Question 2
Whilst reference is made to the benefits of East-West Rail through Bedford, there is no reference within the Vision to the Oxford to Cambridge Arc despite multiple references to this within the document and the significant economic benefits that are likely to accrue in view of the Borough’s strategic location at its centre. Specific reference should be provided within the Vision to this significant long term objective and how the Borough will look to take advantage of it in respect of economic and housing growth and associated infrastructure improvements.
The Respondent supports the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live, and commends the Council’s strategy to deliver more multifunctional green spaces and Green Infrastructure. The Respondent also supports the Council’s vision that the Forest of Marston Vale will continue to grow and mature, and that, together with the completed BRVP, this part of the Borough will be transformed through new leisure opportunities, encouraging increased visitor numbers The Vision document provided in support of these representations demonstrates in greater detail how the water sports lake and associated infrastructure could be delivered at BRVP, and it is clear that a high quality leisure amenity that improves the overall quality of the Forest of Marston Vale Landscape could be created; this would also contribute significantly towards Green Infrastructure in the area. By updating Policy AD23 contained in the ADLP and unlocking the viability of the water sports lake, Bedford River Valley Park would make a significant contribution to the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live.
2.1 The current Vision set out on pages 13 and 14 of the Issues and Options document is currently very general with a lack of detail as to how and where growth will occur across Bedford Borough. 2.2 Decisions will still need to be made about the spatial strategy and therefore, as this early stage it is difficult for the vison to articulate what the area will be like at the end of the plan period. However, as a general point, we consider that as the review moves forward the Vision should be made more specific and paint a more detailed picture of the expectations for growth and development by 2040. 2.3 Whilst there is reference in the Vision to town centre development and development in rural areas these are the only spatial elements to the vision. We believe, in due course, the Vision should be clear about expectations for a new settlement, give it is likely one will be integral to the future strategy for the area, alongside other types of growth. 2.4 It would also be helpful if objectives are provided alongside the vision in the draft of the Local Plan. These will enable the Council to add more detail to the vision and be more specific about what the Council are seeking to deliver over the plan period.
The Vision needs to address how Bedford as an expanding town and the rural villages and countryside are interdependent. “Covid “ lifestyle changes demonstrate how important the rural urban fringe is for recreation for residents of Bedford – seeking countryside walks without using the car and quiet lanes for cycling. Bedford’s countryside setting supports the town’s mental health. Rural dwellers access the town’s amenities – libraries, swimming pools , museums etc. As a Ravensden resident I am very concerned about the potential changes to the parish arising from East – West Rail –loss of rural character, loss of tranquility, farmland developed rather than utilized for food production. Vision should refer to Borough’s agricultural role.
The draft vision is duly noted for wanting this Borough to become a greener, more sustainable and more attractive place to live. Matters such as climate chance appear to be at the heart of the vision to mitigate its effects through the inclusion of green infrastructure, energy efficiency, flood risk reduction and so on. Also notably included within the vision is the benefits brought about by the Ox-Cam Arc, which currently is derived from the progression of the East-West Rail. Furthermore, the consultation paper continues on to acknowledge the Arc is a key economic priority and the Government ambition for up to one million homes by 2050. The East-West Rail and the new expressway as part of this project are already coming into fruition; however, the paper raises questions about the progress of the Arc’s strategy for housing growth. It summarily dismisses the need for additional housing due to the Arc, stating “little progress has been made” on how the strategic growth will be delivered. In short, this plan focuses solely on Bedford Borough’s own growth requirement which is claims will be a significant challenge due to a potential “35% increase in the annual level of housing growth contained in the Local Plan 2030”. The matter of how many houses this plan should accommodate is covered in more detail later in this response; nonetheless, the inclusion of the benefits of the Arc and consideration as to how best to capture such benefits for the Borough residents remains a key question at this stage for this Review, suprisingly. Surely, if the infrastructure required for such growth is being implemented, then a spatial strategy itself is imminent for the Arc. This consultation itself acknowledge the need for appropriate infrastructure prior to accommodating significant growth. Yet, this Authority makes no attempt to query its citizens on what they believe should be a suitable vision in this respect. Certainly, even if accommodating a one third increase in the level of housing will be a challenge, surely this Council must now at least make attempts to help facilitate growth for when a strategy is realised. This is indeed the motivation and justification for the inclusion of Policy 1 within the currently adopted Plan. The examining Inspectors, as explained in the paper, set out that “there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible” (emphasis added). At best, this Authority should make full provision to accommodating further, projected growth given its fundamental location at the heart of the Arc. At worst, it should seek the views of its communities, residents and businesses on the matter as part of this, or any future, consultation to fully assuage whether this is truly unfeasible at this stage rather than irresponsibly dismiss planning for the Arc altogether.
