1.1

Comment

Representation ID: 9103

Received: 14/07/2022

Respondent: Wootton Parish Council

Wootton Parish Council wishes to comment on the Local Plan 2040 - New Policy DM3 (S) to make it clear that Bedford Borough Council's expectation is, where Category 3 dwellings are required, they will be achieved by the provision of bungalows (houses on one level which are not part of a multi-storey block of dwellings).

Comment

Representation ID: 9185

Received: 25/07/2022

Respondent: Mr Tom Tagg

BBC have done the best they can to prepare a new plan early after being forced to account for the Arc, but HMG have failed to deliver on the Arc programme so there is a risk that the new local plan my have to be reworked when and if HMG progress plans for the Arc.

Comment

Representation ID: 9204

Received: 15/06/2022

Respondent: TfL Planning, Transport for London

Thank you for consulting Transport for London (TfL). I can confirm that we have no comments to make in response to the Plan for Submission consultation.

Comment

Representation ID: 9208

Received: 23/06/2022

Respondent: Mr Anthony Roche

There are many welcome developments in the revised plan and it is pleasing to note that the current document appears to have been developed with greater strategic vision related to the wider infrastructure needs of the Borough, recognising that Bedford is now a substantial commuter location largely serving London employment needs. The additional developments are also back-end weighted and phased so that they can only take place when the new infrastructure is in place.
Particularly welcome is to note that the additional development is focused into the existing urban area or in specific new settlements that will be served by major roads and railway stations that have capacity to carry the additional traffic. This, in conjunction with the plans to increase the amount of housing in the town centre, through the conversion / replacement of buildings no longer needed as shops or business premises is an essential step to enable a vibrant town centre for all residents of the Borough to enjoy and use.

Bedford Borough is at last starting to address the fundamental challenges of a growing town, including its rural locations. It is however a major strategic challenge for the Borough Council to ensure that the development of the Oxford/ Cambridge Arc does not become predominant and disproportionate in the determination of the expansion of the Borough.

Comment

Representation ID: 9233

Received: 02/07/2022

Respondent: Bedford and Milton Keynes Waterway Trust

The Bedford and Milton Keynes Waterway Park will establish a new green/blue multifunctional parkland corridor along which the ultimate aim is to create a waterway linking the Grand Union Canal at Milton Keynes with the River Great Ouse in Bedford. It will enhance opportunities for flood risk management in the upper Ouse catchment area and for water transfer from the distribution network in the west to the drier areas of East Anglia. Last but not least it will provide the opportunity to close a small but very significant gap in the UK waterway network.
The Waterway Park can build on the achievements of the Marston Vale Community Forest in regenerating parts of the corridor and creating new habitats between Bedford and Milton Keynes. And like the Forest, the Waterway Park will be deliverable in parts in combination with appropriate environmental management plans. It will set the context for, and embed new natural capital into, expanding communities thus contributing towards the Government’s commitment to its biodiversity as well as health and wellbeing targets.
The Bedford and Milton Keynes Waterway Trust acts as an advocate for the new Waterway Park and works with the Bedford and Milton Keynes Waterway Consortium partners to develop a strong business case for the project.

Object

Representation ID: 9244

Received: 26/07/2022

Respondent: Mr Mark Jones

Legally compliant? No

Sound? No

Duty to co-operate? No

As above

Support

Representation ID: 9253

Received: 27/07/2022

Respondent: Mrs Alison Myers

The Arc no longer carries the same weight - BBC needs to resist the high level of housing demand envisaged for the Arc .

Comment

Representation ID: 9531

Received: 11/07/2022

Respondent: The Coal Authority

The Coal Authority is a non-departmental public body sponsored by the Department of Business, Energy & Industrial Strategy. As a statutory consultee, the Coal Authority has a duty to respond to planning applications and development plans in order to protect the public and the environment in mining areas.

As you are aware, Bedford Borough Council lies outside the defined coalfield and therefore the Coal Authority has no specific comments to make on your Local Plans / SPDs etc.

In the spirit of ensuring efficiency of resources and proportionality, it will not be necessary for the Council to provide the Coal Authority with any future drafts or updates to the emerging Plans. This letter can be used as evidence for the legal and procedural consultation requirements at examination, if necessary.

Comment

Representation ID: 9549

Received: 12/07/2022

Respondent: Clive Baker

Number of people: 2

this plan is Unsustainable, for several reasons.

'Sustainable' is the most abused word in Planning.

The continued ever-increasing abstraction of water to meet planned increases to domestic and commercial consumption is unsustainable.

The continued development of hitherto agricultural land is unsustainable and unacceptable. The disappearance of our rural landscapes is unacceptable.

Your immediate and unquestioning acceptance of government housing and employment targets is unacceptable.

Borough has a shortage of school places, surgeries are built but there are not enough staff to provide adequate services, but this plan will place an even higher burden on services that clearly cannot cope.

Wootton has provided the Borough with £12m CIL from unwanted development in Wootton, none spent in Wootton. The Borough filches £200k from Rural Funds to fund Bedford High Street, a complete waste of money while Wootton is deprived access to S106 funds, indeed the Borough tries to force the Parish to pay for improvements that are the Borough's responsibility to fund.

The Borough's Planning Dept does not have enough staff to properly examine Planning Applications or breaches of Planning Permission, developers have a virtual carte blanche.

reconsider before it is too late

Comment

Representation ID: 9552

Received: 19/07/2022

Respondent: Mr Hugh Moss

The plan does not mention the need for all new houses to have solar panels.
The lists of new dwellings neglects the need for more secondary schools and medical practices

Comment

Representation ID: 9569

Received: 20/07/2022

Respondent: L&Q Estates Limited

In general, L&Q supports the Council’s intention to prepare a new up-to-date Local Plan, prepared in accordance with the 2021 National Planning Policy Framework (NPPF). The adoption of a plan-led system is important to delivering sustainable growth.

Object

Representation ID: 9625

Received: 27/07/2022

Respondent: Catherine Tolmie

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Firstly, if you think that the arrangements for members of the public to engage in and comment on these 'plans' are accessible and easy to follow, they are not. Despite spending a long time trawling through the website and documents, I have not found a simple link to actually submit a concise reply. How much time do you honestly think ordinary working people have to respond to this, to comment on every section? It's inaccessible or too time consuming for most You need a big rethink on this.

The website is convoluted and not user friendly. 'Have your say' on the front of the paper document sent through householder doors...??

So I'll give my response in a manner that suits me.

I know and most people I know also know that these non public consultated plans have been in the 'planning' for years, that we have been disenfranchised from the process as taxpayers and voters and that they are being sold as enhancements to the services and 'opportunities' in this part of the country when they are anything but. What they involve are mass people migration, mass housing and a complete denigration of the Bedfordshire countryside. I'm glad that CPRE are starting Freedom of Information requests because that's exactly what I'm thinking of doing up here in Sharnbrook so that we can finally find out all the real information about what is being done 'in our name'. I was born in Luton and I have seen how that once vibrant town has been totally destroyed by inconsiderate, poor building and planning and huge and unsustainable migrations of people from London and other conurbations. Now you want to do the same to Bedford. You will regret it I assure you when your public services, NHS and transport networks are in even more crisis!

My general comments also pretty much mirror those of the CPRE further below so I've copied that bit.

I would finally say that what you should be concentrating on is improving the struggling areas of Bedford Borough, the failing schools (I've been reading all the data on them this past week and boy, it's not pretty), drug and dependency issues, existing housing issues rather than pandering to Government and private builders and landowners for more housing. You spent money on the Embankment. Great but so many people I know through my son’s Bedford Town football asked what about the problems at my school, down my road, all the drunks and drug users in the Town Centre (I see them every week too as I make an effort to shop in the Town Centre).

Don't get me started on the damage to the River Great Ouse landscape and water management and environment. I genuinely think people on the Borough environmental protection side have lost their minds.

So I think the grandiose, legacy, 'bigging it u with the housebuilders', ego trip whatever you want to call it plans need to be scaled right back and you need to concentrate on helping the existing population of Bedford as opposed to overwhelming the area. And also building in Bedford in terms of the (non publicly consulted) 'arc' might help Oxford and Cambridge but it sure as hell won't help Bedford who will be left with a load of population it can't cope with in terms of services, transport links and everything else.

So I object wholeheartedly to the scale and breadth of these plans. They are wrong for Bedford Borough as was the 2030 version.

