1.1

Showing comments and forms 31 to 60 of 81

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6130

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

Representation Summary:

Staploe Parish Council believe that Bedford Borough Council should request an extension to this plan in view of the importance of the East West rail route decisions, the delays in the Oxford Cambridge Arc process, the potential introduction of development corporations, the difficulty in consulting and public engagement due to the Covid pandemic and the potential changes in the housing need calculations. We believe that Bedford Borough Council should prepare twin track local plans for presentation based on the 2014 vs 2018 housing need figures. Use of the latter would not necessitate a significant new settlement.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6154

Received: 09/09/2021

Respondent: Savills

Agent: Savills

Representation Summary:

Strategic Planning Matters and the Duty to Cooperate
The consultation documents say surprisingly little about strategic planning matters or the position in respect
of cooperation discussions across local authority boundaries.
Strategic policy-making authorities are required to cooperate with each other, and other bodies, when
preparing, or supporting the preparation of policies which address strategic matters. This includes those
policies contained in local plans.
Section 19 of the Planning and Compulsory Purchase Act 2004 relates to the preparation of local
development documents. Section 19 (1B) states:
“Each local planning authority must identify the strategic priorities for the development and use of land in the
authority's area.”
It is not obvious as to how this emerging Local Plan will comply with this.
Paragraph 24 of NPPF (2021) states:
“Local planning authorities and county councils (in two-tier areas) are under a duty to cooperate with each
other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.”
The duty to cooperate is a legal test that requires cooperation between local planning authorities and other
public bodies to maximise the effectiveness of policies for strategic matters in Local Plans. It is separate from
but related to the Local Plan test of soundness.
The statutory duty to co-operate is found in section 33A - Duty to co-operate in relation to planning of
sustainable development, of the Planning and Compulsory Purchase Act 2004.
The following is a quote from sub-section 4 of 33A.
“(4) For the purposes of subsection (3), each of the following is a “strategic matter”—
(a) sustainable development or use of land that has or would have a significant impact on at least two
planning areas, including (in particular) sustainable development or use of land for or in connection with
infrastructure that is strategic and has or would have a significant impact on at least two planning areas, and
(b) sustainable development or use of land in a two-tier area if the development or use—
(i) is a county matter, or
(ii) has or would have a significant impact on a county matter.”
Paragraph 17 of the NPPF requires local planning authorities to prepare a development plan that includes
strategic policies to address each local planning authority’s priorities for the development and use of land in
its area. These strategic policies can be produced in different ways, depending on the issues and
opportunities facing each area, for example through a joint or individual local plan.
It would be useful to see an explanation on this prior to the next consultation. If the Council considers that
the Local Plan does not contain any of the strategic matters laid out under the 2004 Act then this should be
explained. There are examples where Local Plans have not been successful at examination because of this
matter, for example St Albans City and District.
Timescales including Plan Period
We agree that the 2030 Local Plan needs to be reviewed and for a new local plan to be prepared.
We note at paragraph 1.1 that the update to the local plan is described as having to reflect emerging national
policies for the Oxford to Cambridge Arc and that Policy 1 of the Local Plan 2030 requires that the review is
progressed swiftly, with the submission of the plan to Government for examination by January 2023 so that
examination in public can commence. We consider an ambitious timescale is necessary here and would
question whether submission in January 2023 at the earliest, as identified in the January 2021 Local
Development Scheme, is sufficiently ambitious. This would only bring about adoption of the new local plan at
the end of 2023 at the earliest.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15 year period
from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising
from major improvements in infrastructure. Where larger scale developments such as new settlements or
significant extensions to existing villages and towns form part of the strategy for the area, policies should be
set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for
delivery.
It seems likely that this emerging new local plan will include larger scale development of at least one of the
examples provided under paragraph 22 which suggests that whilst the proposed plan period to 2040 can be
seen to be reasonable, the local plan should include a vision that looks further ahead to 2050 or beyond.
The Tests of Soundness
It is acknowledged that this consultation does not require consultation responses to comment against the
tests of soundness found at section 3 plan-making of the NPPF (2021) but it is nonetheless relevant to have
these in mind now ahead of preparation of the submission version local plan.
Monitoring and Review
Paragraphs 31 to 33 of the NPPF (2021) provides policy guidance on preparing and reviewing plans. Whilst
it is acknowledged that reviews at least every five years are a legal requirement for all local plans under
Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012), it is still
necessary for a Local Plan to contain proposals for monitoring against targets and conditions that are
envisaged to give rise to a review ahead of the requirement under the 2012 Regulations.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6331

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

Representation Summary:

BACKGROUND TO THE LOCAL PLAN REVIEW AND ITS RELATIONSHIP WITH NATIONAL POLICY AND OTHER MATERIAL CONSIDERATIONS
Summary of Local Plan 2030 and Requirement for Immediate Review
The Bedford Local 2030 was adopted subject to the provisions of Policy 1 – ‘Reviewing the Local Plan 2030’. The Inspectors’ Report provides further clarification of the requirement for Modifications introducing the approach to this Policy and that it was considered essential for soundness.
Paragraph 1.1 of the Council’s Preferred Options Consultation Document affirms the significance of the ‘guillotine’ mechanism inserted within the review policy, which engages paragraph 11(d) of the NPPF2021 in the event that a new Plan is not submitted for Examination before January 2023. While the Borough Council is aware it cannot avoid the consequences for the statutory development plan of failing to adhere to these timescales the Preferred Options published for consultation must also address the reasons for first introducing Policy 1. Drawing from the Inspectors’ Report:
• Paragraph 17 emphasises the importance of considering longer-term requirements and thus together with other issues with the Plan a need for the review to be undertaken as quickly as possible with the three-year timeframe providing balance to allow work to be completed effectively
• Paragraphs 33-34 anticipate that the review will consider the balance between jobs and workers including any changes in the balance of net out-commuting and the implications of the Oxford-Cambridge Arc
• Paragraph 40 confirms that the Local Plan 2030’s housing requirement was determined as 970 dwellings per annum as a result of transitional arrangements for the Examination of Plans under the 2012 version of the Framework.
• Paragraph 113 confirms an expectation of two reviews before 2030 to address potential issues of non-delivery, maintain a buffer in supply and to ensure that the allocation/supply of housing is sufficient to meet the identified need, which is, itself, likely to change over time (as calculated by the government’s standard method).
• Paragraph 123 recognises that the continued existence of a five-year supply of deliverable sites (within the provisions of the Local Plan 2030) is dependent on the progress with constrained capacity in the urban area and bringing forward allocations within Neighbourhood Plans quickly. The scope for early review is to allow for potential issues of non-delivery to be addressed and to consider the requirement for any additional housing site allocations in the light of evidence on housing need and realistic supply at that time.
Paragraph 18 of the Inspectors’ Report confirms that Policy 1 cannot set the parameters of the updated Local Plan. While there is a desire for alignment with the delivery of cross-boundary strategic priorities (including those related to the delivery of the Oxford-Cambridge Arc) the requirement for review is a result of the deficiencies with the approach put forward by the Council in the Local Plan 2030.
The appointed Inspectors determined (in the context of the 2012 Framework) it would not be effective for the policies of the Local Plan 2030 to look beyond that date. The findings of soundness are predicated on the context of a very narrow remit of addressing the area’s strategic priorities (and even then, only with the application of the three-year ‘guillotine’ following adoption).
It is not open to future Inspectors to reach the same conclusion. This emphasises the importance of the first paragraph of Policy 1 and the overriding objective of the aim of the review to secure levels of growth that accord with government policy. This establishes grounds for a Plan that must be fundamentally deliverable / developable over the plan period and cannot further defer relevant decisions relating to options to meet the area’s strategic priorities.
n not fully responding to the reasons and scope of requirements for the review and subsequent update of the Local Plan the Council risks rolling forward several of the same fundamental shortcomings in the Local Plan 2030. This is not only contrary to the objectives of sustainable development but in the context of the most recent policy and guidance simply fails to provide the basis for a sound Local Plan.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6407

