Question 1
We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. 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. Therefore, there is no support for urban growth in North Beds 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. Those routes 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. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.
We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. 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. Therefore, there is no support for urban growth in North Beds 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. Those routes 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. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.
We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. 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. Therefore, there is no support for urban growth in North Beds 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. Those routes 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. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.
16 September 2020 - Bedford Borough Council Call for Sites Hail Weston Parish Council (HWPC)note that Bedford Borough Council corresponded on 13/07/2020. These observations follow a HWPC meeting held 15 September 2020, it is hoped, considering the current situation, they are acknowledged, and included in the responses already received. Hail Weston village falls within Huntingdon District, however, is adjacent to Staploe and Duloe Parish, within Bedfordshire Borough Council and is impacted to the recent ‘Call for sites’. One of the responses received to the ‘Call for sites’ highlighted in bold below. 1. Cottage Farm, Upper Staploe 0.2 hectares suggested the site could provide 4 dwellings in the time period 2024/25 to 2028/29 2. Flints field (beside B645 and A1) 15.95 hectares. Suggested site could provide in the time period 150-200 dwellings in 2024/25 to 2028/29 and a further 200-250 in 2029/30 to 2033/34 - 400-450 dwellings overall. 3. Top Homes field Beside A1 and Bushmead Road 16.8 hectares. Suggested site could provide in the time period 100-200 dwellings in 2024/25-2028/29 and a further 200 in 2029/30 to 2033/34 400 dwellings over all. The HWPC main objections to development of Flints Field beside the B645 and A1 is the lack of infrastructure in St Neots is already under pressure due to large scale development on the eastern side of the town: Loves Farm, Loves Farm East and Wintringham developments. Hail Weston is classed as a small settlement with Huntingdonshire District Local Plan 2036 and has no facilities.
We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. 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. Therefore, there is no support for urban growth in North Beds 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. Those routes 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. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.
Given the overwhelming evidence highlighting the significant improvements to wellbeing that having access to local green spaces provides, it would seem sensible to have a specific Policy section that deals with this matter directly. This should include specific protection for current and new local green space but also include tracked targets for increasing and improving overall biodiversity across the Borough, including all new development both residential and industrial. There are several good examples of well landscaped business development in the Borough, such as Priory Park, which manages to mix good quality green space within well designed and set-out business units. The successful balance of this type of development should become the template for the future of Bedford; rather than the current apparent drive to cover most of Borough with characterless warehousing units and lacklustre green ‘screening’.
Natural England agree that the local plan review will need to “consider the need to change current policies for the natural environment following the publication of the Environment Act”. We are also aware of recent policy documents such as the “Planning for the Future” White Paper, and the “changes to the current planning system” government consultation which could output fundamental changes to the local planning process. Whilst there are no proposals to weaken existing environmental protections, we are mindful of the need to balance huge growth aspirations against potential environmental impacts to ensure sustainable development that puts nature at its heart. We do believe that due to the 35% in growth proposed by this local plan review (up to 15,000 new homes), that the existing environmental policies and safeguards will need reviewing, particularly in the context of the Habitats Regulations. This is because the impacts of a 35% increase in growth will need to appropriately consider environmental risks.
There seem to be a large number of unknowns. "We may need to make new (housing growth) allocations"..."if the timescale is longer".... "Local and national policies and plans change"... Will a new station be sited at Wixams a/o on the East-West rail route? Furthermore, the results of Covid could be long-lasting. Will people stop commuting to work/London in large numbers? Will there be fewer job opportunities? It seems impossible to come up with a solution if the problem is not clearly defined and may no longer even exist! There has already been a huge amount of development around Bedford. Do we really need more?
When considering climate change policies, this should include how other policies such as flood risk, open space etc will contribute to the management and mitigation of climate change.
The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter. We welcome the inclusion of employment growth in the scope of the Local Plan Review as this was not included in the Local Plan 2030, and this is crucial for the economic growth of the Borough, particularly as we try to bounce back from the impacts of the Covid 19 crisis.
The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter.
This form is submitted on behalf of the 13 landowners who are promoting large sites in the Borough. The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter.
This form is submitted on behalf of 3 landowners who are currently promoting sites in Neighbourhood Plans in the Borough. The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter.