So reassuring that a property developer has been appointed to Chair the (non publicly consulted) 'arc'. Democracy in action clearly....


Copy of the CPRE comments:
We ask what does the government’s recently announced Oxford-Cambridge Arc expert advisory panel mean for the Bedford Borough Local Plan 2040 consultation?
During August, the Government quietly announced that they have appointed Emma Cariaga to Chair a newly established Oxford – Milton Keynes- Bedford – Cambridge Arc “Expert Advisory Panel”. The purpose of the Expert Panel, which will stand for six months, will be to:
“..focus on the area between Bedford and Cambridge, where the government has committed to explore the case for new or expanded settlements including those linked to potential East West Rail stations, to bring forward well-designed, inclusive and vibrant places”.
Emma Cariaga is currently a senior director with the company British Land, one of the largest property development and investment companies in the country.
The development of East/West Rail and particularly the route from Bedford to Cambridge has been driven, not by the needs of local communities for environmentally sustainable transport infrastructure which will reduce congestion on the road network, provide a sustainable transport option for existing communities, and reduce our carbon footprint but rather to provide massive new development opportunities for New Towns in the north Bedfordshire and Cambridgeshire countryside.
Coming so quickly after the latest East West Rail Consultation has been completed, during which the East West Rail Company and Bedford Borough Council said that the development of New Towns in the North Bedfordshire countryside was not the target of the new rail route, this announcement makes a mockery of the whole process.
The government has continually said that local people will be included in the decision making process of developments across the Arc. To put a senior director of a London based property development company as chair of the Expert Panel adds insult to injury. It seems clear that the interests of the people of Bedfordshire and Cambridgeshire and local democracy will not be one of the Panel’s priorities.

Support

Representation ID: 9654

Received: 26/07/2022

Respondent: Mrs Pamela Tidy

I support the Local Plan 2040. I agree that growth should be directed to Bedford and the A421 corridor, rather than to the north of Bedford.

Comment

Representation ID: 9711

Received: 26/07/2022

Respondent: Historic England

Thank you for consulting Historic England on the Bedford Borough Local Plan 2040:
Plan for Submission. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is
fully considered at all stages and levels of the local
planning process.
The county town Bedford lies towards the south of the borough. Founded at a ford on the River Great Ouse, the historic market town was granted borough status in 1165. The Borough has a rich and diverse historic environment with over 1,300 listed buildings including 50 listed at grade I, 68 scheduled monuments including
many moated sites, 8 registered parks and gardens and 28 conservation areas.
The north of the borough bordering Northamptonshire boasts a number of pretty villages with stone and thatched cottages as well as a number of Bedford Estate
cottages. To the south of the borough, the heritage and legacy of the brickworks as well as the hangers at Cardington shape and dominate the landscape.
Situated within the heart of the Ox Cam arc and with fantastic existing and potential transport connections in the form of the A421, M1, A1 as well as located on the
Midland Mainline and the route of the new East West Rail, the area is set to experience considerable growth in the coming years. The challenge is to ensure that this is good growth that respects and takes the opportunity to enhance the historic environment.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Regulation 19 Plan and
consultation material with a view to providing advice on heritage matters. As a general comment, Historic England welcomes emerging plan and work undertaken to date.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.
Under paragraph 35 of the National Planning Policy Framework, some aspects of this Plan are unsound as they have not been positively prepared, are not justified,
effective, or consistent with national policy.
We have summarised below in this letter some of the key issues to be addressed. We have also identified in detail where we find the Plan unsound and what
measures are needed to make the Plan sound. These detailed comments are in the Table at Appendix A which provides more detailed comments on these and other
more minor issues.
In summary we highlight the following 2 key issues: sites and heritage impact assessments.

In preparation of the Bedford Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms
part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues.
Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our
obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Comment

Representation ID: 9742

Received: 29/07/2022

Respondent: Mr Kevin Levvit

1. With reference to the overall plan, there appears to be no mention of interfaces or interaction with the local Clinical Commissioning Group [CCG], with regard to adequate medical facilities for the EXISTING infrastructure south of Bedford [for example WIXAMS and WILSTEAD]. Extra housing stock implies extra bodies that may require medical attention at certain times and currently there is a significant shortfall between the number of places available to register with a GP and the extended population arising from the existing developments. Add to that an aging population who may be currently 50-60, those folks will be the vulnerable in their 70-80s when this plan is supposed to deliver.
2. And for the Borough as a whole what interaction with the CCG has or is intended to be put in place regarding provision at BEDFORD hospital for the significant increase in local population. Given the plan and its intentions, some projections of age ranges should be possible to indicate to the CCG the additional numbers of staff THEY will need to employ to ensure the health of the local people.
3. Similarly, the lack of current provision for local dentistry appears to have been overlooked – again a CCG provision?

Comment

Representation ID: 9745

Received: 29/07/2022

Respondent: Mr Kevin Levvit

5. Much of the plan appears to be in response to the OXFORD-CAMBRIDGE ARC – although phases 2 and 3 affecting Bedford from both sides of the county appear to be in question. The effect of the removal of this need would appear to put the whole local plan for 2040 in jeopardy. When will any rectification planning take place?

Comment

Representation ID: 9767

Received: 12/07/2022

Respondent: Clive Baker

We may respond to this consultation if we are able to say that this plan is Unsustainable, for several reasons.
'Sustainable' is the most abused word in Planning.
The continued ever-increasing abstraction of water to meet planned increases to domestic and commercial consumption is unsustainable.
The continued development of hitherto agricultural land is unsustainable and unacceptable. The disappearance of our rural landscapes is unacceptable
Your immediate and unquestioning acceptance of government housing and employment targets is unacceptable.
Borough has a shortage of school places, surgeries are built but there are not enough staff to provide adequate services, but this plan will place an even higher burden on services that clearly cannot cope.
Wootton has provided the Borough with £12m CIL from unwanted development in Wootton, none spent in Wootton. The Borough filches £200k from Rural Funds to fund Bedford High Street, a complete waste of money while Wootton is deprived access to S106 funds, indeed the Borough tries to force the Parish to pay for improvements that are the Borough's responsibility to fund.
The Borough's Planning Dept does not have enough staff to properly examine Planning Applications or breaches of Planning Permission, developers have a virtual carte blanche.
reconsider before it is too late

Support

Representation ID: 9768

Received: 20/07/2022

Respondent: Knotting and Souldrop Parish Council

Knotting & Souldrop Parish Council unanimously supports the draft Local Plan 2040.

Comment

Representation ID: 9776

Received: 22/07/2022

Respondent: Rob Allen

I just wanted to make a final comment regarding the local plan 2040.
Firstly, I’d like to congratulate you on the sheer amount of work that has been done – it really is quite impressive. You’re to be commended.
I do however have ongoing concerns with some of the processes used to get to this point. Whilst I can only discuss the neighbourhood plan in Turvey where I reside, it was really a farce and I suspect almost illegal. The final referendum was highly close (within a couple of percent) and it was dogged with improper practices. We had people breaking into people’s gardens to take down signs, smear campaigns on social media, it even transpired after the fact that many of the elderly had been told to vote to approve the plan by trusted confidants under the guise that a yes vote was in fact one saying “yes, we don’t want the plan”. All in all, the owners of the land got their way as is usually the case in these situations and the village will be the worse for it – the access road alone was impassable for 6 hours at the weekend. I see that there is already an application to increase the 25 approved houses on the same plot by another 100+ houses which will make the village practically unreachable from that side. Who approves a site that has a single lane access that already cant flow for the majority of the day? Especially when so many good sites are available around the village that were proposed but bullied out of the way by the developers contacts (hell almost everyone on the plan committee no longer lives in the village and just owned land here).
Such a shame – I know you do your best but I’m now looking to leave Turvey. The money has won out against popular opinion, and it is a slippery slope from here on.
I know that you cant investigate fraudulent behaviour in these referendums but it really was distressing to live through and to now live with the results.

Comment

Representation ID: 9884

Received: 29/07/2022

Respondent: Odell Parish Council

A disappointing aspect of the Local Plan 2040 is its omission of any reference to the importance of its rural areas. The River Great Ouse and the open countryside to the north are highly appreciated by Odell’s residents and indeed the many visitors who use its paths, bridleways, and award-winning Country Park. We feel that whilst the Local Plan 2040 is so closely focused on economic growth an opportunity has been lost to stress the importance of preserving this natural environment. The views from this extensive network, the health benefits of clean air and dark skies and the recreational value of this landscape should feature far more prominently in a Plan for a pleasant, successful, and vibrant Borough, to which we all aspire.