3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. Specifically, however, the current Vision in the Local Plan 2030 fails to reflect those spatial options and planned improvements that can make a clear contribution to the Plan’s strategic priorities, such as A421-based growth at Roxton. The settlement is a clear example of where the levels of growth that can be sustainably planned for exceed the apportionment of requirements identified in the current Plan. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 This statement, particularly in the context of Roxton, fails to note that the current spatial strategy is silent on the strategic priorities and opportunities for A421-based growth. It also fails to take account of the fact that the apportionment of growth was determined by arbitrary assumptions on capacity against a constrained plan period and housing requirement reflecting the NPPF2012’s transitional arrangements. Delays to the delivery of growth are further compounded by the deferral of site allocations to Neighbourhood Plans. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 19 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. A substantially greater contribution towards annual requirements for development at Roxton than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. This would seek to fully sustain and enhance its role as a Rural Service Centre while helping to deliver the Council’s strategic priorities as a result of the advantages associated with A421-based growth. 3.7 We have identified three main elements of the Council’s proposed Vision where amendments to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “Delivery of the Borough’s infrastructure priorities throughout the plan period has maximised opportunities associated with planned improvements, including enabling a focus for sustainable growth along the A421 corridor. The early allocation of sites to meet additional requirements for growth has been supported, with a focus on opportunities that secure delivery of the Plan’s objectives for sustainable development, complemented A421-based growth. The development of East-West Rail through Bedford will be complete. Bedford will benefit from a new town centre transport interchange including links to Oxford and Cambridge, increasing connectivity, investment and growth. Local development will be well served by transport links and speedy internet access integrated into the planning process and completed before residents move in.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”
4.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 4.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres than the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 4.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 4.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 4.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: i. The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options (including the proposed allocation of a New Settlement) ii. Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans iii. The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth 4.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at Renhold/Salph End than the levels currently indicated by Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 4.7 These components of an appropriate strategy should complement an aspirational but 17 realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 4.8 We have identified three main elements of the Council’s proposed Vision where amendments to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”
The draft vision should be expanded to address housing as the inability to access suitable housing, or high house prices, threaten the quality of life for the Borough’s residents. Currently, there is a national housing crisis, with record numbers of homelessness and high unaffordability as well as increasing overcrowding of properties. A vision for the Local Plan should be to ensure that there are sufficient homes that meet the needs of the Borough’s residents. The vision as currently drafted does not seek to meet this. BDW recommend that the following text is included within the vision: “Bedford Borough will provide a balanced range of high quality housing to meet differing housing needs and aspirations and offer an excellent quality of life for its communities In addition, the vision does not seek to embrace and capitalise on the Borough’s place at the centre of the Oxford-Cambridge Arc, which is an area of world leading universities and research institutions with a concentration of knowledge-intensive, technology and high performance engineering businesses. If planned for effectively, this will further boost the Borough’s economy. It is therefore, suggest that the following is incorporated into the vision: “The Borough will build on its economic strengths, including its location at the heart of the county and in the Oxford – Cambridge Arc.”
The draft vision is duly noted for wanting this Borough to become a greener, more sustainable and more attractive place to live. Matters such as climate chance appear to be at the heart of the vision to mitigate its effects through the inclusion of green infrastructure, energy efficiency, flood risk reduction and so on. Also notably included within the vision is the benefits brought about by the Ox-Cam Arc, which currently is derived from the progression of the East-West Rail. Furthermore, the consultation paper continues on to acknowledge the Arc is a key economic priority and the Government ambition for up to one million homes by 2050. The East-West Rail and the new expressway as part of this project are already coming into fruition; however, the paper raises questions about the progress of the Arc’s strategy for housing growth. It summarily dismisses the need for additional housing due to the Arc, stating “little progress has been made” on how the strategic growth will be delivered. In short, this plan focuses solely on Bedford Borough’s own growth requirement which is claims will be a significant challenge due to a potential “35% increase in the annual level of housing growth contained in the Local Plan 2030”. The matter of how many houses this plan should accommodate is covered in more detail later in this response; nonetheless, the inclusion of the benefits of the Arc and consideration as to how best to capture such benefits for the Borough residents remains a key question at this stage for this Review, surprisingly. Surely, if the infrastructure required for such growth is being implemented, then a spatial strategy itself is imminent for the Arc. This consultation itself acknowledge the need for appropriate infrastructure prior to accommodating significant growth. Yet, this Authority makes no attempt to query its citizens on what they believe should be a suitable vision in this respect. Certainly, even if accommodating a one third increase in the level of housing will be a challenge, surely this Council must now at least make attempts to help facilitate growth for when a strategy is realised. This is indeed the motivation and justification for the inclusion of Policy 1 within the currently adopted Plan. The examining Inspectors, as explained in the paper, set out that “there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible” (emphasis added). At best, this Authority should make full provision to accommodating further, projected growth given its fundamental location at the heart of the Arc. At worst, it should seek the views of its communities, residents and businesses on the matter as part of this, or any future, consultation to fully assuage whether this is truly unfeasible at this stage rather than irresponsibly dismiss planning for the Arc altogether.
