2.2

Comment

Representation ID: 9212

Received: 23/06/2022

Respondent: Mr Anthony Roche

I support the aspiration to be a greener, more accessible and prosperous Borough with the opportunity for all in the Borough able to take advantage of the betterments that such a plan will provide. Optimising the use of brown-field sites rather than development on farming land for new housing is strongly supported.
The Odell Parish Neighbourhood Plan is now essentially finalised with the vote by Parishioners expected shortly. The Plan is in alignment with Local Plan requirements

Comment

Representation ID: 9386

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

We welcome Theme 1 and its content, but would suggest it includes a stronger reference to protecting and enhancing biodiversity, including through the forthcoming Local Nature Recovery Strategy.
Suggested revision: "Protect and enhance our natural capital resources and the ecosystem services that they provide....."
Suggested revision: Improve access to high quality green and blue infrastructure, including natural green spaces,....."

Theme 2 must make wider reference to sustainable modes of travel and supporting an increase in use beyond the town centres to support a more holistic delivery.

Comment

Representation ID: 9398

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

Wed would comment that the second bullet should be stating that we are aiming for environmentally sustainable economic activity. Focusing on 'growth' is likely to mean that this is not possible.

Comment

Representation ID: 9399

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

Themes 2, 3 and 4 are absent of any specific references to either net zero or environmental sustainability. While we acknowledge that this is covered in Theme 1 its absence from the other themes significantly increases the likelihood that these themes will not deliver either net zero or environmental sustainability when implemented.

Comment

Representation ID: 9403

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

In Theme 1 - the first bullet MUST be to achieve a carbon neutral borough. Anything else is a failure to deliver on the council's declaration of a climate emergency. We have already started to see the impacts of climate breakdown and in the face of a lack of action from central government it is critical that local councils take this responsibility seriously.

Object

Representation ID: 9428

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Please see attached report

Comment

Representation ID: 9541

Received: 13/07/2022

Respondent: Ravensden Parish Council

The Parish Council welcomes the Vision statement including that " development will reflect each areas unique local character" and the focus of Theme 1, which aims to secure a "Greener" Borough. The intention to develop a Green Infrastructure network will support the policies within Ravensden's emerging Neighbourhood Plan. Theme 1 also states that the Borough will "protect and enhance our natural resources". The Parish Council is keen to see strong protection for the high quality soils within Ravensden.

Comment

Representation ID: 9612

Received: 08/08/2022

Respondent: Bedfordshire Police

The local plan 2040 looks sound to us. However, is it possible to have the following paragraph included somewhere? I suppose we come under Theme 4: Better Places but we will leave it to your discretion.


Bedfordshire Police Designing Out Crime Officers provide ongoing specialist advice on the security of new buildings and the refurbishments of existing ones to enable designs to be as safe and secure as reasonably possible, raising awareness of the principles of CPTED (crime prevention through environmental design) as well as generating awareness of, and ensuring the adoption of, recommended security standards and specifications.
We are keen to work with designers and developers at the earliest opportunity of a planning proposal and seek to encourage them to consider applying for Secured By Design developers award.

Comment

Representation ID: 9811

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

4 Themes outlined – 1. Greener
2. More accessible
3. More prosperous
4. Better places
These set out objectives it is generally impossible to object to, but do make one wonder how consistent with them some of the plan proposals are – e.g. a diesel powered E-W rail through quiet and attractive landscape?

Object

Representation ID: 9858

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

CPRE Bedfordshire consider that the Local Plan is not sound (not ‘Justified’ or Effective’) in terms of the Vision Themes in para 2.2 because there are serious gaps and weaknesses in the Themes that need to be addressed.

Theme 1: Greener – Working towards making Bedford a net zero carbon emissions
borough whilst improving, enhancing and creating green infrastructure and spaces

CPRE Bedfordshire commented in response to the Local Plan consultation of 2021 that
we would like to see the plan go beyond general statements of intention to work
towards making Bedford a carbon neutral borough and build in some stronger and more
specific targets in support of this objective. This has not been addressed.

