Any other comments?

No. Thank you for the opportunity.

We very much welcome continued engagement and dialogue.

It is very worrying that with accelerating global warming and epidemics/pandemics we still even consider building on (and concreting over) Greenfield areas. It is easily forgotten that we have to import at least 40% of our food. We remember that we have been told by our government that they consider food production a high priority – given this, we are particularly concerned as, locally, we have a large content of high-grade agricultural land. We are seeing increased extreme swings in our weather with flooding and droughts becoming more regular. It is reported that this year’s cereal and grass crops returned around half of last year’s. Until earlier this year we continued to rapidly increase the pollution that we are creating. Sadly, we can’t even claim that the current reduction in pollution has been the result of our planning, but is due mainly to an unexpected virus totally out of our control. It would appear that our government has not yet woken up to these facts and is doing its best to return us to our polluting old ways whatever the cost. Bedfordshire is a rural county, but how much consideration is given to this? Legally we have to comply with the government building requirements, whether or not we agree with them, whilst maintaining as closely as possible our beautiful rural environment. We must give due consideration to those who wish to live in towns, those who require affordable housing and those who prefer to live in and maintain the existing countryside. All of BBC’s published options may produce the numbers of houses legally required. However little if any consideration is given to the importance of maintaining productive farm land and to the importance of the rural environment of the county of Bedfordshire in terms of wildlife, vegetation and history.

Wilstead: Wilstead is currently in the process of putting together a Neighbourhood Plan. Consultation should be undertaken with Wilstead Parish Council and the Neighbour Plan Group, to determine an acceptable level of housing development within Wilstead and suitable locations for it. It is important to maintain a clear division between Wilstead and Wixams, unhindered by development, to ensure that both villages maintain clear boundaries and are not subject to infill and housing sprawl, so that it becomes difficult to identify where one village starts and the other finishes. During the last consultation round on the Local Plan 2030, a number of very large sites along the A6 were submitted by developers for consideration (one almost opposite Wixams and another further south towards Briar Bank). If these sites are again submitted for consideration, they should be rejected, on the grounds that they would result in a large housing sprawl, with major traffic issues around the A6 and resulting in no clear boundary between Wilstead and Wixams. General: As a general point, in terms of where new development should be located, I strongly believe that new housing should be focussed on the urban part of Bedford. Whilst there is an urgent need for additional housing, the Borough needs to protect villages, villagers and village life from rampant development speculation, building houses that are unlikely to be affordable to those looking to get a foot on the housing ladder. There is a desperate need for housing which is both suitable and affordable for young people. This is best done in urban areas, with access to sites where smaller apartments can be built, with close links to transport, so people can commute easily to work; and near to entertainment venues and sites with possibilities for small employment start-up units. This option is also more environmentally considerate, with fewer car journeys required as a result. Promised infrastructure needs to be built before development, so that we don’t end up with issues similar to those we have experienced at Wixams, where much was promised, but the reality is somewhat different. Equally, we need a better focus on housing design and roads and parking within development, to avoid the scourge of verge parking and congested roads. Ultimately, the Borough needs to fundamentally rethink its approach to the Local Plan and develop one that the Bedford public will happily endorse and support, rather than one that gets grudging acceptance or at worst outright hostility.

Thank you for consulting Central Bedfordshire Council (CBC) on the Bedford Borough Local Plan Review. Central Bedfordshire Council welcomes the opportunity to comment on the review of the local plan from the outset to help shape the next plan for Bedford Borough and we look forward to continuing the good working relations that have already been forged between the two Councils. To this end, I hope you find the comments below useful. CBC welcomes the early review of the Bedford Local Plan in the context of the Oxford-Cambridge Arc and the need to provide additional growth to contribute to meeting the aspirations set out by Government. Given the potential levels of growth that are envisaged, CBC considers it paramount to consider the needs and delivery of infrastructure from the outset of the plan – not just in relation to connectivity, but also key areas such as green infrastructure, education and health. This is relevant to both the delivery of infrastructure within Bedford Borough as well as implications for existing and potential new infrastructure within neighbouring areas. CBC supports the approach for this current consultation in that it focuses on developing a strategy to guide housing and employment growth and identify the infrastructure needed to support it. CBC considers that an appropriate and robust strategy from the outset is paramount to the success of the plan. CBC further supports the approach proposed in terms of identifying policies that seek to deliver quality development at the same time as tackling climate change, protecting the natural environment, providing open spaces, and providing opportunities for self and custom build homes. Whilst it would be helpful to have an understanding of the levels of growth envisaged for the Borough, to be delivered through this plan review, CBC appreciates that this is not possible at the current time. The consultation material suggests that the published Standard methodology would be used to identify the future growth requirements but that the Plan period, which is currently part of this consultation, would be a contributing factor for the identified housing targets. It is currently identified that if the plan period is to 2040, the plan would need to deliver between 5,000 and 15,000 new homes, but if the plan period runs to 2045, this would increase to between 9,000 and 21,625. However, a review of the standard methodology is currently underway and therefore CBC considers that the Borough Council will need to bear this in mind and consider a potential adjustment of plan targets in the future. Having said that, CBC recognises the need to make progress with the plan review and therefore the Council’s early identification and consideration of potential options for the distribution and delivery of growth. It is our view that in the first instance, brownfield and previously development land should be utilised to its maximum capacity before looking to greenfield land to deliver growth. The urban based location options would offer huge benefits in terms of sustainability and growth could be successfully delivered without the need for new large-scale road infrastructure. Intensification of sites within Bedford should be fully considered in line with the estate regeneration objectives of the NPPF and the decisions around East West Rail that have now been taken, which provide confidence in terms of infrastructure in this area. CBC consider some of the ‘cons’ outline in the consultation paper could be successfully overcome through high quality design and exemplar sustainability objectives. Opportunities should be taken to provide exemplar and sustainable development, with the necessary infrastructure available from the outset. The consultation document makes numerous references to new infrastructure, but there is also a need to consider the potential impacts of growth on existing infrastructure, particularly around A421 and the A1 corridor. Planned growth within CBC Local Plan must be taken into account when considering the growth options and their potential impacts. CBC note some of the options suggest development in close proximity to the A1 corridor. If growth in this location is being proposed, a comprehensive understanding of the capacity of the A1 corridor would be required. Further work would be needed to explore a solution for additional traffic impacts. Bearing in mind the known constraints here, this would likely involve the need for large-scale intervention, such as realignment. CBC would welcome the opportunity to be involved in such work. CBC would question whether growth could be considered in these locations without a commitment to such interventions, which would undoubtedly require government funding. CBC would also be interested to understand the rationale behind the potential growth option at St Neots. In relation to employment, CBC appreciates that the evidence work to identify future requirements for employment land is still ongoing and we look forward to future discussions when this is available. The recognition within the consultation material of the need to attract businesses back to the urban areas and the Town Centre is supported. In relation to any future employment requirements and opportunities that are more strategic in nature, it is considered that any expansion of existing sites as well as the provision of new employment sites, should be well located and where it can be supported by both the local and strategic road network. Whilst CBC understand the Planning for the Future White Paper and Changes to the current planning system consultations (Aug 2020) have only recently been released, and this was after the publication of the Bedfordshire Borough Local Plan consultation, there will be a need to consider the implications of these proposals when progressing with further iterations of the plan. I hope you find the above comments helpful. Please do not hesitate to contact me if you wish to discuss these comments further. I look forward to future and ongoing discussions in relation to cross-border working and the provision of a sound Local Plan for Bedford Borough.