Clearly advocate the advantage of Garden Cities and the benefit of make Bedford the No 1 destination for the arc
As a rural parish we note especially the draft vision relating to rural communities: "The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. Rural communities will embrace sensitive development through neighbourhood plans that provide and support much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all." Firstly, we commend that the vision recognises the 'intrinsic character and beauty' of the rural areas. However, as a policy objective, mere 'recognition' carries little meaning. We understand the real underlying sentiment of the Council to be the 'protection' of the intrinsic character and beauty. This should be reflected in the policy wording. Secondly, we note that that the section on the Borough's country side is the only section in the draft vision which implies, and imposes, a value judgement without corroborating evidence. The vision suggests that rural communities 'embrace sensitive development through neighbourhood plans that provide much needed housing' [our emphasis]. As a rural community it can feel as if the Borough's housing needs are imposed on rural communities without adequate regard for the intrinsic character and beauty, transport and infrastructure and, indeed, the actual housing needs of the community itself (as shown, for example, by the Housing Needs Survey conducted as part of the Neighbourhood Plan process). As such we cannot support this particular aspect of the draft vision. Thirdly, the vision specifically identifies 'the Embankment and Victorian parks' as 'jewels in Bedford's crown'. The Borough is equally fortunate to have the River Great Ouse running through its boundaries. The river valley, together with the historic settlements which line the river (such as Harrold) form a beautiful and largely intact rural landscape characterised by open fields, woodlands, ancient churches, villages with their prominent sandstone architecture and conservation areas, single lane bridges and winding country roads. This ecosystem is as much a jewel in Bedford's crown and deserves the same recognition and focus on sympathetic protection and developments as the Embankment and the Victorian parks. Without this recognition there is a very real danger that this historic landscape with its unique character becomes unrecognisable within a generation and irreversibly lost. Each of the villages in the Ouse valley are preparing Neighbourhood Plans and, as part of this process, will draw up Village Design Statements. Given the time and money spent on producing these policies we hope that these could inform a more detailed vision. In conclusion we recommend that the draft vision be amended as follows: "The borough is characterised by both an ancient countryside and an historic market town. The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be protectedrecognised. Rural communities will embrace sensitive development through neighbourhood plans that provide and support much needed housing and employment, and rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all."
The Draft Vision does not mention employment other than attracting high tech employment in the context of East-West Rail. The Vision should also include a desire to facilitate all types of employment in the Borough as a whole and to enable existing sites to expand. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc.
Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc. Further to which, the vision states that development within rural communities will have been achieved purely through neighbourhood plans. It would appear premature to include this point within the vision in advance of determining the borough’s development strategy and approach to growth, particularly given that the second reason given for the requiring this review, is that the 2030 Local Plan relies upon Neighbourhood Plan sites, and the review allows the council to intervene to ensure that house building rates are maintained.
Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc. Further to which, the vision states that development within rural communities will have been achieved purely through neighbourhood plans. It would appear premature to include this point within the vision in advance of determining the borough’s development strategy and approach to growth, particularly given that the second reason given for the requiring this review, is that the 2030 Local Plan relies upon Neighbourhood Plan sites, and the review allows the council to intervene to ensure that house building rates are maintained. Furthermore, the plan period exceeds that of the Neighbourhood Plans currently going through the process and so it needs to facilitate growth in the rural area for when these plans come to end.
Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc. Further to which, the vision states that development within rural communities will have been achieved purely through neighbourhood plans. It would appear premature to include this point within the vision in advance of determining the borough’s development strategy and approach to growth, particularly given that the second reason given for the requiring this review, is that the 2030 Local Plan relies upon Neighbourhood Plan sites, and the review allows the council to intervene to ensure that house building rates are maintained.
