2.1

Showing comments and forms 1 to 30 of 34

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9119

Received: 19/07/2022

Respondent: Mrs Janet Goodland

Representation Summary:

The Vision should include reference to the Bedford -Milton Keynes Waterway Park

Full text:

The Vision should include reference to the Bedford -Milton Keynes Waterway Park

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9195

Received: 25/07/2022

Respondent: Mr Tom Tagg

Representation Summary:

The need to support and maintain sustainable food supply has been removed from the Vision and should be reinserted.

I support the selection of the areas for development.

I support the focus on climate change and protecting Natural Capital.

Full text:

The need to support and maintain sustainable food supply has been removed from the Vision and should be reinserted.

I support the selection of the areas for development.

I support the focus on climate change and protecting Natural Capital.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9265

Received: 27/07/2022

Respondent: Mrs Alison Myers

Representation Summary:

I support the Green Theme but object to the inclusion of the word "through " Bedford Midland for the EW Rail corridor - this is a matter for EW Rail and the uncertainty over the rail route means that all options should be open.

Full text:

I support the Green Theme but object to the inclusion of the word "through " Bedford Midland for the EW Rail corridor - this is a matter for EW Rail and the uncertainty over the rail route means that all options should be open.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9385

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

The Bedfordshire Local Nature Partnership welcomes the recognition of the importance of the environment in the Vision, and the commitment to securing a net gain in biodiversity and environmental quality. We also welcome the statement that development will be sensitively planned to complement the borough's natural environment, but this needs to explicitly mention its wildlife alongside intrinsic beauty and character.
We also welcome reference to key green infrastructure initiatives, delivering multiple benefits in the borough. The Greensand Ridge Nature Improvement area, although occupying a small proportion f the borough's area, has been recognised by the LNP and should be referenced.

Full text:

The Bedfordshire Local Nature Partnership welcomes the recognition of the importance of the environment in the Vision, and the commitment to securing a net gain in biodiversity and environmental quality. We also welcome the statement that development will be sensitively planned to complement the borough's natural environment, but this needs to explicitly mention its wildlife alongside intrinsic beauty and character.
We also welcome reference to key green infrastructure initiatives, delivering multiple benefits in the borough. The Greensand Ridge Nature Improvement area, although occupying a small proportion f the borough's area, has been recognised by the LNP and should be referenced.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9395

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

Representation Summary:

It is a pity that despite our earlier comments there is still no specific focus on increasing wellbeing particularly for the most disadvantaged.

Full text:

It is a pity that despite our earlier comments there is still no specific focus on increasing wellbeing particularly for the most disadvantaged.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9412

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Please see attached main representation report.

Full text:

Please see attached main representation report.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9423

Received: 29/07/2022

Respondent: L&Q Estates Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Vision does not refer to the important role played by The South of Bedford Strategic policy area including the completion and expansion of Wixams, in helping to deliver the housing requirements over the plan period. Policy DS5 (S) Distribution of Growth, indicates that the South of Bedford will provide for 7,050 new homes up to 2040. This represents an important contribution to meeting future housing needs.

Full text:

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.

Paragraph 2.0 Vision and Objectives

The Submission Draft Plan's vision is set out at paragraph 2.1 and states that new settlements at Little Barford and Kempston Hardwick will play a primary role in delivering housing to 2040 and beyond as well as development at Stewartby Brickworks.

The Vision does not refer to the important role played by The South of Bedford Strategic policy area including the completion and expansion of Wixams, in helping to deliver the housing requirements over the plan period. Policy DS5 (S) Distribution of Growth, indicates that the South of Bedford will provide for 7,050 new homes up to 2040. This represents an important contribution to meeting future housing needs.

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9450

Received: 29/07/2022

Respondent: Bedford River Valley Park Landowners

Agent: Woods Hardwick Planning Ltd

Representation Summary:

The BRVP Landowners welcome the specific reference made within the Vision to the completion of the BRVP, recognising its importance as a leisure opportunity, both for local residents, and as a visitor attraction, with benefit to the local economy.

Full text:

The Bedford River Valley Park (BRVP) Landowners comprised of, Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (“The BRVP Landowners”) support the Council’s Vision for the Borough for the plan period and consider it to be sound.

They are particularly pleased to see the acknowledgement given to the need to provide new green infrastructure and to deliver new green spaces for the Borough’s residents, which should be integral to the Plan’s objectives and strategy.

The BRVP Landowners also welcome the specific reference made within the Vision to the completion of the BRVP, recognising its importance as a leisure opportunity, both for local residents, and as a visitor attraction, with benefit to the local economy. They look forward to working with the Council on the delivery of the water sports lake as a key leisure facility within the BRVP.