Thank you for the opportunity to respond to the above Consultation. The consultation identifies the need to build up to 20,000 homes in the Borough during the period to 2040 and it appears that Bedford Borough Council plan to allocate this housing on land in the North of Bedfordshire. Bromham Parish Council urge Bedford Borough Council to consider protecting rural areas in the new local plan and give assurances that existing rural settlements will not be further targeted for unacceptable growth. The Parish Council acknowledge the significant housing growth required to meet assessed needs and the emphasis should be on creating new sustainable communities in the most appropriate locations not in existing rural areas that are already struggling with poor infrastructure. Many villages have had to accept a larger increase in houses than they would like to see. Bromham Parish Council accepted the 500 homes allocation from the Local Plan 2030 but are concerned that the existing infrastructure will not cope with the increase in traffic, particularly accessing and egressing the village at peak times. We ask that you do not allocate more housing in Bromham but concentrate on new sustainable communities in more appropriate locations. The Parish Council sincerely hopes that these observations are helpful.

Thank you for inviting Highways England to comment on the Council’s initial stage of your Local Plan review. Highways England operate, maintain and improve the Strategic Road Network (SRN) in England. Our network carries a third of traffic and two thirds of all freight, it helps to unlock the social benefits of mobility and is critical to regional and national economies. In the area within and surrounding Bedford Borough, we have responsibility for the A421, A428, M1 and A1. Highways England do not have any specific comments with regards to the six spatial distributions that are represented in the current consultation but would request early engagement once these options have been narrowed down. We would also like to have more details on how the Council proposes to assess the impact of the Local Plan growth on the Strategic Road Network (SRN) and review any transport models to be used for that purpose. All the growth options presented within this consultation will have an impact on the SRN and going forward we will need to be confident that those impacts can be fully mitigated, and those mitigations included in the Infrastructure Delivery Plan supporting the new Local Plan. I look forward to working with the Council as the Local Plan is progressed and if you have any questions with regards to the comments made in my letter, please do not hesitate to contact me.

Thank you for the opportunity to respond to this Local Plan consultation. We support your commitment to meet the Council’s growth requirements. We also welcome the strategic longer-term approach to growth within the Oxford Cambridge Arc and continue to be interested in exploring strategic collaboration opportunities across the Wider South East. We note that the GLA uses alternative population and household projections that have consistent outputs for all local authorities in England. They are available on the London Datastore: https://data.london.gov.uk/demography/population-and-household-projections/ Please note that the Borough is located within the two following Strategic Infrastructure Priorities of the new London Plan (see Policy SD3 and Figure 2.15): • East West Rail (Oxford - Cambridge) • Midlands and West Coast Mainline (London - Luton - Bedford / Milton Keynes). As such, they have been endorsed by the Wider South East partnership, and the Council may wish to reflect on their strategic benefits in the emerging Local Plan. Please note that the new London Plan has not yet been formally published. For the latest information please visit our website: https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan. Given the Borough’s strategic location within the transport network, it would be useful to understand the Council’s consideration of land for industry and logistics in the context of related requirements for the wider area.

The Respondent considers that the Local Plan Review fails to adequately plan to meet the Borough’s Local Housing Need as derived from the ‘Standard Method’ - a new version of which is currently being consulted on - and the does not properly plan for implications of the Oxford-Cambridge Arc or East-West Rail. This is at odds with the Government’s objective of significantly boosting the supply homes as per paragraph 59 of the National Planning Policy Framework (adopted 2019). It is likely that the Local Plan Review will have to plan for an unprecedented level of housing growth in the Borough with the annual local housing need requirement under the Government’s updated Standard Method being some 1,153 dwellings per annum. This is a significant increase over the current Local Plan housing target of 970 dwellings per annum. Consequently, a substantial amount of new land will need to be allocated for housing. On this basis, and coupled with the need to accommodate for future growth as part of the Oxford-Cambridge Arc, which itself requires that up to a million homes are delivered in the Arc by 2050, the delivery of new homes in this area is a matter to which significant weight should be attached. The Vision document articulates in greater detail how the water sports lake could be developed in conjunction with a high end, attractive residential scheme set within the attractive confines of the circa 800ha BRVP landscape. An assessment of site constraints and a land budget exercise have informed the Concept Plan contained in the Vision Statement and it is considered that the site would be capable of accommodating circa 700 – 850 ha dwellings based on an assumed low – medium density range. This is a substantial number of dwellings that would contribute towards the Council’s challenging housing need and which would also facilitate the delivery of the water sports lake. The Respondent would also highlight the geo-environmental benefits that will accrue from the development, in addition to other environmental benefits outlined. Part of the site is known to be contaminated and the delivery of the development will facilitate the remediation of the contaminated land, constituting a significant local benefit.