Received: 13/09/2021

Respondent: Mr Steven Kent

Representation Summary:

This is understood. Detailed responses are set out below. One overriding objection is that the Pandemic has shifted a large number of the criteria for planning. It is not clear how work and social patterns will evolve in a post pandemic world. What is clear is that trends that were underway pre pandemic have been accelerated. Increased working from home and an increase in online retail will shift traffic away from town and city centres. We must therefore focus planning on improving the utility of our town and city centres and develop the brownfield sites in those centres rather than continue to unsustainably build on open countryside.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6640

Received: 14/09/2021

Respondent: Bedford Borough Councillor

Representation Summary:

RESPONSE OF THE CONSERVATIVE GROUP
Initial Comment:
This is a Group response and should not be taken as the complete response of any individual councillor, each of whom may have particular concerns in relation to their particular wards.
A weakness of the 2030 Plan, which we articulated at the time, was that it did not, as confirmed by the Inspector, adequately take account of future needs. That was perhaps inevitable given the uncertainty around the impact of the Oxford- Cambridge Arc and the impossibility of assessing how it will affect any given local authority within its area. That uncertainty remains and the Group regards it as absurd that the Borough is required to submit its plans for development up to 2040 without knowing what will be proposed in the Government’s Spatial Framework for the Arc; that is expected in early 2023, almost exactly when the Borough’s 2040 Plan must be submitted for approval.
The Group will support any attempts to persuade the Government that more time needs to be allowed so that the Spatial Framework can be taken into account in the preparation of this plan. Not to do so creates a clear risk that the areas identified for growth in the Local Plan will differ from those similarly identified in the Spatial Framework. It is not joined up government.
We are disappointed that the full range of options set out in the Development Strategy Topic Paper has effectively been excluded from full consideration both by the absence of any open debate in Council about strategy and by the restricted list of options set out in the Summary Paper sent out to residents. For most that will be the only document they see and for it to include only four options is not open government.
There is an added difficulty for those rural residents in locations named in the various options; for example the various “transport corridors”. The fact of possible inclusion offers no clue as to what the impact might be in practice given the areas covered by the locations and the numbers of villages they contain.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6658

Received: 14/09/2021

Respondent: Stevington Parish Council

Representation Summary:

National Context and Plan Period: SPC is aware that the spatial framework for the Oxford Cambridge Arc and the East West rail route are still in the process of being finalised. The spatial framework for the Arc will not be available until January 2023. As the content of this framework will affect the 2040 local plan, SPC accept that the council needs flexibility in the planning process to take account of this as circumstances change and details emerge. In particular we expect the Borough council to adapt plans to address escalating climate change impacts.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6675

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Representation Summary:

para 1. Introduction
The treatment of housing numbers references the Oxford to Cambridge Arc but does not make clear how that has influenced the number of new homes proposed in the Draft Local Plan 2040. The Introduction should state clearly whether the 25500 new homes proposed by 2040 includes an allowance for a housing demand generated by the Oxford to Cambridge Arc project and if it does, state what it is, either as a number of new homes or as a percentage of the 25500 total.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6679

Received: 14/09/2021

Respondent: Willington Parish Council

Representation Summary:

3. Within the Local Plan 2030 the future potential to develop a new settlement at Thurleigh Airfield is mentioned, however there is no mention of this within the Strategy Options and Draft Policies Consultation document.
4. The infrastructure in the Borough is already stretched and utilising opportunities such as Thurleigh Airfield would present an opportunity to develop disused land and create new infrastructure to support the growth, rather than stretching the existing provision in the south and east of the Borough.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6913

Received: 15/09/2021

Respondent: Mr Mark Tippett-Wilson

Representation Summary:

• According to your documents factual and technical information is still being gathered for the site assessment work. When will this be completed and the findings published, and will there be further consultations when the complete documents are published

• I could not find where the proposed East West Rail route maps onto the local plan, would it not make sense to include these in the local plan so that residents can see where the current green belt land will change into brown belt land and then could subsequently be open to the building of dwellings

• Within the current urban area of Bedford have the following been looked at for development and the building of additional dwellings, and if so what are the dwelling numbers:-
o Empty shops
o Flats above shops
o Empty pubs, such as the Phoenix that has been empty for many years
o Various areas of unutilised land within urban areas
o Under utilised car parks, that are used less now since many shop closures.

• What impact has the corona virus had on the need housing. Sadly many people have died, has this increased the empty dwellings in the area, or perhaps this is not known until probate has been carried out, please advise

• There are many warehouses being build on the outskirts of Bedford, if there is such a shortfall of housing should these not be made into dwellings, please advise.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6966

Received: 16/09/2021

Respondent: Mr Robert Tusting

Representation Summary:

Staploe Parish Council believe that Bedford Borough Council should request an extension to this plan in view of the importance of the East West rail route decisions, the delays in the Oxford Cambridge Arc process, the potential introduction of development corporations, the difficulty in consulting and public engagement due to the Covid pandemic and the potential changes in the housing need calculations. We believe that Bedford Borough Council should prepare twin track local plans for presentation based on the 2014 vs 2018 housing need figures. Use of the latter would not necessitate a significant new settlement.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7236

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

Representation Summary:

The provision of First Homes came into effect from 28 June 2021. The consultation does not include any information on what will be required in the Local Plan moving forward. It is critical that site promoters and developers are able to understand what the Council will
seek on sites as part of the Local Plan updates. We note that within the evidence bases the Council has produced they have been part of the consideration to date, and therefore a policy update to clarify would be prudent.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7237

Received: 17/09/2021

Respondent: Bedford and Milton Keynes Waterway Trust

Representation Summary:

Background
The Bedford and Milton Keynes Waterway Park will establish a new waterway, within a multifunctional green corridor, linking the Grand Union Canal at Milton Keynes with the River Great Ouse in Bedford. It will close a small but very significant gap in the UK waterway network, enhancing opportunities for flood risk management in the upper Ouse catchment area and for water transfer between the main network and the drier areas of East Anglia. It will build on the achievements of the Marston Vale Community Forest in regenerating parts of the corridor and creating new habitats between Bedford and Milton Keynes. It will set the context for, and embed new natural capital into, new and expanding communities thus, contributing towards the Government’s commitment to leave the environment in a better state for future generations.
Part of the route of the Waterway Park runs through Bedford from Kempston Mill to Green Lanes on the boundary with Central Bedfordshire.
Potential Outputs
The project sits at the heart of the Oxford to Cambridge corridor. It will
• help preserve and enhance natural capital in the area
• deliver infrastructure resilience to future risks of flooding and contribute towards the challenges of climate change
• provide a mechanism for the transfer water to areas of drought when required
• provide new direct pedestrian and cycle routes between Bedford and Milton Keynes
• create opportunities for healthy lifestyles
• contribute to economic growth by developing new tourism opportunities in an underperforming area and increasing land value
Policy support and alignment
25 Year plan for the Environment
The Waterway Park aligns closely with a number of the goals of the Government’s 25-year plan for the environment
Clean and plentiful water
• reducing the damaging abstraction of water from rivers and groundwater, ensuring that by 2021 the proportion of water bodies with enough water to support environmental standards increases from 82% to 90% for surface water bodies and from 72% to 77% for groundwater bodies

Flood risk is identified by Environment Agency as a key issue cross-Arc, particularly regarding future climate change. Water shortages are a related, but critical, issue.
Water connectivity in the central section of the Arc is poor. The Waterway Park offers the opportunity to manage flood risk and water storage and movement, whilst bringing with it a range of other environmental, social and economic benefits. Early investment in the green/blue infrastructure throughout the route of the waterway park will enable existing and growing communities to see some early benefits as well as improving health and well-being for those living and working in the area.
The Environment Agency is currently investigating the potential of using the B&MK Waterway Park to manage and reduce flood risk. The EA is also considering the contribution the Waterway Park could make to the storage of flood water in local catchments and a reduction of flood risk within Milton Keynes and Bedford.

Thriving plants and wildlife
• creating or restoring 500,000 hectares of wildlife-rich habitat outside the protected site network, focusing on priority habitats as part of a wider set of land management changes providing extensive benefits
• increasing woodland in England in line with our aspiration of 12% cover by 2060: this would involve planting 180,000 hectares by end of 2042

Enhancing beauty, heritage and engagement with the natural environment
• safeguarding and enhancing the beauty of our natural scenery and improving its environmental value while being sensitive to considerations of its heritage.
• making sure that there are high quality, accessible, natural spaces close to where people live and work, particularly in urban areas, and encouraging more people to spend time in them to benefit their health and wellbeing
• focusing on increasing action to improve the environment from all sectors of society

The Waterway Park route runs directly through land owned and managed by the Forest of Marston Vale. Since it was established as a community forest in the 1990s the Forest of Marston Vale Trust has planted over 2m trees and created 12 new woodland sites resulting in an additional 4,917 tonnes of carbon removed from the air annually. The Waterway will add a new dimension to the community forest and open up opportunities for more planting, footpaths, cycleways and bridleways to encourage access to the natural environment between Bedford and Milton Keynes. The Forest of Marston Vale is a clear example of intervention which has significantly enhanced the natural environment and ensured there’s a net environmental gain as development takes place.
The Bedford and Milton Keynes Waterway Trust is currently working with partners on a case study to quantify the potential levels of biodiversity net gain which the waterway can deliver. The outcomes will be available later in 2021.

Mitigating and adapting to climate change
• making sure that all policies, programmes and investment decisions take into account the possible extent of climate change this century
• implementing a sustainable and effective second National Adaptation Programme

A further dimension of the flood risk management study referred to above will be a review of the capacity of the Waterway to contribute to water transfer to help mitigate the impacts of climate change. Overseen by WRE this element of the study will report in October 2021.

Biodiversity/Green and Blue Infrastructure
The Waterway Park is one of 6 strategic priority projects supported by Bedfordshire Local Nature Partnership and the Buckinghamshire and Milton Keynes Natural Environment Partnership.
Local Plan Policies
All three local Plan along the route have policies to support the Waterway Park and Protect the route. The outcomes of the Environment Agency and Water resources East study will have the potential to enhance and strengthen Local Plan policy support in relation to the route and land use planning.
Bedford Borough Council Local Plan
Current policy
Allocations and Designations: Local Plan 2013 Policy AD27 Bedford to Milton Keynes Waterway Park refers specifically to the route of the waterway.
The Council will support the creation of the Bedford to Milton Keynes Waterway Park as a strategic green infrastructure link benefitting the borough as a whole, but particularly important to the delivery of sustainable growth in the Northern Marston Vale. The indicative route of the Waterway Park is shown on the Policies Map. Where appropriate, development will be expected to contribute towards the creation and delivery of the Waterway Park. Pre-determination archaeological evaluation is required.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7246

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

Representation Summary:

De Merke Estates reserve comment on other aspects and policies of the Local Plan which have not been published in this ‘Strategy options and draft Policies’ consultation document. De Merke Estates are aware that the new NPPF and this will require BBC to revisit their strategy and policies, particularly given that the growth options which include new settlement which requires policies to be set within a vision lasting 30 years, rather than the 15 years currently set out in this consultation document.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7249

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

Representation Summary:

This section deals with De Merke’s site-specific promotion of Land East of Green Lane, Clapham. A Vision Document summarising the technical pack of assessments that are available has been provided at Appendix 1 and indicative masterplans for up to 100 homes and access drawings at Appendix 2.
The Site has recently been considered as a reasonable alternative in the Clapham Neighbourhood Plan Strategic Environmental Assessment. The Site was however part of a larger parcel able to accommodate in the region of 500 homes. Given the progression of the East- West Rail route, it has become increasingly obvious to the landowner, De Merke Estates, that a strategic allocation for 500 homes would not be possible with the rail route dissecting the site. A smaller area of the site, capable of around 100 homes has instead been progressed.
This master-plan of the site has been formed from advice from landscape and highways consultants and their respective specialist reports written in support of the site. The layout of the housing indicates that future access will be possible across De Merke’s Land ownership to allow further connections to land north east of Clapham (west of The Baulk).
The density of the residential development on the site is reflective of the local area and would provide in the region of 100homes in a policy compliant mix, including the delivery of affordable housing, in a sustainable location.
In summary, there are no environmental constraints to developing the site, which is currently tenanted agricultural land.
Along with delivering much needed homes and potential future access to land north-east of Clapham, the Site would deliver economic benefits such as:
• construction jobs
• ongoing site landscaping jobs
• Increased roles for companies managing SUDS, Foul Water, and Site Management and Maintenance
• Increased spending in the local area
• CIL payment to Local Authority and financial support to Parish Councils.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7260

