1.45

Object

Representation ID: 3577

Received: 12/08/2021

Respondent: Mr Jonathan Pelham

The text of that definition seems rather vague and circular.

We're a key service centre because we were designated a key service centre?

Our public transport link to Bedford is laughable and is unusable by anyone wishing to commute in Bedford if they don't work either very close to the bus route or don't need to be in by 9.

Indeed it is impossible to travel by Bus to Bedford and from there take a train to London and have any hope of arriving before 9am.

The table in section 2.5/2.6 in your consultation document "
"Town Centres and Shopping Policies Topic Paper".
does give some criteria but that puts us closer to neighborhood centre.

We have one shop, a pharmacy, a cafe that only opened last year, a takeaway and an estate agent. Two streets away we have two convenience shops next door to each other.

Object

Representation ID: 4100

Received: 30/08/2021

Respondent: Debbie Irish

Why is this included for consultation without content???

Object

Representation ID: 5075

Received: 02/09/2021

Respondent: Mr Andrew Murray

The SETTLEMENT HIERARCHY document is from SEPTEMBER 2018, which is now 3 years out of date - Any Site Selection based on this out of date information is clearly flawed.

Object

Representation ID: 5926

Received: 08/09/2021

Respondent: Mr Tom Tagg

The consultation is FLAWED by the failure by BBC to provide an Infrastructure Delivery Plan for at least their emerging preferred options. This is a MAJOR OMISSION that prevents consultees from fully appraising the options and the further impact that infrastructure will have on the landscape, biodiversity and their lives.

Object

Representation ID: 6182

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s Approach to the Assessing Settlement Hierarchy – Objection
Reasoning
2.2 The Council’s work to justify the selected Preferred Options is at a relatively early stage with significant ‘gaps’ in the evidence presented – particularly in terms of development timescales, infrastructure delivery and viability. The Council notes, as follows:
• Infrastructure Delivery Plan – to be prepared alongside site allocations
• Settlement Hierarchy (September 2018) – review underway
• Plan-wide Viability Assessment – yet to be commissioned
2.3 The absence of these documents, and in-particular completion of the review of the Settlement Hierarchy, means that the exclusion of Oakley from the Council’s Preferred Options can be demonstrated to be unsound – not effective, not consistent with national policy and not justified.
2.4 The Council’s approach to the assessment of the existing settlement hierarchy is flawed as it fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available.
2.5 Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by public transport.
2.6 Oakley includes local shopping, significant employment opportunities and has both a Primary and Secondary School. As such, Oakley serves a wider catchment area and, in this context,
it is a reasonable alternative to consider a higher level of growth that the 25-50 homes band proposed under the adopted Plan.
2.7 The key issue with the council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the Settlement Hierarchy.
2.8 As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth.
2.9 The shortcomings of this finding are exacerbated because strategic priorities relating to the requirements for social infrastructure (notably education) were deferred rather than dealt with in the Local Plan 2030. This is contrary to the requirements of national policy (NPPF2021 paragraph 20(c)).
2.10 The current Development Plan (including the Oakley Neighbourhood Plan) makes no provision for the expansion of Lincroft Academy that is required and is a function of the growth that the current spatial strategy supports across other Key Service Centres without Secondary School provision (including Clapham and Bromham).
2.11 Addressing these current unmet strategic priorities together with providing a positive approach towards the longer-term requirements for school infrastructure would be most effectively supported by reclassification of Oakley’s role in the settlement hierarchy to reflect its importance to the wider rural area (and strong links to the urban area).
Remedy
2.12 An appropriate remedy for this would be to complete a review of the preferred options within the Local Plan 2040, treat Oakley specifically as a Key Service Centre and recognise that the area has missed out on potential growth to meet key infrastructure requirements as part of the approach to preparation of the Local Plan 2030.

Object

Representation ID: 6653

Received: 14/09/2021

Respondent: Bedfordshire Great Ouse Valley Environmental Trust

With regard to subsection 1.45, when will the documents listed as unavailable be made available for review? We are concerned about the settlement hierarchy, the sustainability appraisal report and the infrastructure delivery plan, as these will all impact on the river Great Ouse and on the Great Ouse Valley.

