Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10524

Received: 26/07/2022

Respondent: Barton Willmore

Representation Summary:

Paragraphs 1.5 to 1.34 of the plan for submission set out the national context and the Council’s reasoning for extending the plan period to 2040.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long term requirements, for example major improvements in infrastructure. Paragraph 22 goes on to state that policies should be set within a vision which looks further ahead (at least 30 years), where larger scale developments form part of the strategy. The Council acknowledges within paragraph 1.5 that a longer timescale would have the advantage of giving certainty for a longer period. However, decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years, which has influenced the proposed Plan period of 2020-2040. We agree with the Council’s view and consider that the Plan period is appropriate in the circumstances, particularly given the context of the Arc Spatial Framework, which is discussed in further detail below.
Paragraphs 1.6 to 1.22 provide further background in terms of the Oxford – Cambridge Arc, and the Arc Spatial Framework, which is currently being prepared to provide a long-term strategic plan to help coordinate the infrastructure, environment and new developments in the area. The first consultation on the development of the Spatial Framework ran from the 12th of July 2021 and closed on the 12th of October 2021. The feedback from the consultation is currently being analysed. Within the July 2021 consultation document, it was advised that the development of the Spatial Framework would be supported by two further public consultations including one in Spring 2022 and Autumn 2022, however no further public consultation has taken place as of yet.
Within paragraphs 1.13 to 1.16, the Council acknowledges that the timetable for the production of the Arc Spatial Framework has changed over recent years and has been delayed for several reasons including the Covid 19 pandemic. In response to this, some local authorities within the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. In Bedford’s case however, this is not considered to be a viable option for the reasons relating to policies becoming “out-of-date”. As such, it is vital that the Council work alongside the Oxford-Cambridge Arc to ensure the BBLP 2040 and the Spatial Framework align as far as possible.
As the timescales for the preparation and submission of the BBLP 2040 do not allow the plan making process to follow the publication of the Spatial Framework, and given that progress with the Framework appears to be slow, we would encourage the Council to commit to a further early review to ensure that the Borough’s Local Plan remains aligned with the Spatial Framework and to be able to fully take advantage of and support the opportunities brought to the Borough by the Oxford-Cambridge Arc.
Paragraphs 1.23 to 1.28 provide further information in terms of the proposed East West Rail (EWR) and how the delivery of this national project has a bearing on the Plan and its success. It is being introduced in three stages, which are as follows:
• Stage One – Oxford to Bletchley / Milton Keynes
• Stage Two – will extend that service to Bedford
• Stage Three – will connect Oxford all the way to Cambridge
Paragraph 1.5 states that the track between Oxford and Bicester is already complete, and the next part from Bicester to Bletchley is underway. The section to Bedford involves refurbishing existing lines and is expected to follow on from Stage One. The last stage is advised to be more challenging because it involves the construction of a completely new stretch of track from Bedford north towards Sandy / St Neots and Cambourne, then on to Cambridge. No detailed route alignment has however been chosen. Paragraph 1.26 states that the full route is expected to be operational by 2030.
It is our understanding that plans for Stages 2 and 3 are still being developed, with no funding yet to be received for these stages1. Whilst it may be the case that this is quite common with a lot of infrastructure projects of this nature, it does suggest that there are still a large number of unknowns associated with the EWR.
Paragraph 1.29 refers to another significant infrastructure project as being the upgrade of the road route between the Black Cat Roundabout (A421 / A1 junction) and the Caxton Gibbet roundabout on the A428. Similarly, there are still some unknowns in this respect, with the Secretary of State still yet to issue a decision / grant a Development Consent Order2. The deadline for the Secretary of State to make a decision is the 18th of August 2022.
Based on the above, it is considered that significant infrastructure projects should not be over relied upon within the Plan in the event of any delays in delivery, funding etc., with some growth concentrated within areas that are already in sustainable locations, that are already well served by alternative transport links.