Four key Themes are set out below the Vision, with these also endorsed by the BRVP Landowners. Again, it is positive to see the importance being placed on creating new green and blue infrastructure and spaces in the Borough. Delivery of the water sports lake as part of the BRVP on the basis set out in the Enabling Development Vision Document submitted in response to the BBLP 2030 Issues & Options for the revised enabling development mix can contribute significantly to the objective of developing a strong and multi-functional urban and rural green and blue infrastructure network for the enjoyment and health of its residents.

The BRVP Landowners also support the desire to create better places. The BRVP Enabling Development, which is the subject of Policy HOU11 of the BBLP 2040 (Separate representations are made on this Policy on behalf of the BRVP Landowners), provides an ideal opportunity to create a beautiful place alongside the water sports lake in an attractive river valley landscape and environment, and in doing so, will facilitate the delivery of the lake itself, enabling the multifunctional green and blue infrastructure benefits associated.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9456

Received: 29/07/2022

Respondent: Landcrest Developments Ltd

Agent: Woods Hardwick Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst Landcrest broadly support the vision and objectives for the Borough, there are areas of concern that may indicate the plan has not been positively prepared, justified or is effective as per paragraph 35 of the NPPF. These matters include the primary strategy of delivering new residential development in order to meet the new local housing need target of the LP2040 – particularly those proposed at Little Barford and Kempston Hardwick.

Full text:

The purpose of this statement, prepared on behalf of Landcrest Developments Ltd (“Landcrest”), is to respond to the Local Plan 2040: Plan for Submission. Whilst Landcrest broadly support the vision and objectives for the Borough, there are areas of concern that may indicate the plan has not been positively prepared, justified or is effective as per paragraph 35 of the NPPF. These matters include the primary strategy of delivering new residential development in order to meet the new local housing need target of the LP2040 – particularly those proposed at Little Barford and Kempston Hardwick.
Such a strategy presents a multi-pronged aspect of understating the consequences of such a vision in the context of spatial development and temporal development within the borough. The matter is considered in further detail below as part of the representations on the spatial strategy-specific policies.
With regards to the other elements of the vision and objectives for LP2040, as set out above there is otherwise broad support. The development of the East West Rail will go a long way in providing connectivity, investment and growth across the borough and to other locations beyond thereby having a positive compounding effect in terms of its planning gain when considered in the context of benefits local growth. However, recent comments from the Transport Secretary indicate that the project should be cancelled, and accordingly there is no contingency or measures within the plan to accommodate for a potentially radical shift in how transport infrastructure in and across the borough will be utilised. In terms of environmental sustainability, Landcrest also share values on the role played by green infrastructure that aims to complement the natural environment whilst simultaneously creating vibrant, sustainable neighbourhoods.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9570

Received: 20/07/2022

Respondent: L&Q Estates Limited

Representation Summary:

The draft Local Plan document sets out the broad vision and objectives for the district, which are derived from the following four themes:
• Theme 1: Greener – Working towards making Bedford a net zero carbon emissions borough whilst improving, enhancing and creating green infrastructure and spaces
• Theme 2: More accessible – Encouraging sustainable travel as well as taking the opportunities offered by strategic infrastructure for greater regional and national
connectivity
• Theme 3: More prosperous – Supporting new innovative businesses, educational and employment opportunities
• Theme 4: Better places – Developing high quality, well-designed and beautiful places for all to use and enjoy
In particular, we note that the objectives for Theme 4 includes the following:
• Deliver the level of housing growth required by the Government’s standard methodology calculation.
• Support and create a high quality, inclusive and safe built environment which promotes
• Encourage the re-use of land that has been previously developed where it is viable and sustainable to do so.
• Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient.
As a group with a long-term future interest in the Borough, we support the overall vision for Bedford set out in Chapter 2 of the Plan, and in particular the objectives of Theme 4, which plans for the delivery of sustainable housing growth. In our view, the optimisation of housing
delivery on a site-by-site basis requires flexibility in some policy areas to ensure schemes are viable.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9677

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

Representation Summary:

In terms of the economy, the proposed vision for the Borough to 2040 focuses on the development of “high quality commercial and office spaces” and attracting “high tech employment sectors, creative industrial and supporting existing retail centres”. Underpinning this vision, ‘Theme 3’ talks about a ‘more prosperous’ Bedford. It states that the Council will “Support a stronger local economy by building on the strengths of the emerging higher value clusters, to become a location for innovative businesses, with a strategically important employment site as a local innovation hub.” It also talks about allocating land to “provide locations for the delivery of high quality jobs”.
2.2 The vision appears to be informed by the Council’s recent ‘Economic Ambitions Topic Paper’ (2022). This Paper sets out an aspiration by the Borough to shift away from large scale logistics developments towards facilitating employment development that will deliver a wider range of what are perceived to be ‘higher value’ jobs in “non-Class B8 sectors” with the aim of developing a “more balanced, productive and, therefore, higher value economy”.
2.3 This aspiration appears to be based on an overly simplistic analysis of the strengths, weaknesses, opportunities and threats to the economy of Bedford that is not grounded in evidence. The assessment is flawed in terms of its characterisation of the recent growth in demand for logistics space in the area as a ‘weakness’ or a ‘threat’ to the Borough (e.g. insufficient local workers to fill vacancies in logistics, reduction in jobs due to automation, logistics leading to a low-productivity economy) rather than a ‘strength’ or an ‘opportunity’ to be maximised.
2.4 The evidence shows that nationally the industrial and logistics sector is highly productive with Gross Value Added (GVA) per job currently at £58,000, some 12% higher than the average of all sectors. Its productivity is also predicted to grow at a faster pace, increasing by 29% between 2025 to 2039 compared to 18% across the UK economy as a whole1. Therefore, the Council’s vision and evidence fails to recognise that the industrial and logistics sector could provide a significant opportunity to boost the productivity of the Borough, where its own evidence indicates that it lags behind
nearby urban centres (Figure 2) and suggests that part of its aim is to reduce the productivity gap between Bedford and Cambridge. Other analysis also shows that local authorities with higher density of logistics have higher GDP per capita than those with lower logistics densities2.
2.5 Cloud Wing is, therefore, concerned that the overall economic vision for the Borough and its overwhelming focus on ‘innovation’ uses appears to be driven by outdated and erroneous perceptions about the industrial and logistics sector, including: the contribution it can make to the wider economy and overall productivity; and the range and quality of jobs that this creates.
2.6 The Government in its recent ‘Future of Freight Plan’ (2022)3 notes that these “negative perceptions of the industry” need to be addressed and “the availability of attractive, fulfilling jobs at all levels of the industry” be promoted. It also confirms that the sector can make a significant contribution to levelling up between areas and acknowledges that there is “increasing sophistication of roles in the sector with Professional and Associate Professional and Technical roles increasing by 331,000 since 2010”. It also confirms that the number of freight and logistics jobs have grown by 26% since 2010, nearly double the rate of the wider economy.
2.7 Indeed, recent reports published by leading bodies including the British Property Federation4 and Frontier Economics5, amongst others, demonstrate that:
• logistics facilities are a fundamental component of effective and efficient supply chains;
• jobs in the sector are well paid, with average pay higher than the UK average;
• industrial and logistics facilities support an increasingly diverse range of jobs, including a growing proportion of graduate, professional and associate professional roles such as software engineers in charge of automated systems, supply chain managers and data analysts, in addition to professional jobs in product design and research & development, in their wider supply chain;
• other office-based roles (e.g. finance, administrative, research and development, sales and marketing, customer services) are also increasingly co-locating with production and logistics as it is convenient for these people to be closer to the operations, further increasing occupational diversity within the sector;
• the sector provides job opportunities that can support improved social mobility, including to those who are currently unemployed and career progression and promotion opportunities for workers with low levels of formal qualifications into managerial roles, which could help address Bedford’s position as one of the more deprived centres within the Arc;
• logistics jobs provide workers with valuable skills and training, including an average of 41,100 new apprenticeships each year nationally, with this forecast to grow to 53,000 new apprenticeships annually; which is equivalent to over half a million apprenticeships over the next 10 years.
2.8 Bedford itself is also a prime location for logistics at the heart of the Golden Triangle (Figure 36) and within the Oxford-Cambridge Arc (‘the Arc’). At 30 miles west of Cambridge, 40 miles east of Oxford, 50 miles north of London and 98 miles east of Felixstowe. The Borough is extremely well connected to the strategic road network via the A421, which connects to M1 to the west and A1 to the east, which in turn provide connections to the M25. This is evidenced by the number of logistics occupiers that have been drawn to the area and which are actively seeking significant amounts of space.
2.9 On this basis, a vision which does not reflect the strengths of Bedford as a location of logistics and the opportunities this presents as a national and regionally significant growth sector, where there is significant market demand, is not justified. It also risks failing to meet needs of a sector that has been identified by the Government in its recent ‘Future of Freight Plan’ (2022) as “critical to every supply chain into, across and out of the UK and is fundamental to our economic wellbeing.” This Plan specifically states that the planning system needs to fully recognise “the needs of the freight and logistics sector now and in the future”. This is a major oversight and risks Bedford failing to meet the needs of a sector which is fundamental to the effective functioning of the economy and conflicting with the Government’s vision for the future of the sector.
2.10 Cloud Wing is also concerned that the overarching economic vision is overly reliant on attracting a significant scale of new innovation businesses to Bedford. This vision appears to be based on the assumption that Bedford would receive a ‘trickle down’ effect from the ‘pent-up demand’ from existing innovation hubs Oxford and Cambridge as a result of the improved connectivity (i.e. East-West Rail). However, there is no apparent strategy for how the Borough would attract the scale of innovative businesses to the Borough and how it would become a “globally competitive location” for innovation as suggested in its evidence.
2.11 The Council’s evidence refers to a relatively small number of examples of innovative businesses located in the Borough but many of these appear to have been operating in the Borough for some time. There does not appear to be a strong anchor within Bedford or a particular strategy proposed that would generate the scale of interest solely in innovation uses that is envisaged and change historic trends.
2.12 Rather than positively and proactively encouraging sustainable economic growth and create an environment in which businesses can invest, expand and adapt, Cloud Wing is concerned that the Plan’s overreliance on innovation uses could fail to build on its strengths and undermine the delivery of sustainable economic growth contrary to Paragraph 81 and 82 of the NPPF.
(see attachment for figures 2 and 3)