Please accept this as my submission to the “Issues and Options” consultation on the Local Plan, specifically with respect to my own ward. (A separate submission is being made on behalf of the Conservative Councillor Group) The first point to make is that I am submitting this as a written email document and not via the online response form. The way the Planning Department sets out the responses in the online form means that you are limiting the responses that people can give, only to the questions that you feel you want to ask and only allowing them to comment on the issues that you highlight. I think it’s important that you recognise that normal people don’t necessarily think like planners, they have a much more nuanced and localised view of these matters and their views cannot simply be straightjacketed into boxes with the broad brush approach that the Planning Department is taking. Secondly, I think the way that the Planning Department is going about this consultation, starting with a call for sites, is fundamentally flawed. The result will be that you build your plan according to what is submitted, rather than starting with a clear set of objectives that you would like to see as the outcome of the Plan. This absence of any clear strategy for something as important as a Local Plan must be a major cause for concern. The Planning Department needs to do some serious thinking and ask itself in the cold light of day whether this is a right and proper approach to decision making and whether it will ultimately result in the best Local Plan available, or whether it will merely get things across the line and be deemed as ‘acceptable’. I for one want the best possible Local Plan, which addresses the needs, concerns and aspirations of the people of Bedford Borough. I don’t believe your approach will achieve this and by starting with a ‘call for sites’ you will end up making a plan out of what developers thought they could make money from, rather than identifying sites yourselves, that meet your strategic objectives and address clear planning, housing, employment and environmental needs. Wixams: In all matters relating to stations, Wixams Station needs to be top priority and no other new station should be considered as part of a Local Plan which might compromise, delay or otherwise supplant the delivery of Wixams station. With regard to one of the options outlined in the consultation document, that of “New settlement based growth” I believe that the initial Wixams Masterplan, dating back to c.1999 envisaged around 4000-4500 new dwellings as the size of Wixams once everything was built. I would not want to see Wixams expanded any more than has previously been proposed. Anything larger than originally proposed risks creating an urban sprawl that was never envisaged. The nature of Wixams is unique, centred around 4 separate villages, with a (yet to be built) village centre. There have been major issues with delays and undelivered infrastructure. Current proposals for warehousing are extremely controversial and there is a sense that the quiet and ‘green’ environment at Wixams is at risk from overdevelopment, in particular from employment designated sites and the additional traffic and HGVs that they bring with them Therefore, I am opposed to any further expansion of Wixams. The Borough should focus its efforts on delivering what was originally planned for Wixams, rather than looking to identify further housing site options before the current site is built out and complete. Wilstead: Wilstead is currently in the process of putting together a Neighbourhood Plan. Consultation should be undertaken with Wilstead Parish Council and the Neighbour Plan Group, to determine an acceptable level of housing development within Wilstead and suitable locations for it. It is important to maintain a clear division between Wilstead and Wixams, unhindered by development, to ensure that both villages maintain clear boundaries and are not subject to infill and housing sprawl, so that it becomes difficult to identify where one village starts and the other finishes. During the last consultation round on the Local Plan 2030, a number of very large sites along the A6 were submitted by developers for consideration (one almost opposite Wixams and another further south towards Briar Bank). If these sites are again submitted for consideration, they should be rejected, on the grounds that they would result in a large housing sprawl, with major traffic issues around the A6 and resulting in no clear boundary between Wilstead and Wixams. General: As a general point, in terms of where new development should be located, I strongly believe that new housing should be focussed on the urban part of Bedford. Whilst there is an urgent need for additional housing, the Borough needs to protect villages, villagers and village life from rampant development speculation, building houses that are unlikely to be affordable to those looking to get a foot on the housing ladder. There is a desperate need for housing which is both suitable and affordable for young people. This is best done in urban areas, with access to sites where smaller apartments can be built, with close links to transport, so people can commute easily to work; and near to entertainment venues and sites with possibilities for small employment start-up units. This option is also more environmentally considerate, with fewer car journeys required as a result. Promised infrastructure needs to be built before development, so that we don’t end up with issues similar to those we have experienced at Wixams, where much was promised, but the reality is somewhat different. Equally, we need a better focus on housing design and roads and parking within development, to avoid the scourge of verge parking and congested roads. Ultimately, the Borough needs to fundamentally rethink its approach to the Local Plan and develop one that the Bedford public will happily endorse and support, rather than one that gets grudging acceptance or at worst outright hostility.

How will the Local Plan evolve with regard to proposals to grade land for allocation or protection as put forward in the White Paper?