Object

Representation ID: 9933

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

A. Introduction
1. These representations are submitted by Marrons Planning on behalf of Rainier Developments and Strategic Land in response to the Regulation 19 Draft of the Bedford Draft Submission Local Plan 2040 (DSLP2040) prepared by Bedford Borough Council (BBC). There are three main issues with BBC’s approach:
I. BBC have not satisfied the Duty to Cooperate in accordance with s.33A of the Planning and Compulsory Purchase Act 2004, paragraph 24 of the NPPF and paragraph 029 of the Planning Practice Guidance on plan-making. BBC acknowledge within their Duty to Co-operate Position Statement that neighbouring authorities have not yet had sight of their draft policies and strategic allocations, notwithstanding the late stage in the plan-making process. Necessarily, if neighbouring authorities have not seen the detail underpinning the emerging plan, it must follow that they have not meaningfully engaged with it.
II. The DSLP2040 is inflexible by relying on strategic allocations which depend on uncommitted infrastructure. For example, the emerging plan includes allocations for 5,800 homes, which depend on East West Rail (EWR) stage 3, despite the Infrastructure and Projects Authority (IPA) concluding that the project now appears ‘unachievable’ (IPA annual report, 2021-2022). Other strategic allocations depend on schemes to upgrade the Strategic Road Network (SRN), all subject to funding bids and the outcome of Road Investment Strategy 3 (RIS3). In parallel there is a lack of evidence to demonstrate that these strategic sites are developable and viable. This all presents significant risks to the DSLP2040’s delivery. Non-strategic sites in sustainable locations which could otherwise help ensure a deliverable 5-year supply have been rejected without justification.
III. The ‘exceptional circumstances’ to justify a departure from the Local Housing Need (LHN) have not been demonstrated in conflict with NPPF61. Over the first ten years of the plan, BBC proposes a housing requirement 25% below the LHN (1,010dpa vs. LHN of 1,355dpa). Furthermore, the enclosed evidence demonstrates that an uplift in the LHN to 1,744dpa is justified. The critical social and economic consequences of not meeting housing needs from the outset of the plan has not been addressed in the Sustainability Appraisal (SA).
2. These three fundamental failings of the DSLP are now expanded upon below.
B. Duty to Cooperate
3. The legal requirements of the Duty to Cooperate needs to be addressed prior to submission of the plan, as set out in NPPG031 Plan-making: “The local plan examination will first assess whether a local planning authority has complied with the duty to cooperate and other legal requirements… As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with they will recommend that the local plan is not adopted and the examination will not proceed any further…”.
4. At this late stage in the plan-making process (Regulation 19 pre-submission) BBC state that neighbouring authorities have still not had sight of the plan or the strategic site allocations within it (page 5, Duty to Cooperate Position Statements, April 2022). Unresolved issues regarding unmet housing needs, the implications of the Oxford-Cambridge Arc and infrastructure concerns regarding the capacity of transport junctions and congestion are identified throughout BBC’s Duty to Cooperate Position Statements.
5. Whilst BBC sets out that meetings and discussions have taken place, nothing constructive or substantive could have occurred insofar as cooperation and engagement is concerned if these adjoining authorities do not know what is in the plan in terms of its housing requirements, spatial strategy and allocations.
C. Lack of flexibility
Reliance on strategic-scale allocations and new settlements
6. The reliance on strategic-scale sites, including new settlements and extant plan allocations to deliver planned growth is not justified. The DSLP2040 relies on strategic sites comprising 3,175 dwellings finally coming forward on extant allocations (from the 2002 and 2019 plans), two new settlements at Little Barford (4,000 dwellings) and Kempston Hardwick (4,000 dwellings) and other strategic growth on the A421 corridor (4,750 dwellings) – all post 2030.
7. The flaws with this approach are as follows:
• BBC’s own viability evidence demonstrates that the two new settlements at Little Barford (HOU19) and Kempston Hardwick (HOU14) are unviable at the present time (Bedford Local Plan 2040 – Borough Wide Viability Study, BNP Paribas Real Estate, April 2022). The entire strategy is based on speculation that the necessary infrastructure will be in place and that market conditions will have improved to sustain the viability of these schemes.
• It is unclear how strategic infrastructure requirements have been incorporated within the viability appraisal – e.g. Kempston Hardwick New Settlement depends on A421 widening, a £60M scheme where developer funding is to also be sought (refer Infrastructure Delivery Plan (IDP) (AECOM, May 2022)). Similar uncertainty exists for other strategic allocations whereby developer contributions and funding are not identified, limiting the effectiveness of the BBC’s viability evidence.
• Delivering and funding for the strategic infrastructure necessary to unlock the strategic allocations remains uncertain. Table 5.2 of the Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory (AECOM, May 2022), sets out the required infrastructure for each strategic site, for example:
EWR
 Both Kempston Hardwick (HOU14, 4,000 homes) and Little Barford (HOU19, 4,000 homes) – entirely depend on EWR stage 3. EWR is also identified as related to the delivery of East Wixhams (HOU16, 1,800 homes). However, there is no preferred alignment as of yet, no government commitment to its delivery nor confirmed funding. The IPA have recently concluded that both EWR stages 2 & 3 are rated ‘red’ where “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability re-assessed” (IPA Annual Report, 2021-22, page 54). This now calls into question the allocation of these strategic sites, contributing 5,800 homes to BBC’s land supply.
SRN – A428 Black Cat to Caxton Gibbet
 Little Barford is also dependant on this major scheme to the SRN. It is also related to the delivery of River Valley Park (HOU 11, 1,000 dwellings). A decision on the DCO is still pending, as is the government’s funding decision.
SRN – A421 Widening
 This relates to the delivery of 11,930 dwellings comprising allocations HOU3, HOU11, HOU14, HOU16, HOU17 and HOU19. BBC’s IDP identifies that this £60M scheme is dependent on the outcome of RIS3, government funding and developer funding. The outcome of the RIS3 process – whereby BBC will need to make the case for their inclusion in this national investment strategy – is uncertain at this stage, but is clearly fundamental to the delivery of DSLP2040.
 The Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory explains that the identified SRN schemes “must be recognised in the RIS [Government’s national Road Investment Strategy] to be funded and delivered. RIS is therefore key to supporting the LP2040.”
SRN – A421 / A600 Junction
 This is identified a direct requirement to unlock delivery of College Farm (HOU17, for 1,000 dwellings). This £1M scheme is also dependant on RIS3, with a combination of funding from national highways and developer funding (the extent of developer funding remaining unclear with respect to the delivery and viability of HOU17).
SRN – B530 / Manor Road / Kiln Road
 A £5M scheme required to unlock the delivery of Kempston Hardwick new settlement, again dependant on the outcome of RIS3.
SRN – Kempston Hardwick Links
 A £5 scheme dependant on funding and investment decisions by East West Rail, again critical to the delivery of Kempston Hardwick new settlement.
SRN – Little Barford Mitigation
 A £1M scheme not expected to open until 2040, all funded by the developer. It is unclear whether or how this has been factored into the viability assessment for the Little Barford allocation.
• The delivery rates and trajectories for the strategic sites remain unjustified at this stage – for example rates of 300-600dpa projected at Little Barford and Kempston Hardwick, rates of development that are unprecedented in Barford. Furthermore, in terms of the plan’s flexibility and effectiveness, it only takes a delay of one or two years (which could be likely given the various infrastructure requirements and lead-in times) to result in a shortfall in housing delivery to 2040.
• The specific capacities of the strategic allocations and new settlements have not been evidenced – for example, HOU14 Kempston Hardwick and HOU19 Little Barford cannot realistically achieve the delivery of 4,000 homes with respect to other land-use requirements, biodiversity net gain and infrastructure requirements.
• There is no evidence that the extant local plan allocations P11, P12, P13, P14 and P25 are deliverable, given a considerable track record of delay since the adoption of plans in 2002 and 2019. No evidence is included to substantiate their rolling forward and re-allocation in the DSLP2040. As can be seen at Appendix C, these sites were expected to have come forward by 2030 in the 2018 housing trajectory supporting the LP2030 but BBC has now conceded that these are not deliverable within the adopted plan period, and pushed them even further back.
• A sole reliance on strategic sites fails to reflect the invaluable role for a mix of sites in having an important contribution to the housing needs of an area and their ability to be built out relatively quickly under NPPF69, and the need for a variety of land (NPPF60).
Lack of 5-year housing land supply
8. In the early years of the plan and even against BBC’s supressed requirements of 970dpa - 1,070dpa under the stepped approach, BBC’s trajectory shows that demonstrating a 5-year housing land supply plus buffer will not be possible upon adoption of the plan (BBC estimate adoption ‘late 2023’ ).
• At 2022/23 BBC would have a supply of just 4.75 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,915 dwellings).
9. The above position is reliant on windfalls of 148dpa contributing within the 5-year period. If windfalls are removed - given the lack of justification and evidence – BBC’s position worsens.
• At 2022/23 BBC would have a supply of just 4.08 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,223 dwellings, excluding windfalls).
10. BBC’s 5-year land supply is also reliant on extant allocations and sites where ‘clear evidence’ on the deliverability is currently lacking, as set out in Appendix D.
11. Clearly, if the 5-year requirement were to reflect the minimum LHN of 1,355dpa (i.e. no stepped trajectory), or to the uplifted LHN identified in these representations (to 1,733dpa), then the shortfall in deliverable land supply worsens.
Reasonable alternatives to help boost supply
12. The SA rejects the entirely reasonable alternative (a central requirement of NPPG001 – SEA and SA) of delivering homes on non-strategic sites in otherwise sustainable locations. For example, additional growth at Key Service Centres and Rural Service Centres is rejected on the crude assumption that such locations will result in increased car dependency with associated negative consequences in terms of CO2 emissions and air quality. Spatial option 3c was dismissed on this basis and ‘village related growth’ considered the worst component of the strategy (SA paragraphs 7.10, 7.23 and 8.13). However, the Council have not properly assessed the capacity of the KSCs and RSCs to accommodate sustainable growth – there is no assessment of settlement and site options as part of the SA process.
13. It is clear that sustainable, suitable and deliverable sites are available in such locations, as can be seen from the evidence provided at Appendix E (Site 760 Land South of Keeley Lane, Wootton). The evidence shows that such sites are as sustainable as BBC’s preferred allocations and, crucially, are deliverable and can meet pressing local needs.