Attachments:

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9761

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We consider there is insufficient evidence to demonstrate that the vision over the plan period is deliverable because of the proposed spatial strategy and site allocations.
The vision specifically mentions locations for new settlements and other development, but the strategy does not demonstrate deliverability of the sites proposed and it does not factor in sufficient flexibility for under-performance should the spatial strategy and site selection remain unchanged through the examination process.
We consider that to be found sound, the plan should be subject to main modifications in respect of a range of matters but for the purpose of this response to the vision and objectives we confine our comments to the need to review the evidence base and proposed spatial strategy and site allocations.
As it stands the plan in our view is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The objective of delivery of sustainable development will only be realised if sites are deliverable. These tests of soundness are applied to non-strategic policies within the local plan in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.
Paragraph 66 of the NPPF states that strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.
Bedford Borough Council is the strategic policy-making authority in this instance and we accept that the Council has undertaken a call for sites and taking this into consideration in arriving at the proposed strategy and objectives but we consider there is a fundamental issue over deliverability.
The spatial strategy is reliant upon further decisions to be made by other parties in respect of East-West Rail including fundamental considerations of the route west of Bedford Town, locations of stations and timing of subsequent stages for the planning for the development and delivery. The consultation on this local plan comes ahead of refinement of the detail of these extremely important matters and yet the local plan is not scheduled for submission for examination until January 2023. With this consultation comprising the plan for submission (Regulation 19), there would ordinarily not be any further opportunity for stakeholders to comment ahead of submission of the local plan (Regulation 22). As the spatial strategy and some of the proposed site allocations rely on delivery of East-West Rail this is a real point of vulnerability which should have been avoided by first having clarity on this ahead of consultation under Regulation 19.
The Infrastructure and Projects Authority, which is the Government’s centre of expertise for infrastructure and major projects, published its Annual Report on Major Projects 2021-22 on 20 July 2022. This has found that stages 2 and 3 of East West Rail appears to be unachievable.
In this report the East West Rail Connection Stage 2 and 3 which comprises predominantly upgrading of existing infrastructure (between Bletchley and Bedford) to allow services between Oxford and Bedford and East West Rail CS3 which involves building a new line, between Bedford and Cambridge, to extend the railway and facilitate services from Oxford to Cambridge, is identified as 'red' meaning that the 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 reassessed.
A copy of the report is available via: https://www.gov.uk/government/publications/infrastructure-and-projects-authority-annual-report-2022
Paragraph 2.4 states that remaining policies in the earlier Allocations and Designations Local Plan have been reviewed and, in the majority of cases, they remain fit for purpose and do not need to change at this time. Where is the assessment undertaken as referred to here and what is the position in respect of cases (seemingly being in the minority) which might not have been judged fit for purpose and so might need to be changed?
Paragraph 2.5 states that the development strategy to 2030 is already set, it is important that it is allowed to be delivered and for that reason the policies in this emerging local plan build on it, and in doing so, put in place a robust strategy for growth to 2040.
We do not agree with this statement because we consider the strategy proposed in this emerging local plan 2040 does not just ‘build upon’ the local plan 2030. The proposed strategy unlike the existing one identifies new settlements and new strategic-scale development based on East-West Rail over a period of some 15 years. The local plan 2030 adopted in January 2020 only covers the period to 2030 and has a focus on Bedford and Kempston, completing the then already started settlement at Wixams and village extensions including at Wootton, Stewartby and Shortstown.
There is not much, if any, scope for the local plan not already covered within the points at paragraph 2.6 and hence struggle to see why the new local plan seems to be proposed as a partial rather than a full review? In view of the proposed scope for the new local plan it seems appropriate to consider this replacing all existing development plan policy of relevance (acknowledging this will not include neighbourhood plans) and for the local plan to state what the development plan for Bedford Borough currently comprises.
There is an over reliance on larger sites within the plan and we question whether it is realistic to expect the quantum of potential delivery within the plan period.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9810

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

Representation Summary:

It is difficult to take issue with any of the statements included in the Vision; they are to be supported, although there must be some question over the East West Rail project .

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9857

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Local Plan is not sound (not ‘Justified’ or Effective’) in terms of the Vision because it builds in levels of housing growth which by its own admission are excessive and unsustainable.