Received: 01/09/2021

Respondent: Wyboston Lakes Ltd

Agent: Brown & Co Barfords

Representation Summary:

The proposals outlined above in conjunction with the existing approved development will
achieve a sustainable mixed-use development and paragraph 105 of the National Planning
Policy Framework notes, such developments can have the benefit of “limiting the need to
travel and offering a genuine choice of transport modes. This can help to reduce congestion
and emissions, and improve air quality and public health. However, opportunities to maximise
sustainable transport solutions will vary between urban and rural areas, and this should be
taken into account in both plan-making and decision-making”.
The proposals outlined will help meet the more immediate housing need, improve local job
opportunities, and help stimulate sustainable growth in both Bedford Borough and
Huntingdonshire. It will also have the benefits of the suggested new settlement proposals in
terms of proximity of the A421 transport corridor and a proposed new rail station at St.
Neots/Tempsford, with further advantages such as the use of previously developed land,
existing infrastructure, and nearby facilities. Additionally with its smaller scale it is potentially
suited to smaller developers and paragraph 69 of the National Planning Policy Framework
notes small and medium sized sites can make an important contribution to meeting the
housing requirement of an area and are often built out relatively quickly.
The Borough Council’s June 2021 Development Strategy Topic Paper identifies the Council
will have to make a ‘step change’ in the delivery of new housing growth. However, a new
settlement at Wyboston and/or Little Barford will have a relatively long lead in time.
Additionally, four of the five EWR routes being consulted upon pass through the Little Barford
site, and the deliverability of this proposal and the potential number of dwellings it might
deliver will require further assessment following the decision on the route alignment. Given
these uncertainties, the Wyboston Lakes Complex proposal outlined above is readily available
and can come forward now, without being dependant on strategic infrastructure decisions.
The proposals are therefore able to assist in meeting the more immediate housing and
employment land shortfall in advance of the potential longer-term settlements coming
forward.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7313

Received: 02/09/2021

Respondent: Miss Emma Pegler

Representation Summary:

The draft Local Plan does not show how BBC has co-operated and consulted with adjoining authorities nor shown how its plans for housing properly fit into the overall plans for the area. As Dennybrook is right on the corner of Bedfordshire and the majority of the people in Colmworth village can show evidence that either their current doctor/school/station with the most convenient trains is not within Bedfordshire, there has to be significant discussion with adjoining authorities to make sure there will be increases in doctors and other facilities. There is a shortage of doctors located in our surrounding area and the only doctor I could register with when I moved to Colmworth is in Kimbolton outside our county. How has BBC co-operated to ensure there will be sufficient emergency services provided from our neighbours bearing in mind Dennybrook, for example is far from Bedford and it is reasonable to assume that people might gravitate naturally or out of necessity to, eg St Neots for all their needs particularly as the only major road is the A! which takes one to St Neots very quickly whilst the connection to Bedford is further via A1 or requires very narrow and poor backroads across country to get to Bedford. It is likely that Bedford station will not be the preferred station and many of my neighbours use St Neots and have done for many years particularly with fast trains not stopping at Bedford with any frequency. It is my understanding that there is a legal Duty to Cooperate and I see no evidence of this. Having met with the Mayor of St Neots I am aware of his concerns in this regard and the extra pressure Dennybrook would put on St Neots.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7320

Received: 02/09/2021

Respondent: Miss Emma Pegler

Representation Summary:

The NPPF requires that local plans are “shaped by early, proportionate and effective engagement between plan-makers and communities..” There is no evidence this has been addressed in the Draft Local Plan. My personal experience is that there has been no engagement.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7366

Received: 31/08/2021

Respondent: Lone Star Land

Agent: Pegasus Group

Representation Summary:

Pegasus Group are instructed by Lone Star Land Ltd ("Lone Star") to submit representations to the Regulation 18 consultation Bedford Local Plan 2040 (the "draft Plan").
Lone Star control 1.8 hectares of land south of Roxton Road in Great Barford (the "Site", or the "Lone Star Site" - see land control plan at Appendix A). The Lone Star Site has been assessed as part of the Council's Call for Sites, under site reference ID915.
Lone Star have been actively engaged with the local community and Great Barford Parish Council since acquiring an interest in the Site. In addition to maintaining a dialogue with Great Barford Parish Council's Neighbourhood Plan Sub-Committee, Lone Star have presented proposals for the Site to the local community via a website, the distribution of leaflets, an individual consultation event in October 2020 and participation at the "Meet the Developers" consultation event in November 2020. The Site is not allocated for development in the Made Neighbourhood Plan but did score well in the Parish Council's own assessment for deliverability.
Lone Star welcome the opportunity to engage further in the Local Plan process through these representations, having previously made representations to the now adopted Core Strategy and also having made submissions through the Council's Call for Sites.
The tests of soundness that Development Plans need to meet so as to be legally compliant and found sound, are set out in the National Planning Policy Framework (NPPF), paragraph 35:
• Positively prepared – providing a strategy which, as a minimum, seeks to meet objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and
August 2021 | KF | P19-0021 Page | 2
is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the Plan period, and 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; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework.
These tests of soundness, along with other legal and procedural requirements associated with the Plan-making process provide a contextual framework for these representations.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7420

Received: 03/09/2021

Respondent: Thakeham

Representation Summary:

