Question 4
Too much weigth is being given and placed upon development within the Arc area. It simply could not accomodate everything that is being proposed for within it. We support Bedford and Kempston urban development (Brown) or areound the rail stations (Pink). We do not support further expansion of A421 area or of St Neots.
Transport Black Cat enhancements works start date not confirmed. Loves Farm and Wintringham developments have close proximity to St Neots railway station the car park is at capacity without these proposed developments and has resulted in St Neots T C investing huge monies on Local Highways Initiatives to prevent commuters carparking along key roads and residential areas. A major unknown in this plan is the route of the East-West railway and the location of its new stations.
Urban Growth Brown – WPC would support the urban growth described on brownfield sites in Bedford and Kempston. A421 Growth Yellow – WPC oppose any houses built in excess of a quarter of a mile from the A421 itself. Expansion of Wixams is to be encouraged. Rail Growth Pink – WPC support growth to the south and west of Bedford, Wixams and Tempsford. Rail Growth Orange – WPC strongly oppose this scenario. East-West denied that another station North of Bedford was required. Such a station would slow down journey times and was never considered when the rail route options were consulted on. Dispersed Growth Grey – WPC oppose any growth in the Parish. Wilden has no facilities or services. The 500 houses to be built in Great Barford would already be placing a huge load on services there, such as the doctor’s surgery, shop and school, and any extra houses within parish boundaries would add to this problem. New Settlement Growth Red – WPC support growth along the A6
Agreed response: Being a small parish in the far north of the Borough we would not be directly involved in any of the six cited potential areas for growth except Grey-Dispersed growth. The implications of this option are not at all clear but we would be strongly opposed to growth expectations in our two villages higher than those proposed in the Local Plan 2030. We agree with each of the disadvantages listed for this option in Table 1. As for the other 5 options put forward, we do not think it appropriate for us to comment in detail. However, we do feel that the Pink option would be best for our area as traffic generated from development here would not be tempted to use the rural roads through our parish to do east-west movements. We support the development principles set out in the Draft Vision and we found the Pros and Cons set out in Table 1 for each to be well presented.
Brown – YES Yellow – NO Pink – YES Orange – YES Grey – No Red - Yes
Members reiterated concerns about the potential proposal (Brown option) for expansion of the Rushden urban area into Wymington parish, which would mean that East/ North Northamptonshire would entail all of the infrastructure costs, without benefits such as increased Council Tax receipts. If a Rushden South sustainable urban extension into Bedford Borough (Wymington) is supported, this could also be accompanied by a boundary review for East/ North Northamptonshire and Bedford Borough. Support for the potential proposal for Wymington rail station in association was reiterated, although it is unclear where this could be sited
I consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only) and Yellow (A421 based growth) growth would provide the best solution for preserving the character and landscape of the north Bedfordshire countryside, especially its agricultural land and the Great Ouse Valley north of Bedford. I do not consider the north Bedfordshire edge of Rushden designation is appropriately designated as urban. This would use up valuable agricultural land and will undoubtedly increase the traffic pressure on our north Beds rural roads and villages all of which already suffer from rat running. The roads through our villages are narrow and our rural roads dangerous with their 60 mph speed limit and sharp bends. The large commercial vehicles which already use the rural roads network are damaging our road surfaces and create a danger in our villages to pedestrians. A number of village houses have seen their foundations undermined by such vehicles driving through our villages. This would only increase with any large development north of Bedford town along the A6 corridor. Any large scale proposal for this area would eat up valuable agricultural land and cause significant damage to the biodiversity of the region. The area along the A6 north of Bedford is already vulnerable to the effects of urban expansion in Northamptonshire which is also planning significant numbers of houses in the Rushden area alongside the A6/John Clarke Way over the next 10-15 years as well as housing at Rushden lakes. The combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams) and Yellow (A421 based growth) is best placed to offer a greater potential for residents to use and can facilitate travel by walking, cycling, public transport and easy access from Wyboston to the main arterial road networks. Wyboston will also be close to the next East West Rail station after Bedford town. Increasing development density improves public transport viability; use of brownfield land reduces the need for development in open countryside and the destruction of agricultural land; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. However, I am disappointed to see no proposal for large scale development south of