Question 4
30. The consultation document lists seven potential options for housing and employment growth, namely: • Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites • Expansion of the Bedford / Kempston urban area • Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots • Development along the A421 corridor • Development around an East West Rail northern station • New settlements in locations with good accessibility • More dispersed development throughout the borough including the expansion of villages. 31. Our position in respect of the potential options for growth is set out below. However, it important to preface this with a brief discussion of the step change in housing requirement between the adopted 2030 Local Plan and the Local Plan Review, the scale of which is likely to require a spatial strategy comprising (regardless of anu other option), the allocation of new settlements, and this is the approach being advocated here. Housing Requirement The housing requirement in the adopted Bedford Local Plan 2030 is 14,550 dwellings for period 2015 to 2030 (970 dwellings per annum). In contrast, the current standard methodology for assessing housing need generates a minimum requirement of 1,305 dwellings per annum, an increase of 35% on the adopted figure. It is noted that BBC suggest, on page 18 of the Issues and Options Paper, that a reduced figure of 800 dwellings per annum could be required if the standard methodology was revised to utilise the 2018-based calculations. This is RAPLEYS LLP 6 considered extremely unrealistic as even before the consultation on the new standard methodology began in August 2020, the Government had clearly indicated that the purpose of the revising the methodology would be to significantly increase the overall housing requirement for England. 32. The figure generated by the standard methodology is expressed as a minimum, as Planning Policy Guidance (PPG) advises that there are circumstances under which it would be appropriate to plan for a higher housing need figure than the standard method indicates (e.g. areas subject to growth strategies). Given that Bedford Borough falls within the Oxford - Cambridge Arc which is considered a key economic priority by the Government, it is reasonable to assume that a significant uplift to the minimum requirement of 1,305 dwellings per annum will be required. It is noted that BBC state, on page 7 of the Issues and Options Paper, that work on the Local Plan will focus solely on the housing requirement generated by the standard methodology. This is an entirely unacceptable position as one of the key reasons behind the need for an early review of the Local Plan 2030 is the stated acknowledgement that it fails to appropriately respond to the longer term growth requirements of the Oxford – Cambridge Arc. 33. Notwithstanding the implications of the arc, which clearly need to be addressed, the minimum annual housing requirement generated by the current standard methodology itself would result in an overall housing requirement of: • 26,100 dwellings for a plan period comprising 2020 to 2040 (the minimum period); or • 39,150 dwellings for a plan period comprising 2020 to 2050 (our recommended plan period). 34. The Issues and Options Paper indicates that, at the time of writing, existing commitments in the Borough total around 11,000 dwellings. This will therefore require the Local Plan Review to allocate as a minimum, without any additional allowance in respect of the Arc, sufficient land to accommodate between 15,100 and 28,150 dwellings (depending on the plan period). In contrast, the Local Plan 2030, once commitments were taken into account, was only required to allocate sufficient land to accommodate 3,169 dwellings, which were distributed as follows (the total new allocations for the plan equate to 4,470 dwellings): • Bedford Urban Area: 2,647 dwellings (of which 1,900 dwellings are to be delivered by 2030) • Urban Extensions: 210 dwellings • Stewartby Strategic Brownfield Allocation: 1,000 dwellings (of which 100 dwellings are to be delivered by 2030) • Key Service Centres: 2,000 dwellings • Rural Service Centres: 260 dwellings. 35. In respect of the above, it is important to reiterate that when the CGV allocation (2,500 dwellings by 2035) was removed from the emerging Bedford Borough Local Plan in 2018, the Council did not allocate alternative sites to address the shortfall as would normally be expected. Instead, a decision was made to shorten the Plan period from 2035 to 2030, thereby reducing the overall housing requirement. This indicates that there is not a bank of readily available development sites within the Borough. Potential Options for Growth 36. The step change in growth set out above necessitates a fundamental rethink of the spatial strategy contained in the adopted 2030 Local Plan (and in this context we are advocating the creation of new settlements). The key points to note being: • Bedford / Kempston Urban Area: The Bedford / Kempston conurbation is the main settlement within the Borough and contains services and facilities which mean that it is a sustainable location for new development and that intensification should clearly be a component of the spatial strategy. However, in the recently adopted 2030 Local Plan, the area accommodated approximately 47% of the dwellings allocated for delivery within the plan period (2,110 of the 4,470 dwellings). Carrying that proportion forward in the Local Plan Review would require the allocation of land sufficient to accommodate between 7,097 and 13,230 dwellings (depending on the plan period). This is clearly unrealistic, irrespective of which strategy is selected. RAPLEYS LLP 7 • Stewartby Strategic Brownfield allocation: The site comprises former brickworks allocated for 1,000 dwellings, of which only 100 are expected to come forward within the plan period. A greenfield extension to the site may be possible, but even if the extent of the allocation were doubled the delivery of a further 1,000 dwellings would only comprise 6.6% of the 15,100 dwelling requirement or 3.6% of the 28,150 dwelling requirement. • Key Service Centres: In the adopted Local Plan Key Service Centres (i.e. 8 large villages) are expected to deliver approximately 44% of the new allocations within the plan period. Carrying that proportion forward in the Local Plan Review would require the allocation of land sufficient to accommodate between 6,644 and 12,386 dwellings (depending on the plan period). This is an average of between 830 and 1,548 dwellings per village which is clearly both unrealistic and undesirable, irrespective of which strategy is selected. 37. Based on the above, it is clear that the level of growth that the Local Plan Review will be required to deliver, will necessitate a new spatial strategy involving the allocation of one or more new settlements. As the Issues and Options Paper acknowledges, the advantages of new settlements are: • “Potential for sustainable growth using garden village principles, creating self-contained new communities with good infrastructure provision. • Would reduce the amount of development that must be accommodated in other locations. • Detached ‘rural’ setting enable property construction and create ambiance which higher value occupiers aspire to. • Provides opportunities for sustainable and active transport links, both between new settlements and to the urban areas.” 38. In terms of potential locations for new settlements, CGV is the standout candidate, whether one or more new settlements are needed. It was one of four new settlements considered during the preparation of the Local Plan 2030, but was the only one to be identified as a proposed allocation in the January 2018 Regulation 19 Submission Version. 39. It is acknowledged that the CGV allocation was subsequently removed from the Local Plan due to BBC concerns in respect of noise mitigation and deliverability of the railway station. However, as set out earlier in these representations, the recent Call for Sites submission includes information which both addresses those concerns and demonstrates that the reasons that led to BBC to propose the allocation of CGV remain the same today, namely the ability to deliver a genuinely sustainable development with the provision of a new railway station. Therefore, CGV should from part of the spatial strategy for the Review Local Plan.
