is further exacerbated when consideration is given to the fact that the LP2030 had required an immediate review of its strategic policies as per Policy 1, the Council being fully aware of its need to meet higher growth levels in the near future, to only continue to delay meeting its housing need via stepped trajectory. The Standard Methodology (SM) figure for the Borough has not changed considerably since it was first introduced in 2018 and is much higher than the housing target in the LP2030 as acknowledged by the Council. There is thus a genuine concern that this authority is not fully committed to exploring all avenues for growth for real people across the Borough in real need now.
As a whole, the above sets out that in terms of spatial growth the strategy as part of LP2040 is ‘lop-sided’ and nor does it appropriately consider the secondary effects of the East West Rail in enhancing the wider strategic transport corridors that currently existing within the borough, specifically those enjoyed between key service centres, such as Bromham, and the urban area. Equally, there is no effort to prepare to the lack of delivery in the East West Rail given the latest statement made by the Transport Secretary which would then severely impact the sustainability credentials of this proposed plan’s strategy. The consequences of this are further compounded when considered the temporal element of the proposed growth under LP2040, with all elements that suggesting the plan has not been positively prepared, justified or is effective as per paragraph 35 of the NPPF.

Landcrest support the aims of the LP2040 in meeting the local housing need figure derived from the standard methodology (SM) as set out national policy which is identified at 27,100 dwellings across the plan period. However, the proposition for stepped trajectory raises serious concerns about the commitment to real growth when it is needed most – right now. This is most evident when consideration is given to the fact that the LP2030 had required an immediate review of its strategic policies as per Policy 1, the Council being fully aware of its need to meet higher growth levels in the near future due to taking advantage of transitional arrangements at that point in time, to only continue now in delaying meeting its housing need via stepped trajectory. The Standard Methodology (SM) figure for the Borough has not changed considerably since it was first introduced in 2018 and is much higher than the housing target in the LP2030 as acknowledged by the Council. There is thus a genuine concern that this authority is not fully committed to exploring all avenues for growth for real people across the Borough in real need now.
This is in the context that Bedford currently faces increasing house prices and increasing monthly rents. In respect of house prices, the average house price paid in Bedford in the final quarter of 2021 is over £350,000 according to the Office for National Statistics (ONS). When compared to an average income of approximately £33,400 according to ONS figures, an average priced home in Bedford costs over 10 times more than an average household earns, meaning affordability is a significant barrier to many people wishing to acquire a suitable home. The lower quartile house price ratio stands at a similarly staggering 10.43 times household income as per ONS data, and means that many people at the lower end of the market are pushed into the private rented sector, often with poorer living conditions and insecure tenancies.
This situation is fundamentally against Government ambitions to make housing more affordable for everyone, which is why affordability remains a key adjustment factor in the Standard Method, and against ever increasing house prices (despite even the consequences of the current pandemic) it is only reasonably expected that the Council’s local housing need will continue to increase in future years due to this factor alone.
The consequences of this spatial strategy thus become alarmingly apparent. It is no secret that larger development proposals – such as those at the newly proposed settlements - spend a greater amount of time from planning application submission to delivery of the first dwelling that smaller sites. Furthermore, it must also be taken into account that larger sites do not, by comparison, have proportionally larger build-out rates than smaller sites which amplifies the impacts of a stepped trajectory. Specifically, the Nathaniel Lichfield & Partners’ ‘Start to Finish’ report (second edition) investigates average lead-in times and build out rates of large sites and supports the above. Of the new settlements, the report estimates a lead-in time to first delivery at over 8 years based on the scale of growth proposed from the time of an application being submitted. It is evident, then, that the stepped trajectory is derived from the spatial strategy which has at its heart these new settlements for growth. Furthermore, the report identifies that build out rates are estimated to be as no higher than approximately 160 dwellings per year on average for the settlements that have a minimum housing provision of over 2,000.
It follows, then, that a stepped trajectory cannot be appropriate nor justified. The lead-in times and build-out rates of large scale strategic sites are relatively poor. The lack of small and medium sites allocated in LP2040 exacerbates the situation as any complications or delays for development in these locations will have profound consequences for the Council’s housing land supply over the plan period.
All of the above reinforces the critical need to include some smaller and medium sized allocations into the Plan to provide shorter term delivery early in the Plan period. Without this the Plan cannot be considered an appropriate strategy, taking into account the reasonable alternatives to include growth at Key Service Centres. Instead, urban based growth would starve more rural locations of much needed growth -housing or employment – while in turn risking the build-up of urban sprawl.
Were a spatial strategy with a greater focus on the rural areas of the borough implemented, many of the Key Services throughout the borough would be capable – socially, economically and environmentally – of accommodating the necessary levels of growth. As per the Council’s Settlement Hierarchy Background Paper prepared for the currently adopted plan, many of the KSCs that rank highly have good levels of sustainability with respect to key services and facilities, sustainable transport links, the local economy, public infrastructure such as schools and doctors. As a matter of fact, our client has been actively exploring options for developing a site within Bromham which is consistently ranked as one of the most sustainable villages in the Borough according to the settlement hierarchy matrix. In including an element of growth dispersal as part of a spatial strategy, such sustainable sites would be able to come forward and contribute to the local housing need of the future.
