Object

Representation ID: 10508

Received: 29/07/2022

Respondent: Conservative Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

LP2040

I note that under the Local Plan 2030 Bedford Borough Council is obliged to submit a further local plan or risk not unplanned development due to a lack of a 5 year land supply. This is clearly problematic.

Sustainability and Infrastructure
The plan fails to take into account the climate change emergency declared by the council and its own sustainability appraisal-it is too car centric- it therefore fails the sustainability test. In order to be made sound there needs to be a greater focus on modal choice (for example EMP6). There also needs to be a greater focus on providing infrastructure with developments, and indeed in advance of developments to ensure that people can live sustainably in their communities, for example shops, doctors, schools. Greater emphasis should be placed on 15 minute communities- which have historically been well delivered in Bedford Borough but this has recently been lost and is lost in this plan. Some of the proposed developments do not adjoin existing settlements nor do they provide facilities for new residents- this is not sustainable and is therefore unsound (such as HOU16).
There is also a risk of replacing agricultural land and genuine countryside being lost to more urban country parks which are then not managed or used effectively for leisure or biodiversity, or indeed food production.

East West Rail
The Plan is not sound because it makes it does not make it clear that the EWR route corridor is only proposed- it should be amended to reflect the stage that the EWR proposals are at.

Town Centre
The town centre proposals do not accord with the NPPF policy 86. Planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Planning policies should:
d) allocate a range of suitable sites in town centres to meet the scale and type of development likely to be needed, looking at least ten years ahead. Meeting anticipated needs for retail, leisure, office and other main town centre uses over this period should not be compromised by limited site availability, so town centre boundaries should be kept under review where necessary;
f) recognise that residential development often plays an important role in ensuring the vitality of centres and encourage residential development on appropriate sites.
The list of acceptable uses in policy TC3 is too restricted and fails to offer a wider range of opportunities for what the town centre could be in terms of services, businesses and health services. This therefore fails the test of being positively prepared. It also is not sound because it is not sufficiently supportive of residential uses in the town centre including new build residential.

It is also unclear what is meant by a ‘concentration of similar uses whose cumulative impact would be to the detriment of environmental quality, amenity or parking, or would increase the risk of anti-social behaviour or would create a significant length of inactive frontage at ground floor level’. To make the plan sound this should be made clearer.
In order to be made sound these policies need to be broadened to allow a greater scope for residential development and more uses in town centre- for example more leisure and health facilities. Greater clarity should be given on the cumulative impact policy.

Coalescence and Urban Sprawl
There is a real risk of coalescence between a number of settlements including Bedford-Renhold-Great Barford due to EMP6 and Shortstown and Cotton End due to Hou17 (Proposals secure country parks however they do at the cost of actual existing countryside).

Proposal Numbers
The policies in the plan do not clearly set out anticipated numbers on sites- it is therefore difficult to know with any degree of certainty the numbers of units (be it homes, or work places) that will be delivered on any site. To lack such level of detail is unsound and in order for the plan to be made sound there needs to be greater clarity on what is intended and what is acceptable on each site. Although information is provided elsewhere in order to be able to be relied upon it should be in each individual policy. This is a particular issue with Policy EMP6 as it unclear how much of the site will be used and what type of buildings would be on the site for example- quantity and scale of warehousing. In order to be sound further information must be provided as part of the policy, and where mixed use is being considered proportions envisaged should be included (albeit it that it is my submission that EMP6 is not sound).