A letter from the Council to the Secretary of State for Levelling Up Communities and Housing dated 19th April 2022 has been made available to CPRE Bedfordshire through a Freedom of Information request. In this letter the Council asks that the housing need requirement calculated through the standard method should be reviewed and revised making the case that “on the basis mainly of past over-performance, we are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.”

CPRE Bedfordshire’s published response to the Submission draft explains in paragraphs 5 to 8as follows;

Environmentally Unsustainable Housing Numbers

The Plan provides for 27,100 new homes to be delivered over the Plan period (1,355 per year). This is the highest target in the history of Bedford Council and is equivalent to building 7 new towns the size of Ampthill or 27 new villages the size of Sharnbrook. The result of this would be urbanisation on a grand scale.

CPRE Bedfordshire is aware that the Council have made representations to the government asking that the Standard Method derived targets should be revised. A copy of the Council’s letter to the Department of Levelling Up, Housing and Communities and the Minister’s reply have been obtained through a Freedom of Information request.

In their letter the Council states that following the government formula means the Council ‘are obliged to plan for an excessive growth rate far in excess of that which the borough can sustainably accommodate.’ The Minister’s reply states that no flexibility can be shown because they are committed to boosting the housing supply and have concerns about delivery.

The Council say that they have no real choice other than to follow the governments expectation that local housing need will be calculated through the much criticised Standard Method formula. The government insists that outdated and inaccurate 2014 ONS (Office for National Statistics) housing formation data must be used even though more up to date and accurate figures were published by ONS in 2018. These result is a much lower housing growth target of around 1,000 new homes per year. The housing requirement that the strategy for housing growth in Local Plan 2040 is based on is, in our view, and as recognised by the Council, excessive and unsustainable. Therefore the plan is unsound on the grounds that this key aspect of the plan is unjustified.

CPRE Bedfordshire’s full response to the Submission Draft can be found at;
http://www.cprebeds.org.uk/wp-content/uploads/sites/13/2022/07/Submission-version-reponse-LP-2040-July-22-Final.pdf

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9862

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Local Plan is not sound (not ‘Justified’ or Effective’) in terms of its failure to give adequate consideration to the opportunity available in NPPF para 174 to protect valued landscapes in the Borough and in particular to use this provision to protect the River Great Ouse Valley.

River Great Ouse and Valley Area – a “Valued Landscape”

Current planning policy for the protection of valued landscapes in Bedford Borough relies on Local Plan 2030 (saved) Policy 37. This is entirely inadequate for the protection of such a major environmental asset as the River Great Ouse Valley

CPRE Bedfordshire commented in our initial consultation response that the Local Plan Vision fails to recognise the importance of the "River Great Ouse and its Valley Area" right across the Borough from its point of entry near Turvey to where it exits the Borough in the east. This is a serious omission that should be remedied.

The National Planning Policy Framework (NPPF) (2021) Para 174, states that ‘Planning policies and decisions should contribute to and enhance the natural and local environment by ……… protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan).

The NPPF therefore creates the basis for the protection of “valued landscapes” in planning policies and CPRE Bedfordshire would like to see the Council look positively at the opportunity this creates to protect the Great River Ouse and Valley Area right across Bedford Borough.

The area CPRE Bedfordshire recommends being recognised as a “valued landscape” would be the same as that designated an Area of Great Landscape Value in earlier Local Plans, prior to this national designation being removed by government.

CPRE Bedfordshire’s full response to the Submission Draft can be found at;
http://www.cprebeds.org.uk/wp-content/uploads/sites/13/2022/07/Submission-version-reponse-LP-2040-July-22-Final.pdf

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9864

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Representation Summary:

River Great Ouse and Valley Area – a “Valued Landscape”
16. Para 2.1 CPRE Bedfordshire commented in our initial consultation response that the Local Plan Vision fails to recognise the importance of the "River Great Ouse and its
Valley Area" right across the Borough from its point of entry near Turvey to where it exits the Borough in the east. This is a serious omission that should be remedied.
17. The National Planning Policy Framework (NPPF) (2021) Para 174, states that ‘Planning policies and decisions should contribute to and enhance the natural and local environment by ……… protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan).
18. The NPPF therefore creates the basis for the protection of “valued landscapes” in planning policies and CPRE Bedfordshire would like to see the Council look positively at the opportunity this creates to protect the Great River Ouse and Valley Area right across Bedford Borough. The area CPRE Bedfordshire recommends being recognised as a “valued landscape” would be the same as that designated an Area of Great Landscape Value in earlier Local Plans, prior to this national designation being removed by government.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9874

Received: 28/07/2022

Respondent: Mr Rodney Evans

Representation Summary:

As a Milton Keynes resident fully support the inclusion of this Waterway in the new Bedford Plan as It will : bring our two communities closer together,
Improve water resilience from Oxford to Cambridge and into the Anglian region, including improved local flood risk management and, potentially, open water transfer between regions • New and increased opportunities for healthy living and recreational activities • New and direct routes for cycling and walking between Bedford and Milton Keynes • Improved connectivity between existing rivers, canals, water bodies and wildlife corridors • Creating a strategic sense of place for sustainable new communities along the route.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9932

Received: 29/07/2022

Respondent: Rainier Developments Limited

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

OBJECT: The Vision is unsound, reflecting a spatial strategy which is inflexible and ineffective. The exceptional circumstances to justify a departure from the LHN have not been demonstrated in conflict with NPPF61.