Theme 2: More accessible – Encouraging sustainable travel as well as taking the opportunities offered by strategic infrastructure for greater regional and national connectivity.

Cycling

CPRE Bedfordshire believe that the Local Plan does not do enough to encourage cycling through the development of a comprehensive network of safe cycle routes.

There is a complete absence of any detailed recognition of the need for a sustainable network of safe segregated cycle routes across the Borough - e.g. North South linking the Wixams (bridging the A421) to Milton Ernest through the centre of Bedford.

There is also no mention of a safe segregated cycle route to Bedford Station - it is deeply
unsatisfactory that the there is still no segregated cycle route to Bedford station from any direction.

Cycling is the way forward at a time of Climate Change and Biodiversity Loss - it will significantly improve the health and wellbeing of residents but people do not trust lines on a highway – they do not feel safe.

The Council needs to take the bull by the horns, dismiss the gainsayers and move forward at pace with plans for an integrated, safe, segregated network of cycle routes across the Borough, moving the priority away from cars. Our neighbouring cities of Oxford, Cambridge and Milton Keynes are showing the way forward and BBC should move swiftly into the modern era.

Rail

It is deeply unsatisfactory that BBC has recently introduced an updated Rail Strategy without any public consultation and without it being discussed and agreed at a Full Council Meeting where councillors of all political parties are in attendance, members of the general public and the media. Like the Council’s previous submission to the East West Rail consultation, secrecy seems to have been the motivation.

The latest version of the Rail Strategy, is a major update and in view of the considerable concern regarding the impact of East West Rail on our Borough, this document should have followed an open democratic process.

In choosing to support a northern route for East West Rail in Bedford Borough the Council has made a serious error in influencing the direction of the project in a way that will increase noise and air pollution in the town centre and result in substantial negative environmental impacts in an area of quiet countryside and rural communities in the north of the Borough.

The opportunity to reconsider the route choice and to switch attention from the currently proposed northern route in Bedford to a southern route following the A421 transport corridor, is currently threatened by progress on the development of a new station at Wixams.

As far as we understand the location of this station has been identified with other priorities in mind and would be unable to operate as an EWR station interchange with Midland Main Line and Thameslink.

CPRE Bedfordshire urges EWR Co to intervene in this development and ask for the project to be paused so that alternatives could be considered which would serve the needs of EWR as well as residents of Wixams.

CPRE Bedfordshire strongly supports EWR in principle and would like to see the new railway being progressed and delivered, but only if these major concerns are addressed and EWR Co changes course to focus on a more environmentally alternative route.

Theme 4: Better places – Developing high quality, well-designed and beautiful places for all to use and enjoy

As stated with reference to our comments on the Local Plan Vision paragraph 2.1 the Local Plan is not sound (not ‘Justified’ or Effective’) because it builds in levels of housing growth which by its own admission are excessive and unsustainable.

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

Support

Representation ID: 10045

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

The PSBLP identifies four themes to deliver the Vision, which are as follows: greener; more accessible; more prosperous; and better places. The four themes are consistent with national policy and the sustainable development objectives contained in the NPPF. The Southill Estate owns two parcels of land that are identified as draft allocations in PSBLP, which would contribute towards the delivery of all four themes.

The greener theme refers to development integrating with the surrounding landscape and multi-functional green infrastructure. The promoted development at the Abbey Field West of Elstow site (Policy HOU 5) includes policy requirements for the delivery of open space, connections to an existing green corridor, and other green infrastructure. The promoted development at the Pear Tree Farm Elstow site (Policy EMP 5) includes policy requirements for contributions towards the Forest of Marston Vale, and the delivery of a green corridor and landscaping. Therefore, these two promoted developments would contribute towards the greener theme.