The Local Plan Review fails to adequately consider this Borough’s Local Housing Need as derived from the Standard Method, which in any event is undergoing consultation for proposed changes to its methodology in line with increased levels of planned growth by central Government, in addition to the full implications of the Oxford-Cambridge Arc. This is prior to accounting in any way for the Government objective of significantly boosting the supply homes as per paragraph 59 of the NPPF. Presently, the standard method falls short of meeting the 300,000 dpa which the Government has said should be the national annual housing target. The target of building 300,000 homes a year on average in the UK was and remains the founding principle of the Government’s ‘Standard Method’ which was implemented as part of the revised National Planning Policy Framework. This was an effort to standardize house-building targets across the country in an effort to genuinely address the housing needs of real people in real need now. This is now being addressed by the government going forward as evidenced in the White Paper “Planning for the Future” and “Changes to the Current Planning System” which expressly sets out that the government will review the formula for calculating Local Housing Need such that it corresponds to instead to a 337,000 dpa figure (twice the average level of growth in this country). No doubt this Authority is fully considering the implications of the White Paper and revisions to the SM, and as a matter of course will duly consider whether there will be a need to transfer over toward a new form of development plan that considers the predefined “growth, renewal and protection” areas envisaged for new Local Plans in future. Nonetheless, and question that is relevant here and now is that the SM revisions invariably means LPAs across the country will need to deliver more housing against future LHN than what it is identified as at present, including Bedford Borough. This is against the context that Bedford currently faces increasing house prices and increasing monthly rents all set against a backdrop where rates of development has fallen below planned levels. In respect of house prices, the average house price paid in Bedford is £300,477. When compared to an average income of £29,411, an average priced home in Bedford costs 10 times more than an average household earns, meaning affordability is a significant barrier to many people wishing to acquire a suitable home. The lower quartile house price ratio stands at a similarly staggering 10.61 times household income and means that many people at the lower end of the market are pushed into the private rented sector, often with poorer living conditions and insecure tenancies. This situation is fundamentally against Government ambitions to make housing more affordable for everyone, which is why affordability remains a key adjustment factor in the Standard Method, and against ever increasing house prices (despite even the consequences of the current pandemic) it is only reasonably expected that the Council’s LHN will continue to increase in future years due to this factor alone. Coupled with the need to accommodate for future growth as part of the Oxford-Cambridge Arc, which itself aspires to up to a million homes are delivered in the Arc by 2050. Most of the arc is free from constraints like Green Belt, AONB or European protected habitats. Housing delivery on a much larger scale will be planned for in this area. The delivery of new homes in this area is a matter to which significant weight should be attached given this vision for growth by Government and it is unacceptable to this Council to be seeking to meet need as low as potentially “800” homes per year on the basis that the Ox-Cam Arc-wide spatial strategy not being agreed. The East-Wail Rail is progressing in a timely fashion – such that this Council must consider how to best capture the economic benefits of it – is evidence enough that despite there being no clear guidance at present on what is intended for the Arc in terms of housing, these are expected in the very near future and most certainly within the proposed plan period. Current housing targets are at 970 dwellings per annum, shooting to well above 1,000 dpa benchmark due to the Standard Method alone. The supposition that this Council need not plan for a housing figure over and above its own requirement is nonsensical against the above context, and when viewed in the additional context of paragraph 59 of the NPPF. Para 59 sets out ambition for the significant boosting of the supply of homes in this country – an objective which can only be achieved once the minimum levels of growth has been accommodated for. It is an ambition that is further reflected in a recent appeal decision taken by the Secretary of State relating to Land Off Audlem Road / Broadley Lane, Stapeley, Nantwitch (ref: APP/R0660/A/13/2197532), and Land off Peter De Stapeleigh Way, Nantwich (ref: APP/R0660/A/13/2197529). Within the decision letter (DL) at DL28, the SoS accords significant weight to the benefit of delivering new market housing thereby significantly boosting the supply of homes as per paragraph 59 of the NPPF. This is notably in the context of the relevant LPA being able to demonstrate a deliverable five-year supply of housing land. This local authority is also once such authority that claims to have a five-year housing supply of land. Yet, it will flounder and fail to secure even the minimum levels of housing growth over the proposed plan period until 2040 unless it duly accounts for the increasing unaffordability of housing that is explicitly due to such low planned levels of growth, the Ox-Cam Arc, the objective of boosting the supply of homes, and the overall incoming revision to national policy which revises national housebuilding targets to double the average housebuilding rate in the country. Plainly, these are all matters that relevant now and must be accounted for as part of this review.