D. No exceptional circumstances to justify a departure from the LHN
Policy requirements
14. NPPF61 requires that “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” (Emphasis added).
BBC’s approach and exceptional circumstances
15. BBC proposes a stepped trajectory, whereby provision runs at 970dpa for the first 5-years of the plan (2020-2025), 1,050dpa for 2025-2030 and 1,700dpa for 2030-2040. For the first 10 years of the plan period it therefore averages 1,010dpa, 25% lower than the LHN of 1,355dpa, an overall shortfall of 3,450 dwellings 2020-2030.
16. BBC’s justification for this approach is that there will be long lead-in times to bringing forward the strategic-scale allocations and associated nationally significant infrastructure, which is unlikely to be resolved until 2030 at the earliest. It is based on the assumption that the currently unviable new settlements will be viable post-2030 and that there will be greater certainty on the delivery of infrastructure by this point too (e.g. that commitments and funding decisions will have been made regarding EWR and the outcome of whether funding bids to RIS3 were successful will also be known).
17. However, BBC has not demonstrated why these circumstances are exceptional, with no consideration of market signals nor future demographic trends as NPPF61 requires. In fact, evidence undertaken by Marrons Planning, demonstrates that market signals would lead towards an uplift to the LHN, by at least 378dpa - to 1,733dpa, as explained in the Housing Needs Assessment at Appendix A.
18. Furthermore, BBC has embarked on their strategy without testing the implications of a failure to meet the LHN. The SA simply concludes that the stepped trajectory’s implications for housing delivery will be ‘? uncertain’ (SA, Appendix 8, page 113, SA Objective 12). For such a significant issue which goes to the heart of the whole plan and could hinder achievement of sustainability objectives for economic growth (SA objective 5), providing for residents’ needs (SA objective 13) and social cohesion (SA objective 14) as well as people’s quality of life, health and well-being, this lack of evidence and assessment is a significant omission.
19. On the basis of the above it is clear that exceptional circumstances have not been demonstrated, in conflict with NPPF61.
E. Conclusions
20. These representations demonstrate fundamental failings with DSLP2040.
21. In the first instance, the requirements of the Duty to Cooperate cannot be met, and the plan, as drafted, would be unlikely to progress past the first part of the examination process.
22. In terms of matters of soundness:
I. The plan is inflexible, ineffective and in conflict with the government’s ambition to boost the supply of homes (NPPF60), relying on strategic sites and associated infrastructure, the delivery of which is all uncertain.
II. There are no exceptional circumstances to justify a 25% reduction in the LHN over the first 10 years of the plan period.
23. Taking forward the DSLP2040 could have significant economic impacts given Bedford’s location within the Oxford-Cambridge Arc with a failure to address objectively assessed needs also having severe social consequences in the context of a national housing and affordability crisis, as well as the health and well-being of Bedford’s communities.
24. Critically, none of this has been assessed in the DSLP2040’s supporting SA. Reasonable alternative strategies including non-strategic growth to otherwise sustainable locations – including sites which are deliverable, viable and available now to help boost supply and meet local needs - have been rejected.

Comment

Representation ID: 9937

Received: 25/07/2022

Respondent: Bromham Parish Council

The Parish Council considers that the submission version of the Local Plan 2040 is well drafted and, as far as can be determined, is legally compliant and sound.

