1.1

Showing comments and forms 61 to 81 of 81

Object

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

Representation ID: 8273

Received: 03/09/2021

Respondent: Mr Daniel Francis

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: 8275

Received: 26/09/2021

Respondent: Amanda Quince

Representation Summary:

6. GENERAL CONSULTATION ACCESSIBILITY
As mentioned earlier in this consultation response it has been a very challenging time to engage
in a process like this during a transition phase in a global pandemic. Not only is this
unprecedented, it is very clear, not just in the local community, but further afield that individuals
are adjusting to changes in government guidance in different ways depending on their personal
circumstances. This has meant enormous complexities for stakeholders and consultees, in
Renhold, which has a sizeable demographic who are not online, a generation who much prefer
face to face interaction, yet understandably at present do not feel comfortable attending an
event with lots of people. The practicalities of trying to make this consultation on something as
significant as this, has simply not been done in a way that is accessible and fair to all.
It must also be documented that having this consultation following directly on from the East
West Rail consultation which has caused additional pressures to the Renhold community given
the unexpected prospect of having a new railway built within metres of homes in the village.
Renhold is a pro-active parish, even as a close-knit village it has been exceptionally difficult to
arrange volunteers to raise awareness of the consultation, whilst managing and supporting
residents’ questions, fears and upset from afar.
The Parish Council are concerned that the consultation paperwork is ambiguous and already
shows a preference, which then removes integrity from the local authority consultation process,
making it questionable. In addition to this has been the difficulty residents reported on locating
all the strategic growth options forming part of this consultation, as well as the misleading
inclusion of Renhold parish within the shaded maps for Strategic Growth Option 2.

Object

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

Representation ID: 8321

Received: 03/09/2021

Respondent: Mrs K Francis

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: 8406

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

Representation Summary:

This representation has been prepared on behalf of our client, Axis Land Partnerships
Limited, in response to the Bedford Borough Council Local Plan 2040 July – September
2021 consultation in respect of the Strategic Options and Draft Policies and Site
Assessment Pro Formas. This submission is made in respect of Land to the East and
West of Home Road, Gibraltar Corner, Bedford (the Site).

The site, the subject of this representation, was put forward for consideration as part of
the 2020 ‘call for sites’ exercise and has now been assessed under site reference ID 1333.
It is being promoted on behalf of a single landowner, it extends to 21.80 ha and lies on
the northern side of Wood End Lane and Ibbett Close

(see map in attachment)

The following documents are also submitted in support of this representation and should
be read in conjunction with this statement:
 Site location plan – Promap;
 Ramsey Green at Gibraltar Corner Vision Document (September 2020) – Fabrik;
 Heritage Appraisal (August 2021) – JB Heritage Consulting Ltd;
 Preliminary Ecology Appraisal (August 2021) – Applied Ecology Ltd; and
 Preliminary Transport Strategy (August 2021) – Stantec.

This statement provides an overview and analysis in terms of housing delivery, having
regard to the National Planning Policy Framework 2021 (NPPF), past performance and
the need for the inclusion of a significant number of additional site allocations for the future
new Local Plan to successfully meet the tests of soundness. It has been split into two
main elements as follows:
1. Firstly, it considers the four growth options listed as Option 2a, 2b, 2c and 2d having
regard to the need to meet national policy requirements and in particular the
emerging spatial framework for growth in the Oxford-Cambridge Arc.
2. Secondly, it includes a review of the site assessment pro forma for the site which
demonstrates that the site is suitable for allocation and would make a positive and
sustainable contribution to the Borough’s required growth strategy.

Background
The current Bedford Borough Local Plan was adopted in January 2020 and covers a plan
period to 2030. It replaced the previous development plan which was made up of a
number of documents covering a plan period to 2021. However, due to national policy
changes to the way housing numbers are calculated, infrastructure upgrades and potential
strategic growth in the Oxford – Cambridge Arc, Policy 1 of the 2030 Local Plan committed
to the commencement of a review of the Local Plan within one year of adoption. The
review commenced in summer 2020 with an Issues and Options consultation and “call for
sites”.

