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Representation ID: 9002

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Growth Strategy Options
2.1 The 2040 Local Plan consultation document sets out the level of housing growth required in
Bedford Borough and the emerging preferred growth strategy options to meet growth needs
within the Plan period. It states that 25,500 homes are required over the 20-year Plan period
from 2020 to 2040, and that as a result of existing commitments totalling 13,000 homes, the
new Local Plan will need to allocate land for a minimum of 12,500 new homes.
2.2 There are four emerging preferred options forming the spatial strategy to meet this growth.
These are:
• Option 2a: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth.
• Option 2b: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth, plus one new settlement.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, southern and eastern parishes growth, plus one new settlement.
(emphasis added)
2.3 Of the four growth options currently being consulted on, three include the provision of at least
one new settlement. The new settlement options that have been selected at this stage are:
• Little Barford – 3,085 dwellings; and
• Wyboston – 2,500 dwellings.
2.4 The inclusion of one new settlement as part of the growth strategy (options 2b and 2d) would
provide c.20-25% of the housing allocations required over the Plan period. If two new
settlements were included (option 2c), these would provide c.45% of the growth required. This
represents a significant proportion of proposed development across the Borough over the 20-
year plan period.
Growth in Huntingdonshire
2.5 The 2040 Local Plan consultation document shows that both new settlements are located on the
eastern edge of the Borough, in close proximity to the administrative boundary of BBC’s
neighbouring authority Huntingdonshire District Council (HDC). Where new development is
proposed adjacent or near to the boundary with other local authorities, it is important that the
combined effects are taken into account. The location of the new settlements therefore raises
questions around the impact on Huntingdonshire and whether the evidence base has adequately
considered the infrastructure requirements and transport mitigation that may be required to
support these growth strategies, as per the NPPF paragraph 24 and the duty to cooperate.
2.6 At this point, it is important to look at the strategy for development within Huntingdonshire.
The District’s new Local Plan adopted in May 2019 (the HDC Plan) sets out that around 75% of
housing will need to be focused in the spatial planning areas, which are defined as Huntingdon,
St Neots, St Ives and Ramsey. A central part of the Plan strategy is development in ‘Strategic

Expansion Locations’ which offer opportunities that are unprecedented in the District for
sustainable development. One of these locations is the growth of St Neots East.
2.7 Policy SEL 2 details the expansion of St Neots East, which allocates 226ha of land for mixed-use
development including, but not limited to, 3,820 homes (3,265 in the plan period) and 22ha of
employment. Combined with additional allocations for 220 homes within St Neots, this growth
equates to over 17% of the District’s allocated housing requirement. The plan below shows the
cumulation of the two new settlement locations in Bedford and the allocation of St Neots East in
HDC.
Figure 2.1 Location plan of St Neots East, Little Barford and Wyboston new settlements relative to St Neots
Source: Lichfields
2.8 With significant development already proposed in this location, it is particularly important that
the cross-boundary implications of the new settlements at Little Barford and Wyboston are
taken into account. A review of the documents submitted for the HDC Plan shows that the
Council liaised with BBC during the preparation of the Plan, and that BBC stated they were
happy with the relationship between St Neots, development south of the A428 in Bedford
Borough (where Little Barford is located) and green infrastructure corridors traversing the
boundary1. It is also noted that HDC specifically clarified with Central Bedfordshire Council
(CDC) that they had no outstanding concerns regarding the expansion of St Neots East2.
2.9 In this context, the following section discusses the evidence base supporting BBC’s consultation document to see if the cross-boundary implications have been adequately considered, as they were by HDC.
The Evidence Base
Bedford Borough Transport Model Local Plan Assessment Summary Report
2.10 This document has been used to inform the Plan making process and provides a summary of the likely effects of four potential development/spatial scenarios on traffic flows in Bedford Borough. More detail on our review of this report and associated model runs can be found in Section 3.0 of this consultation response. It provides a high-level comparison of the scenarios looking at several key transport metrics and identifies the mitigation measures required for each scenario.
2.11 ‘New settlement-focused growth’ was one of the four spatial scenarios tested in the transport model, which focused on providing growth through the creation of one or more new settlements in the Borough. Figure B.3 of the summary report shows that this scenario is based on the four new settlement proposals put forward as part of the 2020 call for sites. This includes Colworth (2,400 homes), Twinwoods (3,495 homes), Wyboston (2,500 homes) and Little Barford (3,085 homes).
