Question 2
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 Great Barford. 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 Great Barford, 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. 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 Great Barford 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 Key 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 BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 17 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 such as at the Key Service Centre of Great Barford. 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.”
3.1 The Draft Vision of the Issues and Options document should focus on the key considerations included within the scope of the Local Plan Review. 3.2 Whilst at this moment in time it is recognised that options still need to be assessed and decisions made about the spatial strategy, future iterations of the Vision should be more specific and set out clearly what the area will be like at the end of the plan period. 3.3 There is currently limited reference in the Vision to development in the town centre and no mention of the contribution that the redevelopment and intensification of urban sites inside the town centre, such as that owned by the Commission, could make to the overall development strategy and the sustainability of Bedford. Without being site specific, it is suggested that text is added to the Vision to recognise the contribution of such sites to the overall strategy. 3.4 As with any Local Plan Review, it is considered that the successes and failings of the Plan that came before it should be used to refine and alter strategies taken. In this regard, as is discussed under question 5, the lack of allocated sites with short term delivery potential in the Local Plan 2030 has contributed to a situation where the five year land supply is being challenged. This needs to be avoided in the Local Plan Review which requires the allocation of small to medium sized sites for development alongside larger allocations and possibly new settlements with longer lead in times. It is suggested that this flexibility and differential in the deliverability of sites is reflected in the Vision. 3.5 It is also noted that it is common practice for objectives to be used in a Local Plan vision which set out what the Local Plan should achieve to make the Vision a reality. Incorporating objectives into the Local Plan Vision would show in more detail what Bedford Borough are trying to achieve over the plan period.
3.1 Firstly, the draft Vision starts with the wording “by the end of the Plan Period”. Whilst the Plan Period sets out the timetable for the Plan’s Policies to achieve their aims, a Local Plan will ultimately have far reaching consequences well beyond the period. 3.2 This is an unambitious and negative approach, and instead, the Vision for the Plan should be one that provides a pathway for life beyond the Plan Period. 3.3 Secondly, the Vision’s focus appears to be on Bedford and greater consideration within the Vision should be given to other areas, particularly sustainable settlements such as Wootton, and the opportunities for a comprehensive holistic approach to development in those locations which would deliver much needed housing and wider community benefits.
3.1 The Draft Vision set out on pages 13 and 14 of the Issues and Options document is generic. It does not focus on key considerations included within the scope of the Local Plan Review such as how and where growth will occur across Bedford Borough. 3.2 Whilst it is recognised that at this stage options still need to be assessed and decisions made about the spatial strategy, Taylor Wimpey UK Ltd consider that future iterations of the Vision should be more specific and set out clearly what the area will be like at the end of the plan period. 3.3 For example, whilst growth which is already planned for in the town centre and to the west of Bedford is included in the Vision, 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. 3.4 The Vision notes that there will be sensitive development in rural areas which is to be identified through neighbourhood plans. This appears to pre-empt that the Local Plan Review will not plan for growth in rural areas and suggests a degree of pre-determination to a strategy prior to the outcome of the Issues and Options consultation. As will be considered later in relation to Question 5, Taylor Wimpey UK Limited consider that it would be more appropriate for the Local Plan to make strategic decisions about land allocations in rural areas to ensure the deliverability of the plan and because the use of such a strategy as part of the Local Plan 2030 has been unsuccessful in delivering the required homes. 3.5 The use of objectives is commonly associated with a Local Plan vision, setting out what the Local Plan should achieve to make the Vision a reality. The next iteration of the Local Plan should include objectives so that it can be seen in more detail what the Council are trying to achieve over the plan period.
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.
The vision is broadly supported but is currently silent on the delivery of affordable housing and creating a housing tenure mix that meets the needs of the community. It is recognised that housing is referenced but there should be specific mention that this needs to include affordable housing which reflects local need.