These representations are made on behalf of Thakeham Homes in relation to the Regulation 18 Local Plan 2040 consultation.
About Thakeham
Thakeham is an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.
Thakeham build for the future, for communities and for individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in construction and zero carbon in lifetime use.
Each development is different and tailored to its locality, with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other stakeholders from the start of a project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.
The emerging Environment Bill sets out Government’s target of 10% Biodiversity Net Gain across development sites. However, through our landscaping approach, we will seek to achieve 20% Biodiversity Net Gain, including hedgehog highways, year-round variation for wildlife, as well as green and blue infrastructure, open space and play space.
We will engage local primary schools with our ‘Eddie & Ellie’s Wild Adventures’ initiative to promote the importance of ecology and biodiversity, delivering National Curriculum linked activities and early career-based learning.
At every stage, our approach is one that ensures we leave a legacy behind that everyone can be proud of.
Thakeham design all homes to be beautiful and reflect the character of the area. The materials used across all developments are of the highest quality. Thakeham builds all developments tenure blind to ensure no drop off in quality.
As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham we are committed to delivering sustainable, zero carbon communities.
Our level of commitment to sustainability means that we are streets ahead of our competitors and aiming for a far higher level of impact. Thakeham has become the first housebuilder in the UK, and one of only five in the construction sector globally to have made commitments on the SME Climate Hub, and be part of the United Nations’ Race To Zero campaign. As part of this, we have committed to the SME Climate Commitment. Recognising that climate change poses
a threat to the economy, nature and society-at-large, our company has pledged to take action immediately in order to halve our greenhouse gas emissions before 2030, achieve net zero emissions before 2050, and to disclose our progress on a yearly basis. Our sites will include the following sustainability improvements:
• All Thakeham homes will be carbon neutral in production and zero carbon in lifetime operation by 2025. This puts us well ahead of the pledges we have made as referred to above.
• On all Thakeham developments we follow industry best-practice by taking a ‘fabric first approach’, which looks at how design and materials can contribute to the energy performance of the completed building.
• We will also consider the potential for incorporating sustainable energy features, such as air-source or ground-source heat pumps, communal rainwater recycling, solar panels, battery storage, renewable energy tariffs, and highly efficient heating and hot water systems.
• Thakeham uses a UK-based factory which manufactures panels using timber from sustainable sources. The off-site panelised system improves efficiency, speed of construction, quality, and reduces carbon emissions.
• Our Sustainable Procurement Policy encourages the use of recycled materials, such as otherwise nonrecyclable waste plastics (One tonne of MacRebur mix contains the equivalent of 80,000 plastic bottles), as well as utilise products part of a circular economy.
• We ensure that our whole supply chain is a local as possible. We have gold membership with the Supply Chain Sustainability School.
• On site, we monitor and aim to minimise construction travel emissions, construction waste and energy consumption and are registered with the Considerate Constructors Scheme.
Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7433

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

Representation Summary:

I write on behalf of Mr. D De Massey (the client’) in response to the emerging (draft)
Local Plan (‘LP’) 2040 for Bedford Borough which has been published by Bedford
Borough Council (‘BBC’) for the purposes of public consultation under the provisions
of the Town and Country Planning (Local Planning) (England) Regulations 2012.
To ensure full disclosure, our client has an interest in land at Luton Road, Wilstead
which lies adjacent to the settlement and is largely surrounded by existing built form.
The site is referenced within the Site Assessment Document (June 2021) as Land
east of east of Luton Road, Wilstead (Ref ID: 714) within the evidence base which
has informed the consultation document. For the purposes of this letter, the site is
referred to as ‘Luton Road’.
The following is structured to provide succinct representations, on behalf of our client,
to those pieces of literature which have been published by the Council for the
purposes of this consultation. To this end, some contextual details are provided in
respect of the Luton Road site, thought is then afforded to the Council’s evidence
base: namely, the Development Strategy Topic Paper (2021), the Draft Sustainability
Appraisal Report (2021) and the Council’s Site Assessment (2021) publication.
Representations are then provided in response to the Local Plan 2040 – Draft Plan
Strategy Options and Draft Policies Consultation (2021), which has been published
for the purposes of public consultation. Those comments are largely constrained to
the proposed spatial options for growth and the proposed development management
policies.
Our client commends the significant work and undertaking which BBC have embarked
upon to produce and publish the emerging LP consultation document and we welcome
the opportunity to comment on its content at this stage.
The following comments are largely set out in order of their appearance within the
document and are made in the context of our client’s land interests as well as the
content of national planning policy and guidance.
Regarding the other issues which the emerging LP will seek to address, the client
reserves the right to comment on these during the course of future public consultation
events.
In conclusion, the efforts of BBC to produce the consultation document are to be
commended and the thrust and content of those initial draft policies contained therein
is largely welcomed. Whilst the client is supporting of growth Option 2a, it is their
position that the sustainability credentials of Wilstead be considered in greater depth
and the role which it can play in contributing to the future growth of Bedford Borough
be pragmatically assessed.
It is hoped that those revisions referred to above will be positively considered by the
Council and we would be more than happy to answer any questions which you may
have.
In light of the above, if you require clarification on any of those points which have been
raised above or require any further information in respect of the client’s site then
please do not hesitate to contact me via any of those channels listed.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7450

Received: 03/09/2021

Respondent: Phillip C Bath Ltd

Agent: DLP Planning Limited

Representation Summary:

This representation has been prepared by DLP Planning Ltd (DLP) on behalf of Philip C Bath Ltd in response to the Bedford Borough Council Local Plan 2040 consultation.
This representation relates to High Barns Farm, Roxton and their potential to provide for increased employment development. A location plan identifying the site is provided at Appendix 1.
BACKGROUND TO THE LOCAL PLAN REVIEW AND ITS RELATIONSHIP WITH NATIONAL POLICY AND OTHER MATERIAL CONSIDERATIONS
Summary of Local Plan 2030 and Requirement for Immediate Review
The Bedford Local 2030 was adopted subject to the provisions of Policy 1 – ‘Reviewing the Local Plan 2030’. The Inspectors’ Report provides further clarification of the requirement for Modifications introducing the approach to this Policy and that it was considered essential for soundness.
Paragraph 1.1 of the Council’s Preferred Options Consultation Document affirms the significance of the ‘guillotine’ mechanism inserted within the review policy, which engages paragraph 11(d) of the NPPF2021 in the event that a new Plan is not submitted for Examination before January 2023. While the Borough Council is aware it cannot avoid the consequences for the statutory development plan of failing to adhere to these timescales the Preferred Options published for consultation must also address the reasons for first introducing Policy 1. Drawing from the Inspectors’ Report:
• Paragraph 17 emphasises the importance of considering longer-term requirements and thus together with other issues with the Plan a need for the review to be undertaken as quickly as possible with the three-year timeframe providing balance to allow work to be completed effectively
• Paragraphs 33-34 anticipate that the review will consider the balance between jobs and workers including any changes in the balance of net out-commuting and the implications of the Oxford-Cambridge Arc
Paragraph 18 of the Inspectors’ Report confirms that Policy 1 cannot set the parameters of the updated Local Plan. While there is a desire for alignment with the delivery of cross-boundary strategic priorities (including those related to the delivery of the Oxford-Cambridge Arc) the requirement for review is a result of the deficiencies with the approach put forward by the Council in the Local Plan 2030.
The appointed Inspectors determined (in the context of the 2012 Framework) it would not be effective for the policies of the Local Plan 2030 to look beyond that date. The findings of soundness are predicated on the context of a very narrow remit of addressing the area’s strategic priorities (and even then, only with the application of the three-year ‘guillotine’ following adoption).
It is not open to future Inspectors to reach the same conclusion. This emphasises the importance of the of the first paragraph of Policy 1 and the overriding objective of the aim of the review to secure levels of growth that accord with government policy. This establishes grounds for a Plan that must be fundamentally deliverable / developable over than plan period and cannot further defer relevant decisions relating to options to meet the area’s strategic priorities.
In not fully responding to the reasons and scope of requirements for the review and subsequent update of the Local Plan the Council risks rolling forward several of the same fundamental shortcomings in the Local Plan 2030. This is not only contrary to the objectives of sustainable development but in the context of the most recent policy and guidance simply fails to provide the basis for a sound Local Plan.
National Policy and Guidance
The most recent version of the National Planning Policy Framework was published in July 2021, following commencement of the Council’s Preferred Options consultation. The changes were published in draft format in January 2021 (including those relevant to the plan-making framework) and thus available for the Council to consider.
These representations highlight four important components of the 2021 Framework and the changes they necessitate for the scope of the review, relative to the 2012 version of the Framework against which the current Local Plan 2030 was assessed. Other specific provisions of the Framework and NPPG are referred to in comments relating to detailed elements of the consultation proposal.
Firstly, Paragraph 22 of the NPPF2021 confirms that strategic policies should look ahead over a minimum 15-year period from adoption and anticipate long-term development requirements. This is a significant change from paragraph 157 of the 2012 Framework that specified that policies should be drawn up over an appropriate timeframe and only preferably a 15-year horizon.
Secondly, the second paragraph of NPPF2021 Paragraph 22 is a significant addition following the most recent revisions. This requires that policies should the address a vision that looks further ahead (at least 30 years. The transitional arrangements for these provisions at Annex 1 confirm their application to the preparation of all Plans except those that have already undergone consultation on the Submission version Plan. The Oxford-Cambridge