1.0 INTRODUCTION 1.1 On behalf of client Philip C Bath Ltd, we are pleased to submit details of the above sites for consideration as part of the Review of the Bedford Local Plan 2030 – Issues and Options Consultation Document. 1.2 Details of our client’s specific interest have been submitted as part of the ‘Call for Sites’ exercise undertaken alongside this consultation. Details of the relevant submissions are summarised below: • Land at Ford Lane, Roxton o High Barns Farm, Roxton 1.3 In commencing an immediate Review in accordance with Policy 1 of the adopted Plan the Council is, as required, seeking to ensure that future needs for growth are provided for in-line with government policy i.e. local housing need calculated using the standard method. 1.4 This will entail meeting a significant (up to c.35%) increase in the minimum annual requirement for development for at least the period 2020-2040 upon adoption of the Review, expected in 2023. The Review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs. 1.5 The scope for the Review has been enhanced as a consequence of the foreshortened plan period of the current Plan, and its strategy of apportioning specific (albeit minimum) values for the distribution of housing across the settlement hierarchy and the deferral of site allocations to Neighbourhood Plans. Equally, the challenges of housing delivery must also reflect realistic timescales to ‘unlock’ developable sites in the Urban Area, as well as ensuring necessary supporting infrastructure in other locations. 1.6 The Borough Council has acknowledged this through consideration of a diverse range of spatial options to inform the Local Plan Review. As stipulated by national policy this is an opportunity to ensure that plans are positively prepared in terms of seeking opportunities for sustainable development and proactively pursue appropriate growth. 1.7 These representations seek to reinforce and refine the Council’s proposed objectives for development in the Borough, and with specific reference to our client’s interests demonstrate how these can be sustainably delivered in Roxton. As a Rural Service Centre, whose status as such is not disputed by the Council in the context of undertaking the Local Plan Review, Roxton is accepted as a sustainable location for growth. 1.8 The Council has previously assessed that options for the delivery of increased requirements for growth in the rural area would be just as sustainable as those selected (i.e. New Settlements) and then abandoned due to feasibility constraints in the course of preparation of the Local Plan 2030. The Council is assessing various spatial options where further growth at Roxton would make a sustainable contribution to the overall spatial strategy (e.g. as part of a ‘Dispersed’ strategy or a combination of options). 1.9 For the purpose of these representations it is, however, critical to note that the spatial strategy of the adopted Local Plan 2030 is silent on the relationship between planned and future improvements of the A421 corridor and opportunities to deliver the Plan’s strategic priorities. In recognition of this, a spatial option for A421-based growth is specifically identified in the Council’s consultation documents and is associated with the most substantial balance of advantages in favour of sustainable development. 1.10 We consider that in terms of assessing options for the spatial strategy, and in terms of considering reasonable alternatives for the assessment of sites and site selection, the Council must take a positive approach to each of the following elements and avoiding placing arbitrary constraints on appropriate, sustainable levels of growth. These representations explain why the Council must ensure that the role of Roxton within the Council’s settlement hierarchy and its contribution toward the proposed distribution of development requirements is assessed in the context of opportunities to secure A421-based growth. 1.11 As a result, it is inevitable that Roxton as a Rural Service Centre has the capacity for growth, given it is favourably located in the A421 Corridor. Unlike other settlements in the Borough, where a Neighbourhood Development Plan is required to identify sites (under Policy 4S), Roxton has been allocated sites in the Local Plan 2030 (under Policy 27 – Land north of School Lane). It is clear, however, from Policy 4S that the approach towards this specific allocation and apportionment of growth in Roxton has been grouped together within the arbitrary range for development of 25-50 units in Rural Service Centres considered as part of the Local Plan 2030. This reflects that foreshortened plan period and reduced housing requirement pursued under the NPPF2012 transitional arrangements, rather than illustrating that the approach has had regard to the full capacity for growth or opportunities to contribute towards longer-term objectives for each individual Rural Service Centre in the settlement hierarchy. Notwithstanding that this provides a clear context for additional allocations in Roxton to be provided directly as part of the Local Plan Review process this should properly reflect a standalone assessment of the levels of growth that might be supported towards planned requirements. 1.12 It is essential that the delivery of an appropriate strategy, as part of the Review of the Local Plan 2030, is supported through both its strategic policies and allocations. This is necessary to ensure that current priorities and future opportunities to secure sustainable development are not again deferred to future rounds of plan-making. For this reason, we believe that the following elements should become a clear focus for the scope of the review and through these representations demonstrate how our client’s interests would support the achievement of sustainable development: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). This should particularly focus on existing and planned infrastructure improvements along the A421 Corridor, to capitalise on this strategic priority and opportunity it provides to meet future needs. • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community • Maximise opportunities to enhance Green Infrastructure and meet ‘healthy communities’ objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan. • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period, including avoiding over optimism regarding forecast delivery towards the Plan’s requirements from sites in the Town Centre within the period to 2030 and beyond.

I am writing to express my concerns and comments on the 2030 - 2040 Local Plan being developed by Bedford Borough Council (BBC). I have not been able to locate the comments form, so make my comments below: Having reviewed the options outlined in the presentation slides on Bedford's Emerging New Local Plan 2030-2040 while I acknowledge we have to plan for the population growth that is inevitable, I object to the principle of adding high density housing adjacent to or as infill housing of existing villages spread through the County. Additional building adjacent to existing villages at the level outlined will destroy the character of the North Beds area which is characterised by rural communities, smaller roads and countryside. More suitable areas for development would be closer to major road systems such as the M1, A 1 and A421. The concept of building high density housing will overload existing infrastructure such as schools, GP surgeries, roads and emergency services and is a dereliction of Council's responsibility to plan for the healthy sustainable development of Bedfordshire. While a broad Plan is needed, it is vital that permitted housing development matches demand, to avoid devaluing existing housing stock. Therefore Permitting also needs to be under constant review and development initiated at a sustainable rate to meet demand and be matched by investment in essential infrastructure. It is well recognised that high density housing is likely to lead to social unrest and increased mental health issues. It is well documented that access to outdoor space is essential for the healthy wellbeing of a sustainable community. I recognise that it is not possible to provide absolute commitment to development locations until the EW Rail route and location of the stations have been defined, I support the principle that housing expansion should be via Garden Cities sited near good communication corridors, complete with their local infrastructure. Central Bedford is the worst possible location for the EW Railway station in the Bedford area. Access to and parking at the existing mainline station is already overloaded. Parking is woefully inadequate leading to congestion in adjoining streets. In order to realise the ambition of the Council to develop Bedford as a cultural hub attracting recreational visitors, it is clear that traffic through the town centre has to be minimised. If this ambition is more than an empty sound bite this must start with the new EW station being located well outside Bedford centre preferably at its interchange with the N-S mainline to London. To meet the aspiration of planning to house a sustainable, healthy population growth the New Garden Cities should include the supporting infrastructure (schools, medical care, off road parking), connectivity (access to arterial roads, public transport, internet) and environmental requirements (leisure facilities and open space) needed for healthy living integrated into each township. I would also expect the infrastructure and communication links to be funded by the developer and not added in any way as additional costs to existing residents who chose to live in this area because of its rural aspects. This development should meet the requirements for growth in the local community and incorporate schooling, medical care, jobs, off road parking, leisure facilities etc. The design should include the reduction of noise and light pollution as well as preserving the local flora and fauna. I trust these concerns will be considered in your discussion during the planning process.