We support the continued sustainable growth of Bedford Borough and would welcome a combination of the outlined growth options. Some more general comments upon the scale and location of housing growth are set out as for your consideration. Housing Need Page 16 suggests that the per annum housing figure could range between 800 and 1,305 homes. The 1,305 homes requirement is based upon the current standard methodology and represents the minimum number of units that Bedford should plan for in accordance with adopted national policy. The Council suggest that the revisions to the standard method, may result in a decrease in their minimum housing requirement potentially bring this down towards 800 units. However, the proposed revised standard method calculation would result in Bedford’s housing requirement being set at circa 1,153 dwellings per annum. This revised standard method calculation is still being consulted upon and it is likely that further amendments to this may be made, thus it cannot be wholly relied upon at this stage. Nevertheless, it would be sound to conclude that Bedford’s housing requirement will increase from the Local Plan 2030 requirement of 970 units per annum and is far beyond 800 units per annum. At the present time, the Council should plan for the provision of 1,305 units per annum in accordance with the current standard method. We would suggest that even if the revised standard method does reduce the minimum requirement, the Council maintains its approach to provide 1,305 units per annum. By planning for a degree of ‘over-provision’ this will ensure the Local Plan is more robust against future changes in housing supply requirements and can comfortably meet its minimum need. Small - Medium Sites Storey Homes are proud to be a privately owned family business operating across the South East and currently delivering two major developments in Bedford Borough. We are a Small/Medium Enterprise (SME) housebuilder with the capacity and capability of meeting current and future housing needs across the Borough. We currently deliver projects ranging from 12 to 100+ units, these developments are in the form of either a well-located small-medium site or a parcel that forms part of a wider Sustainable Urban Extension (SUE). As such, we would support both the allocation of small-medium sites as brownfield, infill or proportionate village extensions and SUE’s, but would advocate that SUE’s are designed so that small-medium parcels can be released for SME housebuilders to build out. The importance of small-medium sites is recognised at paragraph 66 of the NPPF (2019) which states that “small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out very quickly.” The Council must ensure that spatial strategy will not prevent the Council from delivering the objective set out in paragraph 68 of the NPPF which requires at least 10% of its housing supply to be delivered on sites no larger than one hectare. These can be identified either in the Council’s Brownfield Register or in the local plan itself, but they should not be part of an assumed level of supply within windfall estimates. We would support 10% of the Local Plan allocations being for small sites, this reduces the risk of developing such sites for SME housebuilders. Further to this, the Council should also look to allocate ‘medium’ size sites of 2-5 hectares, the allocation of sites of this size, this would benefit more established/larger SME housebuilders whom are able to deliver units at a major scale, but are not a typical volume housebuilder. Overall, provision of a range of site sizes and types at a variety of sustainable locations (including within or adjacent to rural communities), will bolster Bedford’s housing supply and ensure a variety of house types will come forward in the Borough.
A combination of brown, yellow and pink locations for housing growth. The housing growth should also consider the growth in NDP plans and possible “Fall In” of housing during this period. East West Rail to the north of Bedford will be going through tranquil villages and mainly graded agricultural land that should be safeguarded. Those villages and the graded agricultural land should have mitigations in place that require minimal housing development that has been developed through NDPs. Development should be along the A421 Transport corridor.
1. One of the main influencers for the revision to the Local Plan is the impact of the Oxford/Cambridge Arc and the requirement for additional development along the Arc. We are of the view that any development along the Arc must be part of the requirement of 1,305 houses to be built annually. It should not be in addition to the quota handed down from Central Government and the Borough should oppose any increase to the annual target above this level. We do appreciate that the required figure is still not definite and that the 1,305 is a maximum. 2. Growth along the Arc, as proposed, will put a strain on the existing road network and other infrastructure, which rural areas in particular will not be able to sustain. Any new development should only be located where there is sufficient road capacity to carry the resulting additional traffic, both north-south and east-west towards Milton Keynes and Cambridge. Its location should also be decided upon with regard to the effect of traffic on B roads and minor unclassified roads. Congestion, traffic levels and road safety within the villages is already of extremely serious concern and further development, especially to the north of Bedford, will exacerbate the problems with the current infrastructure. 3. The proposals for additional development in the Local Plan 2040 should therefore be located along the A421 and near the A1 / A428 south of St Neots. This gives the opportunity for further development of the Wixams area, of brownfield sites south of Bedford and in the Wyboston Area, which will benefit from a new station on the east-west rail link and the new A428 dual-carriageway from the A1 Black cat roundabout towards Cambridge. 4. There are 6 proposed areas of growth in the Borough’s consultation paper. Of the six, four favour development in the north of the Borough. We are seriously concerned about the impact of any further development along the A6 corridor, given the current inadequacies of the A6 and the major traffic delays during peak periods to get into Bedford or onto the bypass. Bedford’s single-carriageway bypass and its roundabouts are already heavily congested and it’s unable to carry current levels of traffic. This will increase as a result of development north of Bedford already included in the current Local Plan 2030. Odell Parish Council is firmly opposed to any major development along the A6 corridor north of Bedford because of the already overloaded road infrastructure into Bedford and because of the increased traffic it will generate through Odell heading east / west towards Cambridge and Milton Keynes from the existing villages and new development north of Bedford. 5. Sustainability will be one of the main criteria that the inspectors will consider when assessing the Borough’s proposed Local Plan 2040. It is a major risk that the inspectors will reject the Borough’s proposed Plan on sustainability grounds if it were to include any major development north of Bedford, over and above the several hundred homes already included in the Local Plan 2030. Most of the recent road infrastructure investment and all of the future planned road and rail investment will benefit the town itself and areas in the south and east of the Borough. The additional development required in the Local Plan 2040 should therefore be located where the additional road and rail infrastructure investment has or will provide the necessary transport capacity. In particular, development should be located where there are dual-carriageway roads, such as the upgraded A421 and A428 towards Cambridge and where the new or upgraded stations on the East/West rail route are located. 6. The proposal of large-scale development at Thurleigh and Colworth will have a major impact on the village of Odell. It will create additional demand on the road infrastructure that already exceeds its capabilities and will also damage the environment and air quality. 7. We welcome your comments that completed Neighbourhood Plans will be taken into account when finalising the Local Plan 2040 and endorse the plans for Bedford Town Centre.
