2.1

Support

Representation ID: 6686

Received: 14/09/2021

Respondent: The British Horse Society

There is much in the vision that rings true to the desires of local equestrians – who want to be able to enjoy the rural and semi rural network of bridleways and byways in safety for the benefit of their health and mental well being and to see an improvement in connectivity of these routes.

The BHS supports the vision but is concerned that in the finer details of the Themes there is a risk that we will be “designed out” with a strong focus on walking and cycling to the potential exclusion of horses.

In particular the sections of the vision that resonate are:

Well-planned growth supported by appropriate infrastructure and avoiding areas of high flood risk will enable the creation of strong, safe and resilient local communities in environments that facilitate healthy and independent living for all. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in both biodiversity and environmental quality.”

There will be new multi-functional green spaces to complement and expand the existing network of paths and green corridors. Country parks north of Brickhill, west of Bedford and in the new town centre neighbourhoods will have matured and along with the Bedford to Milton Keynes Waterway will encourage healthy lifestyles, tourism and a diverse ecology”

Please note that ‘all’ and ‘multi-functional’ should be regarded as inclusive of equestrians.

Support

Representation ID: 6721

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 6759

Received: 14/09/2021

Respondent: Ms S Kelly

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 6811

Received: 15/09/2021

Respondent: Mr Damian Smith

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 6859

Received: 13/09/2021

Respondent: Mrs Joanna Ibbett

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 6898

Received: 15/09/2021

Respondent: Master Corey T Farmer

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Support

Representation ID: 6990

Received: 16/09/2021

Respondent: Mr Robert Tusting

This is an important statement for the Council. Staploe Parish Council recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7030

Received: 17/09/2021

Respondent: Mr Robert Tusting

This is an important statement for the Council. Staploe Parish Council recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7079

Received: 09/09/2021

Respondent: June Coles

This is an important statement for the Council. Staploe Parish Council recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7126

Received: 09/09/2021

Respondent: Stephen Coles

This is an important statement for the Council. Staploe Parish Council recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7150

Received: 17/09/2021

Respondent: Mr Richard Hull

Agent: Phillips Planning Services

The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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.”

Support

Representation ID: 7159

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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.”

Support

Representation ID: 7172

Received: 17/09/2021

Respondent: EF Wootton and Son

Agent: Phillips Planning Services

Our client supports the vision for the Bedford River Valley Park with the transformation through new leisure opportunities. Our clients site known as Land Goldington Road (Site 748) is within this area, and has the potential to deliver leisure and recreation opportunities including an expansion of the marina provision, water sports staging area, provision of playing pitches for rugby and football, and an extension of the neighbouring public park. This can be delivered in conjunction with neighbouring ambitions to deliver new commercial and retail opportunities along Goldington Road East.

Object

Representation ID: 7175

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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.”

Object

Representation ID: 7206

Received: 17/09/2021

Respondent: Mr Peter Knight

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7315

Received: 02/09/2021

Respondent: Miss Emma Pegler

I do not see how these proposals fit in with the vision and strategy of the country. At a time when we are focused on reducing our carbon footprint, BBC comes up with a plan to increase housing without showing the basis on which it thinks those houses will be needed and even if it could, why would the houses be built on prime food producing land when there are other alternatives. We replace food and low emission areas with country habitat with masses of traffic and light without properly considering the alternatives.

Support

Representation ID: 7440

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

The Vision appears to align with the wider objectives of the Council and the corporate
priorities for the Borough. However, the clients’ comments regarding Para 22 of the
NPPF remain, whilst it is considered that this emerging plan should not seek to deliver new settlements, if this is to be the case then the vision needs to cover a period up to
2050 at the earliest.

Object

Representation ID: 7505

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

“The borough's countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans. This development will reflect each area's unique local character whilst providing and supporting much needed housing and employment, rural facilities and services, including high speed broadband and public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

2.1 100 word summary
The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7523

Received: 21/09/2021

Respondent: EF Wootton and Son

Agent: Phillips Planning Services

The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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

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


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, for the Plan to be “positively prepared”, 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 review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and help towards reducing the burden going forward.