RE: LOCAL PLAN REVIEW: ISSUES AND OPTIONS CONSULTATION 1. Introduction I write on behalf of Barratt David Wilson Developments Ltd (‘BDW’) who welcome the opportunity to comment on the Issues and Options Consultation which will form part of the Local Plan Review. BDW are the Nation’s largest homebuilder providing quality homes for a variety of customers with properties ranging from those for first time buyers to large luxury family homes. BDW have been rated a Five Star Homebuilder for 11 consecutive years (HBF Customer Service Survey). As a homebuilder, these representations only relate to parts of the document directly related to the delivery of homes and associated infrastructure. BDW have successful delivered a number of Developments within Bedford Borough including Great Denham and Wixams (split between Bedford and Central Bedfordshire). Each of the relevant consultation questions or topics have been addressed in turn below: 2. Housing supply The document states that the emerging plan would need to accommodate 26,100 dwellings, based on the 1,305 dwellings per annum as calculated in accordance with the current standard method. However, NPPF and Planning Practice Guidance recognises this figure is a minimum and there are circumstances where Local Planning Authorities may need to plan beyond this minimum. The Council has not considered whether there are unmet housing needs in neighbouring areas that must be addressed, in accordance with paragraphs 11 and 60 of the NPPF. When considering, Bedford’s location on the strategic rail network the consideration of unmet need may go beyond adjoining Authorities. Therefore, consideration should be given as to whether the Borough can meet some of London’s shortfall. Bedford is within a reasonable commuting distance of London and with the likely shift to enhanced homeworking the Borough is able to address some of London’s shortfall. Furthermore, I would question the impact that Covid-19 has had on people’s lifestyles and whether the desire for larger properties, with private amenity space, would result in a new trend of people moving to commutable areas such as Bedford and the impact this may have on demand and consequently, affordability. In addition, the Council should consider options for delivering housing beyond its Local Housing Need Assessment (LHNA) in order to support the Oxford – Cambridge Arc. In the supporting text it is noted that Bedford is located at the centre of the Oxford – Cambridge Arc and benefits from new east-west transport links. The Council should embrace the Borough’s potential to deliver beyond the minimum requirements. The Council acknowledges, on pages 3 and 4, that one of the reasons for an early review was the Local Plan 2030 Inspectors felt there was a need for a plan which responds appropriately to longer term growth and in particular the Oxford - Cambridge Arc. It is felt that delivering the minimum as identified in the LHNA is not responding to the Inspectors’ concerns and the rationale for the early review. It is the view of BDW that the Council should plan for growth in this plan and not future reviews.

Dear Sirs Bedford Borough Council Local Plan Review: Response by Harrold Parish Council to the Issues and Options Consultation This document is the response by Harrold Parish Council to the Issues and Options Consultations forming part of the Local Plan Review by Bedford Borough Council. We hope you will find our comments to be helpful. The impact of the final Local Plan clearly has the potential significantly to impact our Parish and the lives of our Parishioners. We welcome the opportunity to take an active and constructive role in the Local Plan process, and will be available to discuss our response to the Issues and Options Consultations at your convenience. Yours faithfully David Brough – Clerk to Harrold Parish Council

Dear Sir/Madam, Please find attached response form for the Issues & Options Consultation on behalf of the following landowners who are promoting employment sites in the Borough: • C Jackson & Sons (Bedford) LTD -Land At Keysoe Road, Thurleigh • Mr E F Wootton – Land South Of Goldington Road, Bedford

• Bates Bros (Farms) Limited – Sites at Land North Of Chawston Lane, Chawston; Land North Of School Lane, Roxton; and Land South Of School Lane, Roxton • Bedford Borough Council – Land At Riseley Primary School • Bernard Cornwell - Land Adjoining Box End House, Box End Road, Kempston Rural • Davison & Co – Land Off New Road, Great Barford • Mr M Lovell - Land at Cranfield Road, Wootton Green • Mr Gary Moore – Land South Of Bedford Road, Cople • Mr Glen Moore – Land At 66 Hall End Road, Wootton • Palmer Family Trust – Sites At Tinkers Corner, Wootton; and The Chequers Wootton • Mr Rana - Land At Luton Road, Wilstead • Mr A Sarro – Sites At Hookhams Lane, Renhold; and Land East Of Bedford Road / Oldways Raod, Ravensden, • Mr Wade Gery – Sites At Land East Of Church Road, Chapel End, Colmworth; and At Land West Of Church Road, Chapel End, Colmworth • Mr E F Wootton – Sites At Shrubbery Farm, Wilden; Land South Of Home Farm, Renhold; Land Rear Of Home Farm, Renhold; and Land At Top Farm (Incorporating Chawston Lake & Morris Walk) • Mr J Wright – Land To The West Of Heddings Farm, Wyboston

Please find attached response form for the Issues & Options Consultation on behalf of the following landowners who are currently promoting sites in Neighbourhood Plans in the Borough: • A Kitchiner – Land South Of Keeley Lane, Wootton • Palmer Family Trust – Sites at Tinkers Corner, Keeley Lane, Wootton; and The Chequers Public House, Hall End Road, Wootton • Mr A Sarro – Land East Of Bedford Road / Oldways Road, Ravensden

Dear Sir/Madam, Please find attached response form for the Issues & Options Consultation on behalf of the following landowners who are promoting opportunity sites in the Borough: • Mr. A. Sarro – Land East of Bedford Road, Ravensden • Mr D. Stewart - Bedford North Station Opportunity, Lower Farm Road, Bromham • Mr E F Wootton – Home Farm, Renhold Road, Ravensden (3 sites)

Please find attached response form for the Issues & Options Consultation on behalf of the following landowners who are promoting sites available for self-build dwellings: • Mr Gary Moore – Land To The West Of 52 Keeley Lane, Wootton • Mr Glen Moore – Land At 66 Hall End Road, Wootton • Mr G Morroll and Mr J Wright – Land East Of Heddings Farm, The Lane, Wyboston • Mr E F Wootton – Sites at Top Farm, Wyboston,; Shrubbery Farm, Wilden; Land North Of Home Farm, Renhold; and Land South Of Home Farm, Renhold