Pavenham Parish Council is very conscious that the Borough Council finds itself in a somewhat difficult position in having to identify locations for future residential growth. As acknowledged in the consultation paper, the Council already has to meet the requirements of the latest housing allocation figures and the Government’s recent White Paper “Planning for the Future” – on the assumption that it becomes Government policy during the promotion of this Plan – which is very likely – will impose an even higher housing provision target figure on the Borough. In considering its allocations, the Council is reminded of extant policies in its current Plan, including Policy 3S (viii) which looks to “safeguarding the intrinsic character of the countryside …”, and Policy 7S which, inter alia, provides that development in the countryside must “not give rise to other impacts that would adversely affect the use and enjoyment of the countryside” and will not give rise “to other impacts that would have a significant adverse effect on the environment, biodiversity or designated Natura 2000 sites”– all of which look to the protection of the borough’s countryside – as indeed is reflected in the Council’s “Vision”. The Parish Council would ask the Borough Council not to allocate an open countryside site for a new town settlement. It is fully accepted that this presents as the “easy option’ if the Borough Council is to meet Government targets in the short-term but the longterm planning consequences for future generations and the Borough will be dire - although as noted below, the Parish Council has some concern that this is already part of the Borough’s current strategy. With the Oxford – Bedford – Cambridge Arc fast becoming a reality, the Parish Council would suggest that the primary search areas should be the Yellow (A421 based growth), Pink (Rail growth) to the south and west of Bedford which combines with the Brown Option (Urban based growth). 3 Whilst the Parish Council will no doubt be viewed (and portrayed politically) as adopting a NIMBY attitude, it firmly believes that if the Borough Council opts for a new town settlement option, the only economically sensible and environmentally sustainable sites - subject to any new sites which emerge as part of the “Call for Sites’ exercise - are to the south of Bedford as indicated above. That said, the Parish Council would also support the Wyboston site in the east which although not originally favoured by the Council because it was felt that investment at Wyboston would be pointed in the direction of Cambridge rather than Bedford, with the arrival of the Oxford – Bedford - Cambridge Arc, that is no longer the case. In this context, the Parish Council should add that whilst politically the Borough Council is heralding as a success the fact that the Oxford – Bedford – Cambridge Arc will pass through Bedford Midland Station, it is patently clear that the hidden agenda of the Council is that by driving the line north from Midland Station as opposed to south which would have been the sensible, economically beneficial and environmentally less intrusive route, the Council/politicians simply see the countryside to the north of the town centre as providing the answer to its historic shortcomings in housing provision allocation.
The Society believes that the more urban locations and the rail-based options are less likely to create conflict with equestrianism. East-West rail northern station – this option could negatively impact the Public Rights of Way network available to equestrians depending on its exact location. Dispersed growth and new settlement-based growth are most likely to negatively impact the bridleway and byway networks currently available.
Can the council assure us that the abandoned and disused brown field sites in Bedford will be developed before virgin green sites are used to build on? There should be a green field tax levied on virgin land that would make development of brownfield sites more cost effective because we can’t afford to keep decimating our wildlife habitat. I would hope that the environment survey is a bit more robust than the one conducted for the Bedford Link warehouses where a family of badgers was wiped out on the A421 because they hadn’t been relocated. Are there plans to create nature highways through tunnels underneath roads and railways so that wildlife can pass freely without getting mown down by cars and trains? Are there sufficient green connected corridors for wildlife to roam or will the pocketed into small areas to die of inter-breeding?