It is worth noting that the eastern portion of the site previously formed part of a Local Plan
2035 Consultation Paper in 2017 and was identified as a preferred site for development
under reference number 146 (Home Road East) (please see below Figure 2). It formed
part of a preferred site for an estimated capacity of 500 homes on the edge of the urban
area. Figure 2 below does not include the entirety of the site as promoted within this
representation and also includes wider land that is outside of our clients control. The site,
now put forward (Figure 1 above), comprises the plots shown below as 146, 147 and 153.
In addition, the parcel of land adjacent to the north of plot 147 and 153 is included as well.

Figure 2: Appendix 5 of Bedford Borough Local Plan 2035 Consultation Document 2017 (see attachment)

A detailed description of the site and vision for its development is contained in the
accompanying vision document titled “Ramsey Green at Gilbraltar Corner” , which was
previously submitted in September 2020. The site is located within the Kempston rural
parish on the edge of the settlement of Gibraltar Corner. It extends to approximately 21.8
ha and could accommodate in the region of 450 new homes. It lies between the small
settlement of Gibraltar Corner and Green End to the north and is made up of land on the
eastern and western side of Home Road, from where the access can be obtained, along
with further vehicle access from Wood End Lane to the south. Pedestrian links can also
be provided to nearby public rights-of-way and Ibbett Close.

The site is located approximately 5 km south-west of Bedford town centre and only 2 km
from Kempston High Street. It benefits from good connections to Bedford and Kempston
by foot, bicycle and public transport. The village of Wootton, a key service centre, also
lies a short distance to the south. The regenerated woodlands of Buttons Ramsey and
the Kill lie immediately adjacent to the west and south of the site. The long distance
walking and cycling route of the John Bunyan Trail skirts the eastern edge and then
passes directly through the north-western corner of the site. These offer excellent outdoor
amenities and connectivity directly with nature.

The site is located in a sustainable location, approximately 0.25 kilometres to the west of
the A428, 1.43km from its connection to the A421 to the south, providing connections to
the wider highway network including the M1 Motorway (London to Leeds), the A6 (Luton
to Carlisle) and A1 (London to Edinburgh). There are two bus stops located on Ridge
Road (approximately 300 metres) to the south of the site, providing regular bus services
Monday – Friday on the number 53 bus to Bedford, Kempston and Wootton, the A2 bus
to Kempston, Bromham, Cranfield and Milton Keynes and the C1 bus to Bedford, Marston Moretaine, Kempston, Wootton, Cranfield, Cranfield University, Newport Pagnell and
Milton Keynes. The nearest railway station to the site is Kempston Hardwick, located
approximately 3.9 kilometres to the south on the Marston Vale Rail Line, providing an
hourly service to nearby Bletchley and Bedford.

In terms of constraints, the site is relatively unconstrained, being located within Flood Zone
1 and is therefore not at risk of flooding. A comprehensive landscape buffer could be
provided to the north to ensure no impact on the setting of the three Grade II Listed
Buildings located to the north of the site (see accompanying Heritage Appraisal), whilst
also contributing towards the Forest of Marston Vale.

Support

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

Representation ID: 8414

Received: 03/09/2021

Respondent: Fisher German LLP

Representation Summary:

These representations are prepared on behalf of P. C. Taylor and C. Taylor & Sons in respect of their land interests at Land at Ivy Lane and Land at Cotton End Road respectively. The site areas are illustrated at Figure 1 and Figure 2 below. (see attachment)
The site has been previously promoted through the previous stages of Bedford Borough Council’s Local Plan review.
1.3 Wilstead was designated as a Neighbourhood Plan area in February 2017. Delays to Neighbourhood Plans were previously highlighted as a potential issue with the Council’s adopted approach and would not be supported moving forward. A pre-submission consultation for Wilstead’s emerging neighbourhood plan took place between 1st April 2021 and 31st May 2021. The timescales for the next stage of neighbourhood plan making (Submission Version) are unknown at the time of writing.
1.4 The draft neighbourhood plan did not propose any land designations for either of the sites subject to this representation, however, an identified viewpoint (V2) is noted within the emerging Neighbourhood Plan in relation to Land at Cotton End Road.
1.5 Wilstead is designated in the current Local Plan 2030 as a Key Service Centre. Key Service Centres are described in the adopted Local Plan as settlements “which contain a good range of services and are well connected to larger town centres by regular public transport. They provide a strong service role for the local community and surrounding area”.
1.6 Land at Ivy Lane, Wilstead (P. C. Taylor) measures some 4.4 hectares and at an assumed density of 30 dwellings per hectare (dph) is capable of delivering up to 135 dwellings. The site is currently in agricultural use. Land at Ivy Lane is located within flood risk zone 1 which is the lowest risk of flooding with a 1 in 1,000 year probability. There are no listed buildings on the site and there is 1no. Grade II listed building (Compton Cottage) adjacent to the site, on Ivy Lane to the west. In terms of access, there is an existing agricultural access point from Ivy Lane which could be improved and upgraded to accommodate the dwellings, or a new access could be achieved from Ivy Lane, further south (subject to relevant technical assessments).
1.7 Land at Cotton End Road, Wilstead (C. Taylor & Sons) measures some 11.8 hectares and at an assumed density of 30 dwellings per hectare (dph) is capable of delivering up to 354 dwellings. The site is currently in agricultural use. Land at Cotton End Road is located within flood risk zone 1 which is the lowest risk of flooding with a 1 in 1,000 year probability. There are no listed buildings on or near to the site. In terms of access, there is an existing agricultural access point from Cotton End Road which could be improved and upgraded to accommodate the dwellings (subject to relevant technical assessments).
3
1.8 For ease of reference these representations follow the consultation questions in order they appear in the consultation document, where relevant.

Support

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

Representation ID: 8473

Received: 27/09/2021

Respondent: Mrs G Hunt

Agent: DLP Planning Limited

Representation Summary:

Introduction, national and local policy context have been submitted and can be found in the attachment.

Support

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

Representation ID: 8507

Received: 02/09/2021

Respondent: Bedfordshire Police

Representation Summary:

Bedfordshire Police (BP) welcomes this opportunity to assist Bedford Borough Council with the
preparation of the Local Plan 2040. This stems from our desire to work in partnership with the Council
to ensure that development growth is designed to promote safety, as well as being supported by the
infrastructure necessary to guarantee the security of the new communities and places created by it.
This is why these representations are supported by an updated Bedfordshire Police Infrastructure Plan
(August 2021) (BPIP); the first edition of which was submitted to the Council in April 2020. The purpose
of this being to explain the police infrastructure implications and costs associated with the development
growth now being envisaged for the Borough.
By way of ensuring that these representations are as concise as possible, we only respond to those parts
of the new Local Plan that directly concern the aforementioned priorities of BP:

Attachments:

Object

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

Representation ID: 8560

Received: 03/09/2021

Respondent: Mrs Claire francis

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: 8573

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Representation Summary:

1.1 These representations have been prepared on behalf of Arnold White Group (‘AWG’) in response to the public consultation on Bedford Borough Council’s (‘BBC’) Local Plan 2040 – Draft Plan, Strategy Options and Draft Policies Consultation (‘the Local Plan’).
1.2 AWG are a landowner and strategic land promoter,
owning and controlling significant areas of land within Bedford Borough. These representations are made having particular regard to a 96ha area of land at Broadmead, Marston Vale, north of Stewartby. This land forms part of the wider 222ha ‘Bedford Business Park’ being promoted by Cloud Wing UK Ltd (‘Cloud Wing’).
1.3 A Site Location Plan identifying the extent of land (hereafter referred to as ‘the Site’) is enclosed at Appendix 1.
1.4 The Site has previously been submitted to BBC as part of the Call for Sites process, and AWG has been active participants in every stage of the Local Plan 2030, as well as the 2020 consultation on the Local Plan 2040.
1.5 The response to this consultation considers the key issues of job growth; strategic locations for growth; climate change; and, as an overall point, the relationship of the Local Plan to the Arc Spatial Framework and Government’s proposed planning reforms.
1.6 This response also includes further information in relation to the land at Bedford Business Park, with the enclosed illustrative Masterplan (Appendix 2) demonstrating how the land would deliver substantial employment and economic opportunities in accordance with national policy.