• Mr J Banks – Myers Hill Farm, Bolnhurst • The Banks Family Trust – Land At West End, Little Staughton • Mr & Mrs Barnes - Land Adj 14 Box End Road, Kempston Rural • Mr B Cornwell – Land At Northampton Road, Bromham • Mr S Evans – Land At 138 Milton Road, Clapham • Mr J Gill - Land At Church End, Willington • A Kitchiner – Land South Of Keeley Lane, Wootton • Mr T McQueenie - Land Adjacent Town Lot Lane, Felmersham • Mr G Moore – Land To The West Of 52 Keeley Lane, Wootton • Mr R Pinfold – Land East Of Box End Road, Bromham • Mr K Suri – Woodland Manor Hotel, Clapham • Mr Wade Gery – Sites At Land North Of Cornfilelds Public House, Colmworth; and Land At The Rear Of Cornfileds, Colmworth • Mr R Watson – Land East Of Vicars Close, Biddenham • Mr E F Wootton – Sites At Top Farm, Wyboston; and Land North Of Home Farm, Renhold

Please find attached response form for the Issues & Options Consultation on behalf of Davison & Co (Barford) Ltd in relation to leisure and tourism opportunities and to draw attention to their site – Great Barford Lakes.

The Respondent considers that the Local Plan Review fails to adequately plan to meet the Borough’s Local Housing Need as derived from the ‘Standard Method’ - a new version of which is currently being consulted on - and the does not properly plan for implications of the Oxford-Cambridge Arc or East-West Rail. This is at odds with the Government’s objective of significantly boosting the supply homes as per paragraph 59 of the National Planning Policy Framework (adopted 2019). It is likely that the Local Plan Review will have to plan for an unprecedented level of housing growth in the Borough with the annual local housing need requirement under the Government’s updated Standard Method being some 1,153 dwellings per annum. This is a significant increase over the current Local Plan housing target of 970 dwellings per annum. Consequently, a substantial amount of new land will need to be allocated for housing. On this basis, and coupled with the need to accommodate for future growth as part of the Oxford- Cambridge Arc, which itself requires that up to a million homes are delivered in the Arc by 2050, the delivery of new homes in this area is a matter to which significant weight should be attached. The Vision document articulates in greater detail how the water sports lake could be developed in conjunction with a high end, attractive residential scheme set within the attractive confines of the circa 800ha BRVP landscape. An assessment of site constraints and a land budget exercise have informed the Concept Plan contained in the Vision Statement and it is considered that the site would be capable of accommodating circa 700 – 850 ha dwellings based on an assumed low – medium density range. This is a substantial number of dwellings that would contribute towards the Council’s challenging housing need and which would also facilitate the delivery of the water sports lake.

We note the inaccurate briefing by a local MP which suggests that as part of a local plan the Local Authority would ‘build houses’ directly. We recommend the local authority write to consultation respondents concerned about this housing process to clarify the Government targets and policies with which we are required to comply. We would also recommend that the Borough write to local Conservative MPs to inform them of their Government’s policy, copying in Parish Councils and Borough Councillors. We would also like to take this opportunity to put on record our huge concerns in relation to Conservative Government proposals for the weakening of local communities’ and councils’ planning powers, the ongoing reductions in financial support for local authorities, and their desire to facilitate poor-quality and unaffordable housing. These plans should be resisted and as a champion of parish councils and the rural and urban parishes and town councils, Bedford Borough Council should continue to fight these proposals. We would also specifically advocate for the protection of recreation, leisure and sporting infrastructure including, but not limited to, the Bedford River Valley Park, Great Denham Golf Course, and the central place of the River Great Ouse in our Borough, as well as the surrounding rural area and rural communities.

We feel that North Bedford has already seen huge expansion. There is a danger that the identity of rural communities and environments will be massively and detrimentally damaged by the plans. As there have been so many new developments and there has been scant regard to design, we would urge you to consider what your new houses look like so that they are more suitable to modern day living. Older, existing villages with character developed over 100 years must be protected, and their overall character must be enhanced – rather than submerging them within new builds. We feel that the colour coding for option 1 is very misleading as the colour brown would suggest that this is a brownfield option whereas in reality much of our cherished green space is located here. STOP the E-W Rail Northern route proposal. The housing target for Bedford may well come down so you should NOT proceed with the higher target. We deserve an open, transparent and honest evaluation of the data and a measured debate before a decision is made. You have clearly no intention of building a station north of Bedford. The Borough has submitted 18.1km of new track along Route E so you must have a clear route in mind-even though you profess to have no determination of that as yet. How can that be? The Mayor and the executive must stop hiding behind the 'Commercial Confidence' smokescreen and put all the cards on the table. Many people feel that the oft-repeated claim that the present discussions are being undertaken in an ‘open, honest and transparent’ relationship is a falsehood, that the various public consultations are ultimately a meaningless waste of time as all the major decisions have already been taken, that the exercise is merely to satisfy some process requirement but will not have any influence whatsoever on the ultimate outcome.

14.1 Given the timing of the publication of the draft consultation guidance, it has not been possible for BBC to include this within the emerging Local Plan at this point in time. However, as the Government consultation continues and further clarity is provided, these changes should obviously be included within the Local Plan. 14.2 Consideration must also be given to the changes to the Use Class Order and any repercussions that this could have on the provision of certain uses, particularly retail. These may have implications for Bedford town centre, surrounding local centres and out of town retail units.