Object

Representation ID: 7559

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

CMAT considers that Oakley’s current status within the settlement hierarchy is not reflective of the role and importance of Lincroft Academy and the background to the immediate requirement for expansion. While there is support in principle to deliver an increase in school places within the existing campus under the existing policies of the development plan Oakley’s role as a Rural Service Centre is not consistent with an effective strategy for the long-term planning of community infrastructure in this location. The risks associated with the current strategy can be summarised as follows:
• The current issues with Station Road (although potentially not a reason for refusal in themselves) would benefit from knowledge of the ability to deliver highway improvements to be set out in the policies of the emerging Local Plan 2040; and
• Securing wider benefits associated with optimising the playing field situation, which will not be addressed by the current scheme proposals and could be a barrier to further expansion
The scale and distribution of growth to Rural Service Centres contained in Policy 4S of the LP2030 has not enabled a solution to these issues being provided through the Oakley Neighbourhood Plan albeit there is no prejudice to opportunities to resolve them in future. The Council’s testing of strategy options is based on carrying forward the lack of flexibility in providing for a long-term sustainable solution at Oakley in two ways:
• It’s Preferred Options exclude the possibility of further village-related growth north of Bedford
• In any event, testing has retained the use of arbitrary figures for Key Service Centres and Rural Service Centres (500/35 units respectively)
Within this framework there is no reasonable prospect of securing the required transformation in an approach the best addresses the provision of services and facilities at Oakley. Addressing this requires flexibility in the approach to the scale and distribution of growth that reflects the opportunities and capacity at each settlement, which for Oakley is underpinned by evidence supporting its reclassification as a Key Service Centre. This provides the starting point to potentially enable levels of growth and support other improvements and wider benefits commensurate with its existing role and function.
Reasoning
The Council’s work to justify the selected Preferred Options is at a relatively early stage with significant ‘gaps’ in the evidence presented – particularly in terms of development timescales, infrastructure delivery and viability. The Council notes, as follows:
• Infrastructure Delivery Plan – to be prepared alongside site allocations
• Settlement Hierarchy (September 2018) – review underway
• Plan-wide Viability Assessment – yet to be commissioned
The absence of these documents, and in-particular completion of the review of the Settlement Hierarchy, means that the exclusion of Oakley from the Council’s Preferred Options can be demonstrated to be unsound – not effective, not consistent with national policy and not justified.
The council’s approach to the assessment of the existing settlement hierarchy is flawed as it fails to consider the proximity of services and facilities in neighbouring areas which fall within the prescribed distances. This is particularly relevant for Oakley, which is well positioned to take a greater level of growth given its inherent sustainability and the options for development available.
Oakley is a highly sustainable location and appears wrongly classified by the Plan, notwithstanding our broader concerns over the apportionment of housing numbers and the deferral of site identification to Neighbourhood Plans. Oakley is very well connected to both Clapham (a Key Service Centre some 600 metres distant) and Bedford and is well served by public transport.
Oakley includes local shopping, significant employment opportunities and has both a Primary and Secondary School. As such, Oakley serves a wider catchment area and, in this context, it is a reasonable alternative to consider a higher level of growth that the 25-50 homes band proposed under the adopted plan.
The key issue with the council’s approach is that only limited weight was given to the provision of secondary education, as opposed to primary education in developing the evidence base for the Settlement Hierarchy.
Oakley Primary Academy and Lincroft Academy also generate significant local employment opportunities both presently and in view of the expansion required. This includes around 80 Full-time staff (including teaching and support staff) and at least 50 Part-time roles (including caterers and cleaners), with the vast majority now operating from the campus following the lifting of Coronavirus restrictions. The provision of jobs in each settlement is given no weight in the Council’s scoring of the Settlement Hierarchy and overlooks this as an important aspect of providing for sustainable communities.
As a consequence, the finding on Oakley’s function as a Rural Service Centre is flawed, particularly as the relationship between additional housing growth and improvements in education provision should form a consideration when determining settlement status and ability to provide for housing growth.
The shortcomings of this finding are exacerbated because strategic priorities relating to the requirements for social infrastructure (notably education) were deferred rather than dealt with in the Local Plan 2030. This is contrary to the requirements of national policy (NPPF2021 paragraph 20(c)).
The current development plan (including the Oakley Neighbourhood Plan) makes no provision for the expansion of Lincroft Academy that is required and is a function of the growth that the current spatial strategy supports across other Key Service Centres without Secondary School provision (including Clapham and Bromham).
Addressing these current unmet strategic priorities together with providing a positive approach towards the longer-term requirements for school infrastructure would be most effectively supported by reclassification of Oakley’s role in the settlement hierarchy to reflect its importance to the wider rural area (and strong links to the urban area).
Remedy
An appropriate remedy for this would be to complete a review of the preferred options within the Local Plan 2040, treat Oakley specifically as a Key Service Centre and recognise that the area has missed out on potential growth to meet key infrastructure requirements as part of the approach to preparation of the Local Plan 2030.