The more accessible theme refers to reducing congestion and encouraging travel by sustainable modes of transport. The promoted developments at Abbey Field West of Elstow and Pear Tree Farm Elstow include policy requirements for pedestrian and cycle connections with the surrounding area and existing networks. The promoted developments are in close proximity to one another, with one for residential use and the other for employment uses. The promoted developments are well related to the urban area, to other proposed strategic developments, and to proposed transport infrastructure projects. The promoted development would provide an opportunity for current and future residents to live close to work, and would make it more likely that travel for regular day to day journeys would be by sustainable modes of transport rather than the private car. Therefore, the promoted developments would contribute towards the more accessible theme.

The more prosperous theme refers to supporting a stronger local economy and delivering high value jobs. The promoted development at the Pear Tree Farm Elstow site is within the South of Bedford Area and is specifically identified as a draft allocation for a high value science and innovation park. As such, the promoted development would directly contribute towards the more prosperous theme.

The better places theme refers to meeting housing needs. The promoted development at Abbey Fields West of Elstow is for residential development, and would provide a mix of house types, sizes and tenures including affordable housing. The site is included in the housing trajectory for PSBLP, and it contributes towards the housing supply during the plan period. Therefore, the promoted development would contribute towards the better places theme. As set out in the Southill Estate’s representations to Policy HOU 5, the site could accommodate more dwellings and could be delivered much earlier than currently indicated in the housing trajectory. If the requested changes to Policy HOU 5 are made the promoted development would make a greater contribution towards the better places theme, and provide more housing earlier in the plan period.

The promoted developments at Abbey Fields West of Elstow and at Pear Tree Farm Elstow could contribute towards the delivery of all four themes. The four themes are all supported, and no changes are required.

Comment

Representation ID: 10058

Received: 28/07/2022

Respondent: Mr Richard Owen

‘Green Infrastructure policy’ must protect natural resources. To support an increased housing provision, we must protect high-quality agricultural land within the north Bedfordshire villages. Increased carbon footprints of imported foods do not align with your other objectives.

Comment

Representation ID: 10062

Received: 28/07/2022

Respondent: Great Denham Parish Council

The Parish Council discussed the draft Local Plan 2040 which has been made available for consultation at its meeting on Monday 4th July 2022, and wishes to highlight the following areas that it is unhappy with:
Insufficient provision has been made to address the lack of primary and secondary school places to go with the additional housing proposed.

Lastly, the Council asks that the flood plain is maintained and protected; the floods of 2020 demonstrated that flooding poses a real risk to areas of Great Denham, and housing development should not be permitted where flooding or threat of flooding has occurred.

Object

Representation ID: 10155

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Visions and Objectives
We support the broad intentions set out in the ‘Vision and Objectives’ in so far as they seek to deliver a greener, more sustainable and more attractive place to live, but there are overly optimistic statements about infrastructure delivery. Furthermore, the vision for new settlements is flawed and there is no recognition of the importance growth located on the edge of the most sustainable locations, the urban area and larger existing sustainable settlements.

Object

Representation ID: 10205

Received: 29/07/2022

Respondent: Trustees of the Lawton Pension Scheme

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Vision and Objectives of the Plan
2.4 The delivery of greener, more sustainable, more attractive, and prosperous places to live and work within the borough is supported and reflects the overarching goals of the National Planning Policy Framework for the delivery of development nationally. These are addressed throughout the themes and objectives of the plan showing clear recognition of their importance in ensuring the delivery of sustainable development to benefit local communities and their economies. Furthermore, the ‘Vision’ sets out a clear intention to enhance the sustainability of the borough in response to climate change, adapting and mitigating to its effect through various means. This is of growing importance in planning policy and presents clear acknowledgement of the issues and the council’s desire to employ a robust response through the themes and objectives that are set.
2.5 The value of protecting the open countryside through sensitive development is not disputed, local landscapes throughout the borough are of significant value, providing the setting for sporadic rural settlements surrounding the primary settlement of Bedford Town. It is agreed that appropriate development in rural locations is of value in supporting the delivery of much needed housing and employment and rural facilities and services, provided the intrinsic character and beauty of the countryside is respected.
2.6 The ‘Vision’ makes very bold statements about the delivery of infrastructure, and this must go further than to simply ‘support growth’, it must underpin the delivery of the spatial strategy, and be front-loaded so that without it the major strategic allocations do not make a head start and risk overloading the existing substandard network. Major residential development is “much needed” but it cannot be reliant on a strategy that places the burden and control over the delivery of infrastructure to outside stakeholders. Lessons from Wixams will tell us that the process of delivering new settlements takes much longer than at first considered and the delivery of key infrastructure must be implemented before work begins.
2.7 The ‘Vision’ stops short of locating development in the most sustainable locations on the edge of the urban area and the most sustainable rural settlements. This is a flawed approach. This is a new plan and whilst regard should be had the recently adopted plan, it must take its own steps to deliver dwellings in the most sustainable locations on the edge of the most sustainable settlements. Presently it does not do that.
2.8 In summary, the Vision and Objectives outlined are broadly supported if the applied spatial strategy delivers sustainable development throughout the borough in support of existing settlements, whilst acknowledging the importance of delivering infrastructure in advance of new development especially where it is sensitive to the impacts of development on countryside locations.