The vision states that it recognises the natural beauty and tranquility of the Borough’s countryside, but nowhere in the document does it say how this will be realised. What does it mean? We already know that the East west rail will destroy much of the natural beauty north of Bedford, whatever the alignment is – not to mention one of your proposals to develop around a new northern station
3.1 As currently drafted, the Vision set out on pages 13 and 14 of the Issues and Options document is too generic with a lack of references to how and where growth will occur across Bedford Borough. 3.2 Whilst is it understood that options still need to be assessed and decisions made about the spatial strategy, Axiom consider that future iterations of the Vision should be more specific and set out more clearly what the area will be like at the end of the plan period. 3.3 Whilst there are references to where growth is already planned in the town centre and to the west of Bedford, there is no reference to the role of other settlements, how they will relate to infrastructure enhancements or how they will contribute to the overall aspirations for the Borough. This is an omission that will need to be amended in future iterations of the Vision. 3.4 There is reference in the Vision to sensitive development in rural areas being identified through Neighbourhood Plans which appears to pre-empt that the Local Plan Review will not plan for growth in rural areas. Axiom question this approach as it may be appropriate for the Local Plan Review to take strategic decisions about land allocations in rural areas to ensure the deliverability of the plan. 3.5 It is normal to have objectives associated with a Vision, setting out what the Local Plan Review should achieve to make the Vision a reality. It would be helpful if in the next iteration of the Local Plan Review, objectives are provided so it can be seen in greater detail what the Council are trying to achieve over the plan period.
The draft vision is supported. It is positive that the Council recognises that Bedford Borough is situated centrally within the Cambridge- Oxford Growth Arc. The proposed approach to locate new development in sustainable locations, with good transport connectivity is also supported. This consultation response, has been prepared on behalf of Axis Land Partnerships Ltd, who are promoting land adjacent to Home Road and to the north of Wood End Lane, Gibraltar Corner as part of the emerging Local Plan. As set out on the attached Ramsey Green Vision Document, a residential led allocation at Gibraltar Corner would fully align with the proposed vision for the new Local Plan. Land at Gibraltar Corner is situated within a very sustainable location, with ease of walking and cycling to Kempston, Wootton and Bedford. The proposed development will also align with the key vision for the Local Plan, with tackling climate change being central to the delivery of the proposed development. Alignment of the proposals at Gibraltar Corner with the vision for the emerging Local Plan is set out as follows: It is situated within a flood zone 1 (low risk); A substantial area of green infrastructure and a green and blue corridor is provided centrally through the site, which will provide open space, biodiversity and sustainable urban drainage benefits; The location of Gibraltar Corner is situated in close proximity to Bedford and Kempston Town Centres, and the allocation of this site has the ability to assist with the creation of more vibrant town centres, with new residents walking, working and spending money in the respective town centres; The proposed Community Hub area, will assist in providing a new facility for existing residents in Gibraltar Corner to use and enjoy. The proposed development has the potential to provide substantial biodiversity net gain including an extension of Buttons Ramsey Wood The site will promote ease of access to the John Bunyan Trail. The above points are expanded upon in detail within the Vision Document that accompanies this representation. As the Local Plan progresses it is important that the allocations within the plan reflect and align with the vision for the Local Plan.
The vision is quite long and overly detailed. It could be shortened and simplified. We welcome the reference to heritage and the historic environment at the end of paragraph 5. This could be further improved by including the vision to enhance the historic environment and increase access to heritage for all, as required by the NPPF. We welcome the plans for the town centre - reference could be added here to the Heritage Action Zone. Finally we welcome the reference to heritage in relation to Stewartby brickworks.
3.1 Firstly, the draft Vision starts with the wording “by the end of the Plan Period”. Whilst the Plan Period sets out the timetable for the Plan’s Policies to achieve their aims, a Local Plan will ultimately have far reaching consequences well beyond the period. 3.2 This is an unambitious and negative approach, and instead, the Vision for the Plan should be one that provides a pathway for life beyond the Plan Period. 3.3 Secondly, the Vision’s focus appears to be on Bedford and greater consideration within the Vision should be given to other areas, particularly Marston Vale, and the opportunities for strategic employment growth. 3.4 This would then reflect the opportunities to deliver a significant increase in high quality employment within the Borough, lowering out commuting and attracting skilled workers to the area. The importance of this as an opportunity is recognised in the Sustainability Appraisal Scoping Report, at para 7.13 3.5 There would then in turn be significant knock on benefits, and therefore the Vision should include a statement that recognises this. Additional wording is therefore suggested as follows: The Vision for Bedford Borough runs through and will extend beyond the Plan Period…. Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 4 In areas such as Marston Vale, the Borough will deliver new high quality jobs which will keep and attract a skilled workforce to the area, and reduce out commuting. This will encourage and deliver sustainable transport and commuting patterns which will in turn deliver environmental benefits for the Borough, its residents and workforce.