The vision states that development within rural communities will have been achieved purely through neighbourhood plans. It would appear premature to include this point within the vision in advance of determining the borough’s development strategy and approach to growth, particularly given that the second reason given for the requiring this review, is that the 2030 Local Plan relies upon Neighbourhood Plan sites, and the review allows the council to intervene to ensure that house building rates are maintained. Furthermore, the plan period exceeds that of the Neighbourhood Plans so it needs to facilitate growth in the rural area for when these plans come to end. The Council is presently reliant on Neighbourhood Plans delivering growth in the rural area. The vision should also encourage suitable windfall sites in the rural area to assist with maintaining the long-term sustainability of these settlements and their services, rather than just relying on Neighbourhood Plans. This is particularly important in areas which are not preparing a Neighbourhood Plan otherwise this will create inconsistencies in growth across the Borough. It is important that all settlements are given the opportunity to grow proportionately in order to enhance or maintain their vitality as required by the NPPF and Planning Practice Guidance on rural housing. We would contend that self-build and custom housing offers that opportunity, with such plots being more capable of addressing local design and landscape character. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc.
The vision states that development within rural communities will have been achieved purely through neighbourhood plans. It would appear premature to include this point within the vision in advance of determining the borough’s development strategy and approach to growth, particularly given that the second reason given for the requiring this review, is that the 2030 Local Plan relies upon Neighbourhood Plan sites, and the review allows the council to intervene to ensure that house building rates are maintained. Furthermore, the plan period exceeds that of the Neighbourhood Plans so it needs to facilitate growth in the rural area for when these plans come to end. The Council has put too much focus on Neighbourhood Plans delivering growth in the rural area. The vision should also encourage suitable windfall sites in the rural area to assist with maintaining the long-term sustainability of these settlements and their services, rather than just relying on Neighbourhood Plans. This is particularly important in areas which are not preparing a Neighbourhood Plan otherwise this will create inconsistencies in growth across the Borough. It is important that all settlements are given the opportunity to grow proportionately in order to enhance or maintain their vitality as required by the NPPF and Planning Practice Guidance on rural housing. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc.
Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate on how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc. Although the Vision states that there will be tourism opportunities as a result of the Bedford To Milton Keynes Waterway Park, it does not set out any objectives for increasing tourism elsewhere in the Borough. Tourism can help to promote economic growth and should be considered as part of the overall economic package.
The Respondent supports the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live, and commends the Council’s strategy to deliver more multifunctional green spaces and Green Infrastructure. The Respondent also supports the Council’s vision that the Forest of Marston Vale will continue to grow and mature, and that, together with the completed BRVP, this part of the Borough will be transformed through new leisure opportunities, encouraging increased visitor numbers The Vision document provided in support of these representations demonstrates in greater detail how the water sports lake and associated infrastructure could be delivered at BRVP, and it is clear that a high quality leisure amenity that improves the overall quality of the Forest of Marston Vale Landscape could be created; this would also contribute significantly towards Green Infrastructure in the area. By updating Policy AD23 contained in the ADLP and unlocking the viability of the water sports lake, Bedford River Valley Park would make a significant contribution to the Council’s vision to make the Borough a greener, more attractive and more sustainable place to live.
We would suggest the vision should recognise the need to plan positively for new growth and infrastructure, and particularly residential development in order to build upon the wider strategic developments identified. As noted by the Inspector’s Examination Report there is a need for the plan to respond appropriately to longer term requirements, and in particular the Oxford-Cambridge Arc as soon as possible. We agree with the aim of the draft vision to place the challenge of climate change and adapting to and mitigating against its effects -at the heart of new development. We agree with the draft vision’s focus on new multifunctional green spaces to complement the existing network of paths and green corridors. We consider such spaces should be integral to new residential developments wherever possible. It is considered the Vision should lead to a series of objectives which establish how the plan deals with the identified critical issues, which should include the requirement to respond to the significant need in the borough for new housing.
No issues with the overall draft vision. However there is concern that with EWR, Bedford Borough will become a dormitory for Cambridge, with increasing house prices, an influx of new people, sprawling growth and significant infrastructure pressures. The vision should therefore include mitigation of the impacts of EWR on rural communities. The framework for the Oxford – Cambridge Arc is likely to add to these pressures. The vision should emphasis Bedford as a discrete town of medium size linked by vibrant well connect communities including Clapham. The vision should not be inward looking but ensure that the surrounding communities are not forgotten in the drive to deliver a “Greater Bedford.”