Object

Representation ID: 10103

Received: 29/07/2022

Respondent: Rainier Developments Limited - Bromham

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

A. Introduction
1. These representations are submitted by Marrons Planning on behalf of Rainier Developments and Strategic Land in response to the Regulation 19 Draft of the Bedford Draft Submission Local Plan 2040 (DSLP2040) prepared by Bedford Borough Council (BBC). There are three main issues with BBC’s approach:
I. BBC have not satisfied the Duty to Cooperate in accordance with s.33A of the Planning and Compulsory Purchase Act 2004, paragraph 24 of the NPPF and paragraph 029 of the Planning Practice Guidance on plan-making. BBC acknowledge within their Duty to Co-operate Position Statement that neighbouring authorities have not yet had sight of their draft policies and strategic allocations, notwithstanding the late stage in the plan-making process. Necessarily, if neighbouring authorities have not seen the detail underpinning the emerging plan, it must follow that they have not meaningfully engaged with it.
II. The DSLP2040 is inflexible by relying on strategic allocations which depend on uncommitted infrastructure. For example, the emerging plan includes allocations for 5,800 homes, which depend on East West Rail (EWR) stage 3, despite the Infrastructure and Projects Authority (IPA) concluding that the project now appears ‘unachievable’ (IPA annual report, 2021-2022). Other strategic allocations depend on schemes to upgrade the Strategic Road Network (SRN), all subject to funding bids and the outcome of Road Investment Strategy 3 (RIS3). In parallel there is a lack of evidence to demonstrate that these strategic sites are developable and viable. This all presents significant risks to the DSLP2040’s delivery. Non-strategic sites in sustainable locations which could otherwise help ensure a deliverable 5-year supply have been rejected without justification.
III. The ‘exceptional circumstances’ to justify a departure from the Local Housing Need (LHN) have not been demonstrated in conflict with NPPF61. Over the first ten years of the plan, BBC proposes a housing requirement 25% below the LHN (1,010dpa vs. LHN of 1,355dpa). Furthermore, the enclosed evidence demonstrates that an uplift in the LHN to 1,744dpa is justified. The critical social and economic consequences of not meeting housing needs from the outset of the plan has not been addressed in the Sustainability Appraisal (SA).
2. These three fundamental failings of the DSLP are now expanded upon below.
B. Duty to Cooperate
3. The legal requirements of the Duty to Cooperate needs to be addressed prior to submission of the plan, as set out in NPPG031 Plan-making: “The local plan examination will first assess whether a local planning authority has complied with the duty to cooperate and other legal requirements… As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with they will recommend that the local plan is not adopted and the examination will not proceed any further…”.
4. At this late stage in the plan-making process (Regulation 19 pre-submission) BBC state that neighbouring authorities have still not had sight of the plan or the strategic site allocations within it (page 5, Duty to Cooperate Position Statements, April 2022). Unresolved issues regarding unmet housing needs, the implications of the Oxford-Cambridge Arc and infrastructure concerns regarding the capacity of transport junctions and congestion are identified throughout BBC’s Duty to Cooperate Position Statements.
5. Whilst BBC sets out that meetings and discussions have taken place, nothing constructive or substantive could have occurred insofar as cooperation and engagement is concerned if these adjoining authorities do not know what is in the plan in terms of its housing requirements, spatial strategy and allocations.
C. Lack of flexibility
Reliance on strategic-scale allocations and new settlements
6. The reliance on strategic-scale sites, including new settlements and extant plan allocations to deliver planned growth is not justified. The DSLP2040 relies on strategic sites comprising 3,175 dwellings finally coming forward on extant allocations (from the 2002 and 2019 plans), two new settlements at Little Barford (4,000 dwellings) and Kempston Hardwick (4,000 dwellings) and other strategic growth on the A421 corridor (4,750 dwellings) – all post 2030.
7. The flaws with this approach are as follows:
• BBC’s own viability evidence demonstrates that the two new settlements at Little Barford (HOU19) and Kempston Hardwick (HOU14) are unviable at the present time (Bedford Local Plan 2040 – Borough Wide Viability Study, BNP Paribas Real Estate, April 2022). The entire strategy is based on speculation that the necessary infrastructure will be in place and that market conditions will have improved to sustain the viability of these schemes.
• It is unclear how strategic infrastructure requirements have been incorporated within the viability appraisal – e.g. Kempston Hardwick New Settlement depends on A421 widening, a £60M scheme where developer funding is to also be sought (refer Infrastructure Delivery Plan (IDP) (AECOM, May 2022)). Similar uncertainty exists for other strategic allocations whereby developer contributions and funding are not identified, limiting the effectiveness of the BBC’s viability evidence.
• Delivering and funding for the strategic infrastructure necessary to unlock the strategic allocations remains uncertain. Table 5.2 of the Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory (AECOM, May 2022), sets out the required infrastructure for each strategic site, for example:
EWR
 Both Kempston Hardwick (HOU14, 4,000 homes) and Little Barford (HOU19, 4,000 homes) – entirely depend on EWR stage 3. EWR is also identified as related to the delivery of East Wixhams (HOU16, 1,800 homes). However, there is no preferred alignment as of yet, no government commitment to its delivery nor confirmed funding. The IPA have recently concluded that both EWR stages 2 & 3 are rated ‘red’ where “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability re-assessed” (IPA Annual Report, 2021-22, page 54). This now calls into question the allocation of these strategic sites, contributing 5,800 homes to BBC’s land supply.
SRN – A428 Black Cat to Caxton Gibbet
 Little Barford is also dependant on this major scheme to the SRN. It is also related to the delivery of River Valley Park (HOU 11, 1,000 dwellings). A decision on the DCO is still pending, as is the government’s funding decision.
SRN – A421 Widening
 This relates to the delivery of 11,930 dwellings comprising allocations HOU3, HOU11, HOU14, HOU16, HOU17 and HOU19. BBC’s IDP identifies that this £60M scheme is dependent on the outcome of RIS3, government funding and developer funding. The outcome of the RIS3 process – whereby BBC will need to make the case for their inclusion in this national investment strategy – is uncertain at this stage, but is clearly fundamental to the delivery of DSLP2040.
 The Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory explains that the identified SRN schemes “must be recognised in the RIS [Government’s national Road Investment Strategy] to be funded and delivered. RIS is therefore key to supporting the LP2040.”
SRN – A421 / A600 Junction
 This is identified a direct requirement to unlock delivery of College Farm (HOU17, for 1,000 dwellings). This £1M scheme is also dependant on RIS3, with a combination of funding from national highways and developer funding (the extent of developer funding remaining unclear with respect to the delivery and viability of HOU17).
SRN – B530 / Manor Road / Kiln Road
 A £5M scheme required to unlock the delivery of Kempston Hardwick new settlement, again dependant on the outcome of RIS3.
SRN – Kempston Hardwick Links
 A £5 scheme dependant on funding and investment decisions by East West Rail, again critical to the delivery of Kempston Hardwick new settlement.
SRN – Little Barford Mitigation
 A £1M scheme not expected to open until 2040, all funded by the developer. It is unclear whether or how this has been factored into the viability assessment for the Little Barford allocation.
• The delivery rates and trajectories for the strategic sites remain unjustified at this stage – for example rates of 300-600dpa projected at Little Barford and Kempston Hardwick, rates of development that are unprecedented in Barford. Furthermore, in terms of the plan’s flexibility and effectiveness, it only takes a delay of one or two years (which could be likely given the various infrastructure requirements and lead-in times) to result in a shortfall in housing delivery to 2040.
• The specific capacities of the strategic allocations and new settlements have not been evidenced – for example, HOU14 Kempston Hardwick and HOU19 Little Barford cannot realistically achieve the delivery of 4,000 homes with respect to other land-use requirements, biodiversity net gain and infrastructure requirements.
• There is no evidence that the extant local plan allocations P11, P12, P13, P14 and P25 are deliverable, given a considerable track record of delay since the adoption of plans in 2002 and 2019. No evidence is included to substantiate their rolling forward and re-allocation in the DSLP2040. As can be seen at Appendix C, these sites were expected to have come forward by 2030 in the 2018 housing trajectory supporting the LP2030 but BBC has now conceded that these are not deliverable within the adopted plan period, and pushed them even further back.
• A sole reliance on strategic sites fails to reflect the invaluable role for a mix of sites in having an important contribution to the housing needs of an area and their ability to be built out relatively quickly under NPPF69, and the need for a variety of land (NPPF60).
Lack of 5-year housing land supply
8. In the early years of the plan and even against BBC’s supressed requirements of 970dpa - 1,070dpa under the stepped approach, BBC’s trajectory shows that demonstrating a 5-year housing land supply plus buffer will not be possible upon adoption of the plan (BBC estimate adoption ‘late 2023’ ).
• At 2022/23 BBC would have a supply of just 4.75 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,915 dwellings).
9. The above position is reliant on windfalls of 148dpa contributing within the 5-year period. If windfalls are removed - given the lack of justification and evidence – BBC’s position worsens.
• At 2022/23 BBC would have a supply of just 4.08 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,223 dwellings, excluding windfalls).
10. BBC’s 5-year land supply is also reliant on extant allocations and sites where ‘clear evidence’ on the deliverability is currently lacking, as set out in Appendix D.
11. Clearly, if the 5-year requirement were to reflect the minimum LHN of 1,355dpa (i.e. no stepped trajectory), or to the uplifted LHN identified in these representations (to 1,733dpa), then the shortfall in deliverable land supply worsens.
Reasonable alternatives to help boost supply
12. The SA rejects the entirely reasonable alternative (a central requirement of NPPG001 – SEA and SA) of delivering homes on non-strategic sites in otherwise sustainable locations. For example, additional growth at Key Service Centres and Rural Service Centres is rejected on the crude assumption that such locations will result in increased car dependency with associated negative consequences in terms of CO2 emissions and air quality. Spatial option 3c was dismissed on this basis and ‘village related growth’ considered the worst component of the strategy (SA paragraphs 7.10, 7.23 and 8.13). However, the Council have not properly assessed the capacity of the KSCs and RSCs to accommodate sustainable growth – there is no assessment of settlement and site options as part of the SA process.
13. It is clear that sustainable, suitable and deliverable sites are available in such locations, as can be seen from the evidence provided at Appendix E (Site 757 Land South of Northampton Road, Bromham). The evidence shows that such sites are as sustainable as BBC’s preferred allocations and, crucially, are deliverable and can meet pressing local needs.
D. No exceptional circumstances to justify a departure from the LHN
Policy requirements
14. NPPF61 requires that “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” (Emphasis added).
BBC’s approach and exceptional circumstances
15. BBC proposes a stepped trajectory, whereby provision runs at 970dpa for the first 5-years of the plan (2020-2025), 1,050dpa for 2025-2030 and 1,700dpa for 2030-2040. For the first 10 years of the plan period it therefore averages 1,010dpa, 25% lower than the LHN of 1,355dpa, an overall shortfall of 3,450 dwellings 2020-2030.
16. BBC’s justification for this approach is that there will be long lead-in times to bringing forward the strategic-scale allocations and associated nationally significant infrastructure, which is unlikely to be resolved until 2030 at the earliest. It is based on the assumption that the currently unviable new settlements will be viable post-2030 and that there will be greater certainty on the delivery of infrastructure by this point too (e.g. that commitments and funding decisions will have been made regarding EWR and the outcome of whether funding bids to RIS3 were successful will also be known).
17. However, BBC has not demonstrated why these circumstances are exceptional, with no consideration of market signals nor future demographic trends as NPPF61 requires. In fact, evidence undertaken by Marrons Planning, demonstrates that market signals would lead towards an uplift to the LHN, by at least 378dpa - to 1,733dpa, as explained in the Housing Needs Assessment at Appendix A.
18. Furthermore, BBC has embarked on their strategy without testing the implications of a failure to meet the LHN. The SA simply concludes that the stepped trajectory’s implications for housing delivery will be ‘? uncertain’ (SA, Appendix 8, page 113, SA Objective 12). For such a significant issue which goes to the heart of the whole plan and could hinder achievement of sustainability objectives for economic growth (SA objective 5), providing for residents’ needs (SA objective 13) and social cohesion (SA objective 14) as well as people’s quality of life, health and well-being, this lack of evidence and assessment is a significant omission.
19. On the basis of the above it is clear that exceptional circumstances have not been demonstrated, in conflict with NPPF61.
E. Conclusions
20. These representations demonstrate fundamental failings with DSLP2040.
21. In the first instance, the requirements of the Duty to Cooperate cannot be met, and the plan, as drafted, would be unlikely to progress past the first part of the examination process.
22. In terms of matters of soundness:
I. The plan is inflexible, ineffective and in conflict with the government’s ambition to boost the supply of homes (NPPF60), relying on strategic sites and associated infrastructure, the delivery of which is all uncertain.
II. There are no exceptional circumstances to justify a 25% reduction in the LHN over the first 10 years of the plan period.
23. Taking forward the DSLP2040 could have significant economic impacts given Bedford’s location within the Oxford-Cambridge Arc with a failure to address objectively assessed needs also having severe social consequences in the context of a national housing and affordability crisis, as well as the health and well-being of Bedford’s communities.
24. Critically, none of this has been assessed in the DSLP2040’s supporting SA. Reasonable alternative strategies including non-strategic growth to otherwise sustainable locations – including sites which are deliverable, viable and available now to help boost supply and meet local needs - have been rejected.

