Object

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

Representation ID: 8998

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Representation Summary:

This section addresses two main themes. It firstly sets out the shortcomings of the Vision in
terms of reflecting comprehensive opportunities for sustainable development across the
Borough. Secondly, it addresses that while there are many positive aspects of outcomes
sought under the vision these will not be addressed as part of the strategy due to the
Council’s selected Preferred Options.
Reasoning

The draft Vision sets out:
“Well-planned growth supported by appropriate infrastructure and avoiding areas of high
flood risk will enable the creation of strong, safe and resilient local communities in
environments that facilitate healthy and independent living for all.”

This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options
omitting a significant number of the Borough's KSCs and RSCs from the spatial strategy and
do not seek to provide for the additional development required to secure balanced
communities.
The Vision further states:
“Rural communities will embrace appropriate development, in many instances through
the preparation of their own Neighbourhood Plans.”

This would imply a requirement for additional growth, which the preferred options exclude for
a significant number of centres. The draft Vision feels to address that it is part of the role of
the Local Plan review (and resulting updates) to address strategic priorities deferred as a
consequence of the Local Plan 2030 (for example expansion of primary healthcare and
secondary education). The Vision also fails to reflect that the proposed development strategy
is not looking to provide for any additional growth in rural areas as part of an uplift to meet
housing needs in full before 2030. This is a significant shortcoming of the strategy and
overlooks suitable and deliverable sites that could be prioritised now to meet these increased
needs alongside the delivery of other substantial benefits.

The Vision makes limited reference to specific benefits that the Local Plan 2040 will secure
in relation to the natural environment, including Country Parks north of Brickhill and west of
Bedford.

The Vision is artificially constrained as a result of the Council’s current position on Preferred
Options. There is no reason that other sustainable developments cannot achieve
complementary and significant advantages for Green Infrastructure provision (e.g., our
client’s proposals to provide a Riverside Park as part of the development opportunity at
Stoneyfields, Sharnbrook).

Theme 4 (Better Places) of the Council’s proposed Objectives for the Local Plan 2040 sets
out:
“Provide appropriate amounts and types of housing to meet the needs of the borough’s
urban and rural communities over the lifetime of the Plan making the housing stock more
adaptable and resilient
Achieve a borough where everybody has appropriate access to high quality health and
social care, as well as everyday essential services and community facilities where social
and cultural wellbeing are supported, enabling all residents to lead healthy and
independent lives.”

The principle of these objectives is supported but is reliant on flexibly supporting diverse
opportunities for development across the settlement hierarchy. There are a substantial number of centres where the level of development identified is insufficient to secure the opportunities identified.