Further justification and detail is provided in response to Policy DS2(S) and DS3(S).

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9971

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Representation Summary:

The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for housing and other development can be produced.
The NPPF requires that plans set out a vision and a framework for future development and seek to address the strategic priorities for the area. Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered ‘sound’.
The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for, to address housing, economic, social and environmental priorities and to help shape the development of local communities for future generations.
In particular, paragraph 16 of the NPPF states 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 plan-makers 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).”
To support the Government’s continued objective of significantly boosting the supply of homes, it is important that the Bedford Local Plan 2040 provides a sufficient amount and variety of land that can be brought forward, without delay, to meet housing needs. In determining the minimum number of homes needed, strategic plans should be based upon a local housing needs (LHN) assessment defined using the standard method. LHN sets the minimum number of homes required and this is the starting point for determining the number of homes required in any local planning authority area, unless there are circumstances to justify an alternative approach.
Once the minimum number of homes that are required is identified, the strategic planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 68 sets out specific guidance that local planning authorities should consider when identifying and meeting their housing needs, with Annex 2 of the NPPF providing definitions for the terms “deliverable” and “developable”.
Once a local planning authority has identified its LHN, these needs should be met as a minimum, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so, or the application of certain policies in the Framework would provide a strong reason for restricting the overall scale, type and distribution of development (paragraph 11b)i.). Where it is found that full delivery of housing needs cannot be achieved (owing to conflict with specific policies of the NPPF), local authorities are required to engage with their neighbours to ensure that identified housing needs can be met in full (see paragraph 35).
The July 2021 revision to the NPPF provides greater focus on the environment, design quality and place-making alongside providing additional guidance in relation to flooding setting out a Flood Risk Vulnerability Classification at Annex 3, the importance of Tree-lined streets and amendments to Article 4 directions. Moreover, Local Plans which had not yet progressed to Regulation 19 stage should ensure that where strategic developments such as new settlements or significant extensions are required, they are set within a vision that looks ahead at least 30 years. The Regulation 19 Bedford Local Plan 2040 has no such vision for a 30-year period.
Vision and Objectives
The NPPF is clear that where development plans are proposing large scale developments such as those within the Bedford Local Plan 2040, policies should be set within a vision that looks further ahead, at least 30 years, to take account the likely timescale for delivery. The vision should therefore be amended and updated to reflect this requirement of national policy.

Attachments:

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9995

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

Representation Summary:

3. VISION AND OBJECTIVES
3.1 Wates supports the vision identified at pages 11 and 12 of the Draft Local Plan. The vision sets out that, by the end of the Plan-period in 2040, the Bedford Borough will be greener, more sustainable, more attractive and more prosperous, as a place to live and work. Addressing climate change and adapting to and/or mitigating its impacts, is identified as a key cross-cutting element within the overall vision.
3.2 In relation to the vision (and also reflected in Theme 2: ‘More Accessible’), Wates note and agree that the Bedford Borough presents very significant opportunities for public transit-oriented development. The proposed vision clearly recognises this as providing an impetus for achieving genuinely sustainable growth.
3.3 The East West Rail project has the potential to spur local economic development and employment growth, by better integrating the Borough within a larger regional economy. This brings with it the potential to create new settlements (such as those proposed at Little Barford and Kempston Hardwick), alongside the opportunity to expand Wixams as a successful new town that will (by 2024) be served by a new train station.
3.4 The proposed vision (and Theme 1: ‘Greener’) also envisages the growth of the Forest of Marston Vale, recognising the potential for the community forest project to transform the landscape of the Borough. Wates is particularly supportive of this aspect of the vision, noting that Land South of Wixams has the potential to provide a significant contribution to the reforesting project, thereby helping to address climate change goals directly
3.5 In terms of the other themes and objectives identified at pages 13 to 15, it is welcome that the Draft Local Plan strives to fully address the level of housing need established through the Standard Method, with new homes to be provided through holistic ‘place-making’ strategies. Likewise, Wates supports the focus on improving accessibility and concentrating growth at key transport modes, and agrees that the approach will help the Borough to achieve of carbon neutrality and strategic biodiversity gains.
Compliance with the Tests of Soundness
3.6 For the reasons described above, the proposed vision and objectives are consistent with the economic, social and environmental aspects of sustainable development, as defined at NPPF paragraph 8. They also represent a positive and justified approach, as they aim to fully meet development needs (as per NPPF Section 5) and respond to the opportunities presented by future planned transport infrastructure (consistent with NPPF paragraph 73).