Object

Representation ID: 10113

Received: 29/07/2022

Respondent: Rainier Developments Limited - Roxton

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

A. Introduction
1. These representations are submitted by Marrons Planning on behalf of Rainier Developments and Strategic Land in response to the Regulation 19 Draft of the Bedford Draft Submission Local Plan 2040 (DSLP2040) prepared by Bedford Borough Council (BBC). There are three main issues with BBC’s approach:
I. BBC have not satisfied the Duty to Cooperate in accordance with s.33A of the Planning and Compulsory Purchase Act 2004, paragraph 24 of the NPPF and paragraph 029 of the Planning Practice Guidance on plan-making. BBC acknowledge within their Duty to Co-operate Position Statement that neighbouring authorities have not yet had sight of their draft policies and strategic allocations, notwithstanding the late stage in the plan-making process. Necessarily, if neighbouring authorities have not seen the detail underpinning the emerging plan, it must follow that they have not meaningfully engaged with it.
II. The DSLP2040 is inflexible by relying on strategic allocations which depend on uncommitted infrastructure. For example, the emerging plan includes allocations for 5,800 homes, which depend on East West Rail (EWR) stage 3, despite the Infrastructure and Projects Authority (IPA) concluding that the project now appears ‘unachievable’ (IPA annual report, 2021-2022). Other strategic allocations depend on schemes to upgrade the Strategic Road Network (SRN), all subject to funding bids and the outcome of Road Investment Strategy 3 (RIS3). In parallel there is a lack of evidence to demonstrate that these strategic sites are developable and viable. This all presents significant risks to the DSLP2040’s delivery. Non-strategic sites in sustainable locations which could otherwise help ensure a deliverable 5-year supply have been rejected without justification.
III. The ‘exceptional circumstances’ to justify a departure from the Local Housing Need (LHN) have not been demonstrated in conflict with NPPF61. Over the first ten years of the plan, BBC proposes a housing requirement 25% below the LHN (1,010dpa vs. LHN of 1,355dpa). Furthermore, the enclosed evidence demonstrates that an uplift in the LHN to 1,744dpa is justified. The critical social and economic consequences of not meeting housing needs from the outset of the plan has not been addressed in the Sustainability Appraisal (SA).
2. These three fundamental failings of the DSLP are now expanded upon below.
B. Duty to Cooperate
3. The legal requirements of the Duty to Cooperate needs to be addressed prior to submission of the plan, as set out in NPPG031 Plan-making: “The local plan examination will first assess whether a local planning authority has complied with the duty to cooperate and other legal requirements… As the duty to cooperate relates to the preparation of the plan it cannot be rectified post-submission, so if the Inspector finds that the duty has not been complied with they will recommend that the local plan is not adopted and the examination will not proceed any further…”.
4. At this late stage in the plan-making process (Regulation 19 pre-submission) BBC state that neighbouring authorities have still not had sight of the plan or the strategic site allocations within it (page 5, Duty to Cooperate Position Statements, April 2022). Unresolved issues regarding unmet housing needs, the implications of the Oxford-Cambridge Arc and infrastructure concerns regarding the capacity of transport junctions and congestion are identified throughout BBC’s Duty to Cooperate Position Statements.
5. Whilst BBC sets out that meetings and discussions have taken place, nothing constructive or substantive could have occurred insofar as cooperation and engagement is concerned if these adjoining authorities do not know what is in the plan in terms of its housing requirements, spatial strategy and allocations.
C. Lack of flexibility
Reliance on strategic-scale allocations and new settlements
6. The reliance on strategic-scale sites, including new settlements and extant plan allocations to deliver planned growth is not justified. The DSLP2040 relies on strategic sites comprising 3,175 dwellings finally coming forward on extant allocations (from the 2002 and 2019 plans), two new settlements at Little Barford (4,000 dwellings) and Kempston Hardwick (4,000 dwellings) and other strategic growth on the A421 corridor (4,750 dwellings) – all post 2030.
7. The flaws with this approach are as follows:
• BBC’s own viability evidence demonstrates that the two new settlements at Little Barford (HOU19) and Kempston Hardwick (HOU14) are unviable at the present time (Bedford Local Plan 2040 – Borough Wide Viability Study, BNP Paribas Real Estate, April 2022). The entire strategy is based on speculation that the necessary infrastructure will be in place and that market conditions will have improved to sustain the viability of these schemes.
• It is unclear how strategic infrastructure requirements have been incorporated within the viability appraisal – e.g. Kempston Hardwick New Settlement depends on A421 widening, a £60M scheme where developer funding is to also be sought (refer Infrastructure Delivery Plan (IDP) (AECOM, May 2022)). Similar uncertainty exists for other strategic allocations whereby developer contributions and funding are not identified, limiting the effectiveness of the BBC’s viability evidence.
• Delivering and funding for the strategic infrastructure necessary to unlock the strategic allocations remains uncertain. Table 5.2 of the Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory (AECOM, May 2022), sets out the required infrastructure for each strategic site, for example:
EWR
 Both Kempston Hardwick (HOU14, 4,000 homes) and Little Barford (HOU19, 4,000 homes) – entirely depend on EWR stage 3. EWR is also identified as related to the delivery of East Wixhams (HOU16, 1,800 homes). However, there is no preferred alignment as of yet, no government commitment to its delivery nor confirmed funding. The IPA have recently concluded that both EWR stages 2 & 3 are rated ‘red’ where “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability re-assessed” (IPA Annual Report, 2021-22, page 54). This now calls into question the allocation of these strategic sites, contributing 5,800 homes to BBC’s land supply.
SRN – A428 Black Cat to Caxton Gibbet
 Little Barford is also dependant on this major scheme to the SRN. It is also related to the delivery of River Valley Park (HOU 11, 1,000 dwellings). A decision on the DCO is still pending, as is the government’s funding decision.
SRN – A421 Widening
 This relates to the delivery of 11,930 dwellings comprising allocations HOU3, HOU11, HOU14, HOU16, HOU17 and HOU19. BBC’s IDP identifies that this £60M scheme is dependent on the outcome of RIS3, government funding and developer funding. The outcome of the RIS3 process – whereby BBC will need to make the case for their inclusion in this national investment strategy – is uncertain at this stage, but is clearly fundamental to the delivery of DSLP2040.
 The Bedford Infrastructure Delivery Plan - The Need for a Stepped Trajectory explains that the identified SRN schemes “must be recognised in the RIS [Government’s national Road Investment Strategy] to be funded and delivered. RIS is therefore key to supporting the LP2040.”
SRN – A421 / A600 Junction
 This is identified a direct requirement to unlock delivery of College Farm (HOU17, for 1,000 dwellings). This £1M scheme is also dependant on RIS3, with a combination of funding from national highways and developer funding (the extent of developer funding remaining unclear with respect to the delivery and viability of HOU17).
SRN – B530 / Manor Road / Kiln Road
 A £5M scheme required to unlock the delivery of Kempston Hardwick new settlement, again dependant on the outcome of RIS3.
SRN – Kempston Hardwick Links
 A £5 scheme dependant on funding and investment decisions by East West Rail, again critical to the delivery of Kempston Hardwick new settlement.
SRN – Little Barford Mitigation
 A £1M scheme not expected to open until 2040, all funded by the developer. It is unclear whether or how this has been factored into the viability assessment for the Little Barford allocation.
• The delivery rates and trajectories for the strategic sites remain unjustified at this stage – for example rates of 300-600dpa projected at Little Barford and Kempston Hardwick, rates of development that are unprecedented in Barford. Furthermore, in terms of the plan’s flexibility and effectiveness, it only takes a delay of one or two years (which could be likely given the various infrastructure requirements and lead-in times) to result in a shortfall in housing delivery to 2040.
• The specific capacities of the strategic allocations and new settlements have not been evidenced – for example, HOU14 Kempston Hardwick and HOU19 Little Barford cannot realistically achieve the delivery of 4,000 homes with respect to other land-use requirements, biodiversity net gain and infrastructure requirements.
• There is no evidence that the extant local plan allocations P11, P12, P13, P14 and P25 are deliverable, given a considerable track record of delay since the adoption of plans in 2002 and 2019. No evidence is included to substantiate their rolling forward and re-allocation in the DSLP2040. As can be seen at Appendix C, these sites were expected to have come forward by 2030 in the 2018 housing trajectory supporting the LP2030 but BBC has now conceded that these are not deliverable within the adopted plan period, and pushed them even further back.
• A sole reliance on strategic sites fails to reflect the invaluable role for a mix of sites in having an important contribution to the housing needs of an area and their ability to be built out relatively quickly under NPPF69, and the need for a variety of land (NPPF60).
Lack of 5-year housing land supply
8. In the early years of the plan and even against BBC’s supressed requirements of 970dpa - 1,070dpa under the stepped approach, BBC’s trajectory shows that demonstrating a 5-year housing land supply plus buffer will not be possible upon adoption of the plan (BBC estimate adoption ‘late 2023’ ).
• At 2022/23 BBC would have a supply of just 4.75 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,915 dwellings).
9. The above position is reliant on windfalls of 148dpa contributing within the 5-year period. If windfalls are removed - given the lack of justification and evidence – BBC’s position worsens.
• At 2022/23 BBC would have a supply of just 4.08 years supply (a 5-year requirement of 5,177 dwellings (1,035dpa), including 5% buffer, against a supply of 4,223 dwellings, excluding windfalls).
10. BBC’s 5-year land supply is also reliant on extant allocations and sites where ‘clear evidence’ on the deliverability is currently lacking, as set out in Appendix D.
11. Clearly, if the 5-year requirement were to reflect the minimum LHN of 1,355dpa (i.e. no stepped trajectory), or to the uplifted LHN identified in these representations (to 1,733dpa), then the shortfall in deliverable land supply worsens.
Reasonable alternatives to help boost supply
12. The SA rejects the entirely reasonable alternative (a central requirement of NPPG001 – SEA and SA) of delivering homes on non-strategic sites in otherwise sustainable locations. For example, additional growth at Key Service Centres and Rural Service Centres is rejected on the crude assumption that such locations will result in increased car dependency with associated negative consequences in terms of CO2 emissions and air quality. Spatial option 3c was dismissed on this basis and ‘village related growth’ considered the worst component of the strategy (SA paragraphs 7.10, 7.23 and 8.13). However, the Council have not properly assessed the capacity of the KSCs and RSCs to accommodate sustainable growth – there is no assessment of settlement and site options as part of the SA process.
13. It is clear that sustainable, suitable and deliverable sites are available in such locations, as can be seen from the evidence provided at Appendix E (Site 776 Land off Bedford Road, Roxton). The evidence shows that such sites are as sustainable as BBC’s preferred allocations and, crucially, are deliverable and can meet pressing local needs.