This important point is supported by updated guidance in the revised National Planning Policy Framework (2021); and, while it is accepted that this Consultation was developed in advance of the publication of the revised Framework, we must highlight that under paragraph 22 it states that where Local Plans are to include new settlements or significant extensions to towns and villages, then it should be set within a vision which looks at least 30 years ahead. As the transitional arrangements at paragraph 221 of Annex 1 confirm this applies to plans that have not reached Regulation 19 stage; then, no matter which strategy is chosen, the Bedford Local Plan 2040, must expand its “vision” to set out how it will accommodate growth beyond 2040 and deliver on the ambitions of the Arc.

Object

Representation ID: 7539

Received: 21/09/2021

Respondent: Bates Bros (Farms) Limited

Agent: Phillips Planning Services

The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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.

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 a 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 have to”, rather than seeking to embrace the ambitions that Government has for development within the Arc.

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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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

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

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, for the Plan to be “positively prepared”, 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 review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and help towards reducing the burden going forward.

This important point is supported by updated guidance in the revised National Planning Policy Framework (2021); and, while it is accepted that this Consultation was developed in advance of the publication of the revised Framework, we must highlight that under paragraph 22 it states that where Local Plans are to include new settlements or significant extensions to towns and villages, then it should be set within a vision which looks at least 30 years ahead. As the transitional arrangements at paragraph 221 of Annex 1 confirm this applies to plans that have not reached Regulation 19 stage; then, no matter which strategy is chosen, the Bedford Local Plan 2040, must expand its “vision” to set out how it will accommodate growth beyond 2040 and deliver on the ambitions of the Arc.

Object

Representation ID: 7554

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

The draft Vision sets out:
“Well-planned growth supported by appropriate infrastructure and avoiding areas of high flood risk will enable the creation of strong, safe and resilient local communities in environments that facilitate healthy and independent living for all.”
This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options omitting a significant number of the borough's KSCs and RSCs from the spatial strategy and do not seek to provide for the additional development required to secure balanced communities.
Theme 4 (Better Places) of the Council’s proposed Objectives for the Local Plan 2040 sets out:
“Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient
Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives.”
The principle of these objectives is supported but is reliant on flexibly supporting diverse opportunities for development across the settlement hierarchy. There are a substantial number of centres where the level of development identified is insufficient to secure the opportunities identified or, as in the case of Oakley, to provide for a long-term strategy for improvement of the facilities at Lincroft Academy.

SUPPORT FOR THE REQUIRED EXPANSION OF LINCROFT ACADEMY
(a) Summary of the Expansion Proposals Requiring Immediate Support
Lincroft Academy has an immediate requirement for expansion to support a Pupil Allocation Number of approximately 240 admissions per annum from 2023. This should be reflected in the policies of the Local Plan 2040. In summary, plans for the works required to achieve the additional intake have been drawn up and the requirement for expansion has been agreed by Bedford Borough Council’s Education department.
The Borough Council’s Education department has further confirmed with CMAT details of the NOR forecasts necessitating the increase in the Pupil Allocation Number to 240. To our knowledge the evidence base for the emerging Local Plan 2040 makes no reference to these forecasts and the account they take of growth at neighbouring Key Service Centres including Clapham and Bromham and other committed development. It follows that while the current proposals would address the immediate need for expansion it would be necessary for the evidence base for the Local Plan 2040 to consider the potential demand for a further increase in the PAN over the plan period. Annual applications are apparently at or in excess of the Pupil Allocation Number.
This requirement for expansion is not currently reflected anywhere within the policies of the emerging Local Plan 2040, and has not been assessed within the emerging evidence base. The Council’s Infrastructure Delivery Plan is not yet available and assumptions within the AECOM Transport Model assume limited growth in housing assumed beyond 2030 in the reference case (which assumes no further growth beyond the adopted Local Plan). For Oakley, this means that the reference case only takes account of development within the Neighbourhood Plan and ignores altogether the settlement’s role in providing Primary and Secondary education. The current position of the existing and emerging development plan means expansion will need to be achieved in the context of the existing traffic conditions on Station Road.
Given the background and context of the development plan the strategy to achieve the expansion required within the necessary timescales represents a freestanding development proposal within the existing site west of Station Road. This current approach precludes the wider benefits of incorporating CMAT’s interests east of Station Road, considered later in these representations.