Spatial Framework is also seeking to cover the period to 2050 (i.e., 30 years).
The Council’s Preferred Options clearly anticipate reliance on these approaches to growth and the associated implications in terms of extended timescales for development. None of the Council’s Preferred Options set out the proposed approach beyond a 20-year horizon. As a result, detailed policies for the scale and distribution of growth cannot be considered consistent with national policy without significantly extending their scope alongside provision for the other requirements of sustainable development.
Thirdly, the requirements of Policy 1 of the Local Plan 2030 accord with the circumstances outlined at Paragraph 33 of the NPPF2021.
Finally, Paragraph 35 of the NPPF2021 confirms that the criteria for the assessment of soundness have changed since the 2012 Framework. In order to provide for a justified approach the policies for the Plan must provide for ‘an appropriate strategy’ rather than the ‘most appropriate’ strategy when assessed against reasonable alternatives. Paragraph 32 of the NPPF2021 provides further detail on the basis for assessing the proposed strategy in terms of seeking net gains for sustainable development and ensuring that the Plan has addressed relevant economic, social, and environmental objectives.
In summary, there is no longer any support in national policy for the outcomes of the Local Plan 2030 Examination in terms of pursuing constraints to the plan period and overall level of growth and deferring decisions on key components of approaches to meet strategic priorities for the area (particularly in terms of overall housing need (including affordable housing) and the delivery of social and community infrastructure (including health and education).
DLP, on behalf of Philip C Bath Ltd, welcomes the Council’s decision to review and update the various elements of the extant development plan and provide for a new local plan document that will fully reflect the policies of the National Planning Policy Framework (the Framework) and provide for the up-to-date development needs of the Borough and its residents in a sustainable manner. DLP wishes to make a number of comments on the consultation document as part of the background context to the representations we are submitting on the site itself.
This Report addresses the Council’s consultation proposals and identifies in-principle support for those elements of Council’s Preferred Strategy Options that indicate growth in the ‘east’ transport corridor parishes, specifically at Roxton. Reservations are, however, expressed in the context that the inclusion (and resultant levels of development) of the ‘east’ corridor parishes is unconfirmed and contingent upon only Option 2d being selected. Furthermore, in the case of our client’s interests, this strategy option should reflect the ability to complement opportunities for economic development through the intensification and expansion of existing commercial floorspace.
DLP wishes to make a number of comments on the consultation document as part of the background context to the representations we are submitting on the site itself.
Section 2 provides a background to the Local Plan Review and its relationship to national policy and other material considerations
Section 3 addresses specific comments on the Council’s Preferred Strategy Options and Preferred Option Policy Proposals together with their supporting evidence.
Section 4 discusses the suitability of our client’s land for development following a review of the Council’s Site Assessment Proforma.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7540

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Representation Summary:

These representations to the ‘Bedford Local Plan 2040 – Draft Plan Strategy Options and Draft Policies (Regulation 18) Consultation’ have been prepared by the DLP Planning Ltd (DLP) acting on behalf of the Cambridge Meridian Academies Trust (CMAT) in respect of its interests at Lincroft Academy, Oakley.
Submission of these representations, firstly, sets out the immediate need for the expansion of Lincroft Academy to support the intake of approximately 240no. new pupils per annum within the pupil roll, based on current development commitments, and to emphasise that this requirement should be reflected in the policies of the Local Plan 2040.
Secondly the representations support the reclassification of Oakley as a Key Service Centre within the Council’s settlement hierarchy. This is considered to better reflect the settlement’s important role, including in the provision of both primary and secondary education to a wide surrounding area, alongside other services, and facilities. Reclassification is also considered consistent with providing measures through the policies of the development plan to enable Lincroft Academy to address the likely potential requirement for further expansion in the future.
CMAT’s interests include the existing Lovell Road Playing Fields located on land East of Station Road, which form part of the existing facilities of the Lincroft Academy (formerly operated by the Sharnbrook Academy Federation (SAF)).
CMAT’s interests on Land East of Station Road were submitted (via SAF) to the Council as part of the Summer 2020 Call for Sites Consultation. Details were provided as part of a single site boundary also comprising land owned by the Bedfordshire Charitable Trust and promoted on its behalf by Bedfordia Property. The land East of Station Road has subsequently been considered as one site for the purposes of the Council’s site assessment process (assigned Site ID: 839 and 832).
These representations confirm that CMAT, in principle, support indicative land-use proposals for a ‘one-site’ solution, which incorporates the land East of Station Road including that controlled by CMAT, i.e., the Lincroft Academy site and the arrangements for a ‘land swap’ agreed with the adjoining land owners, The Bedfordshire Charitable Trust which would allow for the creation of a single, self-contained educational campus and provide the opportunity to expand the existing site and facilities, including the relocation of existing sports pitches and other operational improvements to the school including a new school access and parking/circulation space.
Submission of these representations reflects that negotiations between the parties are advanced, ongoing and expect an agreement that will satisfy the Education and Skills Funding Agency regarding the enhancement of facilities to be achieved, retain the support of other stakeholders (including Sport England), and recognise the wider benefits of developing the larger site.
As such, these representations should be read alongside submissions on behalf of Bedfordia Property and the Bedfordshire Charitable Trust outlining the indicative proposals for development on land East of Station Road. The details within this submission have been provided with the agreement of the Bedfordshire Charitable Trust and Bedfordia Property.
This Report addresses the Council’s consultation proposals and identifies that the approach proposed insofar as it relates to Oakley is unsound and fails to make sufficient provision or community facilities (including education infrastructure). Modifications are suggested to enable preparation of a version of the draft Local Plan 2040 that addresses the issues identified, ahead of further consultation and subsequent Submission and Examination.
This Report, which should be read alongside any supporting documents and appendices referred to, addresses our instructions to cover the following topics:
• Section 2 provides further background to the current requirement for expansion at Lincroft Academy and whether this is reflected in the evidence base for the emerging Local Plan 2040
• Section 3 considers the Council’s settlement hierarchy and the current and expected contribution of Lincroft Academy to Oakley’s role and function, both now and in the future
• Section 5 summarises the potential benefits of indicative land use proposals on land East of Station Road.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7779

Received: 23/09/2021

Respondent: National Highways

Representation Summary:

Highways England welcomes the opportunity to comment on the Bedford Borough Draft Local Plan - Strategy Options and Draft Policies consultation which covers the period from 2020 to 2040.