D. No exceptional circumstances to justify a departure from the LHN
Policy requirements
14. NPPF61 requires that “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” (Emphasis added).
BBC’s approach and exceptional circumstances
15. BBC proposes a stepped trajectory, whereby provision runs at 970dpa for the first 5-years of the plan (2020-2025), 1,050dpa for 2025-2030 and 1,700dpa for 2030-2040. For the first 10 years of the plan period it therefore averages 1,010dpa, 25% lower than the LHN of 1,355dpa, an overall shortfall of 3,450 dwellings 2020-2030.
16. BBC’s justification for this approach is that there will be long lead-in times to bringing forward the strategic-scale allocations and associated nationally significant infrastructure, which is unlikely to be resolved until 2030 at the earliest. It is based on the assumption that the currently unviable new settlements will be viable post-2030 and that there will be greater certainty on the delivery of infrastructure by this point too (e.g. that commitments and funding decisions will have been made regarding EWR and the outcome of whether funding bids to RIS3 were successful will also be known).
17. However, BBC has not demonstrated why these circumstances are exceptional, with no consideration of market signals nor future demographic trends as NPPF61 requires. In fact, evidence undertaken by Marrons Planning, demonstrates that market signals would lead towards an uplift to the LHN, by at least 378dpa - to 1,733dpa, as explained in the Housing Needs Assessment at Appendix A.
18. Furthermore, BBC has embarked on their strategy without testing the implications of a failure to meet the LHN. The SA simply concludes that the stepped trajectory’s implications for housing delivery will be ‘? uncertain’ (SA, Appendix 8, page 113, SA Objective 12). For such a significant issue which goes to the heart of the whole plan and could hinder achievement of sustainability objectives for economic growth (SA objective 5), providing for residents’ needs (SA objective 13) and social cohesion (SA objective 14) as well as people’s quality of life, health and well-being, this lack of evidence and assessment is a significant omission.
19. On the basis of the above it is clear that exceptional circumstances have not been demonstrated, in conflict with NPPF61.
E. Conclusions
20. These representations demonstrate fundamental failings with DSLP2040.
21. In the first instance, the requirements of the Duty to Cooperate cannot be met, and the plan, as drafted, would be unlikely to progress past the first part of the examination process.
22. In terms of matters of soundness:
I. The plan is inflexible, ineffective and in conflict with the government’s ambition to boost the supply of homes (NPPF60), relying on strategic sites and associated infrastructure, the delivery of which is all uncertain.
II. There are no exceptional circumstances to justify a 25% reduction in the LHN over the first 10 years of the plan period.
23. Taking forward the DSLP2040 could have significant economic impacts given Bedford’s location within the Oxford-Cambridge Arc with a failure to address objectively assessed needs also having severe social consequences in the context of a national housing and affordability crisis, as well as the health and well-being of Bedford’s communities.
24. Critically, none of this has been assessed in the DSLP2040’s supporting SA. Reasonable alternative strategies including non-strategic growth to otherwise sustainable locations – including sites which are deliverable, viable and available now to help boost supply and meet local needs - have been rejected.

Comment

Representation ID: 10174

Received: 29/07/2022

Respondent: Jeremy Clayson

Planning continues in a state of turmoil, nationally and locally. We have moved from a National Plan to Local Plans where they set out how much growth there is to be in the Borough (i.e housing , jobs and social infrastructure up to 2030 and this has now been replaced by Local Plan 2040 and specific current Neighbourhood Plans. The Local Plan has needed to be updated quickly and the draft plan is currently out for consultation until 29 July 2022. Parishes have to respond to the consultation including East /West rail proposals (preferred route of Oxford to Cambridge rail line north of the town) and not to support the allocation of a new town in Borough North.
Bedford does retail a superb river valet and facilities, Harpur Trust Schools and the 1166 Charter including its 43 rural parishes.
Soundness is my only query and with respect to planning and development proposals.