The scheme drawn up has an itemised cost of circa £8m. The cost is considered the minimum necessary to achieve an efficient expansion to 240-pupil entry and reflects the absence of any funding strategy previously agreed upon the change of Lincroft Academy’s role as a secondary school.
Together with the expansion in teaching and classroom space the scheme drawn up offers some limited improvements for staff parking and an ‘Activity Centre’ is proposed within the new buildings. The proposals allow for improvement to highways conditions on Station Road.
The plans and proposed funding sources for expansion take no account of relocation or enhancement of the existing sports pitches and are not expected to raise any implications for the ESFA.
(b) Background to Lincroft Academy and the Requirement for Expansion
The buildings at Lincroft Academy and Oakley Primary Academy share a single site on land west of Station Road. This is important in the context of the ongoing implementation of school reorganisation across the Borough to provide full primary and secondary education provision (age 4-16 years) within Oakley and the role of the schools in serving the wider rural area.
The evidence base for the Bedford Local Plan 2030 substantially pre-dates the reorganisation of school provision in Bedford Borough. It cannot be overlooked that as part of the change from a two-tier to three tier system Lincroft Academy is the only former Middle School within the North Bedfordshire area, expanded and repurposed to provide secondary education provision for pupils aged 11-16. Oakley Primary Academy, forming part of the same campus, provides education of those aged 4-11.
Middle Schools in a number of settlements have been closed altogether with a total net reduction in the number of schools from 74 to 60. This emphasises the contribution of settlements such as Oakley with a range of education provision to providing services and facilities for the wider rural area.
The recent reorganisation represents a substantial challenge in planning terms, albeit in the first instance change in the role of a school building from providing Middle School to Secondary School facilities is not in itself a change of use requiring planning permission. The wider repercussions of this in terms of extant planning history and the requirements for future use and development must be considered further. This includes not only meeting the demand for school places but also acknowledging the campus’ (Oakley Primary Academy with Lincroft Academy) role as a key employer and provider of wider benefits to the local community.
CMAT is committed to addressing as part of maintaining and enhancing education facilities and outcomes in Oakley itself and across the Borough but notes the absence of any comprehensively agreed funding strategy or development proposals supporting the changes outlined above.
A review of the planning history clearly indicates that there is no application activity associated with the recent school reorganisation to provide full secondary education (age 11-16) facilities at Lincroft Academy. This follows from substantial previous activity to sustain and enhance the facilities available and address growing demand on school places; albeit no explicit planning to support an increase in pupil numbers has been undertaken in recent years. The popularity of the school has been associated with a reactive approach.
In practical terms planning condition no.4 attached to application reference 16/00329/MAF limiting the pupil roll at Lincroft Academy to 855 pupils is instructive of how the planning history of the campus fails to reflect the current and future requirements of the site.
(c) Background to Provision of School Places
It is agreed with the Council’s Education department that NOR forecasts for Lincroft Academy necessitate increase of the PAN to 240 pupils intake at ‘year 7’ from 2023 onwards. While these forecast are not set out in detail in these representations, data on the number of current pupils at each school and the confirmed intake for the 2019/20 academic year was compiled to support representations to the Oakley Neighbourhood Plan submission (Regulation 16) version consultation in August 2019. The Council’s Planning Policy Team therefore has advanced knowledge of the pressure on school places from before commencement of the immediate review of the Bedford Local Plan 2030.
This is important because it provides an insight into overall demand and the ongoing impact of reorganisation. Data for previous years was obtained direct from the Department for Education’s absence and pupil population records to 2017/18.
Failure of either the Local Plan 2030 or emerging Local Plan 2040 to take any apparent account of the Council’s own NOR forecasts is a significant deficiency in the context of ongoing reorganisation and forecasts for future housing growth across the borough; including within Key Service Centres and Rural Service Centres. This represents a significant risk at the authority level in terms of ensuring the need for school places is addressed.
Table 1. Pupil Roll and Forecast – Lincroft Academy and Oakley Primary Academy (see attachment)
The past intake data demonstrates the continued high demand for school places in Oakley and ongoing impact of reorganisation. For example, in 2016/17 the Oakley Primary Academy was still a lower school, i.e., only accommodated pupils up to Year 4, after which point, they moved to a middle school. In 2017/18, the school started transitioning to a Primary School and took pupils up to Year 5. In 2018/19, it became a full Primary School, with pupils up to Year 6. For this reason, there is also some short-term fluctuation in the total number of pupils at Lincroft Academy as the school roll transfers to a secondary education facility. For Lincroft Academy the September 2017 intake (2017/18 data) is based on year 6 to year 9 pupils only).