Object

Representation ID: 10215

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Visions and Objectives
We support the broad intentions set out in the ‘Vision and Objectives’ in so far as they seek to deliver a greener, more sustainable and more attractive place to live, but there are overly optimistic statements about infrastructure delivery. Furthermore, the vision for new settlements is flawed and there is no recognition of the importance of growth located on the edge of the most sustainable locations, the urban area and larger existing sustainable settlements.

Object

Representation ID: 10221

Received: 29/07/2022

Respondent: Mr Ben Pile

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Vision and Objectives of the Plan
2.4 The delivery of greener, more sustainable, more attractive, and prosperous places to live and work within the borough is supported and reflects the overarching goals of the National Planning Policy Framework for the delivery of development nationally. These are addressed throughout the themes and objectives of the plan showing clear recognition of their importance in ensuring the delivery of sustainable development to benefit local communities and their economies. Furthermore, the ‘Vision’ sets out a clear intention to enhance the sustainability of the borough in response to climate change, adapting and mitigating to its effect through various means. This is of growing importance in planning policy and presents clear acknowledgement of the issues and the council’s desire to employ a robust response through the themes and objectives that are set.
2.5 The value of protecting the open countryside through sensitive development is not disputed, local landscapes throughout the borough are of significant value, providing the setting for sporadic rural settlements surrounding the primary settlement of Bedford Town. It is agreed that appropriate development in rural locations is of value in supporting the delivery of much needed housing and employment and rural facilities and services, provided the intrinsic character and beauty of the countryside is respected.
2.6 The ‘Vision’ makes very bold statements about the delivery of infrastructure, and this must go further than to simply ‘support growth’, it must underpin the delivery of the spatial strategy, and be front-loaded so that without it the major strategic allocations do not make a head start and risk overloading the existing substandard network. Major residential development is “much needed” but it cannot be reliant on a strategy that places the burden and control over the delivery of infrastructure to outside stakeholders. Lessons from Wixams will tell us that the process of delivering new settlements takes much longer than at first considered and the delivery of key infrastructure must be implemented before work begins.
2.7 The ‘Vision’ stops short of locating development in the most sustainable locations on the edge of the urban area and the most sustainable rural settlements. This is a flawed approach. This is a new plan and whilst regard should be had the recently adopted plan, it must take its own steps to deliver dwellings in the most sustainable locations on the edge of the most sustainable settlements. Presently it does not do that.
2.8 In summary, the Vision and Objectives outlined are broadly supported if the applied spatial strategy delivers sustainable development throughout the borough in support of existing settlements, whilst acknowledging the importance of delivering infrastructure in advance of new development especially where it is sensitive to the impacts of development on countryside locations.

Object

Representation ID: 10233

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Visions and Objectives
We support the broad intentions set out in the ‘Vision and Objectives’ in so far as they seek to deliver a greener, more sustainable, and more attractive place to live, but there are overly optimistic statements about infrastructure delivery. Furthermore, the vision for new settlements is flawed and there is no recognition of the importance growth located on the edge of the most sustainable locations, the urban area, and larger existing sustainable settlements.