Objectively Assessed Housing Need Firstly, prior to commenting on the various growth options presented in support of this question it is important to clarify the appropriate range in respect of dwelling numbers that the plan should be based on. Currently, the I&O document states the following as an approximation of the growth target for the Borough: Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 4 “Bedford’s annual housing requirement calculated in accordance with the standard method is currently 1,305 dwellings per annum. If the end date of the plan is 2040, using this figure there would be a need to plan for 26,100 dwellings over a 20 year plan period. It is important to note, however, that during the course of the plan preparation period this figure may change. There are two reasons for this. Firstly, the Government figures for affordability are published annually (and may therefore change when new data is published in March 2021); and secondly, the Government has announced that it intends to review the standard methodology in its entirety in the course of this year. Taking account of these uncertainties this consultation seeks views on a housing figure in the range of 800 –1,305 dwellings per annum. It should be borne in mind that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum. The 800 figure represents an estimate of the possible figure were the standard methodology to be reviewed and based on the 2018-based population projections rather than the 2014-based figures.” Since the publication of the I&O document the situation in respect of the Government’s Local Housing Need calculations has in fact moved on. There is now a current consultation into a revised methodology set out within the Government’s ‘Changes to the Current System’ paper, comments on which are invited until 1st October 2020. Central to the revised methodology is the way in which the Government can continue to ensure that the national annual target of 300,000 homes continues to be achieved. The revised methodology focuses on three issues: the physical capacity of a local area to assume additional homes (i.e. is it an urban or rural area); the current affordability of new homes locally; and the change in affordability over the preceding 10-year period. This ensure that areas capable of accommodating growth do and areas that have seen an escalation of the affordability ratio, indicative of increasing demand, do more to accommodate these trends. Currently, and based on the consultation draft of the revised methodology, Bedford’s projected annual housing figure is 1,153 dwellings1. This factors in a significant uplift that recognises both the current issues in respect of affordability and the fact that this situation has in fact worsened over the last decade. Accordingly, then, the indicative range upon which the Borough’s emerging housing requirement should be based is 1,153 to 1,305 dwellings per annum. Based on a 20-year plan period until 2040 and taking into account existing commitments of approximately 11,000 dwellings this results in a revised residual requirement for the plan period of between 12,000 and 15,000 dwellings by way of new allocations. This is before any additional uplift relating to strategies such as Arc-related growth are factored in on top. It is clear that a significant task lies ahead for the Council in respect of accommodating what will be a significant amount of growth over the plan period. The Appropriate Spatial Strategy Based on the huge scale of required growth it is imperative that the spatial strategy of the plan is driven by the identification of demonstrably deliverable sites rather than the type of complex and often aspirational development opportunities that were considered during the course of the preparation of the Local Plan 2030. The Council encountered repeated difficulties throughout the production of the current plan due to an over-reliance on the proposed new settlement at Sharnbrook. Even once the plan received an endorsement from the presiding 1 The starting point prior to adjustment is the higher of either Bedford’s annual household growth based on the 2018 projections (623.1 dwellings) or 0.5 of the 2019 estimate of housing stock (378.3 dwellings). So 623.1 x [(AR (9.2) – 4 / 4) x 0.25) + (2019 AR (9.2) – 2009 AR (7.1) x 0.25) + 1] = 1,153 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/907215/200805_Changes_to_the_current_planning_system_FINAL_version.pdf Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 5 Inspectors their report cast clear aspersions over the deliverability of elements of the current framework of sites with a particular level of doubt applied to the prospects of both the land at Ford End Road and South of the River. It of course did not escape our attention that the Council had earlier deleted eminently deliverable and entirely sustainable development options from the plan such as our client’s land at Salph End principally on the basis of both the new settlement and the urban sites delivering quickly. The evidence now before us suggests that these decisions were miscalculated – indeed, the inadequacy of the adopted spatial strategy and series of allocations is one of the main reasons for such an early review of the plan. Decisions on the eventual spatial strategy of the plan must, then, be substantially informed by the availability of sites and the evidence put forward at Call for Sites stage that provides the Council with certainty that they are available and deliverable. The Strategic Housing Land Availability Assessment (SHLAA) comprising part of the evidence base of the plan must represent the starting point in considering whether each of the spatial options presented in support of Question 4 are viable. From our client’s perspective they are pleased to once again present their own site, land between Hookhams Lane and Ravensden Road, Salph End, as a spade-ready opportunity to deliver a substantial sustainable extension, comprising up to 400 dwellings and a site for a new primary school to the north of the Bedford urban area. The credentials of this site were recognised by the Council prior to its identification as a draft allocation in the 2017 Consultation Document published as part of the Local Plan 2030 process. The graphic supporting the urban option includes hatching identifying a combination of sites around the periphery of Bedford and at the centre of the town it is inevitable that any additional allocations required to support this strategy would be urban edge. Few options of scale beyond the stalled allocations included in the Local Plan 2030 existing within the urban area. Table 1 which accompanies the list of options recognises this, that the brown option would largely entail urban edge development. Curiously, however, it identifies this as a factor that would count against this strategy. We disagree – the identification of suitable and sustainable urban edge greenfield sites would ensure both deliverability and swift access to the strategic highway network. The principal objective of the new local plan is to ensure the 13,000 to 15,000 additional homes required across the Borough can be delivered from the earliest years of the plan period.
The cursory analysis in Table 1 of the pros and cons of the potential locations for growth does not provide a sufficient basis for choosing a preferred option. First, the analysis as it stands is inconsistent. One example is the con comment for the Red option, “New settlement based growth”, that “There could be an adverse impact on local landscapes, loss of agricultural land and countryside”. This exact comment could equally apply to the Grey, Orange, Pink and Yellow options. More fundamentally however is the need to subject all location strategies to an analysis of how they could achieve the objectives of new policies along the lines of those we propose in answer to Question 1, namely; • Include new policies to ensure that the totality of new allocated development, when fully completed, would be sustainable in terms of natural resources, in particular water supply and treatment of waste and surface water, would maintain, and if possible improve, the level of natural capital, and would maintain, and if possible improve, the agricultural and food production assets of the borough. • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change. • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change.
The potential locations for growth include ‘Red – New Settlement based growth’ including the four potential new settlements options considered in the preparation of the Local Plan 2030 but not taken forward. The potential new settlement options include Thurleigh Airfield. However, St Modwen have subsequently confirmed that they will not be promoting a new settlement at Thurleigh Airfield through the Local Plan Review process. St Modwen continue to own and manage Thurleigh Airfield as a business park and support its continued allocation for employment use, classified as Protect and Enhance. Under the Local Plan 2030 sites classified as Protect and Enhance play the primary role in supporting economic development and growth by offering attractive and available opportunities for development to retain and support existing businesses and to secure new inward investment. These sites, and in particular brownfield sites such as Thurleigh Airfield, should be identified and prioritised as a location for employment growth.
