Object
Bedford Borough Local Plan 2040 Plan for Submission
Representation ID: 9595
Received: 29/08/2022
Respondent: Urban & Civic plc
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is
an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.
• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.