Highways England is responsible for the operation, maintenance and improvement of the Strategic Road Network in England on behalf of the Secretary of the State. In the area within and surrounding Bedford Borough we have responsibility for the A1, A421, and A428.

Highways England will consider the following aspects of the Local Plan in this review:

• Visions and Objectives;
• The overall Spatial Strategy, including growth location options and consideration of the housing and employment growth targets;
• Employment sites

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7830

Received: 03/09/2021

Respondent: Mr Mark Ibbett

Representation Summary:

I run my own business as an agricultural contractor/farmer, working on the very land that you propose to put the new Dennybrook development on. If the development was to go ahead, my business and farm would no longer be viable. What support would be available to me? Would you compensate me for this?
I keep cattle on the holding and therefore any development would need to be a significant distance away. If the development was to go ahead, I would be subject to a lot of stress due to potential noise complaints about the animals or farm machinery moving late at night or early mornings, or even during the nights. There may be complaints about the smell too. I would also have concerns about security and vandalism, being so close to a large development.
Another question would be how will I get across a development of that size with large machinery to get to other customers.

A further general point; there’s not enough local employment to support a development of the size of Dennybrook. The additional employment proposed will take time to bring in and establish.

This whole situation has bought a lot of stress to myself and many people in our area. We moved here to enable me to have ground to keep livestock and equipment and to bring in work. Much of this will be removed if Dennybrook goes ahead.
I can currently unwind by star gazing due to the lack of light in the area as it is so rural. This will be impossible if there is a large development with street lights and homes. Farming can be a stressful profession, as I am sure you know. This wind down time is invaluable and Dennybrook would destroy that. How could you possibly make up for that?

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7870

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Representation Summary:

Thank you for consulting Central Bedfordshire Council (CBC) on the Strategy Options and Draft Policies consultation for the Bedford Local Plan 2040. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continued joint working moving forward.

CBC are supportive of Bedford Borough Council (BBC) in commencing a Plan Review in line with Policy 1 of their adopted Local Plan 2030. We have provided some comments below on the consultation document which we hope are useful. Please do not hesitate to contact us if you have any further questions.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7911

Received: 24/09/2021

Respondent: Mr Julian Kingston

Representation Summary:

As a lifelong supporter of lighter than air aviationI wish to raise an objection to your proposals for, and treatment to date, of the nationally important Cardington Airship Sheds.

Anything that restricts or nullifies their future use should not be considered. This is particularly pertinent in the light of the climate emergency and advances in lighter than air technology and how it can benefit the area building on the already long and unique history of the site.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7929

Received: 20/09/2021

Respondent: Pavenham Parish council

Representation Summary:

This response to Bedford Borough Council’s emerging Local Plan 2040 – Strategy Options and Draft Policies Consultation is submitted on behalf of Pavenham Parish Council.
The Parish Council would wish, at the outset, to record its thanks to the Borough Council for the extension in time granted so as to enable the Parish Council to formulate its response and in so doing, apologises that by reason of its late submission, it has not been possible to complete its submission on-line.
To place this response in context, it should be noted that the Parish Council is currently promoting its own Neighbourhood Plan. That Plan is now in an advanced stage – albeit awaiting final consultation and exhibition - and full account will be taken, insofar as is practicable and legally acceptable, of the Borough Council’s emerging Plan as it impacts on the Bedford Local Plan 2030 and the Parish.
The Parish Council recognises the very real challenges the Borough Council now faces in meeting the Government’s latest housing provision required target. The 33% housing provision uplift when compared with the locally-calculated housing growth which was planned for in the Local Plan 2030, (paragraph 1.11 of the Consultation Document) is recognised and the Parish Council’s comments on housing provision are made in the context of the Borough Council’s obligations.
In addition to this required substantial housing provision uplift are the challenges created by the Oxford to Cambridge Arc – the policies and proposals for which are at this stage, general in the extreme – the “Arc Spatial Framework” which is to a large extent dependent on the collaboration of all of the other local authorities within the Arc – whilst also having to deal with the challenge of a failing town centre and the long-lasting impact of the pandemic.
The Parish Council notes that the current updating exercise for the 2040 Plan is being undertaken in the context of the Local Plan 2030 which was only adopted last year. The Parish Council agrees that there is no need for a radical review of the extant Plan. That means, of course, that the final adopted Local Plan 2040 will constitute only a partial update of the 2030 Plan. The Parish Council hopes, however, that the final published version of the Local Plan 2040 will be produced as a single standalone document, as opposed to a Plan which cross references still current policies extant in the 2030 Plan, thereby effectively requiring a constant need for cross reference between two documents. Bearing in mind the growing list of related development control policy documents, a single comprehensive principal published Local Plan, containing new, updated and saved policies in one place would be far more “user-friendly” for the general public.
The final point that the Parish Council would wish to make in this introduction is that it has deliberately tried to avoid providing a NIMBY – “not in my back yard” response. That said, the Parish Council does note that some of the proposed shifts in policy, whilst small in number, may have far-reaching effects for the Parish and total objectivity may not always be possible.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8065

Received: 03/09/2021

Respondent: Wilshamstead Parish Council

Representation Summary:

This document represents the considered response of Wilstead Village Neighbourhood Plan (NP) Team to the strategic proposals set out by Bedford Borough Council in their consultation conducted June to September 2021.

Wilstead Neighbourhood Plan Team believes that all of the Borough should contribute to the housing need identified in Bedford Borough Council’s Local Plan 2040.

We are supportive of sharing some development across the rural communities surrounding Bedford, together with development within the urban area. This sharing should include some development in the communities north of Bedford and should not concentrate solely on development along the A421 corridor.

We recognise that the A421, A6, East West Rail and Midland Mainline railway are travel corridors which would support development along part of their routes south of Bedford but would also point out that the A6, EWR and Midland Mainline go north from Bedford as well and therefore should attract their fair share of development along this part of their routes.

