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Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10137

Received: 29/07/2022

Respondent: Roebuck Land and Planning

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

All EWR refenced paragraphs including: 4.3, 4.18, 4.23, 4.24, 4.27, 4.34, 4.35, 4.38, 4.52, 4.93.
Spatial Strategy and evidence base
In its current form, the plan cannot be considered sound because some of the fundamental principles that the plan relies upon to guide development are uncertain. This specifically relates to the over reliance on the East West Rail (EWR) scheme coming forward during the early stages of the plan period and assumptions on where any new station locations may be sited. There is no certainty that the potential EWR scheme between Bedford and Cambridge will be delivered. There is not currently any funding, nor is there a definitive plan for the route or new station locations given the stage reached to date (non-statutory consultation stages only).
As such to focus development based on a non-statutory options stage of the EWR project is considered to be unjustified. Accordingly, the draft BLP2040 Plan should be considered unsound. The Plan should acknowledge that EWR is a possibility to support and direct growth in the future but it cannot rely upon EWR for the purposes of plan-making at this Regulation 19 stage. The submission plan and evidence base should ensure that all proposed allocations for growth are fully evidenced and implementable as required.
It is considered premature to allocate a new settlement in an area where there is no certainty on a station actually being delivered. The stage that relates to this location is the third and final stage ‘Bedford to Cambridge’ which is still in the early (non-statutory) stages of consideration. There is no clear timetable by EWR on the final route to be progressed or the Development Consent Order process that it would need to complete to give certainty to the scheme from which the location, amount and type of growth can be evidenced and justified.
Although it is acknowledged that much of the housing at Little Barford will be provided towards the end of the plan period given the size of the site, delivery would have to start shortly after the adoption of the plan to ensure that the site is largely complete by 2040 to enable the 3,800 homes to be relied upon.
It is possible that the full EWR project as originally envisaged by the Government to connect Oxford to Cambridge will not be completed. The Government has already announced its rollback of the Oxford to Cambridge Arc. Even if the route beyond Bedford is progressed, fundamental decisions on the final alignment and station locations is not yet known. Sufficient certainty cannot be given at the current time to justify a spatial strategy that includes the Little Barford New Settlement policy. The EWR team are still reviewing consultation responses on the 2021 public consultation on five route alignments and there is no forward programme available to enable BBC to progress through to the submission of the draft plan.
The neighbouring authorities of Huntingdonshire, South Cambridgeshire and Cambridge City Council and Central Bedfordshire have not been able to progress their respective Local Plan reviews given these uncertainties. The Greater Cambridge Local Plan team has revised their Local Development Scheme to take account of the delays and the fact that the new station locations are not fixed and it is not possible therefore to properly evidence any related development allocations that they may propose.
Central Bedfordshire administrative area borders the Little Barford New Settlement proposal and the new station location would have a direct impact on where they may opt to place some of their future growth requirements.
The EWR June 2021 Non statutory consultation documents stated:
Work is ongoing to consider whether it is preferable for the railway alignment to serve a station at Tempsford or St Neots South. We currently understand that there could be substantial advantages to choosing to go via Tempsford but are awaiting further evidence to give us confidence in that judgement.”
It is widely publicised that Central Bedfordshire are considering the potential option for a significant new community at Tempsford should that option be chosen (c12,500 homes) which would directly adjoining the proposed Little Barford New Settlement. The potential for wider impacts has to be acknowledged and considered if BBC continue to plough ahead without any certainty of the EWR project and emerging strategies of the other LPA’s. Central Bedfordshire has set out in its response to the Arc Vision Consultation in October 2021 that it has already been detrimentally impacted and future growth compromised following the decision not to progress with the planned Expressway, due to the significant capacity issues that need to be addressed around Junction 13 of the M1 motorway, potentially placing further emphasis on needing to place its growth beyond 2035 in locations that can take advantage of the EWR initiative.
[See attachment for diagram.]
More recently, the Greater Cambridge Local Plans team has reported on its draft response to the current consultation to its 11 July cabinet, also highlighting that “the sustainability performance and deliverability of a new settlement at Little Barford is dependent on delivery of East West Rail and on the preferred East West Rail route alignment. The preferred alignment and wider programme for delivery of East West Rail have yet to be confirmed. The Sustainability Appraisal Report supporting the Plan for Submission acknowledges the risk of the delay or non- implementation of the planned East-West rail project, but does not identify the impacts of this eventuality”.
The two authorities (South Cambridgeshire and Cambridge City) have resolved that, despite their own pressures to prepare a new joint plan for the Greater Cambridge area, they recognise the need to monitor progress with the East West Rail programme and keep under review implications of any potential uncertainty around East West Rail as the plan is progressed and have revised their Local Development Scheme to reflect the delays.
We also note the objections to the previous spatial options at the Regulation 18 consultation stage of the draft BLP by neighbouring Huntingdonshire District Council over any spatial option that included land at Little Barford. We echo their concern regarding the proposed location of significant growth to meet Bedford Boroughs needs at the boundary of their administrative area; and its impact on St Neots. There is no adequate assessment that has been published to support the plan that deals with the impact of the Little Barford New Settlement proposal on St Neots town. It is our view that this allocation would function as a detached Sustainable Urban Extension to St Neots, rather than a sustainable new settlement. It is highly constrained by the East Coast rail line that cuts the site in two. If the A428 Improvement Scheme is properly referenced in the plan it would show that there are no direct connections into this site that can be relied upon as main strategic access points from which to serve 4,000 new homes and associated land uses.
This further demonstrates the fact that BBC Sustainability Appraisal and supporting evidence when taken as a whole has significant shortcomings and cannot be relied upon.
We are also aware that the Transport Secretary Grant Shapps thought the remaining stages of the EWR project “should be cancelled”, he added that he thought it would be the Department for Transport’s first choice for cancellation. (Source: Cambridge News 19 July 2022). There is no Government funding currently secured for the remaining phases of the project, no permissions are in place and the route is yet to be defined, it is therefore reasonable to argue that there is a great deal of uncertainty on the delivery of this project. Even if the remaining sections of the scheme are not scrapped in their entirety, it is still not certain where the stations would be albeit EWR state that they are happy to work with the local councils in this regard.
The Infrastructure and Major Projects Authority Annual Report 2021-2022 has changed the status for the remaining stages 2 and 3 of the EWR Initiative as ‘Red’ which is expressed as “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability reassessed”.
The relevant extract is reproduced below:
[See attachment for insert.]
If the Bedford to Cambridge section of the EWR project is eventually abandoned, we consider the sustainability and connectivity of development in this location would alter. To our knowledge this possibility has not been tested in any of the supporting evidence. Conversely, throughout the supporting evidence, it is very much suggested that the provision of East West Rail through the site is key to the appropriateness of the site for development.
The Development Strategy Topic Paper (May 2022) states that the coordination of the Wyboston and Little Barford proposals alongside the delivery of the EWR project and the A421 road improvements scheme is challenging. The schemes were all tested against the sustainability appraisal framework, with Little Barford being given the advantage due to the planned East West Rail interchange in addition to avoiding the high quality agricultural land. Effectively this scheme has been unfairly and unjustifiably ranked higher due to a sustainable connection which is unreliable. This is a fundamental failing of the Local Plan and its evidence and needs to be rectified prior to it being submitted for examination. Additional work is required to ensure that a development of such size is correctly located and without additional research and justification the plan should not be considered sound.

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