Attachments:

Support

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

Representation ID: 8584

Received: 27/09/2021

Respondent: Elstow Parish Council

Representation Summary:

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from ELSTOW PARISH COUNCIL September 2021
OVERVIEW
This document represents the considered response of Elstow 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
Elstow 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 Elstow Parish Council makes clear its view as the
first tier of local government. The Parish Council, have a further roll as always, serving its
electorate and ensuring they are supported through this process, so there has been additional
work done ensuring residents are not only aware of the proposals, their direct impact on Elstow,
but also in further encouraging residents to effectively engage in this 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 the Borough Council, Elstow specific items that have
previously been expressed.
Elstow Parish Council, as usual, has been active in attending the local authority led consultation
events directed at local parishes. As a small parish Elstow Parish Councillors have spent time
studying the consultation documents, however, must feedback that it has been very challenging
for Councillors to do this within the consultation timeframe. Elstow has a number of new
Councillors who have not been through a Local Plan process before so it has been quite over
whelming at times for them to come forwards with feedback on a topic which is so new to them.
The many different technical and complex items being considered mean it has been difficult to
ensure that all areas receive sufficient scrutiny and appropriate coverage within this Parish
Council response. More so when Councillors are all volunteers and the Clerk is only part time
for a few hours a week. Naturally this has been frustrating for those representing Elstow as it
understood the significance of the proposals within this consultation given Elstow’s geographical
location in relation to the A241 transport corridor. Trying to decipher not only so many different
strategic options, in addition to a huge number of important accompanying planning policy
documents which will shape the future of Elstow and all local communities across the Borough,
really has been testing.
The Parish Council have tried during the consultation to support Elstow residents to make sure
they are aware of the enormity of the proposals, and that they can have their say and their voice
heard. This has included communicating via a leaflet to every household in the whole parish, to
set out why it is important to become involved and how to respond to the consultation.
The Parish Council as previously detailed – 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 local authority documents which need to be read and understood before attempting to
communicate with our residents and before collating this response to this consultation. This has
been compounded further because of the government Covid restrictions, new Councillors and
some Councillors being unable to support their colleagues as they would have liked. Elstow
Parish Council would also like to highlight that they do not have access to specialist planning
professionals so have very much wished to focus on their local knowledge of the historic parish
they are proud to call home.
1
BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from ELSTOW PARISH COUNCIL September 2021
It should also be noted that due to the challenges set out above during this consultation, it has
impacted on any opportunity for any meaningful engagement with neighbouring areas. Elstow
always look to work collaboratively and cohesively with its neighbouring rural communities,
however this has simply not been possible on this occasion.
As a result, for this stage of consultation on strategic development options, it was important to
Elstow Parish Council that they focus on Elstow 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: Overall Strategic Policy
3. Draft Plan: Draft Policies
4. Urban Area - Safeguarding Elstow
5. Elstow Important Local Factors
6. Consultation Accessibility
The consultation submission will reflect the supporting evidence collated, thus enabling Elstow
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 such as Elstow.

Support

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

Representation ID: 8590

Received: 27/09/2021

Respondent: Elstow Parish Council

Representation Summary:

The consultation references a significant number of accompanying policy documents that are
being reviewed as part of the Local Plan process. Again this is a huge challenge to fully
understand the terminology, digest the technical nature of the documents, and to fully
appreciate and understand the context of which these policies will be used by the local authority.
These policies will effectively underpin the strategic development through to 2040, so they are
hugely important. The Parish Council understand the need for robust and effective planning
policy documents to support positive experiences for all stakeholders involved within the
planning process. Whilst the Parish Council are sympathetic to the difficulty in balancing all the
different needs and consideration, it is absolutely critical that these policy documents enable the
local authority decision making process to be secure.
Housing growth allocation numbers calculated by BBC that have been identified are of concern
to the Parish Council. Whilst the Council are not familiar with the calculations of such data, it
was interesting to read Bedfordshire Campaign to Protect Rural England’s submission to this
consultation which raised some alarmingly and most worrying discrepancies with BBC’s growth
when compared to nearby local authorities. Therefore, the Parish Council wish to seek clarity
on the questions raised given the presented evidence within the CPRE response that clearly
show Bedford Borough having a disproportionate amount of growth.
Given Elstow’s locality the Parish Council will set out in 4. Urban Area Boundary Safeguarding
Elstow further specific feedback to the part of the consultation regarding the urban area
boundary.
Frustratingly, with the limited resources of the Parish Council it has not been possible to study in
greater depth all the detail within these documents which relate to Elstow However, there are
some specific policy items that it is wished to raise, these are set out below.

Support

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

Representation ID: 8593

Received: 27/09/2021

Respondent: Elstow Parish Council

Representation Summary:

6. GENERAL CONSULTATION ACCESSIBILITY
As mentioned earlier in this consultation response it has been a very challenging time to engage
in a process like this during a transition phase in a global pandemic. Not only is this
unprecedented, it is very clear, not just in the local community, but further afield that individuals
are adjusting to changes in government guidance in different ways depending on their personal
circumstances. This has meant enormous complexities for stakeholders and consultees, in
Elstow, which has a sizeable demographic who are not online, a generation who much prefer
face to face interaction, yet understandably at present do not feel comfortable attending an
event with lots of people. The practicalities of trying to make this consultation on something as
significant as this, has simply not been able to be done in a way that is accessible to all.
Elstow is a pro-active parish, even as a close knit village it has been exceptionally difficult to
arrange volunteers to raise awareness of the consultation, whilst managing and supporting
residents’ questions, fears and upset from afar.
The Parish Council are concerned that the consultation paperwork is ambiguous and already
shows a preference, which then removes integrity from the local authority consultation process,
which is a worry.

Support

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

Representation ID: 8647

Received: 28/09/2021

Respondent: West Northamptonshire

Agent: Mr Alan Planning Policy SNC

Representation Summary:

Thank you for your email. West Northamptonshire Council welcome the opportunity to engage with you on the Bedfor Borough Plan 2040 and wish to remain on your consultation list.

We have no detailed comments to make on the draft options at this stage.

Object

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

Representation ID: 8700

Received: 13/09/2021

Respondent: Mr J Francis

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: 8827

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Representation Summary:

Vision And Objectives
3.2. The Vision sets out general planning aims, and we support the Borough becoming more sustainable, the delivery of good design, and improved transport options etc. However, it is surprising that the Vision does not make any stronger statements on growth, where it will be located, or make a commitment to delivering the required number of new dwellings, and employment land, as identified in the remainder of the Draft Plan.

3.3. Given the emerging focus on the delivery of the Oxford - Cambridge Arc, as identified in the document and the current consultation on priorities for the Spatial Framework, it seems a missed opportunity for the plan not to take a lead in setting out how it could play an important role in delivering the Vision. The statement at paragraph 1.11 appears to read as “we will do what we have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

3.4. In particular it would seem sensible for the plan to make some provision for the possibility of an uplift in housing and employment growth that may emerge through the preparation of the Arc’s Spatial Framework. Paragraph 5.5 of the Government’s current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states:

“concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”
(Our emphasis underlined)

3.5. At paragraph 5.8 of the consultation, it adds:

“In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself.
(Our emphasis underlined)


3.6. While it is acknowledged that the Local Plan review and the Spatial Framework will be prepared in parallel, it is clear that the emerging vision is targeting a more advanced and robust form of growth. Therefore, we would contend that the Local Plan Review should allow for some uplift whether that be 10 or even 20%. If the Spatial Framework is adopted at the same time as the plan, there is likely to be the added pressure to consider another urgent Local Plan review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and provide flexibility, helping towards reducing the burden going forward.