While we understand this is an issues an options consultation, the approaches outlined may be overly simplistic and need to also reflect the adopted position up to 2030. While the premise of new settlements is supported they would need to be aligned with existing/improved infrastructure or new infrastructure of which much is still unclear. Therefore, there would need to be a mixed approach which allows for new settlements, growth in the urban centres and some dispersed growth particularly in key service centres such as Clapham and Bromham, where Neighbourhood Plans are bringing forward community led growth with appropriate stepping in mechanisms if required. New settlements may also take sometime to come online and therefore may only start delivering towards the back end of the plan period, further demonstrating the need to early deliverable sites such as land west of Milton Road, Clapham and others at key service centres.
It is noted that there are six alternative spatial options for growth. Of the six options, the yellow, pink and orange approaches are similar, insofar as these focus upon the A421 and east/ west rail corridor. The other options could have implications for adjoining local authorities to the north (East Northamptonshire, Wellingborough and Huntingdonshire), as follows: • Urban based growth (brown option) – Potentially significant implications, as this includes potential proposals for urban extensions to the south of Rushden and west of St Neots • Dispersed growth (grey option) – Some implications, due to the potential increased scale of development at villages to the north of Bedford Borough • New settlement based growth (red option) – Potentially significant implications for East Northamptonshire, as three of the four potential locations are situated along the Midland Mainline/ A6 corridor. Red and brown options – potentially significant implications for East Northamptonshire In the case of the new settlement based growth option, this was previously proposed for the current Local Plan. This Council (Planning Policy Committee, 19 February 2018, Item 6) raised concerns about the Colworth proposal. While there was no objection in principle to Colworth Garden Village, it was considered that the evidence base was insufficiently robust in relation to green infrastructure and the strategic road network. If this approach is revived in the new Bedford Local Plan, then it is emphasised that East Northamptonshire Council’s previous concerns should be satisfactorily overcome. The brown option is a significant new proposed spatial strategy. The Local Plan 2030 and previous Core Strategy focused upon growth around the Bedford/ Kempston urban area, with the rural north of the Borough regarded (for spatial planning purposes) as rural, although the Local Plan 2030 does include proposals for a strategic allocation at Sharnbrook. It is emphasised that the proposals for urban extensions to the south of Rushden (Wymington Parish) will have implications for Rushden and Wellingborough. At this stage, it is recognised that these could present new growth opportunities. The Council’s consideration of these proposals are summarised as follows: • It is noted that the Plan acknowledges the potential for SUEs/ growth adjoining Rushden and St Neots, although in the case of the possible expansion of the Rushden urban area to the south this was previously assessed in the Rushden Sustainable Urban Extension Background Paper (January 2015), but significant concerns such as coalescence of Rushden and Wymington were highlighted; • It is emphasised that Rushden and St Neots are significant urban centres, both already hosting major growth over the next 20-30 years, so it is critical that adjacent local authorities and infrastructure providers work closely together to ensure delivery of development in a coordinated manner; • It is unclear from the document the exact location of potential growth to the south of Rushden, although this could potentially be supported if it provides a catalyst for the development of significant infrastructure provision, such as a new rail station at Wymington, located on the Midland Main Line, which could serve the new development and provide opportunities for Rushden and North Northamptonshire.
Eclipse Planning Services has carefully examined the material illustrating the six potential options on pages 18 to 20 of the Consultation Paper and the summary in Table 1. On the whole we think that the advantages and disadvantages of each are quite well summarised, but some important factors appear to have been overlooked. Most important of all, none of the options has been considered in terms of the great range in the potential residual housing requirement, in other words the number of additional dwellings above existing commitments this review must plan for. The Council acknowledges, and we note in our response to Question 3, that this figure ranges from 5,000 to 15,000 dwellings. For example, the Grey option – dispersed growth – would be less unsustainable at the lower end of the range; but the lower end would also significantly if not entirely undermine any strategy based on one or more new settlements, in this case both the Orange and Red options. We note what the Council says about the eventual strategy possibly combining elements of more than one option; indeed, there is some overlap between options already. We consider that, for reasons given below, some options should be eliminated from the start, irrespective of the size of the residual housing requirement. Brown - Urban based Growth This option appears to be closest to the pattern of development which has on the whole taken place up to now. In the last twenty years or so, however, there has been increasing concern that the continued outwards expansion of small and medium sized towns is not necessarily the most sustainable option. The effect of such growth has been (among other things) to place an increasing proportion of the population of these towns outside reasonable walking or cycling distances of the centres which still provide many services and much employment, and to put increasing strain on infrastructure including the road network. Many local authority districts contain a number of such towns. Here, however, Bedford itself dominates and contains more than half of the Borough’s total population. The problem of peripheral expansion is therefore perhaps not quite so acute; there is for example a critical mass available in Bedford to support a reasonable level of bus services. Nevertheless, given the high and increasing cost of infrastructure, it is essential that best use be made of it. The potential locations for growth are illustrated on page 18. Even in this diagrammatic form, some locations, for example on the north side of Bedford and at Rushden, are not well placed to benefit much, if at all, from the investment in major infrastructure which has already been completed (the A421) or is planned (the East West rail link, the A428 to the east). The location of development shown in the drawing west of St Neots is not what L & P Chess are now promoting; land west of the A1 at Wyboston is located south west of St Neots, rather than west, and although extensive, is not on a scale implied by the diagram. We therefore consider that the elements of the