2.12 Notably, the four scenarios tested within the assessment are all discrete, and are not considered in combination with one another. For instance, the transport assessment considers ‘urban-focused growth’, ‘infrastructure-focused growth’ and ‘new settlement-focused growth’ as three separate scenarios, whereas the emerging preferred options are a combination of these. The highway impact of the emerging preferred options is therefore unclear in this regard.
2.13 In terms of the effect on traffic beyond the Borough, one of the key transport metrics analysed is ‘cross-boundary impacts’. This is the forecast of vehicle volume to road capacity, measured at junctions outside of Bedford Borough. While this metric could provide a valuable insight into the impact of the proposed new settlements on traffic outside of the Borough, the outcome is limited for two reasons.
• Firstly, the results for the ‘new settlement-focused growth’ scenario reflect the combination of all four new settlements listed above, and not just the two (Wyboston and Little Barford) that have now emerged as the preferred locations. This extends to the assessment of transport mitigation; the ‘cross-boundary impact’ is forecast to neither improve or worsen with the inclusion of mitigation measures, but this includes the mitigation required to support all four new settlements.
• Secondly, the results are intended to present the forecast scale of change between the four development scenarios, highlighting the relative performance of the scenarios and not the absolute performance. For the ‘cross-boundary impact’ metric, the data analysed the number of nodes (junctions) where the volume-capacity ratio exceeded 85% (the threshold for which congestion becomes apparent) and varied significantly (over 5%) across the four growth scenarios.
2.14 As a result of this two-factor approach, the results do not truly reflect the impact on congestion outside of the Borough.
2.15 We acknowledge that more in-depth transport assessments have been carried out which analyse the Little Barford and Wyboston new settlements both alone and in combination. However, while these do appear to analyse the impact on the highway network outside of the Borough,
they are not explicit in terms of the impact on neighbouring authorities or the cross-boundary mitigation required to support the proposals.
(Draft) Sustainability Appraisal Report
2.16 An essential part of the evidence base, this document sets out the sustainability appraisal framework and sustainability objectives for the emerging 2040 Local Plan. The draft report provides an appraisal of the likely social, economic, and environmental effects of each growth strategy option put forward in the process of Plan preparation and concludes that the four emerging preferred growth options (2a to 2d) are the best performing overall.
2.17 Throughout the appraisal of each spatial option, there is not a clear consideration of the sustainability impacts on neighbouring authorities. The only point that categorically discusses the wider social, economic and environmental impact outside of Bedford relates to the objective to ‘promote vital and viable town centres’; the comments for spatial options including a new settlement state that residents might visit competing town centres outside of the Borough if these are nearer or easier to visit with improved transport links.
2.18 Further, the assessment states that locating growth in new settlements is still likely to increase the need to travel and length of trips to ‘the urban area’, which is where most services, facilities and employment opportunities will remain located. Here, the urban area refers to Bedford only and not nearby settlements beyond the Borough boundary which are geographically closer to the two new settlement proposals.
2.19 The lack of consideration around the potential cross-boundary impacts on Huntingdonshire (or any other neighbouring local authority) within the report may be due to the fact that there is no specific reference to this within the fifteen sustainability appraisal objectives. It appears that this matter has been somewhat neglected, and that the sole focus of the appraisal is on the effects within Bedford. It is therefore questionable whether the sustainability appraisal is sufficiently robust in justifying the preferred growth options; strategic discussions between neighbouring authorities is essential to the delivery of sustainable development (e.g. sustainable transport links).
Development Strategy Topic Paper
2.20 It is a requirement of the Plan-making process that Plans are tested to ensure their deliverability. This document provides a deliverability assessment of the development strategy options that have been considered so far in the preparation of the new Local Plan, in particular why options 2a, 2b, 2c and 2d have emerged as the preferred options for inclusion in the consultation document.
2.21 The deliverability analysis of each option is high level only. This is due to the absence of more detailed work, including a full infrastructure delivery appraisal, Plan wide or site-specific viability appraisals and detailed transport modelling. For each option, the key strengths and weakness are identified as a basis for determining whether, in delivery terms, there is a case for them to be selected as preferred options.
2.22 Throughout the analysis, there are only two parts that touch on wider cross-boundary implications. First, in assessing option 2a, one of the delivery challenges identified is that “substantial development has already taken place on the edge of Bedford. Further outward spread runs the risk of coalescence with nearby settlements”. However, given that option 2a focuses growth around the urban area and southern parishes, this only relates to settlements south of Bedford, such as Wootton, Stewartby and Marston Moretaine. It is of concern that this is thought to be a strategic delivery issue for this growth option, but not for others proposing a
new settlement on the eastern edge of the Borough, given that these pose a greater risk of coalescence with St Neots.