Support

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

Representation ID: 8968

Received: 03/09/2021

Respondent: East West Railway Company Limited

Agent: Mrs JANE PARKER

Representation Summary:

Adams Hendry Consulting Ltd submit this response to Bedford Borough Council on the Local Plan 2040:
Strategy Options and Draft Policies Consultation on behalf of our client, East West Railway Company
Limited (EWR Co).
As background, EWR Co is the organisation responsible for delivering East West Rail (EWR), a major rail
project aiming to deliver both new and enhanced rail infrastructure to provide frequent, fast, and reliable
rail links for communities between Oxford, Milton Keynes, Bedford, and Cambridge. The latest EWR
proposals were subject to a second round of non-statutory public consultation between 31st March 2021
and 9th June 2021. The EWR documentation library can be found at
https://eastwestrail.co.uk/library/documents.
The EWR route is split into six sections where improvements are to be made to existing infrastructure, and new connections are to be constructed. The Bedford Local Plan area is located within project Section B:
Bletchley and the Marston Vale Line, Section C: Bedford and Section D: Clapham Green to The
Eversdens.
Following the close of the consultation, EWR Co is considering consultees’ feedback and carrying out
further development work to inform the selection of a preferred route alignment in due course, including
on the options presented at the 2021 consultation that would affect Bedford borough.

General information on EWR timeframes
The EWR Project is being delivered in four stages. The first stage (already in operation) has improved the
link between Oxford and Bicester and was completed in 2016. This part of the EWR Project was delivered
by the Chiltern Railway Company Limited and Network Rail under the Chiltern Railways (Bicester to Oxford
Improvements) Order 2012, made under the Transport and Works Act 1992 (TWA 1992).
The second stage (Connection Stage 1) will extend EWR further north and east, allowing services to run
between Oxford and Milton Keynes. Creating this link requires the reinstatement of an out-of-use railway
line between Gavray Junction at Bicester and Bletchley including a new bridge over High Speed 2 (HS2),
a new station at Winslow and two new platforms at Bletchley station. Network Rail obtained the Network
Rail (East West Rail) (Bicester to Bedford Improvements) Order 2020 (the 2020 Order), made under the
TWA 1992.
The 2020 Order authorises the construction, operation and maintenance of works to the railway between
Bicester and Bletchley, and major civil engineering construction work has commenced. These works will
enable the introduction of two trains per hour in each direction between Oxford and Milton Keynes, plus
provide additional freight capacity.
The third stage (Connection Stage 2) would upgrade the existing railway between Oxford and Bedford to
meet the Strategic Objectives set by the Department for Transport (DfT). These works go beyond those
authorised by the 2020 Order obtained by NR, and so will require a new, separate consent. Enhancements
to the railway between Oxford and Bicester, to the Marston Vale Line between Bletchley and Bedford, and
to Bedford Station form part of EWR Co’s proposals.
The fourth stage (Connection Stage 3) would provide an entirely new railway infrastructure between
Bedford and Hauxton. This would facilitate the extension of the Oxford – Bedford services through to
Cambridge and the introduction of a further two trains per hour between Bletchley and Bedford.
Details of the potential enhancements to the existing railway infrastructure were provided as part of the
non-statutory public consultation that was undertaken by EWR Co from March to June 2021. EWR Co will
be undertaking further public consultation in 2022 on the preferred options.

EWR Application Process
The EWR Project has been designated as a nationally significant infrastructure project (NSIP). This means
that instead of applying for planning permission from a local authority, permission is given at a national
level by the Government; this is called a Development Consent Order (DCO).
The preferred options are currently being developed for both Connection Stage 2 and Connection Stage
3. EWR Co will develop a red line boundary to encompass all the land required for the construction and
operation of these works, as part of a Development Consent Order (DCO) application for the preferred
options. EWR Co will present further information on its emerging proposals during statutory consultation
which is currently scheduled to take place in 2022.
After this further statutory stage of consultation, EWR Co will submit an application for a DCO to the
Government. The application will then be considered by a single inspector or a panel of inspectors from
the Planning Inspectorate who will make a recommendation to the Secretary of State for Transport on whether the application should be approved. The final decision to grant or refuse the DCO application for
the Project would then be taken by the Secretary of State in line with the National Policy Statement for
National Networks.