Brown option which do not form part of other options should be rejected; or to put it another way, the Brown option could be discarded altogether because the more promising and appropriate elements of it are also included in other options – Yellow and Pink. Yellow – A421 Based Growth We note from the diagram on page 18 that this option is illustrated by a continuous yellow band from south west of Bedford to a point on the A1 west of St Neots. Even without a detailed site analysis, it is clear from scrutiny of the most recent Ordnance Survey sheets that development in this corridor cannot, or at least should not, be continuous. There is for example no junction on the A421 between Workhouse End and the A1, and we suppose that Highways England would be reluctant to approve any more junctions on the section of the road covered by the yellow band. There may be some limited opportunities off the old A421 running through Great Barford. This option might however better be characterised as nodes on a corridor rather than simply as a corridor; this would avoid giving the impression that this option could “appear as urban sprawl and join-up nearby villages”. In terms of the other stated pros and cons in the Consultation Paper, the land west of the A1 at Wyboston is a first-class opportunity for development even if “western expansion of St Neots or a new settlement at Wyboston” are not needed. Pink – Rail Growth We note that the diagram on page 19 shows significant development to the south west of Bedford and at Tempsford. This raises a question about the scope for development at Tempsford, bearing in mind that the existing settlement is in Central Bedfordshire and that the boundary between Bedford Borough and Central Bedfordshire runs along the River Great Ouse. This imposes constraints on where Bedford Borough Council can legitimately allocate land, and where it can then in practice do so given the extent of areas of flood risk. This option implies the successful completion of the East West rail link sooner rather than later. The Council is right to be cautious about the speed with which this can be achieved. However, the key point is that the Council must also be realistic about the extent to which the new rail link will contribute to sustainable travel, particularly for journeys to work. Only in London does rail make a significant contribution to travel to work; and even in some of England’s eight major provincial cities, such as Bristol and Nottingham, it makes a very limited contribution. None of this should however deter the Council from identifying other suitable opportunities in the area which would be appropriate locations for major development irrespective of the speed of completion of the rail link. We consider that the development of land west of the A1 at Wyboston would be appropriate even of the rail link were not proposed. The rail link should be regarded as a significant incidental benefit to the St Neots area as a whole. The land west of the A1 at Wyboston is the best option in this part of Bedford Borough in terms of its location in relation to existing development and the road network, and the absence of any significant constraints. Orange – East West Rail Northern Station Growth Eclipse Planning Services considers this to be the least convincing of all the options, either on its own or in combination with any other. Even the title is a contradiction in terms. We have examined the material on the East West rail website, which clearly shows the lack of firm proposals for the section from Bedford to Cambridge – in contrast to the Bletchley to Bedford section, which was never closed, or the Oxford to Bletchley route, where a significant section has been reopened. The proposals appear to make greater use of the existing Bedford Midland station, which is surprising given the layout of the existing and former railway lines in the area and what would appear to be the somewhat limited scope for alternative routes, particularly in the built up area. In this context it is difficult to see how a new settlement and station north of Bedford fits in. Such a scheme might provide improved access to London, but this is not in our view a factor of great weight. Grey – Dispersed Growth This is likely to be the least sustainable option, especially if the residual housing requirement is at the higher end of the range. It is likely to result in the greatest increase in the number and length of journeys by private car and the least efficient in its use of infrastructure. Eclipse Planning Services considers that this option should be discarded altogether. Red – New Settlement Based Growth A historical perspective is very important in this context. The Government has for some time lent support to the principle of new settlements in the form of garden villages or towns, and to some schemes in particular. Such support stems in our view to a certain extent from a misunderstanding of the circumstances in which the original New Towns were proposed, which are quite different from those of today, and the scale on which they were built. Notwithstanding Government support, new settlements have in recent years often not found favour as a means of meeting housing and other requirements. The recent experience in Essex alone should give the Council serious cause to think about any option involving new settlements. The combined Local Plan for north Essex (Braintree, Colchester and Tendring districts) ran into difficulties over its reliance on new settlements; Examination of the Section 1 Plan began in October 2017 but strategic issues were still being discussed in January 2020. Shortly afterwards in nearby Uttlesford, the Local Plan proposed three new settlements, where there appeared to be a reasonable case for only one of them owing to its proximity to Stansted Airport. In a letter to the Council dated 10 January 2020, the Inspectors stated that the Local Plan was unsound for reasons summarised in no fewer than thirteen bullet points. Some of these were clearly specific to this particular Plan; but some were potentially applicable to any new settlement. The Inspectors also concluded that the Plan was incapable of being made sound by means of Main Modifications and thee Council resolved on 30th April to start a new Plan. One of the disadvantages of new settlements is the relatively high cost of physical infrastructure (roads, utilities, and other engineering work) in the early years of development. Another is the speed at which social infrastructure (schools, shops, other facilities and services) is provided, which tends to lag behind housing provision. This was a common criticism of the New Towns.
This cannot be answered without comment on the misguided decision of the BBC (and the similarly misguided enthusiasm of the Mayor) for the Northern route of the East-West rail link. The route should be the obvious one to the South parallel to the A421 and then going North around Tempsford. In any other European country road and rail go together wherever possible, both for convenience and to lessen environmental damage. The logic of this argument is that most development should be brownfield sites plus South of Bedford (around the A421) and West towards Cranfield, as it is inevitable that Bedford and Milton Keynes will join up at some stage in the future.