At the point that the condition restricting pupil numbers at Lincroft Middle School (855no pupils) was imposed as part of application ref: 16/00329/MAF Oakley Lower School had a pupil allocation number of approximately 200, equating to 1,055 places in total. It is clear from the data for 2016/17 that the condition on pupil numbers at Lincroft Middle School was breached in 2016/17, as was a cumulative total of 1,055 across the combined sites.
Due to its sustainable location, it was accepted that provision for up to 290 pupils at Oakley Primary Academy is acceptable in transport terms, as assessed under application ref: 17/03321/DC3. However, it is also clear that the school is already operating at this capacity with significant further growth to be provided for.
Previously confirmed pupil intake figures for Lincroft Academy in September 2019 indicate the increasing demand for places. The full Pupil Allocation Number (PAN) of 210 places was met or exceeded for year 7 and year 8; along with a waiting list of 5 places for additional year 7 students. Each year 7 group is expected to be filled in the future, equating to a total potential pupil roll total of 1,050 pupils across years 7-11. This significantly exceeds the present restriction to accommodate a maximum 855 pupils based on extant planning permission 16/00329/MAF.
Any breach of the extant planning condition should be considered to have adverse environmental consequences in terms of (for example) land use and traffic impacts. It is important that the policies of the development seek to manage and address these challenges, which is not currently provided for within the development plan, which imposes significant restrictions on the development of the campus and surrounding land.
Lincroft Academy also provides 28 further places for specialist education provision as part of its Autistic Spectrum Centre (ASC) reflecting an important dimension of the school’s wider role. These pupils are additional to the PAN for years 7-11.
This background informs the current requirement to further increase the PAN to 240 for years 7-11. The following analysis reflects our own review of committed development and does not replicate the Council’s own unpublished NOR forecasts.
Data obtained by Lincroft Academy shows the significant role of the school in maintaining the supply of school places for the wider rural area. Table 2 below shows the confirmed pupil roll by year group in September 2019 and indicates all catchment districts which represent the origin location of 25 or more pupils on the total roll:
Table 2 - see attachment
Lincroft Academy provides the secondary school for the Clapham catchment, while the Bromham catchment offers preference for places at either Lincroft Academy or Biddenham Upper School. This is reflected in the high numbers of pupil on the roll for each year from these catchments.
Both Bromham and Clapham are Key Service Centres within the borough’s settlement hierarchy and are required to provide for the development of up to 500 dwellings as part of the spatial strategy set out in Policy 3S of the emerging Local Plan 2030.
Bedford Borough Council’s Planning Obligations Supplementary Planning Document (July 2013) provides benchmark figures for the increased requirements for secondary school places based on the typical increase in population generated by new development:
• 11-15 year old pupils: 4.2 children/age group/100 dwellings
• Equivalent to 21 secondary school age pupils (11-15 year olds) per 100 dwellings
The provision of 500 dwellings would therefore be expected to generate around 105 pupils in total, or 21 in each year group. Notwithstanding the potential for demographic change in the existing population, these pupils would be additional to the existing roll. It should also be noted that the total roll in years 9-11 will increase going forward based on Lincroft Academy’s intake reflecting its full Pupil Allocation Number (PAN).
We have assumed that the number of these additional pupils likely to attend Lincroft Academy will be consistent with the existing proportion of the 11-15 year old population that is recorded on the pupil roll in Oakley. The have based this on the proportion of the population as recorded in the 2017 mid-year population estimates for the Built Up Area of Bromham and Clapham respectively. This is illustrated in Table 3 below:
Table 3. Local Plan 2030 Related Growth In Secondary Age Pupils – Bromham and Clapham (September 2019) - see attachment
Development in-line with the emerging Bedford Local Plan 2030 is therefore likely to generate an additional demand for secondary school places of around 63 pupils from Bromham and 75 pupils from Clapham. These figures are likely to be a minimum, given that in future Lincroft Academy will meet or exceed its current PAN for each year group. Furthermore, the popularity of Lincroft Academy as a choice for feeder schools in the Bromham catchment is likely to increase.
This demonstrates the role of Lincroft Academy in serving a wider rural catchment and the imperative of ensuring its future requirements can be met to safeguard sustainable development. This will be in the context of Lincroft Academy regularly exceeding the cap of 855 pupils imposed via planning condition on 16/00329/MAF.
The planning strategy for the increase in the PAN to 240 is required in the short-term to address this increased demand. Depending on the extent to which the Council’s own NOR forecasts take account of development within the Neighbourhood Plans at Clapham and Bromham that is not already consented (i.e., over-and-above extant commitments) there is a strong possibility of the requirement to accommodate further increase to the PAN.

