1.5

Support

Representation ID: 9187

Received: 25/07/2022

Respondent: Mr Tom Tagg

2020-2040 is an appropriate period, but given the key outstanding strategic issues, 5 yearly reviews will be needed.

Object

Representation ID: 9586

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Plan Period
2.19 Turning to the matter of Plan length, Mr XX contends that the Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change.
2.20 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for.
2.21 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas.
The next review of the Local Plan would then not need to extend the Plan Period, but instead revise housing and employment growth to reflect the latest position as relevant at that time.

Object

Representation ID: 9639

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Turning to the matter of Plan length, AWG consider that the Plan Period should run to
2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a
sufficiently long enough extension to effect real change.
2.32 As the Council will be aware, strategic growth and development, along with wide scale
change, takes many years to deliver. Sites take a long time to plan correctly and then
commence delivery, and thus a longer Plan Period should be allowed for.
2.33 Furthermore, by extending to 2050, this would bring the Plan in line with others in the
Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and
important role that Bedford Borough plays within the Arc, it would represent ‘good
planning’ and a holistic approach to align the Local Plan Period with those other areas.
The next review of the Local Plan would then not need to extend the Plan Period, but
instead revise housing and employment growth to reflect the latest position as relevant
at that time

Object

Representation ID: 10317

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SECTION 1: FUNDAMENTAL UNSOUNDNESS OF THE PLAN
The Parish Council having reviewed the Local Plan and associated planning policy feel the document is unfit for purpose and unsound as it is does not meet current National Planning Policy requirements.
The document is unsound as it fails to meet the fundamental requirement of achieving sustainable development, as set out in Section 2 of the NPPF 2021. The areas in particular which are not met, are the overarching objectives, “which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):
a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.
9. These objectives should be delivered through the preparation and implementation of plans and the application of the policies in this Framework; they are not criteria against which every decision can or should be judged. Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.
10. So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).
11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt
to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within
neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
Furthermore, para 16 of the NPPF expects that:
“Plans should:
a) be prepared with the objective of contributing to the achievement of sustainable development
b) be prepared positively, in a way that is aspirational but deliverable;
c) be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e) be accessible through the use of digital tools to assist public involvement and policy presentation; and
f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).”
This non compliance shows the draft Plan is unfit for purpose.

Object

Representation ID: 10362

Received: 29/07/2022

Respondent: Renhold Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SECTION 1: FUNDAMENTAL UNSOUNDNESS OF THE PLAN
The Parish Council having reviewed the Local Plan and associated planning policy feel the document is unfit for purpose and unsound as it is does not meet current National Planning Policy requirements.
The Parish Council believe the draft Local Plan 2040 is unsound as it fails to meet the fundamental requirement of achieving sustainable development, as set out in Section 2 of the NPPF 2021. In particular, the overarching objectives, “which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):
a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

9. These objectives should be delivered through the preparation and implementation of plans and the application of the policies in this Framework; they are not criteria against which every decision can or should be judged. Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.
10. So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).
11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
Furthermore, para 16 of the NPPF expects that:
“Plans should:
a) be prepared with the objective of contributing to the achievement of sustainable development
b) be prepared positively, in a way that is aspirational but deliverable;
c) be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e) be accessible through the use of digital tools to assist public involvement and policy presentation; and
f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).”

Comment

Representation ID: 10382

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

• If passed, the Levelling Up and Regeneration Bill will deliver many of the Government’s planning changes set out in their Planning White Paper. It encourages the construction of new vertical slums. It proposes the removal of powers of local authorities to ensure housing is good enough to live in, the removal of powers to protect active frontage in town centres – threatening the viability of shopping parades – and risks a lack of control over waste collection, with rubbish piled in streets effectively the result of current Government policy. This should be safeguarded against with specific policies to ensure all can live in safe, healthy and sustainable housing.

Object

Representation ID: 10402

Received: 29/07/2022

Respondent: Orchestra Land

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Plan Period
2.19 Turning to the matter of Plan length, Mr R S contends that the Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change.
2.20 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for.
2.21 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas. The next review of the Local Plan would then not need to extend the Plan Period, but instead revise housing and employment growth to reflect the latest position as relevant at that time.