9.1 Wates considers that the Draft Local Plan’s proposed Vision and Spatial Strategy are well reasoned and supported by the evidence base. The aspiration to progress a strategy for growth that is centred on sustainable (transport-oriented) locations, has sustainability at its heart and is consistent with the NPPF. This approach is also supported by the Sustainability Appraisal, particularly when compared to the wide range of alternatives considered.

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10046

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Representation Summary:

The Vision refers to growth supported by infrastructure, sustainable transport, green infrastructure, new neighbourhoods, high quality commercial and office spaces, and good design. The Southill Estate owns two parcels of land that are identified as draft allocations in the Pre Submission Bedford Local Plan (PSBLP): land at Abbey Field West of Elstow site for residential development (Policy HOU 5); and land at Pear Tree Farm Elstow for a science and innovation park (Policy EMP 5). These two draft allocations could deliver parts of the Vision for PSBLP. The sites are well related to the urban area. The promoted developments would provide housing and employment including high quality innovation space, and would contribute towards the growth of the local economy. The sites are in an accessible location, and the promoted developments would provide connections by sustainable modes of transport. The promoted developments would include open space and green infrastructure, and would connect with a green corridor project in the surrounding area. The design and layout of the promoted developments would take into account the characteristics of the site and surrounding area, including the historic environment and landscape character. The Vision is supported, and no changes are required.

Attachments:

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10050

Received: 28/07/2022

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Representation Summary:

It is considered that the ‘Vision’ set out at paragraph 2.1 of the Plan is in the most part a positive narrative which seeks to summarise the way in which the policies within the draft plan will impact the borough in the coming plan period.

The Howbury Hall Estate supports the Vision in this regard.

The Estate does however seek to raise two points:

Firstly, there is only a quite incidental reference to the Oxford to Cambridge Growth Arc where East / West Rail is mentioned rather than any specific commentary upon the important role that Bedford will play as a sustainable settlement located centrally within it.

Policies within the plan, particularly those related to employment and housing growth do place more emphasis on this aspect which we submit should be included in the Vision.

Secondly the Vision notes that in the period to 2040 the plan and its proposals will:

“…..have a positive impact on the local economy attracting high tech employment sectors, creative industries and supporting existing retail centres.”

Whilst again this is supported as set out in our separate representations regarding the Spatial Strategy and proposed allocation at Water End / St Neots Road (EMP6), it is considered that it is important that the plan does not turn entirely turn its back on those areas of the local economy which have proved successful historically in this area and which can complement and deliver a mix of jobs an prosperity alongside the aspiration to attract the high tech and creative industries to the area.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10102

Received: 29/07/2022

Respondent: Rainier Developments Limited - Bromham

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

OBJECT: The Vision is unsound, reflecting a spatial strategy which is inflexible and ineffective. The exceptional circumstances to justify a departure from the LHN have not been demonstrated in conflict with NPPF61.

Further justification and detail is provided in response to Policy DS2(S) and DS3(S).

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10112

Received: 29/07/2022

Respondent: Rainier Developments Limited - Roxton

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

OBJECT: The Vision is unsound, reflecting a spatial strategy which is inflexible and ineffective. The exceptional circumstances to justify a departure from the LHN have not been demonstrated in conflict with NPPF61.

Further justification and detail is provided in response to Policy DS2(S) and DS3(S).

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10250

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Representation Summary:

2. Vision & Objectives
2.1 CBC support the positivity of the vision for Bedford, which states that by the end of the plan period “The borough will have become a greener, more sustainable, more attractive and prosperous place to live and work. Tackling climate change and adapting to and mitigating its effects will be at the heart of new development throughout the borough”. The four themes identified within the Submission plan are also generally supported as they provide a clear direction as to how the vision could be achieved.
2.2 It is noted within Theme 2 relating to accessibility, that there is an emphasis on improving east-west connectivity and enhancing multi-modal travel, through the construction of the East West Rail line. As the EWR proposals are still being considered and timeframes for delivery are still to be determined, it is considered that it may be prudent to also identify alternative means for improving connectivity within the Borough.
2.3 CBC also considers that it may be beneficial to reference within the vision and objectives for the plan, the potential improvements to east west connectivity that could also be realised through the Bedford to MK Waterway.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10278

Received: 29/07/2022

Respondent: Roxton Parish Council

Representation Summary:

