Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10515

Received: 29/07/2022

Respondent: Liz Calvert

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Unsustainable Housing Numbers

1. The vast numbers that this Plan commits BBC to is based on very uncertain ground. The demand for housing and jobs is not at all related to the likely population change in the area or even nearby demend. The recent Census proves this – existing growth is already increased by the building houses under earlier plans and the advertising of these well beyond our area. ORS Opinion Research Services, pointed out that existing planned in migration (HNA p 74 para 6.16) was already notable and that the extra 8877 dwellings represented as increase of 88% over and above that included in the most up to date household projection.

2. Housing needs are projected in an inefficient and inaccurate way – that even Mr Gove admitted. In addition, targeting Greenfield out of convenience and the profits of developers is extremely short-sighted and a poor management of resources.

3. The inflated number of houses is explained by the concept of the Ox Cam Arc – illustrated in PfP (Parnering for Prosperity) and finalised in A new deal for the Cambridge, Milton Keynes, Oxford Arc (NIC National Infrastructure Commission). This has now lost the support of the Department for LU H and C. Since it is also unlikely that the EW Rail will be completed, then the basis of much of this plan would need to be redrawn. Why, anyway, does BBC have far more new homes to target than than other parts of the Arc region?

4. The department of housing obviously has to face a housing supply commitment, but the vast number of houses built so far in this area are not addressing the real housing need as very little social housing is provided (not affordable housing but most even under that name are not for the majority of those in need.

5. The Local Authority should continue to stand up for an area which is taking far more than its fair share of development without even discussing this issue with local residents.

6. Natural Environment Policies – loss of valuable green areas, not environmentally sustainable.

The National Planning Policy Framework (NPPF) (2021) Para 174, states that ‘Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils. Using these and the three additions to the document which add a new emphasis on tree numbers and protection, tackling climate change and producing design codes, then the impact of the 2040 Plan is not environmentally sustainable.
The idea that ‘man-made river parks (Great Ouse) is better than the already largely accessible and ‘natural’ Gt Ouse Valley is strange. The Waterway planned would be pleasant for those using the canal but its construction removes natural landscape in the process. This does not appear to enhance natural environments.

Local environments that already exist are often greatly impacted. Small settlements are surrounded by completely different views and the character of their environment changed forever. One natural area has its biodiversity connection etc removed and there is increased pollution – noise, visual and air pollution.

7. Defra’s Nature Recovery Network NRN and their National Food Strategy also are in conflict with these plans. All too often good farmland is lost, natural landscapes which help to protect us from climate change. Huge depots which serve our desire to consume but do not provide many jobs (and often unpleasant conditions for employees) remove even more natural environment which is gone for good.

8. Soundness
There is much overlap with previous points so I will simply mention water and existing infrastructure.
Bedfordshire is one of the driest counties in the country. The current near droubt is showing what happens as climate is also changing. The situation gets worse while we plan to increase the housing dramatically and cover over land which benefits water supply and helps to prevent extreme high rainfall events.

Sewage – there are all to many examples or water authorities in the area not coping with existing volumes and very often discharging into local rivers. . How can we cope with more?

Social Infrastructure – Even if this is addressed to some extent, BBC area already has a dreadful situation as far as numbers of doctors are concerned. The Mayor himself has discussed this. Can we not improve that experienced by existing residents instead instead of making it worse for them?