Object

Representation ID: 8063

Received: 03/09/2021

Respondent: Wilshamstead Parish Council

We reiterate here points made by Wilshamstead Parish Council which we fully support.

Both Wixams and Wilstead are included in the draft Local Plan as “Key Service Centres”.
These KSCs are spread around the perimeter of Bedford with gaps between them. Only 2 KSCs are immediately next to each other i.e., Wixams and Wilstead separated only by the width of the A6.

Wilstead should not be a KSC. Its facilities are suited to the existing size of the village – not to any expansion e.g., there is no Primary School capacity, only one small shop and the bus service only covers part of the village and passes more than 800m from most residents

It is believed that the designation of “Key Service Centre” to Wilstead is based upon incorrect assumptions. For example, the village is shown in the Settlement Hierarchy document as having 3200 residents. This must be incorrect, as there are only approximately 1100 dwellings in the village and, of those, 196 are park homes for people over the age of 50. It is possible that the figure of 3200 relates to a population size including residents of Wixams; therefore, allocating Key Service Centre status to both Wixams and Wilstead is double counting some of the residents and some facilities. It is recognised that Option 2 does not take into account KSC designation but, nevertheless, the size of Wilstead vs other communities (and therefore its capacity to accept further development) must be more accurately assessed.

Another incorrect assumption is the presence of a part-time GP surgery. This no longer exists. A statement just received from Oliver Street Surgery in Ampthill is as follows: “We unfortunately had to close the branch surgery we used to hold at the Methodist church last year as the facilities are not fit for the purpose of a GP surgery.”

Also the bus service in the village is very limited and should not rate a high score: there is no East West service despite the village stretching nearly 2 miles in that direction. In addition, bus stops for the service to Bedford are located more than 800m from the majority of residents.

The above should mean that Wilstead be given Rural Service Centre status.

The Parish would submit that Wilstead is in a similar situation to Oakley, a Rural Service Centre, which sits in open countryside between Bromham and Clapham, both Key Service Centres.

Support

Representation ID: 8233

Received: 26/09/2021

Respondent: Amanda Quince

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
The Parish Council would like to highlight that within the many policy documents forming part of
this consultation, disappointingly the Settlement Hierarchy document is not included in this
process. Whilst it is classified as being under review that makes it challenging for the Parish
Council at the time of responding to this current consultation for the Local Plan 2040 document.
The Settlement Hierarchy as a supporting policy document, plays a crucial and pivotal part in
sitting alongside the strategic growth options being considered by the local authority.
When seeking stakeholders’ views on Key Service and Rural Service Centres potentially being
included in a specific strategic growth option, not having clarity on whether a particular has
changed settlement classification makes it impossible to comment in a meaningful way. When
potentially the Settlement Hierarchy document could change a village designation and therefore
significantly changes the position a parish could be in, in terms of development it may receive.

Support

Representation ID: 8745

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

1.8 The Trust is keen to engage with the Council in the emerging Local Plan. We note from paragraph 1.45 that BBC plans to prepare an ‘Infrastructure Delivery Plan’ alongside the site allocations. The healthcare and social infrastructure aspects of this would be particularly relevant to the Trust, and we would be happy to discuss any matters in further detail.