Wilstead is a relatively small village with a rich history and heritage and local residents are attracted to the village by its proximity to the countryside. This rural character must not be affected by large-scale development in the future. In particular we ask that the Settlement Hierarchy review takes into account the anomalies in what has been produced so far, and the relatively small size of the village (now that it is separated from Wixams).

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8222

Received: 26/09/2021

Respondent: The Forest of Marston Vale Trust

Representation Summary:

On behalf of the Forest of Marston Vale Trust, thank you for the opportunity to comment on this draft document, and for the short extension of time for us to respond. Our comments and observations are set out below:
• As an active member of the Local Nature Partnership, the Trust strongly endorses and reinforces the comments made by the LNP in its own response. We are not reiterating the LNP comments here in the interests of brevity, but wish the Council to note our desire to effectively restate them through our endorsement of them.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8230

Received: 26/09/2021

Respondent: Amanda Quince

Representation Summary:

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
OVERVIEW
This document represents the considered response of Renhold Parish Council to the strategic
proposals set out by Bedford Borough Council (BBC) in their consultation conducted June to
September 2021.
Our Approach to the Consultation
Renhold Parish Council is experienced in understanding the due process relating to public
consultations and is therefore mindful of the importance of presenting clear and robust evidence
even at this consultation stage, to ensure that Renhold Parish Council makes clear its view as
the first tier of local government. The Parish Council, has a further role as always, serving its
electorate and ensuring they are supported throughout this phase, so considerable work has
been done ensuring they are not only aware of the proposals, their direct impact on Renhold,
but also in encouraging effective engagement in the consultation process.
The Parish Council also feels at this stage of drafting such a significant development strategy
document that it is important to reiterate to BBC, Renhold’s specific items that have previously
been expressed, given the potential personnel changes internally at BBC.
Renhold Parish Council, as usual, has been extremely pro-active in attending BBC led
consultation events directed at local parishes, as well as the various public engagement
activities within the consultation run by BBC. Renhold Parish Council and local representatives
have in addition, been liaising closely with the elected Borough Councillor representatives for
the parish. Renhold has not only thoroughly studied the consultation documents, throughout
the consultation period, they have strived to understand more about the many different technical
and complex items being considered. This has been apparent during this consultation, with
BBC looking at so many different strategic options in addition to a huge number of important
accompanying planning policy documents which will shape the future of Renhold and all local
communities across the Borough.
Councillors wish to thank BBC Planning Policy Officers for their helpful assistance in dealing
with the Parish Council’s various enquiries throughout the consultation.
The Parish Council has also facilitated a number of different ways to encourage Renhold
residents to engage with this consultation process, whether directly to BBC representatives as
well as Renhold Parish Councillors. Throughout this consultation we have made it an absolute
priority that all in Renhold are aware of the enormity of the proposals, and that they can have
their say and their voice heard. This has included using the village electronic circulation list,
website publications to raise awareness, plus multiple communications made via leaflets and
the Village Magazine to every household in the whole parish, along with residents being
welcomed to the July and September Parish Council meetings. The Parish Council arranged a
specific drop-in session on Saturday 20th August at Renhold Village Hall to enable residents who
had questions and/or required assistance with understating how to engage in responding to the
consultation, were able to access support. 38 residents took the time to attend the event, giving
Councillors feedback as well as expressing comments on the consultation literature so it could
be incorporated into the Parish Council response.
The Parish Council – all volunteers and all laymen in this particular field - have become
increasingly conscious of the level of technical detail contained in the many, often large BBC
documents which need to be read and understood before attempting to communicate with our
BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
residents and before collating our response to this consultation. This was compounded further
because of the government Covid restrictions, therefore, Renhold Parish Council who do not
have access to specialist planning professionals have been incredibly grateful for the number of
residents who have given their time to assist with the collation of residents’ views, to enable
them to be reflected within this consultation response.
The above challenges during this consultation have also impacted on any opportunity for any
meaningful engagement with neighbouring areas, who have had an exceptionally busy six
months solid of consultation. This has meant it has been exceptionally difficult not only due to
anxiety as Covid restrictions change, but in addition to this consultation following on
immediately from the East West Rail which took an unprecedented amount of volunteer time in
light of the intention to decimate rural countryside in north of Bedford.
In light of Renhold unexpectedly finding itself in the path of a proposed new railway line, it really
should not be underestimated the true exhaustion in the local community and fatigue from
responding to East West Rail, to then immediately following this, be required to unpick the
various elements within this technical and lengthy documentation.
As a result, for this consultation, it was important to Renhold Parish Council that they focus on
Renhold only. Local communities around the borough area will be better equipped to represent
with their superior local knowledge of the area(s) they serve.
The Parish Council response will focus on these six key areas:
1. Draft Plan: Strategic Options
2. Draft Plan: Draft Policies
3. Renhold Neighbourhood Plan
4. Urban Area Boundary Safeguarding Renhold
5. Renhold Important Local Factors
6. Consultation Accessibility
The consultation submission will reflect the supporting evidence collated from various local
resources, thus enabling Renhold Parish Council to provide information on how truly detrimental
and catastrophic poorly thought-out development strategy options would be and how negatively
they would impact on a small rural village.
BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
residents and before collating our response to this consultation. This was compounded further
because of the government Covid restrictions, therefore, Renhold Parish Council who do not
have access to specialist planning professionals have been incredibly grateful for the number of
residents who have given their time to assist with the collation of residents’ views, to enable
them to be reflected within this consultation response.
The above challenges during this consultation have also impacted on any opportunity for any
meaningful engagement with neighbouring areas, who have had an exceptionally busy six
months solid of consultation. This has meant it has been exceptionally difficult not only due to
anxiety as Covid restrictions change, but in addition to this consultation following on
immediately from the East West Rail which took an unprecedented amount of volunteer time in
light of the intention to decimate rural countryside in north of Bedford.
In light of Renhold unexpectedly finding itself in the path of a proposed new railway line, it really
should not be underestimated the true exhaustion in the local community and fatigue from
responding to East West Rail, to then immediately following this, be required to unpick the
various elements within this technical and lengthy documentation.
As a result, for this consultation, it was important to Renhold Parish Council that they focus on
Renhold only. Local communities around the borough area will be better equipped to represent
with their superior local knowledge of the area(s) they serve.
The Parish Council response will focus on these six key areas:
1. Draft Plan: Strategic Options
2. Draft Plan: Draft Policies
3. Renhold Neighbourhood Plan
4. Urban Area Boundary Safeguarding Renhold
5. Renhold Important Local Factors
6. Consultation Accessibility
The consultation submission will reflect the supporting evidence collated from various local
resources, thus enabling Renhold Parish Council to provide information on how truly detrimental
and catastrophic poorly thought-out development strategy options would be and how negatively
they would impact on a small rural village.