It is noted that this consultation includes a revised housing figure provided as a range between 800-1,305 dwellings per annum. However, there is no consideration within this Local Plan consultation in regards to the suitability of these figures. It is centrally important to consider the Local Housing Need requirement in order for an appropriate and sustainable level of growth to be identified and provided for across the Borough, delivering a sufficient amount of housing within the plan period. The requirement for an early review of the Bedford Borough Local Plan 2030 was recognised through the main modifications with the inclusion of Policy 1S. The policy requires the Local Plan 2030 to be reviewed much sooner than usual: a review is required within a year, and a new plan to be submitted for examination within three years of the Local Plan 2030 being adopted. Within the Inspector’s final report, it was recognised that the Standard Method figure was circa 30% higher than current housing figure in the Local Plan 2030. The expectation was that the housing need figure would increase in order to accommodate the anticipated growth from the Oxford to Cambridge Arc. Rather than providing a housing figure of 1,305, based on the current Standard Methodology, (which is some 35% above the currently adopted Local Plan 2030 figure of 970 dwellings per annum) the range of 800 -1,305 has been considered for a number of reasons. These include the Governments figures for affordability, published on an annual basis, are subject to change when new data is published, as well as the Government has announced its intentions to review the Standard Method in its entirety, which is currently out for consultation. Whilst it is accepted that these are uncertainties, the Local Plan should be based on a figure which is in accordance with the agreed method of the time, which in this case, is the current Standard Method approach based on the 2014-based population projections. Furthermore, the Governments figures for affordability are likely to fluctuate in any given year. The Local Housing Need figure when calculated using the Standard Method can fluctuate year to year based upon the housing projections and the SM doesn’t take account of economic growth. Furthermore, if using a range is the preferred approach to the Local Housing Need, it may be more appropriate to use the current standard method figure as a base for the range, with the higher end to be set using an economically led figure which could include the additional dwellings for the Oxford to Cambridge Arc and an appropriate buffer. The Local Housing Need figure as calculated utilising the proposed new Standard Method approach has predicted c.1,153 dwellings per annum may be required across the Borough, some 300 dwellings more than the suggested 800 figure. It is not appropriate to use a figure (800) based on a calculation which has not, as yet, been confirmed. This figure would also provide some 170 dwellings less than the current Local Plan 2030, which was only adopted in January 2020. This will set an unrealistically low target and is unlikely to provide a sustainable amount of housing over the plan period, leading to further housing shortages and affordability problems. Therefore, it is unlikely the plan will be sound if using a figure lower than the current housing need figure in the current local plan. n addition, Paragraph 60 of the NPPF states that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” It is important to note that Paragraph 60 of the NPPF and the associated guidance within the PPG are clear that the standard method represent the “…minimum number of homes needed…” Considering the uncertainty currently surrounding the additional growth due to the Oxford to Cambridge Arc, it is likely that there will be a higher need for housing than that which is currently proposed in the adopted Local Plan and may even be higher than the allowance provided for within the current Standard Method. Furthermore, the plan must respond to the Governments key objective of boosting the supply of housing, which a plan utilising a lower housing figure is unlikely to achieve. It is important that there is flexibility in the number of housing allocations, to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance. In addition, a buffer should also be provided in order to maintain flexibility and to take into account any fluctuations that may occur on a yearly basis. A 5% buffer above the top range is unlikely to be sufficient, just as the Local Housing Need can fluctuate, so can the buffer that is required in regards of the five-year housing land supply. Usually, with a confirmed five-year housing land supply, a 10% buffer would apply, unless the rate of deliverability falls over the plan period, in which case a 20% buffer would apply. To ensure the plan is future proofed and enough flexibility, choice and competition has been provided for in the housing market, in order to reflect government guidance, we consider that a 20% buffer in addition to the top range of housing need, would provide this. Any Local Plan currently under review or in current consultation will also have to consider the effect of the coronavirus pandemic on the housebuilding industry, and subsequently the deliverability of the Council’s current five-year housing land supply. Whilst still relatively unknown, delays in the deliverability of housing are likely and therefore a subsequent undersupply may occur. The Plan must be aspirational but deliverable to be positively prepared (NPPF, paragraph 16) and in order to be found sound, the Local Plan should be targeting higher growth, rather than less than the current target within the Local Plan 2030. Currently, the Local Plan 2030 relies on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, whilst a number are in progress, only two have been ‘made’. Any delays to these emerging neighbourhood plans, could stall the delivery of housing within the Borough. Furthermore, the two which have been ‘made’ are based on the current Local Plan 2030 housing need of 970 dwellings per annum. These ‘made’ neighbourhood plans are likely to require reviewing, to ensure their compliance with any new Local Plan and potentially higher Local Housing Need. It was also highlighted in the Inspector’s final report on the Local Plan 2030, that another reason for the early review of the plan was due to the uncertainty of the preparation and adoption of the Neighbourhood Plans within the timescales envisaged on the housing trajectory. (Para 123) Finally, Neighbourhood Plans are not subject to the same, stringent examination as Local Plans and therefore the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.