Bedford at the Stewartby Brickworks site, particularly since the former Head of Planning recommended to the Borough’s Local Plan Action Group (LPAG) which comprised the Mayor and political group leaders in a report dated 19th July 2017 that this site could accommodate up to 8,000 homes. In his view this corresponded to the NIC interim report of November 2016 which made the case for boosting housing and employment along the Oxford, Milton Keynes, Cambridge growth corridor, it would concentrate growth in a sustainable location close to existing and proposed transport links south of Bedford with good accessibility to the town and would also enable the development of brownfield and damaged land. A copy of this report is attached. Orange (East-West rail northern station growth). Whilst the preferred route for East - West Rail is likely to be from Bedford Midland station there is no proposal for an additional East-West Rail station in Bedford Borough. I am therefore surprised to see this as an option and find it misleading given the implied suggestion that there could be such a station. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are choosing through neighbourhood plans to deliver housing growth appropriate to their parishes as chosen by their residents. These should be allowed to progress without the imposition of large numbers of houses allocated through the Borough’s new Local Plan. The Key Service Centres of Sharnbrook, Great Barford, Clapham and Bromham have already been allocated large scale development in the current Local Plan of up to 500 houses each and so the growth in the rural area north of Bedford town will be considerable without any new settlements of thousands of houses. Red (New settlement-based growth) I oppose any New Settlement based growth along the A6 corridor for the reasons given above however would support a new settlement of up to 8,000 homes at the Stewartby Brickworks for the reasons given in the report prepared for the LPAG on 19th July 2017 as detailed above and attached. I would also support a new settlement at Wyboston for the reasons given above.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner; Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
Having considered the potential locations for growth illustrated above, and the pros and cons in Table 1, which one(s) if any do you support? It may be that the local plan strategy will need to combine elements from more than one of the locations to achieve the scale of growth required. Can you suggest other locations? The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
Transport Black Cat enhancements works start date not confirmed. Loves Farm and Wintringham developments have close proximity to St Neots railway station the car park is at capacity without these proposed developments and has resulted in St Neots T C investing huge monies on Local Highways Initiatives to prevent commuters carparking along key roads and residential areas. A major unknown in this plan is the route of the East-West railway and the location of its new stations.
The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. As part of the recently adopted Local Plan for Bedford there will be potentially 1750 new homes in the key service centres and villages northern half of the Borough including 500 which are planned in the adjacent village of Sharnbrook. This will add further traffic and pressure on an already busy A6 road. The East Northamptonshire Joint Core Strategy (2011-2031) identifies three towns – Rushden, Higham Ferrers and Irthingborough - immediately north of the boundary with Bedford Borough as 'Growth Towns'. A total of 5195 houses are planned for these towns with the core growth (3285) proposed in Rushden. The Sustainable Urban Extension at Rushden East is located off the A6 and nearest to the shared boundary with Bedford Borough. It will include 2,700 of these new homes, employment opportunities, including offices and industrial premises as well as other infrastructure. East Northants Council identify local transport issues and impacts that must be resolved as part of the 'master plan' for the area. However, no reference is made to the impacts that this planned growth will have on the wider road network including the A6 south. It is well known that lower house prices in Rushden compared to Bedford has encouraged people working in Bedford to live in Rushden (see average house prices in respective towns on Rightmove and Zoopla). This significant planned growth immediately north of Bedford Borough will, in all likelihood, continue to encourage commuting into Bedford creating additional traffic and associated noise and pollution on the villages such as Bletsoe located off the A6. Any significant house builds in Bedfordshire cannot be considered in isolation to this planned growth in East Northants which is already an adopted policy and of course the new dwellings proposed as part of the Bedford Borough Local Plan 2030. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. Bletsoe Parish Council do not support further urban growth in the northern part of the Borough adjacent the A6 as there is no current or proposed road or rail infrastructure available. This would mean that all associated new growth traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land. □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston which offers the best sustainable transport solution for growth) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner; Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.