Comment

Representation ID: 10524

Received: 26/07/2022

Respondent: Barton Willmore

Paragraphs 1.5 to 1.34 of the plan for submission set out the national context and the Council’s reasoning for extending the plan period to 2040.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long term requirements, for example major improvements in infrastructure. Paragraph 22 goes on to state that policies should be set within a vision which looks further ahead (at least 30 years), where larger scale developments form part of the strategy. The Council acknowledges within paragraph 1.5 that a longer timescale would have the advantage of giving certainty for a longer period. However, decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years, which has influenced the proposed Plan period of 2020-2040. We agree with the Council’s view and consider that the Plan period is appropriate in the circumstances, particularly given the context of the Arc Spatial Framework, which is discussed in further detail below.
Paragraphs 1.6 to 1.22 provide further background in terms of the Oxford – Cambridge Arc, and the Arc Spatial Framework, which is currently being prepared to provide a long-term strategic plan to help coordinate the infrastructure, environment and new developments in the area. The first consultation on the development of the Spatial Framework ran from the 12th of July 2021 and closed on the 12th of October 2021. The feedback from the consultation is currently being analysed. Within the July 2021 consultation document, it was advised that the development of the Spatial Framework would be supported by two further public consultations including one in Spring 2022 and Autumn 2022, however no further public consultation has taken place as of yet.
Within paragraphs 1.13 to 1.16, the Council acknowledges that the timetable for the production of the Arc Spatial Framework has changed over recent years and has been delayed for several reasons including the Covid 19 pandemic. In response to this, some local authorities within the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. In Bedford’s case however, this is not considered to be a viable option for the reasons relating to policies becoming “out-of-date”. As such, it is vital that the Council work alongside the Oxford-Cambridge Arc to ensure the BBLP 2040 and the Spatial Framework align as far as possible.
As the timescales for the preparation and submission of the BBLP 2040 do not allow the plan making process to follow the publication of the Spatial Framework, and given that progress with the Framework appears to be slow, we would encourage the Council to commit to a further early review to ensure that the Borough’s Local Plan remains aligned with the Spatial Framework and to be able to fully take advantage of and support the opportunities brought to the Borough by the Oxford-Cambridge Arc.
Paragraphs 1.23 to 1.28 provide further information in terms of the proposed East West Rail (EWR) and how the delivery of this national project has a bearing on the Plan and its success. It is being introduced in three stages, which are as follows:
• Stage One – Oxford to Bletchley / Milton Keynes
• Stage Two – will extend that service to Bedford
• Stage Three – will connect Oxford all the way to Cambridge
Paragraph 1.5 states that the track between Oxford and Bicester is already complete, and the next part from Bicester to Bletchley is underway. The section to Bedford involves refurbishing existing lines and is expected to follow on from Stage One. The last stage is advised to be more challenging because it involves the construction of a completely new stretch of track from Bedford north towards Sandy / St Neots and Cambourne, then on to Cambridge. No detailed route alignment has however been chosen. Paragraph 1.26 states that the full route is expected to be operational by 2030.
It is our understanding that plans for Stages 2 and 3 are still being developed, with no funding yet to be received for these stages1. Whilst it may be the case that this is quite common with a lot of infrastructure projects of this nature, it does suggest that there are still a large number of unknowns associated with the EWR.
Paragraph 1.29 refers to another significant infrastructure project as being the upgrade of the road route between the Black Cat Roundabout (A421 / A1 junction) and the Caxton Gibbet roundabout on the A428. Similarly, there are still some unknowns in this respect, with the Secretary of State still yet to issue a decision / grant a Development Consent Order2. The deadline for the Secretary of State to make a decision is the 18th of August 2022.
Based on the above, it is considered that significant infrastructure projects should not be over relied upon within the Plan in the event of any delays in delivery, funding etc., with some growth concentrated within areas that are already in sustainable locations, that are already well served by alternative transport links.