SECTION 2.1:
The Local Plan states that EWR through Bedford will be complete and that it will attract connectivity, investment, and growth. However, there is a very real danger that this could have a negative impact and make Bedford a dormitory town by providing fast transport links to employment in the neighbouring cities. The recent public comments made by Grant Shapps (Secretary of State for Transport) that “…he would scrap phase 2 and 3 of the EWR project saving £3-5billion…” cast significant doubt on the prospect of EWR line coming through Bedford towards Cambridge. A Local Plan predicated on a project whose future is in so much doubt must render much of the assumptions on which BBC Local Plan 2040 is based flawed and therefore unsound. In this respect RPC suggest the Local Plan 2040 needs to be re-written to determine suitable polices in a world without EWR passing through the borough.
The statement about Riverside villages forming the backbone of the green and blue infrastructure is questionable when the intended route of EWR will destroy a number of those villages.
Transport policy suggests improvements to the overall movement of people with an integrated system which is good. However, the X5 from Roxton which allowed the transport of bicycles, buggies etc in the hold has been replaced by the 905 which does not provide those facilities.
RPC support the intent that developments are sensitively planned to complement the borough’s natural environment. Planned developments such as EWR and the A428/Black Cat development require sensitive planning, as will other potential developments that result of these projects (additional service stations/area, warehouse, and commercial developments). If these items are proposed, they must be considered alongside the need to maintain the rural nature of the surrounding areas and the character of nearby villages. RPC must be part of the drafting of the brief for any masterplan for the allocation site of policy EMP8.

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10343

Received: 29/07/2022

Respondent: Barton Willmore

Representation Summary:

Draft Plan’s ‘Vision’ is set out at paragraph 2.1, which states that its purpose is to demonstrate the focus and direction of the Local Plan.
2.2 The second paragraph of the Vision states that by the end of the plan period “well-planned growth supported by appropriate infrastructure… will enable the creation of strong, safe and resilient communities in environments that facilitate healthy and independent living for all.” However, there is no specific reference to healthcare infrastructure, and we are of the view that this is an important element that should be included within the Vision (as mentioned in our previous Representations).
2.3 The fifth paragraph of the Vision briefly makes reference to the transformation of “brownfield sites on the western side of the town and south of the river”, the latter of which we assume relates to the Policy 14 Area which includes some of Bedford Hospital South Wing site and wider car parking land to the northeast of Britannia Road. Again, we are of the view that explicit reference to the Bedford Hospital sites should be made within the Vision, as these are key locations for development and improvement during the local plan period to 2040.
2.4 The Plan sets out four ‘Themes’ that are intended to reflect the Vision, including: Greener; More Accessible; More Prosperous; and Better Places.
2.5 We note that one of the objectives under Theme 3 (More Prosperous) has been amended since the Draft Plan, to include reference to health:
“Deliver the necessary health and social infrastructure to increase well-being in both the urban and rural areas of the borough.”
2.6 We support this amended objective and recognition of the importance of health infrastructure to support wellbeing and development.
2.7 Theme 4’s objectives include the following, which remains unchanged from the Draft Plan, and which we continue to support:
“Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives.”

Attachments:

Support

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10369

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

Representation Summary:

• The vision: We welcome the vision, which highlights the need for the whole Borough to be “a greener, more sustainable, more attractive and prosperous place to live.” We note and agree with the specific references to River Great Ouse and valley as an asset to the Borough. We are also pleased that explicit support for sustainable transport and local renewable energy generation has been added following our previous consultation response.

Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10452

Received: 29/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Representation Summary:

The aspirations as set are laudable but not always matched by specific policy decisions set out subsequently. In particular, as we said in our response to the Draft Plan, the proposals crucially fails the tests of sustainability and the requirements of DS1(S) mean the plan is unsound for that reason alone.
The Council's own SA clearly states that urban growth is the most sustainable on virtually all criteria yet this Plan, despite that, is a lost opportunity.
We believe that properly planned urban expansion, including some areas of high density housing but inevitably entailing some expansion would not only be more sustainable but more closely meets the needs of the main growth sectors as noted in the LHNA. The failure to follow up that initial option (and to put it forward for consideration at the draft stage) means again we are presented with a plan which will lead to sprawling development, merging of communities and landscape degradation with resulting loss of amenity for all residents.

Attachments:

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10472

Received: 29/07/2022

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Please see accompanying Representations Report Paragraphs 3.4 – 3.9

The Vision within the submission version Bedford Local Plan 2040 fails to recognise or provide for needs for community facilities necessary to deliver the objectives for the spatial strategy or to provide for sustainable development specifically in relation to the settlement at Oakley and secondary education provision at Lincroft Academy.

The Council’s assessment of our client’s interests at Lincroft Academy Site ID: 832 / 839 is inadequate and takes no account of the submitted details in terms of the ability to secure the required improvement of facilities and a range of additional benefits to the local community. Furthermore the site option has not been assessed in the same detail as other reasonable alternatives to enable identification of the positive effects associated with the improvement of social infrastructure and education provision at this location