Supported: Yellow - Growth along the A421 road corridor which already has good road links and opportunities to improve road-based public transport would seem to be an obvious choice, especially given this could connect well with the outskirts of Bedford Town, allowing for improved green transport connectivity to the town centre as an area for employment opportunity and commerce. Pink - Developing housing growth which is closely aligned to existing and planned road and rail infrastructure would make most sense. Potentially Supported: Brown – from a local perspective this option is somewhat welcome as it has potentially minimal impact on the key and rural service centres, however, it should also be noted that any development along the A6 is very likely to increase peak time congestion to and from Bedford on a road that commuters already experience significant delay on. This will potentially increase traffic on rural roads as residents look to alternative routes around the Borough ‘blackspots’. Not Supported: Orange – would have a significant impact on an area of open countryside and rural villages in North Bedford due to the loss of green space and increased traffic on predominately rural roads. The proposal is also very dependent on several factors that are outside of the control of the Borough, such as the opening of a new station north of Bedford, train re-scheduling etc. To include this option would seem to add significant and unneeded risk to the Local Plan delivery target. Grey – this option seems to be completely at odds with the draft vision statement “Sustainable development and transport, the use of renewable energy technology, green infrastructure and new high quality green spaces”, there are little to no employment opportunities within rural locations, any new development will encourage commuting. Very few rural settlements have any significant level of services, so again, travel to and from service centres will be required, increasing traffic flows making development unsustainable from the outset. As there are insufficient green transport links between rural areas the majority of these journeys are likely to be via public or private transportation, the bulk of which are not yet underpinned by renewable energy resources. The advantages listed for this option are also very weak. Red - this option would result in unacceptable intrusions into areas of open countryside and unmanageable pressures on existing road infrastructure. There is no evidence as to how this development approach is going to be able to deliver on the benefit to ‘provide opportunities for sustainable and active transport links, both between new settlements and to the urban areas’. Almost all traffic generated from these sites would need to access the A6 north of Bedford, a road already considered a notorious ‘blackspot’ for local residents at peak times.
The expansion of the Bedford / Kempston urban area: We are aware that a band of ancient woodland exists west of Kempston, stretching south from Hanger Wood SSSI to Wootton Wood. We would encourage your Council to consider such protected environmental features as assets that could – with carefully strategic planning - sit alongside anticipated development. For example, an opportunity exists here to join these woods together creating a bigger, better and more sustainable green space around Bedford. Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots: Development pressure east of Rushden is a current concern for Natural England due to the potential destruction of Functionally Linked Land and or the potential for increased recreational pressures on the Upper Nene Valley Pits Special Protection Area, SSSI and Ramsar. Please refer to the East Northamptonshire Local Plan documents for our current position regarding development around Rushden. Our most recent statutory response to the East Northamptonshire Local Plan is letter dated 19 March 2020 (Our Ref: 308298). Consequently, cumulative / in-combination effects Page 3 of 5 will need to be considered for sites such as the Upper Nene Valley Gravel Pits SPA. In addition, there is already significant growth proposed around St. Neots through the Huntingdonshire Local Plan with main issues likely to be recreational pressure, water / flood risk management / Sewage Treatment Works discharge, and air quality. The Water Cycle Study for the Huntingdonshire Local Plan confirmed that St Neots Waste water Treatment Works is almost at capacity and without further improvements there is potential for adverse effect in the Ouse Washes and Portholme N2K sites. Consequently, cumulative / in-combination effects will need to be considered for sites such as Portholme SAC and the Ouse Washes SAC/SPA/SSSI and Ramsar. Referring back to our 07 August 2019 response (Our Ref: 291131) to the Bedford Local Plan 2030 HRA Addendum we write: “In terms of the Growth Arc proposals, uncertainty also remains surrounding the future water quantity and quality in the tributaries of the River Great Ouse pending independent assessments by Anglian Water, which will have their own HRA’s. However, it is