4.4.1 The Plan needs to actively enable economic development and growth, prioritising central government projects that have local, regional and national implications, such as the Oxford-Cambridge Arc. Following the completion of Phase 3 of East-West Rail, the connectivity of Bedford will be significantly enhanced. The Plan therefore needs to take a mixed approach to the location of new housing, in order to fully capture the benefits associated with this critical infrastructure investment across all communities. 4.4.2 With the cross-boundary effect of the Oxford-Cambridge Arc, and under the Duty to Cooperate, Bedford Borough should state how it intends to work with all neighbouring authorities and for cohesiveness, the other 30 local planning authorities within the Arc Group that they have previously committed to working with13. The approach to fulfilling the Duty to Cooperate should be regarded as a vitally important consideration from the earliest stages of the plan making process and communicated through the Council’s consultation material in a transparent manner. There will also be a need to consider whether the Borough can assist in accommodating unmet housing needs arising from London because Bedford and the surrounding area benefits from being within reasonable commuting distance of the capital, particularly when aligned with the likelihood of an increased trend in home working over the course of the plan period. 4.4.3 Gladman encourage the Review to be undertaken on a ‘boundary blind’ basis in order to fully recognise and reflect the way people live their lives across local authority boundaries. The nature of connections between places in this area and future infrastructure projects like East-West Rail will have impacts across authorities and will be central to developing a sustainable strategy for the growth of Bedford Borough over the plan period. It will be important for this to be fully recognised by the Council and its neighbouring authorities, working under the Duty to Cooperate, as the process of reviewing and updating multiple local plans is undertaken.
This form is submitted on behalf of 3 landowners who are promoting opportunity sites in the Borough: The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter.
2.1 We broadly agree with the scope of the local plan review, as was instructed by the local plan Inspector. It is very important that the Council plans for sufficient housing and other uses to meet needs over a local plan period longer than that in the adopted plan (which now has less than ten years to run).
This form is submitted on behalf of 4 landowners who are promoting sites available for self-build dwellings: The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. We support the proposal to include a policy to deliver self & custom build opportunities. Self-Build plots are an excellent way of facilitating good quality, well designed, cost effective, and energy efficient housing which is tailored to the needs of the purchaser. Self-build dwellings are an essential part of the housing mix going forward but they need to be provided in the right location. Up until now, Self Build dwellings have tended to come forward as individual windfall plots, where the self-builder is competing with the small and medium scale house builder, or as a small percentage of more recently approved larger sites. However, in order to encourage more self-build and custom housebuilding, it is important that the plots are located where the market wants them to be, and there is greater interest from the market for bespoke plots in the rural area rather than plots which are part of large scale sites dominated by market housing. The Council should therefore be looking for suitable sites in the rural area, that can address this need. Several of our clients have land which is suitable of providing small clusters of bespoke self-build plots in the rural area and this presents an opportunity for the Council to facilitate the delivery self-build in more desirable locations where the demand is higher. These self-build plots will encourage local people to stay in the locality and attract others to it, and this will contribute towards the NPPF’s objective of enhancing and maintaining the vitality of rural communities. The sites below have all been submitted through the Call For Sites process and are available for self-build: • Land East Of Heddings Farm, Wyboston • Top Farm, Wyboston • Shrubbery Farm, Wilden • Land North Of Home Farm, Renhold • Land South Of Home Farm, Renhold • Land Rear Of Home Farm, Renhold • Land To The West Of 52 Keeley Lane, Wootton • Land At 66 Hall End Road, Wootton
This form is submitted on behalf of 15 landowners who are promoting small sites in the rural area: The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter. We support the development of a strategy and allocate new development sites to accommodate growth in line with national policy requirements and hope this will include the allocation of small sites in the rural area.
The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter. The scope of the Local Plan Review should also include some allocations for leisure and tourism uses. Although previous Local Plans have encouraged leisure and tourism through general policies in the Plan, they have not actively promoted any sites through allocations. There is an opportunity for this be addressed as part of the Review.