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 The vision should also include reference to supporting proposals that provide suitable accommodation for older people. There is a clear rising need for specialist accommodation for older people in the Borough, and this should be a key part of the vision and the proposed strategy of the Local Plan. 4.5 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.” 4.6 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 4.7 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’ 18 strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at Turve/Turvey Station than the levels currently indicated by Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 4.8 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). 4.9 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 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 are 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.
1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the Arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery to meet minimum indigenous growth requirements. Rather, the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of development associated with the Arc being attained before the end of the plan period. 1.5. The Vision could also include more ambitious commentary regarding Bedford unique character and locational position within the arc which could see it grow beyond its traditional role as a small town to be of regional significance. 1.6. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 3 PHILLIPS PLANNING SERVICES LTD 1.7. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 1.8. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.
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.
1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery of basic indigenous growth requirements. Rather the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of growth associated with the arc being attained before the end of the plan period. 1.5. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 1.6. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 3 PHILLIPS PLANNING SERVICES LTD 1.7. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.
1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery of basic indigenous growth requirements. Rather the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of growth associated with the arc being attained before the end of the plan period. 1.5. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 1.6. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 3 PHILLIPS PLANNING SERVICES LTD 1.7. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.
1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery of basic indigenous growth requirements. Rather the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of growth associated with the arc being attained before the end of the plan period. 1.5. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 1.6. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 3 PHILLIPS PLANNING SERVICES LTD 1.7. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.
2.5 MGH supports the Council’s proposed vision wording.
The role of Bedford within the wider Arc community should be emphasised in any statement of Vision with clear acceptance that prosperity (and many other advantages to the Borough) will be better achieved by working in partnership with neighbouring Authorities rather than in competition. The impression of Bedford “grabbing everything for its own advantage” should be avoided since its future wellbeing depends on the wider success of the Oxford-Cambridge Arc project. The BBC focus on developments around Bedford Mainline Station may be to the detriment of EWR (and therefore to neighbouring communities) and to the future exchange of ideas, and personnel and to future wealth creation. Emphasis on Bedford being a major strategic transport hub needs to be avoided in the priorities for the future. It lacks credibility and is largely irrelevant to the future prosperity of the Borough. Future transportation and infrastructure plans should centre on the role of the Borough within the Arc development and not in fanciful aspirations to be an ‘international rail hub’. The Vision statement currently lacks clarity on the future identity and the characteristics which will differentiate the Borough from those neighbouring Authorities and urban centres (many of which have significant advantage over Bedford.). There is a temptation to focus on new houses, shops, businesses, and factories, extending past plans into the future. Although these are important issues there is a need to establish Bedford as a place to live and visit. This requires emphasis is given to the environment, to green spaces and leisure facilities. Such a vision will attract the new workforce being drawn into the Arc area. Bedford’s existing characteristics, including its schooling, riverside scenery, and rural countryside, put it in a strong position but the vision of “an ideal place to live” needs to be stated more explicitly. Whilst the Vision claims some benefits could arise if East West Rail comes through Bedford, it does not mention the disbenefits to the rural communities through which it will pass and that these impacts must be mitigated. The Vision statement (and subsequent policies) should attempt to steer a course for the Borough in the post-Covid world. Realism about the affordability and timing of future plans, and the likely shift in work and other lifestyle practices need to be assessed. Increases in ‘working from home’ are a clear option and the need for high quality communications into home and business properties will be even more essential and should be implemented and held up as a selling point for the Borough. The importance of Neighbourhood Plans should be explicitly accepted since they provide a source of local knowledge, an expression of residents’ priorities, and have formal authority in the planning process that will be reassuring to local residents.
to attract high tech employment sectors. It is considered that the Plan should look to take advantage of opportunities for economic growth by helping new and existing business with readier access to the commercial space they need.
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.