clear within the current Water Resource Management Plan (WRMP) that Bedford area is in a water-stressed zone, and the report predicts potential deficits under dry year annual average conditions within the Bedford area in 2026/27 (page 330).” It is clear that Bedford Borough is a water stressed area. It is important for your Council to ensure that development does not go ahead unless Anglian Water is confident that there is going to be water available for the growth identified in this new plan. Further, your Council should explore the topic of water resources within the HRA. Development along the A421 corridor: Development here will need to be considered in-combination with other potential environmental impacts within the area resulting from developments such as the Black Cat to Caxton Gibbet Improvement Scheme NSIP, and developments such as the Marston Vale New Villages within Central Bedfordshire Local Plan. The A421 is already constrained from an air quality perspective (confirmed within the SA Scoping report attached to this present consultation). Development around an East West Rail northern station: Regarding the East West Rail section from Bedford Midland to Tempsford, a series of ancient woodlands are within this corridor, including Tilwick Wood SSSI, which should be safeguarded from development, and preferably buffered with additional woodland planting. The countryside north of Bedford is relatively undeveloped. We understood from the 2030 Local Plan HRA process that further work on the Growth Arc will take place within a Local Plan review process. We advise that when information does becomes available on the East West Rail route and other growth arc developments, that it is considered within the HRA process. Once enough information is available, we expect the environmental impacts of the growth arc projects to be assessed alone or in-combination with the Bedford Borough growth proposals. New settlements in locations with good accessibility & More dispersed development throughout the borough including the expansion of villages: When considering development across the borough, a number of tools are available to help inform sustainable options. 1. National Character Area profiles https://www.gov.uk/government/publications/national-character-area-profiles-data-for-local-decision-making/national-character-area-profiles#ncas-in-east-midlands 2. The Habitat Opportunity Mapping done by the Bedfordshire Local Nature Partnership. 3. The Bedfordshire and Luton Green Infrastructure Plan and the Bedford Green Infrastructure Plan
Looking at the options I prefer: 1/ Brown - urban based growth Better for the environment, using up under used land rather than unspoilt countryside 2/ Yellow - A421 based growth 3/ Pink - rail growth Both developing around existing expansions.
Your Strategic Flood Risk Assessment (SFRA) should include an assessment of these scenarios to determine where flood risk is a constraint and where development is an opportunity to reduce the existing risk.
In addition some concerns are raised with regard to the sustainability of the option which involves providing housing growth along the A421. It is considered that this would promote reliance on the private car and will result in development that fails to meet national and local objectives to reduce climate change and improve air quality. Luton Council considers that housing and employment delivery options that can be directly served by the rail network should be given significant priority.
The Dispersed Growth option allows growth to be distributed proportionally throughout the Borough. We agree that the majority of development will still be focused around Bedford but growth will also be allocated proportionally in other settlements. This will ensure that no particular area will be overburdened with development whilst enabling the benefits of development to be shared throughout the Borough. This will help to increase and maintain the vitality of settlements in the rural area. We disagree that this strategy would not facilitate employment growth provided this is directed to the most appropriate locations. This would also provide new rural employment opportunities and facilitate the expansion of existing sites.
The council’s acknowledgement that a combination of development strategy approaches may be required to achieve the anticipated scale of growth is welcomed. Countryside Properties (UK) Limited have promoted Land at Green End/Bedford Road, Great Barford to the Great Barford Neighbourhood Plan for 500 new homes and hold additional land to the south and west of this site which is available and has been submitted under the council’s Call for Sites consultation in parallel to this response. Early work to date suggests the potential for around 2350 new homes and 10ha of commercial and employment space. The development of the site would support the delivery of growth within the A421 corridor, be close to the route of East-West Rail, and would clearly comply with the ambitions of delivering development which corresponds to strategic connections within the Oxford-Cambridge Arc.