2.23 For options 2a to 2d (the emerging preferred options), a strength is identified as the ‘opportunity to establish a new planned community at Wyboston or Little Barford in proximity to the proposed EWR station at St Neots / Tempsford’. It therefore acknowledges the proximity of the proposed new settlement options to existing areas within Huntingdonshire; however, it does not then consider the cumulative impact of this on the neighbouring local authority as a weakness. This appears to be one-sided, disregarding the cross-boundary impact as a delivery challenge.
2.24 Taking the two points above together, the deliverability analysis is therefore inconsistent in its approach and does not represent an objective assessment of each option.
Issues & Options Consultation – Summary and responses
2.25 This document summarises responses to the 2020 Issues and Options consultation. In the comments received (not specifically attributed to any party), concern was expressed about the impact of growth on communities and infrastructure beyond the Borough boundary (particularly around St Neots), and that cross-boundary discussions should continue through the Duty to Co-operate. Other respondents also felt that the cumulative impact on infrastructure is important and therefore cross-boundary master-planning may be an option. The Council’s response does not provide a clear and reasonable answer to these concerns.
Cooperation with Huntingdonshire
2.26 As set out above, a review of the evidence base supporting the consultation document indicates that the location of the proposed new settlements adjacent to Huntingdonshire has not been adequately assessed. Overall, it does not provide a clear justification demonstrating that there will be no significant adverse impacts on the neighbouring Authority in terms of deliverability, highway mitigation and infrastructure, and further evidence is needed to show that the proposed new settlements are achievable; significant investment in infrastructure may be necessary in order to deliver development in this area at scale.
2.27 National policy states that:
“Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary.” (NPPF Paragraph 26).
2.28 To demonstrate effective and on-going joint working, national policy requires strategic policy-making authorities to prepare and maintain statements of common ground documenting the cross-boundary matters being addressed and progress in cooperating to address these. The statements should be made publicly available throughout the Plan-making process to provide transparency (NPPF, Paragraph 27). They also form part of the evidence required to show that local planning authorities have complied with the Duty to Cooperate; this is a legal duty to engage constructively and actively with neighbouring authorities and other prescribed bodies in planning for strategic matters that cross administrative boundaries.
2.29 A Duty to Cooperate statement forms part of the evidence base for the adopted Bedford Local Plan 2030. While the adopted Plan does not include any proposals for new settlements, those put forward in the 2020 call for sites were consulted on throughout the Plan-making process. In the record of cooperation, one of the issues identified was that a new garden village at Wyboston would be adjacent to Huntingdonshire. The record goes on to state that should the Wyboston
proposal proceed, there will be a need for cross-boundary implications to be assessed by HDC and BBC and that ”the two Councils will continue to cooperate in respect of future new settlement proposals”.
2.30 Following this, we cannot find any evidence that further discussions are taking place with neighbouring authorities now that new settlement proposals in this area are being consulted on. For Plan-making, national planning practice guidance (NPPG) makes clear that councils are expected to document the activities undertaken during the process of addressing strategic cross-boundary matters, including working together at the outset of Plan-making and producing joint research. This is particularly important for new settlements, which typically constitute a significant proportion of growth over the Plan period, and even more so now in the context of the NPPF 2021 paragraph 22 and the need to develop a vision within which to set policies for larger scale development such as new settlements for a minimum of 30 years, ten years more than the emerging Plan period. The proposition for a new settlement at Wyboston is in excess of 10,000 new homes3, quadruple the emerging allocation figure of 2,500 and with a potential impact on Huntingdonshire which is significantly greater than that associated with just 2,500 homes. Little Barford has an emerging allocation for 3,085 homes, with its maximum potential set out as 3,385 to 3,955 in the site pro-forma4, which is more in line with the 2040 Local Plan.
2.31 It is therefore not clear that BBC is currently cooperating with HDC in assessing the cross-boundary impacts of the proposed new settlements at Little Barford and Wyboston. Such an approach is not in compliance with national policy. The Council needs to show that it is engaging with HDC to determine that the new settlements are deliverable over the Plan period and that they are based on effective joint working across the local authority boundaries. This evidence is also needed to provide communities and other stakeholders with a transparent picture of how they have collaborated.