The draft vision is supported. It is positive that the Council recognises that Bedford Borough is situated centrally within the Cambridge- Oxford Growth Arc. The proposed approach to locate new development in sustainable locations, with good transport connectivity is also supported. This consultation response, has been prepared on behalf of Axis Land Partnerships Ltd, who are promoting land adjacent to Home Road and to the north of Wood End Lane, Gibraltar Corner as part of the emerging Local Plan. As set out on the attached Ramsey Green Vision Document, a residential led allocation at Gibraltar Corner would fully align with the proposed vision for the new Local Plan. Land at Gibraltar Corner is situated within a very sustainable location, with ease of walking and cycling to Kempston, Wootton and Bedford. The proposed development will also align with the key vision for the Local Plan, with tackling climate change being central to the delivery of the proposed development. Alignment of the proposals at Gibraltar Corner with the vision for the emerging Local Plan is set out as follows: It is situated within a flood zone 1 (low risk); A substantial area of green infrastructure and a green and blue corridor is provided centrally through the site, which will provide open space, biodiversity and sustainable urban drainage benefits; The location of Gibraltar Corner is situated in close proximity to Bedford and Kempston Town Centres, and the allocation of this site has the ability to assist with the creation of more vibrant town centres, with new residents walking, working and spending money in the respective town centres; The proposed Community Hub area, will assist in providing a new facility for existing residents in Gibraltar Corner to use and enjoy. The proposed development has the potential to provide substantial biodiversity net gain including an extension of Buttons Ramsey Wood The site will promote ease of access to the John Bunyan Trail. The above points are expanded upon in detail within the Vision Document that accompanies this representation. As the Local Plan progresses it is important that the allocations within the plan reflect and align with the vision for the Local Plan.
3.5 The draft vision appears, on first reading, to be comprehensive. It however fails to emphasise the need to deliver new homes, in the right places, at the right time, where they are needed most. This has direct parallel into policy on housing strategies including the spatial distribution of new homes. Housing does not appear to be an emphasis on this Local Plan Review draft vision, despite an increase of 335 dpa requirement set out by the current Standard Method. The White Paper on Planning Reform (August 2020) may also result in further changes to the standard method calculation, altering the Plan’s housing requirement. 3.6 The current consultation version of the Standard Method 2 proposed by Government would result in a minimum Local Housing Need of 1,153 dpa, which would still equate to an uplift of at least 183 dpa when compared with the current adopted Local Plan 2030 requirement (a 19% uplift). De Merke Estates Representation 4 Land East of Clapham Road, Clapham, Bedford Issues and Options Consultation Neame Sutton Ltd. 02392 597 139 August Chartered Town Planners info@neamesutton.co.uk 2020 3.7 Housing will therefore continue to be a key emphasis of the Plan and remains at the top of the Government’s agenda for planning particularly in the context of restarting the economy following the national lockdown as a result of the COVID-19 pandemic. 3.8 It is suggested that planning for housing is made a clear, separate, and detailed focus for the vision.
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.
Yes, we agree in principle with the vision, but it is very generic and very general, stating simply that pretty much everything will be improved. However, there are no specific commitments or targets, timescales or measures by which success or failure may be determined.
27. The absence of any explicit reference to the Cambridge - Milton Keynes - Oxford Arc within the draft Vision is a significant omission. As set out in our response to the first question, the context underpinning the preparation of the Local Plan review, not to mention the reason behind the requirement for an early review, is the need to sustainably facilitate the economic and housing growth that is required to support the Government’s ambitions in respect of the Arc. As such, an aspiration to fulfil this task must be front and centre of the vision for 2050. It is therefore essential that the vision is amended to make the following key points: • Bedford Borough falls within Oxford – Cambridge Arc, a sub-region that will have experienced significant economic growth and is recognised globally, alongside areas such as Silicon Valley, as a hub for high-tech and science investment. • The significant level of economic growth will have been accompanied by a commensurate increase in housing and necessary infrastructure. This growth will have been achieved in a sustainable manner that protected and enhanced key natural, built and historic environments.
The draft vision pinpoints a series of specific projects to be completed, including East West Rail and the Stewartby Brickworks redevelopment. These appear more like objectives rather than the vision, which is typically more overarching in its remit.
Where will the new transport interchange be located and does it include links to Oxford/Cambridge? The Oxford/Cambridge rail infrastructure will have fundamental impact on the villages north of Bedford. What mitigation has been considered to lessen that impact? The Great Ouse valley through Bedford Borough is a jewel in the crown. It should have policies for protection and enhancement. This should be incorporated into the Vision. The plan should be to 2040 as it is very difficult to predict the future beyond this date. The NPPF requires the Local Plans to be reviewed every 5years so that it can be updated as the economy requires. The absence of a question on housing growth is a deficit in this consultation. We understand that the government is currently consulting on a new Standard Method. The potential figures of 800-1300 represent at worst a 35% increase compared to current Local Plan 2030 this will have detrimental impact on the urban and rural environment. Where is the industrial and commercial strategy to support this level of housing growth?
The A6 corridor north of Bedford is already completely grid-locked and cannot sustain further housing development. New building development should be concentrated on brownfield sites, or near to the main road networks such as the M1 or A421.