4.21

Comment

Representation ID: 9184

Received: 10/06/2022

Respondent: Mr Russ Maddox

Many thanks for the brochure outlining the local plan for the future.

One thing that’s obviously missing from the plan, unless I’ve missed it, is where is the provision for a new or extra hospital facilities, or expansion of the NHS services? With endless house building and planning the local hospital is under strain (12 hour wait at A & E is not uncommon) yet no provision highlighted on plan.

Whilst funding may come from central government finances, surely you’ve made reservations about implimenting the plan, without seeking assurances about public services?
Thank you

Object

Representation ID: 9330

Received: 28/07/2022

Respondent: Mr Eric Benton

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Infrastructure Delivery Plan outlines the requirement without explaining adequately how this can be achieved. The likely effect of increased traffic is a major problem, partcularly approaching the A421 on the A6 from the South

Comment

Representation ID: 9555

Received: 19/07/2022

Respondent: Oakley Parish Council

Oakley PC considers that insufficient consideration has been given to senior school places for students from new developments. 500 homes will be built in Clapham and Bromham but Lincroft School is in a poor state of repair and has no space to expand to accommodate additional students. School place planning is not transparent in the 2040 Plan.

Comment

Representation ID: 9556

Received: 19/07/2022

Respondent: Oakley Parish Council

Oakley PC considers that insufficient consideration has been given to how adequate water and sewage systems can be supplied to new developments as Bedford Borough is in one of the driest parts of the country.

Comment

Representation ID: 9567

Received: 20/07/2022

Respondent: English Regional Transport Association

Oxford-Cambridge Expressway(including A428 Black Cat Junction improvements) – This will bring no benefit at all to Bedford. The new road will affect Green Belt areas, and will bring in more traffic which is already increasing with the significant housing growth between these two towns.

Prebend Street Relief Road and dualling of Bedford Western By-pass This will bring more traffic and the Government is pitifully complacent on CO2 emissions

Object

Representation ID: 9597

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

In the Summary of Comments document (on the Issues and Options stage) the need for effective cross boundary planning is not properly addressed, despite our representation and others in a similar vein.
The Duty to Co-operate Submission Statements (amongst the supporting documents to the Submission Plan) provide no further reassurance, in fact they serve to highlight the inadequacy of the co-operation. It is stated that the discussion with neighbouring authorities has proceeded without any disclosure of potential allocations, so it is difficult to see how it might have yielded effective outcomes. There is no evidence of engagement with South Cambridgeshire, which would seem to be vital given the implications for the A421. Furthermore, the statements identify a long list of cross boundary considerations noting potential significant impacts arising from what is proposed. These are precisely the matters that should have been subject to detailed discussion and resolution, to inform policy formulation, particularly the approach to the delivery and the timing of development relative to cross boundary infrastructure. Instead, these critical considerations are identified as ‘requiring further co-operation’ and the relevant strategic policies fail to address delivery issues entirely. The Statement records no progress on the relevant matters and as such is not in the spirit of or reflective of the approach required by the NPPF (paragraphs 24-27). On this basis, the Plan is at risk of being found not to be effective in the terms of the NPPF: the allocations reliant on cross boundary infrastructure ‘are not deliverable over the plan period, based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.’ The stated position in the DtC Submission Statements is that all major issues are deferred.


U&C are used to working in circumstances where there is an absence of clarity on infrastructure timing and delivery. Bedford Borough Council must be applauded for wanting to get on with the job, even though so much contextual information and infrastructure commitment is lagging. It is not, however, appropriate to simply ignore the very significant burden that uncertain infrastructure requirements place upon development and make allocations without constraint or regard for the potential implications. Where allocations are dependent upon significant, future infrastructure investment, policy should be clear that the development must either deliver that infrastructure (identify developer contributions) or cannot proceed until there is a clear commitment to delivery. The lack of clarity in the Policies, contingent upon investment in East West Rail or other significant infrastructure, risks delivery of the Plan allocations and potentially compromises the proper planning and delivery of growth elsewhere within the Central Area.
It appears to be possible to shape allocations for the earlier part of the Plan period, which can be justified by the evidence base, as it stands (it appears comprehensive in respect of localised need and impacts) and then to shape more broadly scoped policies for longer-term growth locations. While the NPPF/PPG provides limited guidance on the form of such policies, it does point to them shaping a process as a way forward, including further work required. In our experience as a master developer, it is helpful if such policies:
• are explicit about the limitations of the evidence base at the point the Plan is prepared.
• identify the issues and inter-dependencies that are relevant to determining the future scale and location of growth within the broad parameters identified;
• are clear about the pre-requisite infrastructure requirements and associated triggers (or addresses the need to resolve this at a later date, when there is further clarity);
• scope the further work and the cross-boundary collaboration which is necessary to safeguard comprehensive and co-ordinated development.

Comment

Representation ID: 9610

Received: 29/07/2022

Respondent: Wilshamstead Ward

Development from Central Bedfordshire Council
The Local Plan 2040 appears to take no account of the significant amount of development proposed by Central Bedfordshire Council in their own Local Plan, which is immediately south of Wixams and Wilstead. (Wixams being a shared development between the authorities). The cumulative effect of both Local plans will be to put overwhelming press on local roads and services around the A6 through Wilstead and Wixams. The failure to consider this issue will only be to the detriment of good planning and the soundness of either Local Plan.

Comment

Representation ID: 10114

Received: 29/07/2022

Respondent: Mr Martin Towler

I would like to see more work done by developers before any sizeable development is built the local services and infrastructure are bolstered ,doctors surgery's ,hospital development local shops ,transport etc this needs to be in place before not after then go back after to reduces its input if your building that many house per year it inflicts on the present borough residents

Object

Representation ID: 10466

Received: 29/07/2022

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Please see accompanying Representations Report (Chapter 2)

As part of the Summer 2021 Consultation upon Preferred Strategy Options and Draft Policies (para 1.45 and 8.35) our client objected to the failure to prepare a Draft Infrastructure Delivery Plan to inform the testing of reasonable alternatives and identification of an appropriate strategy.

The Council’s submission version Bedford Local Plan 2040 and its evidence base, including the published IDP, both fail to recognise the requirements for expansion at Lincroft Academy notwithstanding our client’s earlier submissions and that this need is acknowledged by the Borough Council’s Education department.

In relation to our client’s interests at Lincroft Academy Site ID: 832 / 839 MAT further objects to the failure to respond to the school’s clear and urgent requirement for expansion as part of determining the spatial strategy and distribution of growth through the plan-making process.