Preferred options are urban based, rail growth based and A421 based growth
2.10 The Consultation Document sets out 6 potential options for the spatial distribution of growth through the Local Plan review, these include urban based growth, A421 based growth, rail growth, east-west rail growth, dispersed growth and new settlement-based growth. The consultation document also sets out that any eventual strategy could be a combination of the above options. 2.11 We do not agree there should be any significant form of reliance on strategic sites, particularly in the form of new villages. Strategic sites, including new villages, could be included as a facet of the supply, but any plan which relies on the timely delivery of a number of strategic sites forming the largest component of supply is considered to be problematic. Such a strategy lacks flexibility and the failure of even a small number of sites could have significant impacts on housing delivery. In particular, new free-standing settlements are notoriously difficult to deliver and as such a strategy including a number of such settlements would be very difficult to support. If a new settlement is allocated within the Plan, then caution must be applied when calculating proposed build-out rates and this must be supported with sufficient other methods of delivery to insure the Plan against non-delivery. It is noted that the Council previously promoted a strategy of delivering new settlements as part of the preparation of the adopted Local Plan, but ultimately concluded such 2.12 With regards to placing greater impetus on further delivery adjacent to urban areas, regard must be had for market absorption rates and the willingness of housebuilders to be building concurrently in one urban area. Given the number of allocations and permissions already in place, the Council must have evidence that there is capacity in the designated urban areas for further growth, in regards of both market and infrastructure capacity. 2.13 Whilst increased densities around public transport nodes or in urban areas is a way of increasing housing numbers and can be appropriate in certain circumstances, regard must be had for issues relating to design and housing quality. Moreover, regard must be had for the capacity of local infrastructure and services, given the significant increases in population through increased densities. 2.14 Whilst we do not have any particular objection to basing growth around planned transport infrastructure, clearly such infrastructure is likely to have capacity limitations and over reliance on such may cause significant issues relating to capacity and congestion. Notwithstanding this, it limits the geographical spread of development, which can place undue impacts on infrastructure and capacity of services and facilities. 2.15 We concur that the eventual strategy could be a combination of the listed options, but consider it must include an element of dispersed growth. Dispersed growth has a number of advantages and cannot be fully excluded in any adopted strategy. Firstly, the Council’s adopted strategy promotes a level of dispersed growth. Moreover, in the development of the adopted Local Plan, the Council did consider, and at one stage prefer, a strategy of greater dispersed growth, including higher levels of growth directed to both the Key Service Centres and Rural Service Centres. We consider the Council should revisit such proposals, particularly in light of the increased housing requirement derived from the Standard Methodology and influenced by the Oxford-Cambridge Arc, which is likely to see the housing requirement further increase by at least 200 dwellings per annum (thereby an overall requirement of circa 1,360 dwellings per annum). Smaller sites in sustainable locations are also likely to be able to deliver quickly, which will also enable the authority to respond quickly to the increase in housing requirement. As a number of large sites are already allocated in the adopted Local Plan, this should be balanced with sites being allocated for less than 100 units which can come forward quickly and assist the Borough in housing delivery, affordable housing delivery and maintaining their housing land supply. By allocating sites in the Key Service Centres and Rural Service Centres the Borough would secure a mixture of sizes to ensure development can be brought forward to meet the needs of the community.
I believe the growth locations should be either 1. Brown – Urban based growth – provided it is within the current boundaries of an existing urban settlement. 2. New settlement growth. I believe the other options would result in housing which was not adequately supported by infrastructure or services
My first reaction to this leaflet is that it has one virtue (on the Council's side): when the horrid deed is done, the Borough Council can claim - 'Well, we told you so. You can't say you werern't warned!' I can't detect any other virtues. A lot of the information is based on a hypothesis. We don't know yet where the East-West Rail Link is going to go. Without that information a lot of the speculation as to housing etc, is fatuous. The cheapest way to restore the Oxford to Cambridge railway is to rebuild the track from Bedford St. Johns to Sandy, some 8 miles. Anew railway might invlove the demolition of a few houses en route. It would require very few new houses. This is the fundamental flaw in this document. It puts the cart before the horse. This area need improved transport links, not more houses. A bi-mode train could take advantage of existing electrified railway between Sandy and Cambridge via Hitchin. This is the value for money option, and you can't demonstrate otherwise. The priority should be the railway, not more houses.
Of the 6 options suggested by Bedford BC, a combination of brown (urban), yellow (A421) and pink (rail growth) is preferred. Considering the 2018 ONS data, the current target of around 900 homes p.a. should be reviewed. The change in work/transport patterns should be considered and net zero around connectivity and transport should be explained. Criteria surrounding A6 congestion and environmental impacts, including air pollution, should also be published. Bedford BC should complete Wixams as soon as possible rather than pausing development as with land in Central Bedfordshire, 6,000 more homes could be provided.
David Chadwick -- David and Jean Chadwick 01234 721497
My preferred solutions would be the Brown and Yellow choices. There is existing new development in and adjacent to Bedford and the A421 is similarly undergoing considerable development. Pink choice is not likely to be available for some years to come as the rail route has yet to be finalised. Grey choice is a poor choice as the villages have very poor infrastructure which implies that most residents have to use the car in order to go anywhere. The north Beds villages are noted (according to the census) for having an aging population with a very high percentage of residents of retirement age.
John Dillnutt
There is a clear public desire for the Black cat round about to be sorted out, The yellow plan suggests development on either Wyboston or Great Barford. Both would cause additional traffic however a park and ride scheme from the Gravel pits at Roxton would alleviate the traffic and encourage people to come into Bedford for a bit of shopping and a day by the river from Stevenage and St Neots. Both Park and rides should also stop at the railway station.
I am a County Council in Hertfordshire representing the Tring Divison. Tring residents (including me) find the Marston Vale Line now a convenient method of getting to Bedford by changing at Bletchley. Depemding which part of the town they wish to visit they will select either of Bedford Midland or Bedford St Johns. 1. The current East-West Rail Line is proposed, under the agreed favoured route, to run to the north of Bedford. If, however, problems develop with regard to the acquisition of land or the granting of planning permission along the favoured route, then it might prove useful to continue to have this land available should an alternative route prove necessary. 2. The development site as highlighted in the current consultation documents will only be marginally effected by the continued preservation of the relevant railway land. 3. Should a tram or light rail transport system be required in Bedford – a town beset by serious road traffic congestion – the Bedford St Johns Station, not far from the hospital, would need more space as a significant transport interchange between road, rail and tram services. The full length of the trackbed to Cardington Road would be essential to any tram route. 4. Until, or instead of being, needed either for an alternative E-W Rail Route or for a tram system, the land could almost immediately be put to a pro-social use as a footway/cycle way to and from Cardington Road and with some space devoted to secure cycle parking.