Object

Representation ID: 7626

Received: 01/09/2021

Respondent: Miss Nicola Tagg

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

2.1 100-word Summary
The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7673

Received: 01/09/2021

Respondent: Mr Simon Goodship

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

2.1 100-word Summary
The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7755

Received: 22/09/2021

Respondent: Mr Michael Thompson

This is an important statement for the Council. Staploe Parish Council recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

2.1 100 word summary
The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7773

Received: 22/09/2021

Respondent: Lance Feaver

Overall I support the aspiration to be a greener, more accessible and prosperous Borough, and in particular any decision to optimise brown-field sites for new housing rather than development on farming land. Bedford Town Centre is increasingly desolate and a major shift from retail use to residential could, if properly planned, help revitalise it, and would help promote Bedford’s position within the Oxford Cambridge arc.

Support

Representation ID: 7780

Received: 23/09/2021

Respondent: National Highways

The Local Plan (LP) states that by the end of the plan period, the Borough will have become a greener, more sustainable, more attractive and prosperous place to live. The LP suggests that sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the Borough’s carbon footprint and securing a net-gain in both biodiversity and environmental quality. This is an approach that Highways England supports.
A key theme of the LP is accessibility, encouraging sustainable travel as well as taking the opportunities offered by strategic infrastructure for greater regional and national connectivity. An objective of the LP is to reduce congestion in the Borough, particularly into and around the town centre, including making journeys by public transport, walking and cycling more attractive to encourage an increase in more sustainable and healthy modes of transport, which is something Highways England welcomes.
Creating the transport strategy for plan around the five actions taken from the EEH Transport Strategy appears to be a sensible approach.
• Focus on decarbonisation of the transport system by harnessing innovation and supporting solutions which create green economic opportunities;

