Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6008

Received: 08/09/2021

Respondent: Mrs Christina Farmer

Representation Summary:

I did not agree that this Issues and Options consultation was sound or fair. I agree with Staploe Parish Council who responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or under utilised land. Our whole parish is classed as open countryside for planning purposes. Our three tiny hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.

We believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots which are already under pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here to make sustainable travel choices – we have one bus on Thursday and it would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would not improve viability of retail and leisure in Bedford Borough. People would go to St. Neots.”

We still feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.

It is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.

In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses: Number of respondents = 315
• 222 were from within the borough – out of a total estimated population of 174,687. This is a pitiful 0.12% response rate
• 93 were from outside the Borough or did not give a postcode
• 53% were from individuals.
Top areas for numbers of responses:
• Bedford 46
• Sharnbrook 23
• Staploe 18 (a 6% response rate which was 50 times the Borough average)
• By contrast – no other areas were in double figures. This brings into further question the validity of the consultation. We believe Bedford Borough Council should be arguing for an extension of time such that the Local Plan 2030 remains “in date” for another year to enable proper consultation, to allow the East West rail route to be announced and for the Oxford Cambridge Arc to decide about development corporations.

1.33 100 word summary


I believe that the Issues and Options consultation was invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2).

We would also call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.

A rail based growth strategy policy may be required if growth is to be located around rail.

1.34 Landscape Character Assessment – LUC

I note the following statements in the assessment:
1E.1.37 Conserve and enhance surviving historic field boundaries and restore hedges where possible in areas of former ancient enclosures, while retaining the open character of areas which were formerly open field land.
1E.1.38 Enhance the hedgerows consistent management and resist development that will result in further loss/fragmentation of hedgerows and hedgerow trees. Encourage the growth of new hedgerow trees to maintain landscape structure and connectivity.
1E.1.42 Conserve the character of the rural roads and limit urbanising influences – widening/kerbing and ensure that traffic management measures are sympathetic to the rural character.

Staploe Parish Neighbourhood Plan survey demonstrated that the peace and quiet, open countryside views and rural feel of our parish are of great value to our residents. In addition, our single track, often high sided lanes and roads are a distinctive local feature. Many have roadside nature reserves due to the rare plants present such as Bath Asparagus. The verges and hedges are cut as little as we can manage in order to maintain visibility and this has enhanced them as green corridors and added to the rural feel of the area. Developing a large new town of Dennybrook (site 977) or other large sites in Duloe such as Cobholden, Manor Farm, Duloe Field, Flints Field and Top Homes may necessitate widening of these roads which would urbanise them and destroy valued hedgerows which is contrary to the comments in this landscape character assessment. We would also like to point out that our hamlets are very different to Thurleigh. Our three hamlets of Staploe, Duloe and Honeydon (including Begwary) are very sparsely populated often with large gaps between homes and usually only with houses on one side of the road. All have countryside views from their gardens. This is different from a larger settlement such as Thurleigh on which the Landscape Character Assessment appears to be modelling future development.