Object

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

Representation ID: 8971

Received: 01/10/2021

Respondent: Dacorum Borough Council

Representation Summary:

Thank you for the opportunity to comment on the above Local Plan consultation. We
note that the draft Local Plan is an update to existing policies contained within the
Borough’s adopted 2030 Local Plan.
We also note that a number of evidential base documents understandably remain to
be either prepared, revised or updated, including the Infrastructure Delivery Plan,
Sustainability Appraisal, HELAA and Settlement Hierarchy. Our following comments
are therefore somewhat constrained and we would appreciate being notified when
those papers are available
Given the geographical distance between our respective authorities and the fact that
we do not share a common boundary our comments will focus on potential strategic
cross-boundary matters, the greatest of which we perceive to be the potential
cumulative impact of new development on the M1.
In all cases, it is important that the cumulative and cross-boundary effects of
development are recognised across our individual administrative areas. By way of our further observations upon the draft Local Plan the following may be of interest to you.

Support

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

Representation ID: 8977

Received: 01/10/2021

Respondent: South Cambridgeshire District Council

Representation Summary:

This response to the Bedford Borough Local Plan 2040 – Draft Plan Strategy Options and Draft Policies Consultation is made by Greater Cambridge Shared Planning on behalf of Cambridge City Council and South Cambridgeshire District Council.
We support the broad approach that Bedford Borough Council has taken to developing the emerging spatial strategy in terms of considering carbon emissions and natural capital as integral components to inform the preferred approach – this approach matches with the Themes in our emerging Greater Cambridge Local Plan, which reflect our Councils’ commitments to addressing the climate crisis and biodiversity emergency.
Given that the South Cambridgeshire and Bedford Borough boundaries do not adjoin we consider it unlikely that the Plan would have direct impacts on our districts. However, given the possible growth at new settlements in the north-east of Bedford Borough linked to East West Rail, we would like to highlight at a high-level potential strategic cross-boundary matters of relevance (under the Duty to Cooperate) between Bedford Borough and South Cambridgeshire and Cambridge (noting that Cambridge and South Cambridgeshire are producing a joint plan: strategic cross-boundary matters affecting one district will have implications for the other).

Support

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

Representation ID: 9031

Received: 04/10/2021

Respondent: Historic England

Representation Summary:

Thank you for consulting Historic England on the Draft Plan Strategy Options and Draft Policies Consultation for Bedford Local Plan. As the Government’s adviser on
the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.
We have reviewed the Draft Plan and consultation material. As a general comment, Historic England welcomes emerging plan and work undertaken to date.
In preparation of the forthcoming Bedford Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage
groups.
Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.
Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our
obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.
We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.
We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.

Object

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

Representation ID: 9055

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Representation Summary:

1.1. The Draft Local Plan explains the reason that a Local Plan update is needed is in order to reflect emerging national policies for the Oxford to Cambridge Arc. However the Spatial Framework for the Arc has not been determined by Government. .
“Normally local plans are reviewed every five years but this update is require sooner in order to reflect emerging national policies for the Oxford to Cambridge Arc.”
1.2. Indeed, the Local Plan Inspectors for the currently adopted Local Plan 2030 necessitated an early review of the Local Plan in their Report2. However, it is critical that the context of this conclusion by the Inspectors is understood and appreciated. The Inspectors considered that there was a need for the plan to respond appropriately to longer term requirements, particularly the Arc. It was envisaged by the Inspectors that a review of the Local Plan and any update to it be submitted for examination within three years of adoption would be an ample amount of time for sufficient clarity about the implications (for Bedford and its neighbours) of the Arc to be known to enable such a review.
“Nevertheless, there is a need for the plan to respond appropriately to longer term requirements, and in particular the Arc, as soon as possible. Consequently, notwithstanding the statutory requirement for the plan to be reviewed, and then updated if necessary, within five years of its adoption, it is necessary for a review and update to be completed more quickly. On this basis (and for other reasons detailed elsewhere in this report), MM1 is necessary for the plan to be justified and effective. This requires a review of the plan and any update of it/new plan to be submitted for examination within three years of adoption of the current plan. Based on the discussion at the hearings the three year deadline appropriately balances the need for the plan to be reviewed and updated as quickly as possible with the realities of the time likely to be necessary for the Council to effectively undertake this work.”
“The wording of the policy recognises the need to align strategic growth with the delivery of planned infrastructure and refers to the aspiration of preparing a joint strategic plan in future. These are both appropriate aims and whilst we recognise that the policy cannot dictate the parameters of a future plan, we are satisfied that the wording proposed is effective and justified.”