Object

Representation ID: 10240

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Visions and Objectives
We support the broad intentions set out in the ‘Vision and Objectives’ in so far as they seek to deliver a greener, more sustainable and more attractive place to live, but there are overly optimistic statements about infrastructure delivery. Furthermore, the vision for new settlements is flawed and there is no recognition of the importance growth located on the edge of the most sustainable locations, the urban area and larger existing sustainable settlements.

Object

Representation ID: 10253

Received: 29/07/2022

Respondent: J C Gill Developments Ltd

Agent: Optimis Consulting

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Visions and Objectives
We support the broad intentions set out in the ‘Vision and Objectives’ in so far as they seek to deliver a greener, more sustainable and more attractive place to live, but there are overly optimistic statements about infrastructure delivery. Furthermore, the vision for new settlements is flawed and there is no recognition of the importance growth located on the edge of the most sustainable locations, the urban area and larger existing sustainable settlements.

Comment

Representation ID: 10370

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

• Healthcare provision: Successive Labour and Conservative Governments have put Bedford Hospital at risk – in light of population growth we hope these plans can now be permanently shelved. However, there is a growing crisis in access to GP services and access to primary healthcare, with staffing levels of family GPs in Bedfordshire among the lowest in England per number of patients

Support

Representation ID: 10378

Received: 29/07/2022

Respondent: Liberal Democrat Party Bedford Borough Council

• The aim to continue to establish Bedford as a place for innovation is very important. We welcome the emphasis on attracting new high-tech businesses and bringing high-skilled jobs to the Borough, as well as enhancing skills and education.

Object

Representation ID: 10494

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Although BP welcome the aim of creating a safe built environment, it would be significantly strengthened through direct references to Secured by Design and reducing crime. In doing so, it would being Theme 4 into much closer alignment with:

• Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July 2021) (NPPF);

• Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5;

• Bedford Borough Community Safety Partnership – Community Safety Partnership Strategic Plan – 2020-2023 – Vision; and

• Section 17 of the Crime and Disorder Act 1998 (as amended).

Furthermore, National Planning Practice Guidance (NPPG) is very clear that:

‘Planning provides an important opportunity to consider the security of the built environment, those that live and work in it and the services it provides.

Section 17 of the Crime and Disorder Act 1998 (as amended) requires all local, joint and combined authorities (as well as National Parks, the Broads Authority and the Greater London Authority) to exercise their functions with due regard to their likely effect on crime and disorder, and to do all they reasonably can to prevent crime and disorder. Crime for these purposes includes terrorism.’

Paragraph: 009 Reference ID: 53-009-20190722
Revision date: 22 07 2019

‘Good design that considers security as an intrinsic part of a masterplan or individual development can help achieve places that are safe as well as attractive, which function well, and which do not need subsequent work to achieve or improve resilience. However good security is not only about physical measures and design, it requires risks and mitigation to be considered in a holistic way…

‘Good design means a wide range of crimes from theft to terrorism are less likely to happen by making committing those crimes more difficult.’

Paragraph: 010 Reference ID: 53-010-20190722
Revision date: 22 07 2019

This has been expanded on by the National Model Design Code (July 2021) (Parts 1 and 2), which makes the following points:

• Page 32 – Paragraph 63 (iv) – Safety and Security – ‘All schemes should aim to create a safe and secure environment and provide a sense of security for all users. Where development is for or has potential for a significant concentration of people schemes should also consider appropriate and proportionate security measures.’

• Page 61 – Paragraph 144 – Secured by Design – ‘Neighbourhoods need to be designed to make all people feel safe and to reduce the incidents of crime in accordance with the recommendations of Secured by Design which includes guidance for housing, commercial space, schools, hospitals and sheltered accommodation. Support and advice is available from the police through a network of Designing Out Crime Officers (DOCOs) across the UK. Secured by Design advice incorporates proven crime prevention techniques and measures into the layout and design of places and spaces.