• Promote investment in digital infrastructure as a means of improving connectivity, in order to reduce the need to travel

• Use delivery of East West Rail and mass rapid transit systems as the catalyst for the transformation of our strategic public transport networks

• Champion increased investment in active travel and shared transport solutions to improve local connectivity to ensure that everyone has the opportunity to realise their potential

• Ensure that freight and logistics needs continue to be met whilst lowering the environmental impact of their delivery

Support

Representation ID: 7784

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

3.2. The Vision sets out general planning aims, and we have no particular comments to make on the Borough becoming more sustainable, the delivery of good design, or 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 a 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 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. The current consultation on “Creating a Vision for the Oxford-Cambridge Arc”, states that the Government is:

“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

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


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 review to keep pace with the changing policy context, therefore allowing for some uplift would pre-empt this and help towards reducing the burden going forward.

Object

Representation ID: 7814

Received: 03/09/2021

Respondent: Mr Emilio Meola

The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 7853

Received: 03/09/2021

Respondent: Mr Mark Ibbett

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Support

Representation ID: 7932

Received: 20/09/2021

Respondent: Pavenham Parish council

Whilst the Parish Council fully applauds and supports the laudable Vision and Objectives – there is just a slight residual concern as to whether they may be more idealistic than realistic.
2.2 As the Plan progresses, the Parish Council would welcome more practical information in relation to the following aspirations –
(a) Flood risk – that development in high flood risk will be avoided. Many local authorities across the country have a less than enviable record in this respect and whilst it is acknowledged that the Local Plan looks to such a strategy, it is one thing to have a policy – quite another to resist the overtures of developers intent on development and offering as inducements short-term financial gains in the context of the overriding need of the Borough Council to identify an increased number of sites for residential development. A “catch-22” scenario.
(b) The East-West Rail Arc - as a concept, is fully supported by the Parish Council. It is queried, however, whether in the context of the proposed link, the Borough Council can justifiably assume that as a result of the delivery of the Arc – if it is delivered - “up-front transport links” and “speedy internet” will also be delivered. Whilst “greater connectivity” must clearly be an objective, the Parish Council is firmly of the view that as currently proposed, local transport links to the north of the town will suffer and we fail to understand how the East-
3
West Rail Arc will actually improve internet connectivity. This seems to us to be little more than political hype. It should be noted in this context, that the Parish Council opposes the northern option for East-West Rail which appears to the Parish Council to have no commercial nor environmentally sustainable justification.
(c) Bedford Town Centre – the Parish Council queries whether the entirely laudable objectives expressed by the Borough Council in terms of re-invigoration will ever be achieved. The Parish Council believes that the ‘town centre” as a concept, certainly for Bedford, is under serious threat – as and indicated by the Borough Council, requires both reinvigoration and possibly reinvention. The Parish Council supports the strengthening of independent outlets – ideally with improved parking provision at a lower or no cost? We do, however, believe that serious consideration should be given to residential growth within the town centre - particularly in light of the consequences of the Pandemic. Indeed, in this context, the Parish Council suggests that more emphasis should also be placed on hotel growth and tourism – the “staycation” effect. Bedford Borough has a great deal to offer in terms of attractions and tourism and the long-term impact of the pandemic ironically presents, in this context, positive opportunities for the Borough. The Parish Council notes the Borough Council intention to consider this matter further as noted in its Position Statements.
(d) Better places – the natural environment and the Embankment – these objectives of the Borough Council are fully supported by the Parish Council as indeed are the “Themes”, subject to the caveat sounded in relation to the East-West Rail link.
In this context we would also draw specific attention to the River Great Ouse Valley which it is suggested, should be formally addressed by the borough from its point of entry at Turvey to where it exits the borough in the East. The River Valley is the single most important environmental feature in the Borough – not just for its environmental and habitat value – but for the positive contribution that it offers for recreation and better understanding of the history of the area.