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Object

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

Representation ID: 9060

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

Representation Summary:

3.1. Section 33A of the Planning and Compulsory Purchase Act 2004, as inserted by section 110 of the Localism Act 2011 requires the council to cooperate with other local planning authorities and other ‘prescribed bodies’ in preparing and developing development plan documents and other local development documents so far as it relates to a strategic matter.
3.2. Local authorities must fulfil the legal requirement to cooperate with the Duty to Cooperate prescribed bodies by “engaging constructively, actively and on an ongoing basis” on cross boundary strategic matters from the commencement of preparing the Local Plan to submission of the Local Plan to the Secretary of State for examination.
3.3. There is no reference in the consultation documents or the supporting evidence to the ouncil’s legal requirements to discharge its Duty to Cooperate as part of the plan-making process. Given the potential for strategic development proposed in close proximity to neighbouring authorities and clear cross boundary strategic matters one would expect cross boundary working on these matters to be active, ongoing and constructive from the commencing of Local Plan preparation.
3.4. Furthermore, BBC purports its main purpose for undertaking a Local Plan update is to ensure compliance with Policy 1 of the adopted Local Plan. A key part of this policy is where it states that “The review will also serve to build stronger working relationships with adjoining and nearby authorities and may result in the preparation of a joint strategic plan based on a wider geography”. Yet the Draft Local Plan fails to acknowledge how BBC has worked with adjoining and nearby authorities or address whether a strategic plan for the wider geography is still being pursued or has been shelved and any reasoning for this.
3.5. BBC has also failed to comply with the Town and Country Planning (Local Planning) (England) Regulations 2012 which states that:
“(6) Where a local planning authority have co-operated with another local planning authority, county council, or a body or person prescribed under section 33A of the Act, the local planning authority’s monitoring report must give details of what action they have taken during the period covered by the report.”
It is therefore impossible to determine what Duty to Cooperate activities have taken place since commencement of local plan preparation as BBC has not made this information available.
3.6. In any case Planning Practice Guidance (PPG) states that authorities should make any statements of common ground (SOCG) available on their website by the time they publish their draft plan so that communities and stakeholders have a transparent picture of how they have collaborated:
Authorities should have made a statement of common ground available on their website by the time they publish their draft plan, in order to provide communities and other stakeholders with a transparent picture of how they have collaborated.
3.7. There are no published SOCGs with any prescribed bodies for communities and other stakeholders to demonstrate that BBC has fulfilled the legal and policy requirements of Government.
3.8. The PPG explains what a Statement of Common Ground should contain. The PPG also tates that “The level of cooperation detailed in the statement is expected to be proportionate to the matters being addressed. The statement is expected to be concise and is not intended to document every occasion that strategic policy-making authorities meet, consult with each other, or for example, contact prescribed bodies under the duty to cooperate. The statement is a means of detailing key information, providing clear signposting or links to available evidence on authorities’ websites.”
3.9. As there is no mention of cross-boundary strategic matters or joint working in the Draft Local Plan or its supporting documentation, it is impossible to comment on this topic apart from saying that the Council is clearly not discharging its legal Duty to Cooperate as required by Government.

Attachments: