Comment

Representation ID: 10252

Received: 29/07/2022

Respondent: Central Bedfordshire Council

4. Spatial Strategy to 2040
4.1 CBC supports the use of the Standard Methodology for calculating the housing requirement for the period from 2020 to 2040. It is recognised that this results in a total requirement of 27,000 new homes (1,355 dwellings per year), and that taking account of existing commitments, completions and an allowance for windfall, which amount to 14,824 dwellings, there is a need to identify sufficient land for 12,276 dwellings within the Bedford local plan to 2040.
 
4.2 As stated in our response to the Strategy Options and Draft Policies Consultation in September 2021, CBC is of the 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 Council therefore welcomes the approach taken within the submission local plan for new development to be focussed firstly on brownfield sites within and adjacent to the urban area, as well as town centre sites that offer regeneration opportunities. Policy DS5(S) is therefore supported to the extent that it identifies that the urban area will accommodate 1,200 new homes, whilst 1,500 new homes will be delivered in strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale, incorporating the Bedford Milton Keynes Waterway Park and the Bedford River Valley Park.
4.3 Policy DS5(S) also identifies that 10,850 new homes (and 73ha of employment land) will be delivered at two growth locations on the A421 corridor – south of Bedford including a new settlement, and Little Barford new settlement.
4.4 It is considered that the emphasis placed on these two growth locations to deliver such a substantial quantum of growth is likely to have significant impacts upon Central Bedfordshire and our communities. The Council has significant concerns about the transport implications that will undoubtedly arise for Central Bedfordshire as a consequence of this growth being focussed on the EWR / A421 transport corridor and therefore cannot support these two proposals at this time.
4.5 In the assessment of the options, the Pink, Yellow and Brown options focus development around the A421 corridor and the assumed East-West Rail corridors. Whilst the yellow option was one of the two options detailed within the evidence as performing the best in terms of the assessment metrics that were applied, it results in sub-options where development is focused to the south and east of Bedford and therefore with the most immediate potential for impact on the transport network within CBC, including the A421 and A1 corridors. When considering the future 2040 reference case it is also noted that the A421 and A1 (strategic cross boundary routes into Central Bedfordshire) are the routes that the modelling predicts will undergo the greatest levels of increase in terms of background traffic.
4.6 Four sub options (2a- 2d) were then considered, each being variants of the yellow option, resulting in an overall preferred option, which focuses development around the A421 and East-West Rail. In testing these options, the modelling report identifies flow increases on routes in CBC including the A1, A421, C94 with associated increases in both delay and volume/ capacity ratios. There are also increases predicted on the B530.
4.7 The proposed package of mitigation works, which predominantly provides a strengthened ring road to the south and west of Bedford, appears to have the general effect of releasing suppressed trips onto the wider major road network, in particular the A1, A421 and B530, all of which sit, at least partially within CBC. This is of immediate concern to CBC, especially in the context of our own growth strategy and allocated sites in our Adopted Local Plan (July 2021).
 
4.8 Including a focus on sustainability within Theme 2 of the Bedford Submission Local Plan is critical to managing growth and is welcomed, but we suggest that East West Rail and the reintroduction of ‘faster north- south travel’ (presumably on the Midland Mainline but this is not clarified) is not strictly an objective of the Plan as both interventions are in part controlled by external parties.
4.9 In terms of policy DS2, the South of Bedford policy area raises some specific concerns with regard to the A421 corridor and M1 junction 13 which we address in further detail later on in our response. Rail based development as a concept around Stewartby Hardwick and Wixams is supported, but this must be delivered alongside a robust highways mitigation strategy due to the nature of planned growth across the whole A421 corridor. Similarly, the Little Barford policy area raises concerns around impact on the A1 corridor and erosion of future capacity of the new Black Cat roundabout and realigned A428.