In incorporating dispersed growth as part of a strategy, many rural communities such as Bromham would continue to be well-connected places without experiencing overdevelopment. Dispersing growth further allows for rural centres to retain and enhance their vitality and improve the quality of living in these areas in line with what they are capable of accommodating thereby securing a more vibrant Borough as compared to a single, densified urban area that rural communities become entirely dependent upon.
An allocation such as that proposed at Bromham by our client, which has previously had a recommendation for approval by Officers for 80 dwellings, would provide a significant, and suitable, opportunity for the village to grow and thrive, and would also support local services and infrastructure, to include those in nearby villages, and would have made an important contribution to the Council’s housing land supply and targets in the earlier years of the plan period which would alleviate the dependency on large scale strategic sites for growth.

Of the minimum 27,100 new dwellings to be built across the plan period, 10,850 are to be distributed to the South of Bedford and at Little Barford as part of the new settlement development strategy which represents a staggering 40% of the local housing need figure. A further 1,500 dwellings are to be delivered as part of the strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale, which increases this proportion to 45.5% - almost half of the housing target for the plan period.
Housing is thus primarily intended to be supplied via large sites – more specifically, the strategic and new locations for growth – and LP2040 makes very little provision for allocated housing sites elsewhere. Consequently, this would not provide a sufficient mix of sites.
As a result, a number of small to medium scale developers would struggle to bring forward housing, if at all, of varying sizes, types and tenures in rural areas given the very restrictive policies under the currently proposed Plan for rural settlements. Indeed, there are a number of sites, such as one put forward by our client in Bromham, that is of an appropriate scale so as to make provision of various types and tenures, yet would not be permissible.
Paragraph 72(c) requires that LPAs, in identifying suitable locations for large scale development, should ensure the needs of different groups in the community will be provided. However, the lack of small, rural site allocations indicates that the needs of all groups in many rural communities will not be met. While large scale development may offer significant benefits, they should not be the only form of growth.
The Council has not set out any contingency plan in the event that these above sites do not deliver as expected. This is not good planning and means the LP2040 cannot be consider to be positively prepared, justified, or effective.
A stepped trajectory therefore, as it is currently proposed by the Council due to the above distribution of growth, would have a significant impact on the level of housing supply and delivery in the short run; it would be unable to meet the needs of residents upon adoption, many of whom require suitable housing now, thereby introducing a protracted period of time where there is to be a dismal supply of housing to facilitate growth in the plan area and inevitably worsening affordability issues in the borough. This significant concern is further deepened when consideration is given to the fact that the LP2030 had required an immediate review of its strategic policies as per Policy 1, the Council being fully aware of its need to meet higher growth levels in the near future due to taking advantage of transitional arrangements at that point in time, to only continue now in delaying meeting its housing need via stepped trajectory. The Standard Methodology (SM) figure for the Borough has not changed considerably since it was first introduced in 2018 and is much higher than the housing target in the LP2030 as acknowledged by the Council. There is thus a genuine concern that this authority is not fully committed to exploring all avenues for growth for real people across the Borough in real need now.
In its heavy reliance on strategic sites, the Council also runs the risk of not meeting the increase in supply and delivery at the appropriate time and in the long run, which would have a detrimental impact on being able to meet housing need for the plan period. The expected housing supply per year at the higher end of the stepped trajectory is invariably above the average supply of housing per year at a sustained trajectory; therefore, a shortfall in supply in even one year at the higher trajectory would put the Council in a very precarious position of being unlikely to deliver it minimum targets as it has been demonstrated there are greater risks in delivering larger sites. There would be little, if any, opportunity to rectify any shortfall in housing supply and delivery. For these reasons the Plan is not considered to be a sound one.
It is suggested that the Council should make suitable allocations for smaller sites across the borough in further consultation with developers so that they may be considered as specific, deliverable sites that can and will contribute to the housing supply upon adoption. Certainly, smaller sites face less risk of non or under deliverability and would present a step change in its current approach which is likely primed to fail.
There is clearly not a sufficient variety of allocated sites in terms of location, types and time horizons. There is no provision being made for rural housing contrary to Policy 79 of the NPPF, which requires:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Certainly, three of the identified locations for growth form a very substantial proportion of housing land, with very little regard hard to (prospective) rural residents and businesses. The Council have not demonstrated in any way how or why smaller allocations in smaller settlements, particularly rural settlements, have not been made and therefore fails to address their potential growth in the Plan.
An allocation such as that proposed at Bromham by our client, which has previously had a recommendation for approval by Officers for 80 dwellings, would provide a significant, and suitable, opportunity for the village to grow and thrive, and would also support local services and infrastructure, to include those in nearby villages, and would have made an important contribution to the Council’s housing land supply and targets in the earlier years of the plan period which would alleviate the dependency on large scale strategic sites for growth.