Orange; that said, Traffic Surveys need to be considered to identitfy the current and proposed volume of traffic - having regard to future developments - from the north of the town in orderto ascertain whether a Parkway Station or Park & Ride facility (electric buses!) would be viable.
In my opinion the preffered growth should be either the Yellow or Pink proposal. The other suggested growth areas would have more detrimental effects on the area as a whole. The other proposals would lead to much more loss of open spaces and less distance bewteen exisiting villages leading ultimately to urban sprawl and teh gradual loss of individual village identity in teh beautiful area of North Beds.
Orange: Yes. Red: possible option. Pink: Possible option. Yellow: No. A421 route is already overstretched. Grey: No. Too much pressure on villages. Brown: No. Beacuse of overstretching the existing facilities + St Neots/Rushden could be a problem.
Combine elements from Brown urban based growth and Pink rail growth, this will help attract high tech jobs from both Cambridge and Oxford.
Urban based growth - Ravensden Parish Council does not support further large scale growth on the edge of Bedford in the parish but urges that maximum use is made of urban opportunities such a brownfield land, office and retail conversions and sensitive redevelopment. The Review should be mindful of minimising the need to travel, thereby reducing emissions and promoting a low carbon economy. Taking into account the Graze Hill commitment (which will add 50% to the housing stock in the parish), there are no suitable sites for significant housing development anywhere in the parish, without seriously compromising landscape character, existing or proposed open space, or the setting and role of our settlements; or adding unacceptably to the already high volume of traffic which crosses the parish, or overloading other existing infrastructure (e.g. drainage). Existing landscape features, amenity spaces, strategic gaps and recreation areas should continue to be protected. A421 based growth - Ravensden Parish Council supports this scenario as it would sustainably integrate new housing with the strategic road network and with major existing and potential new employment sites. This scenario could also form the basis of a longer term strategy for accommodating appropriate levels of growth resulting from the Oxford-Cambridge Arc and couple into a Bedford south parkway station serving Thameslink, MML and EWR services. Rail growth - Ravensden Parish Council supports this scenario for the same reasons as A421 growth, i.e. south west of Bedford. EWR Northern Station - Ravensden Parish Council do not consider there is "significant potential for growth north of Bedford". We are emphatically and unanimously opposed to this scenario which we consider to be wholly unrealistic, for the following reasons. 1. The principle, route, financing and timescale for the implementation of the central section of EWR have yet to be confirmed and EWR can therefore form no basis at the present time for any development strategy in this Review; 2. EWR advised Parish Councils as recently as 18th August 2020 that an intermediate station north of Bedford is not being considered by them. This would slow journey times and reduce the so-called benefits of the scheme. If intermediate stations were to be planned, the cost-benefit assessment for all route options should be re-appraised; 3. There is no suitable large scale developable land within the Route E corridor for a new station and associated development. Any proposal to divert the line outside the current Route E corridor to allow for an additional station on developable land would open up the need for EWR to recommence their whole consultation process on route options, thereby delaying the whole project significantly; 4. Road infrastructure to serve major new development north of Bedford is wholly inadequate and other services (e.g. electricity and water supply, which occasionally cannot cope even with present demand) would require significant reinforcement; 5. Major residential development would further increase undesirable levels of commuting by road to employment sites within Bedford and beyond, seriously impacting road conditions, highway safety, and the environment of the Parish; 6. There would be unacceptable impacts on local landscape character, recreational and visual amenity, and the nature conservation value of this acknowledged tranquil area; 7. There are no large brownfield sites anywhere in the Route E corridor north of Bedford and therefore major development would mean the loss of the most versatile Grade 2 and 3a agricultural land, contrary to the Review's stated objective of maximising the use of brownfield land for development; 8. By suggesting a parkway station is required, this proposal tacitly accepts that Bedford town centre and the road network serving Bedford Midland Station are unable to absorb any additional travel demand that might arise from EWR, especially at peak periods. If parkway stations are needed to relieve congestion at Bedford Midland, then they would be better placed on the Midland Main line north-west of Bedford where travel demand and railway capacity already exists, and south of Bedford where EWR and Thameslink/MML services could be integrated. Dispersed growth - The current local plan 2030 defines a settlement hierarchy and a policy approach to development at settlements which Council officers confirmed in the Issues and Options presentation to Parish Councils, are to be retained in this Review. However, allocating development proportionately to settlement size would take limited account of the existing settlement hierarchy or policies. In line with the adopted policies in the 2030 Local Plan, any dispersed development proposed for lower order settlements such as Ravensden Church End and Ravensden Crossroads should, if it is needed, be appropriate in scale and well related to the built form of the settlements. Development adjacent to the settlements would also need to be supported by local communities through Neighbourhood Plans or meet a particular local need. Development in the open countryside should be allowed only for specific and appropriate types of development. To reiterate the Parish Council's comments under the Urban Growth scenario, any further large scale development on the northern edge of Bedford should not be considered. New settlement based growth - Ravensden Parish Council is not opposed to the principle of new settlement(s) along the A6 corridor as proposed by landowners in the call for sites for the 2030 Local Plan. Some of these proposals provide opportunities to make significant use of large brownfield sites, (which the Review intends to prioritise) and all of them would meet a large proportion of the projected housing need requirement, thereby relieving pressure for large scale development on the fringe of Bedford or on an unacceptable scale elsewhere. However, there could be significant traffic effects in this parish which would need to be planned for, infrastructure should be provided before development takes place and the environment of existing communities protected, through effective traffic management including enforcement.
I would support any of the Brown, Yellow, Pink or Orange options. I would not support the Grey or Red options.