Comment

Representation ID: 10249

Received: 29/07/2022

Respondent: Central Bedfordshire Council

1. General Comments
1.1 CBC recognises that following the adoption of the current Bedford Local Plan in 2020, the review was commenced in line with adopted Policy 1, and that whilst the plan period is rolling forward by 10 years, this is a partial review of the plan, undertaken to ensure the Policies remain up to date and to take account of changing government guidance.
1.2 We therefore note that the review and this consultation focuses on the following key policy areas:
• Vision and objectives
• Climate Change
• Spatial strategy to 2040 and site allocations
• Town centre and retail policies
• New and updated Development Management policies

1.3 Whilst CBC recognises the context within which the plan review commenced, we are mindful that there are numerous references to the Oxford to Cambridge Arc and the previously planned Arc Spatial Framework. Government have more recently indicated that the Arc will not be being taken forward as envisaged with a government-led strategy, but rather that any future growth within the geographical area of the Arc should be ‘locally-led’. We do recognise the many benefits of emulating the Arc Principles that many local authorities, including Bedford, have previously signed-up to, particularly in relation to climate change, economic growth and the natural environment, however, it is considered that the plan would benefit from reflecting the lesser role and influence that the Arc will now have on local planning.
1.4 With regard to transport matters, our comments are set out in detail below. However, both Central Bedfordshire and Bedford, alongside other stakeholders, including National Highways, are involved in ongoing meetings in relation to both M1 Junction 13 and the A1/A428 Junction and wider A1 Corridor. These meetings were initiated as all parties involved recognise and acknowledge that there are issues and opportunities at these two locations that can only be resolved through collaborative working and the joint consideration of existing growth proposals and future opportunities. Discussions are at the early stages and whilst solutions are yet to be identified, CBC hopes that these wider discussions will continue, and that progress can be made towards a resolution that meets the needs and aspirations of all.
1.5 It is also noteworthy, that whilst CBC are not looking to Bedford Council to meet any of Central Bedfordshire’s housing or employment growth at this time, that this is in the absence of any future discussions with other authorities about any potential unmet housing and economic needs.

Support

Representation ID: 10276

Received: 29/07/2022

Respondent: Ms Alison Field-Foster

I am sending this as my individual response to the Local Plan consultation.

I believe that the submission version of the Local Plan 2040 is well drafted and, although cannot comment on whether it is legally compliant and sound.

I do support the strategy whereby the initial focus for growth is in the urban area, which I consider to be the most sustainable location for growth. I am pleased that it also includes
two new settlements, one at Kempston Hardwick, and one at Little Barford. I believe these new settlements will create new sustainable communities along the A421 transport corridor which offers good and accessible growth opportunities. Growth along this corridor should be encouraged.

I am pleased that the focus of the Local Plan is on ensuring that new development is supported by new infrastructure, including green infrastructure and also to see that development will help to bring forward the new water sports lake at Bedford River Valley Park to the east of Bedford at Willington along with other development at this important site.

The draft Plan also recognises the challenge that town centres face and importantly includes policies that would permit more residential properties in the town centre to help support existing and new town centre businesses and reduce the use of motor vehicles in the town centre and, that policies provide for an enhancement of the cultural offer.

I believe it is important the Plan also focuses on encouraging high-skilled employment opportunities alongside housing development, with up to 26,700 jobs planned at several sites across the borough. These employment sites are being allocated where they have good connectivity, including by rail, along the A421 corridor and the A1 close to the Black Cat Roundabout.

I am pleased the draft plan outlines the distribution of growth by location and takes into account existing commitments. This factors in the growth envisaged by adopted neighbourhood plans in rural areas, and it recognises that some Parish Councils with existing neighbourhood plans may choose to allocate further sites for development in their neighbourhood plans to meet particular local needs in the future.

I am concerned that the Government Guidance on the Standard Method for assessing housing need and calculating the housing target upon which the plan is based puts Bedford Borough in a difficult position whereby we are obliged to builds more houses than the Borough actually needs. The government’s insistence that local planning authorities calculate housing targets through a formula that uses out of date data from the Office for National Statistics has a huge impact on the calculation of housing need for Bedford Borough and results in a massively inflated and unjustified target for future housing growth in this draft plan.

I do support the draft Local Plan although I should point out that this does not mean that I support the proposed route for East West Rail, which I do not.

I would like to thank you and your team for all the hard work you have put in to preparing this document.

Comment

Representation ID: 10316

Received: 29/07/2022

Respondent: Elstow Parish Council

Parish Council Approach to the Consultation
Elstow Parish Council is experienced in understanding the due process relating to public consultations and is therefore mindful of the importance of presenting clear and robust evidence at all stages, but in particular at this part of the consultation process, to ensure that Elstow Parish Council makes clear its view as the first tier of local government. The Parish Council, has a further role as always, serving its electorate and ensuring they are supported throughout this phase, so considerable work has been done ensuring they are not only aware of the proposals and their direct impact on Elstow, but also in engaging effectively in the consultation process.
The Parish Council also feels at this stage in light of the Local Plan shortly being taken forwards to government inspection, that with such significant development earmarked for both employment and housing in the parish of Elstow within this strategy document, that it is important to reiterate items that have previously been expressed in earlier consultations relating to the Local Plan through to 2040.
Elstow Parish Council, as usual, has been extremely pro-active in attending BBC led consultation events directed at local parishes, as well as the various public engagement activities within the consultation run by BBC. There has been a thorough review of the consultation documents, throughout the consultation period, as Parish Councillors have strived to understand more about the many different technical and complex items being considered.
This is in addition to a huge number of important accompanying planning policy documents which will shape the future of Elstow and communities across the Borough.
The Parish Council has facilitated a number of different ways to encourage Elstow residents to engage with this consultation process, whether directly to BBC representatives or through feedback to Elstow Parish Councillors. Throughout this consultation it has remained an absolute priority that all in Elstow are aware of the enormity of the proposals, and that they can have their say and their voice heard. This has included using a website publications, social media posts, information in local shops, in addition to multiple leaflet communications made to the village population through along with residents being welcomed to the June and July Parish Council meetings. The Parish Council also arranged a specific drop-in session on Tuesday 26th
July at Elstow Playing Field Hall to enable residents who had questions understanding and/or required assistance with engaging to the consultation. The Parish Council knows the proposed allocations within this consultation are of interest to residents as the drop in session was so well attended.
It is also important to recognise that Parish Councillors are lay persons, volunteering their time, trying their best to review, consider and digest all the information relating to many different technical aspects of this Local Plan process. In addition, the volume of associated policy documents being consulted on, which again are also complex, however, are fundamentally crucial in the important role they play in the wider context of the development strategy.
As a result, it was important to Elstow Parish Council that they focus on the impact the proposed allocations have on Elstow and the surrounding areas - the area known best to Councillors.

Object

Representation ID: 10354

Received: 29/07/2022

Respondent: Leon Staszak

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Firstly the council has failed to represent the best interests of the borough’s residents by not providing them with a meaningful way to find out the plans for their community. No open sessions have been held, not forums for Q&A or legitimate discussion. The council have simply pushed out a set of static published information and expect residents to digest, understand and recognise the aspects which they agree/disagree on. This is not democratic and seems deliberate.

Comment

Representation ID: 10368

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

Introduction: Context, local and national
Bedford is one of the fastest growing authorities in the UK and delivers its housing need. It is vital that current and future residents benefit from new developments and therefore must have the infrastructure in place to serve their needs.
Claims that local government stops development are false. But it is true that the planning system, set out by the Government, benefits large developers at the expense of infrastructure, health, education and sustainable transport and, fundamentally, local residents.
Due to the way the Standard Method is calculated across the country as a whole, Bedford Borough’s housing target is higher than would be needed if other authorities met their housing need. Because the Borough has met its need, we are unfairly getting a higher target. The local authority should make this position clear to the Conservative Government and residents.
Overall, the Local Plan 2040 must fight for sustainable housing, active travel, access to healthcare, insultation and energy efficiency in the face of the Conservative Government’s cost of living crisis, and local energy generation wherever possible.