1.0 INTRODUCTION AND SUMMARY OF REPRESENTATIONS 1.1 On behalf of client Old Road Securities PLC (ORS), we are pleased to submit details of the above sites for consideration as part of the Review of the Bedford Local Plan 2030 – Issues and Options Consultation Document. 1.2 Details of our client’s specific interest have been submitted as part of the ‘Call for Sites’ exercise undertaken alongside this consultation. Details of the relevant submissions are summarised below: • Old Road Securities PLC o Willoughby Park Land north of Roxton Road Great Barford 1.3 In commencing an immediate Review in accordance with Policy 1 of the adopted Plan the Council is, as required, seeking to ensure that future needs for growth are provided for in-line with government policy i.e. local housing need calculated using the standard method. 1.4 This will entail meeting a significant (up to c.35%) increase in the minimum annual requirement for development for at least the period 2020-2040 upon adoption of the Review, expected in 2023. The Review of the Local Plan is an important opportunity to address issues regarding flexibility and choice in a variety of locations for growth, as well as ensuring a balanced allocation of land for development sufficient to meet future needs. 1.5 The scope for the Review has been enhanced as a consequence of the foreshortened plan period of the current Plan, and its strategy of apportioning specific (albeit minimum) values for the distribution of housing across the settlement hierarchy and the deferral of site allocations to Neighbourhood Plans. Equally, the challenges of housing delivery must also reflect realistic timescales to ‘unlock’ developable sites in the Urban Area, as well as ensuring necessary supporting infrastructure in other locations. 1.6 The Borough Council has acknowledged this through consideration of a diverse range of spatial options to inform the Local Plan Review. As stipulated by national policy this is an opportunity to ensure that plans are positively prepared in terms of seeking opportunities for sustainable development and proactively pursue appropriate growth. 1.7 These representations seek to reinforce and refine the Council’s proposed objectives for development in the Borough, and with specific reference to our client’s interests demonstrate how these can be sustainably delivered in Great Barford. As a Rural Key Service Centre, whose status as such is not disputed by the Council in the context of undertaking the Local Plan Review, Great Barford is accepted as a sustainable location for growth. 1.8 The Council has previously assessed that options for the delivery of increased requirements for growth in the rural area would be just as sustainable as those selected (i.e. New Settlements) and then abandoned due to feasibility constraints in the course of preparation of the Local Plan 2030. The Council is assessing various spatial options where further growth at Great Barford would make a sustainable contribution to the overall spatial strategy (e.g. as part of a ‘Dispersed’ strategy or a combination of options). 1.9 For the purpose of these representations it is, however, critical to note that the spatial strategy of the adopted Local Plan 2030 is silent on the relationship between planned and future improvements of the A421 corridor and opportunities to deliver the Plan’s strategic priorities. In recognition of this, a spatial option for A421-based growth is specifically identified in the Council’s consultation documents and is associated with the most substantial balance of advantages in favour of sustainable development. 1.10 We consider that in terms of assessing options for the spatial strategy, and in terms of considering reasonable alternatives for the assessment of sites and site selection, the Council must take a positive approach to each of the following elements and avoiding placing BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 6 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission arbitrary constraints on appropriate, sustainable levels of growth. These representations explain why the Council must ensure that the role of Great Barford within the Council’s settlement hierarchy and its contribution toward the proposed distribution of development requirements is assessed in the context of opportunities to secure A421-based growth 1.11 As a result, it is inevitable that the current (500-unit minimum) figure for the apportionment of growth to Great Barford as identified in Policy 4S of the Local Plan 2030 must be reviewed in the period to 2030 and beyond. 1.12 It is essential that the delivery of an appropriate strategy, as part of the Review of the Local Plan 2030, is supported through both its strategic policies and allocations. This is necessary to ensure that current priorities and future opportunities to secure sustainable development are not again deferred to future rounds of plan-making. For this reason, we believe that the following elements should become a clear focus for the scope of the review and through these representations demonstrate how our client’s interests would support the achievement of sustainable development: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). This should particularly focus on existing and planned infrastructure improvements along the A421 Corridor, to capitalise on this strategic priority and opportunity it provides to meet future needs. • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community • Maximise opportunities to enhance Green Infrastructure and meet ‘healthy communities’ objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period, including avoiding over optimism regarding forecast delivery towards the Plan’s requirements from sites in the Town Centre within the period to 2030 and beyond.

1.1 This Issues and Options representation is made on behalf of The Police and Crime Commissioner for Bedfordshire who has a land interest in Kempston. A separate call for sites submission has been made for this site. 1.2 The Police and Crime Commissioner for Bedfordshire is promoting land west of Bedford Police HQ for residential development. 1.3 This site is located within the urban area of Kempston and has access to a wide range of services including education provision and Woburn Industrial Estate (a major employment area). Services and facilities in Bedford and those being provided as part of the recent growth to the south of Kempston are also in close proximity to the site. Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 2 1.4 The site is relatively unconstrained, although it is noted that it is currently identified as an urban open space, despite being inaccessible to the public and lacking amenity/biodiversity value. 1.5 The site will be able to connect to an access onto Woburn Road, which was granted consent (application ref: 20/00278/MAF) in early 2020. 1.6 This representation is structured around the 13 comments which are set out in the Issues and Options Paper. However, only those questions that are relevant to The Police and Crime Commissioner for Bedfordshire’s land interest have been answered.

1.0 Introduction 1.1 This Issues and Options representation is made on behalf of Taylor Wimpey UK Limited who have land interests in Willington and Wilstead. Separate call for sites submissions have been made for each of these sites. 1.2 Land at Balls Lane, Willington is located on the western edge of the village. It has the potential to deliver up to 150 new dwellings and new green infrastructure to re-enforce the Forest of Marston Vale. 1.3 The site has been promoted for allocation through the emerging Willington Neighbourhood Plan which is being developed by the Parish Council and has also been submitted to the Bedford Borough Council Call for Sites July 2020. Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 2 1.4 Land east of Luton Road, Wilstead is located at the southern gateway into Wilstead with good connections to the A6. The village has a good range of facilities. The site has the capacity to deliver approximately 69 dwellings and associated infrastructure. 1.5 This site has been submitted to the Bedford Borough Council Call for Sites July 2020. A planning application was submitted for the site in 2019 which was later refused in December 2019, a resubmission application was then made at the end of July 2020 which has addressed the previous reasons for refusal. This is currently pending. 1.6 This representation is structured around the 13 comments which are set out in the Issues and Options Paper. However, only those questions that are relevant to Taylor Wimpey’s land interests have been answered.