In general terms we support the draft vision as set out on pages 13 and 14 of the Issues and Options – Consultation Paper, Summer 2020. We support the vision’s emphasis on transport links and connectivity providing opportunities within the borough for development. However, the third paragraph of the vision should be expanded to acknowledge that some of the strategic infrastructure, which will assist in unlocking growth potential in the borough, is at the edge of or beyond the borough’s boundaries. The vision should acknowledge the potential for major infrastructure to influence the location of residential and employment development and deliver additional locations with good access via sustainable transport modes, to benefit from the new station as part of the East West Rail project to be located between Little Barford and Church End. The following amendments would achieve this: “The development of East-West Rail through Bedford will be complete. Bedford will benefit from a new town centre transport interchange including links to Oxford and Cambridge, increasing connectivity, investment and growth. The East-West Rail will also provide a new station to the south of Little Barford to the east of the borough, which combined with the A428 Black Cat roundabout to Caxton Gibbet improvements will see the east of the borough grow and prosper. Collaboration with neighbouring local planning authorities to the east and other stakeholders, will deliver a spatial growth strategy with the distribution of growth recognising the intrinsic potential of the settlements and areas adjacent to the boundaries between Bedford Borough, Central Bedfordshire Borough and Huntingdonshire District. Local development will be well served by transport links and speedy internet access integrated into the planning process and completed commensurate with before residents movinge in. Bedford borough will continue to attract new business through the completion of significant infrastructure projects, in and close to the borough and through the development of high quality commercial and office spaces.”
Please avoid, at all costs, ruining the intrinsic beauty and character of our historic villages by building over them and obliterating our heritage. Tree planting should be actively encouraged and the importance of protecting open green spaces for the emotional health and physical wellbeing of all residents must not be underestimated. We must ensure political will and secure finance in place to deliver environmentally friendly, sustainability proposals. We are amazed that there is no mention of the proposed East West rail link as this will, if the contentious Route E is chosen, have a detrimental impact on our community cohesion, open countryside, rural landscape and precious village amenities-with all of the gains going to those who live in the town and all the losses going to those who live in rural North Bedfordshire. Furthermore, there is no mention of the long term development needs of the Oxford to Cambridge arc.
2.1 Although it is acknowledged that the vision is still evolving, in its current form it lacks clarity and focus. The vision should be a short, bullet pointed explanation of what the Local Plan hopes to deliver. In its current form it is hard to understand what the main focus of the plan is. It needs explicit reference to what growth is being planned and where and how this growth will seek to improve the built environment while protecting and enhancing the natural environment. 2.2 Whilst there are references to the town center and the west of Bedford, where growth is already planned, there is no reference to the role of other settlements, how they relate to infrastructure enhancements nor how they will contribute to the overall aspirations for the Borough. This is an omission and will need to be amended in future iterations of the Vision. 2.3 It would perhaps be useful to establish a number of objectives which would clearly identify how the vision for the borough is going to be met. This would give greater clarity in terms of what is being proposed.
3.1 Although it is acknowledged that the vision is still evolving, in its current form it lacks clarity and focus. The vision should be a short, bullet pointed explanation of what the Local Plan hopes to deliver. In its current form it is hard to understand what the main focus of the Plan is. It needs explicit reference to what growth is being planned; and, where and how this growth will seek to improve the built environment while protecting and enhancing the natural environment. 3.2 Whilst there are references to the town center and the west of Bedford, where growth is already planned, there is no reference to the role of other settlements, how they relate to infrastructure enhancements nor how they will contribute to the overall aspirations for the Borough. This is an omission and will need to be amended in future iterations of the Vision. 3.3 It would perhaps be useful to establish a number of objectives which would clearly identify how the vision for the Borough is going to be met. This would give greater clarity in terms of what is being proposed.
No
This vision suggests a rosy one for Bedford. On what basis? Where is the analysis? The Riverside North was deliberately to be serviced by national brand shops with local independent ones excluded. To date there are no shopos in the area apart from a tiny 'One stop' Niche shops: On what economic prediction can you say that niche shops would survive financially in the town centre in the present dire economic circumstances when across the last 45 years most imaginative 'niche 'shops have seldom survived long and most have long since closed?
No
3.0 QUESTION 2 – DRAFT VISION COMMENTS AND IMPROVEMENTS 3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: • The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options. • Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans. • The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth. 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at settlements including Sharnbrook and Oakley than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 3.7 These components of an appropriate strategy should complement an aspirational but realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 3.8 We have identified three main elements of the Council’s proposed Vision where amendments BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 19 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”
3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: • The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options. • Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans. • The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth. 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at settlements including Sharnbrook and Oakley than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 3.7 These components of an appropriate strategy should complement an aspirational but realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 3.8 We have identified three main elements of the Council’s proposed Vision where amendments BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 19 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”