2.1

Support

Representation ID: 7958

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

“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: 8015

Received: 24/09/2021

Respondent: Mr Larry Gooch

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

Support

Representation ID: 8055

Received: 03/09/2021

Respondent: Mr Henry Vann

• The vision: We welcome the vision, which highlights the need for the whole Borough to be “a greener, more sustainable, more attractive and prosperous place to live.” We also note the specific references to River Great Ouse and valley as an asset to the Borough. To improve further upon this inspiring vision, we would welcome explicit support for sustainable transport and local renewable energy generation.
• The protection of green spaces has never been more important, something the Covid pandemic has made abundantly clear. Parks, green spaces, golf courses, and other areas of important ecological significance as well as green corridors across the rural and urban areas should be explicitly protected in policy.

Object

Representation ID: 8073

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should include and elaborate upon how it will have supported and contributed to the ambitious growth objectives within the Oxford to Cambridge Arc by the end of the Plan period.

Policy 1 (Reviewing The Local Plan 2030) of the Local Plan 2030 states that the review will secure levels of growth that accord with government policy and any growth deals that have been agreed.

Whilst as noted in our comments in response to paragraph 1.7 of the draft plan, it is accepted that there are no finalised figures for housing growth at this stage, it is important that some form of uplift is included to provide flexibility and forward planning in a positive manner and in anticipation that additional housing will be required.

If the plan simply takes the view that it cannot consider additional growth at this stage or until firm figures are released it will fail in this regard and will require further early review.

Support

Representation ID: 8091

Received: 02/09/2021

Respondent: G Morroll

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 we 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: 8121

Received: 03/09/2021

Respondent: Dr Emma Thompson

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: 8160

Received: 03/09/2021

Respondent: Mr Ross Thomson

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.

Support

Representation ID: 8199

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

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.

Support

Representation ID: 8223

Received: 26/09/2021

Respondent: The Forest of Marston Vale Trust

• Vision: We welcome and strongly support the specific inclusion of the Forest of Marston Vale within with Vision. We also support the inclusion of a reference to the Bedford River Valley Park.

Support

Representation ID: 8231

Received: 26/09/2021

Respondent: Amanda Quince

DRAFT PLAN: DRAFT POLICIES
Paragraph 2.1 of the consultation document sets out the overarching vision and objectives. Of
particular relevance to the parish of Renhold is the following:
“Development will be sensitively planned to complement the borough’s natural environment.
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 supported by the Parish Council, together with the statement made in paragraph 1.25.
The continued cooperation between the Council and Parish Council's regarding additional
development in or around villages is welcomed and supported.

Object

Representation ID: 8258

Received: 03/09/2021

Respondent: Mr Daniel Francis

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: 8302

Received: 03/09/2021

Respondent: Miss Erin Francis

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: 8344

Received: 03/09/2021

Respondent: Mrs K Francis

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: 8376

Received: 02/09/2021

Respondent: Bedford Borough Councillor

Our vision would be for a Borough that aims fundamentally for increasing wellbeing, and particularly for the most disadvantaged: by contrast, the draft aims fundamentally for increasing the rate of economic activity, whether or not that activity is consistent with the other elements of wellbeing, and whether or not that activity worsens inequality.
We welcome the early mention in the document and apparent high priority given to “Tackling climate change and adapting to and mitigating its effects”. However, if the council “has pledged to incorporate the carbon neutral ambition into all Council strategies, including the Local Plan 2040”, this Plan should include policies consistently written in ways that pay more heed to the climate emergency than those revealed in this document. Detail is needed on how to meet the ambition of “Bedford [being] a net zero carbon emissions borough whilst improving, enhancing and creating green infrastructure and spaces”. Such detail is very notably absent. Unless there are major amendments this document will be a massive missed opportunity. All told, our assessment is that this document does nothing like enough to meet that aim of tackling climate breakdown, adaptation and mitigation, nor is it consistent with the non-economic elements of wellbeing, or promoting equality.

Among the “Vision and Objectives” actually listed, wherever infrastructure projects actually are roadbuilding, we reject that as an appropriate means to attract “new business through the completion of significant infrastructure projects”. Attracting business by roadbuilding is fundamentally contrary to the requirements of getting to net zero, and using “infrastructure” to disguise the promotion of roadbuilding is deception of a sort that the council should not be indulging in. Put simply, roadbuilding works against the more fundamental aim of “Tackling climate change and adapting to and mitigating its effects”. Further, there is a tendency for businesses attracted by roadbuilding to be in locations that are difficult for potential employees to access except by cars, restricting employment to those with access to cars (when some cannot afford cars, increasing numbers live in properties without car parking, and others have impairments such as visual impairments and epilepsy that preclude driving). Thus, attracting businesses by roadbuilding can worsen inequality.
The overall lack of ambition is, in part, seen by talk in the “vision and objectives” of High Street businesses only being retailers. A visionary approach to the High Street would include attracting repair businesses, as well as combined production/retail spaces such as artists’ studios and artisan bakeries. Moreover, the better part of the objective, making it “a more enjoyable place, where … people choose to linger” will require policies to encourage non-retail development, including (daytime) performance spaces and opportunities for free recreation, yet these policies are absent.
Talk of “Additional town centre living” would be welcome, but this needs to be town centre living with sustainable transport, which implies better cycling provision than current Plan 2030 policies, yet there is no proposal for relevant better policies, and as already mentioned, businesses attracted to locations that are difficult for potential employees to access except by cars will exclude those living in the town centre, at a time when town centre employment is reducing. Again, the words of the “Vision and Objectives” sound good but are not reflected in detailed policies that will actually meet the good ambitions.
Unusually with respect to walkable neighbourhoods, we don’t even get what might notionally be called significant ambition in the “Vision and Objectives” – “More” is an incredibly weak word. A visionary objective would be that the norm will be walkable neighbourhoods. It is only when neighbourhoods being walkable becomes the norm that significant reductions in car use for such local journeys becomes realistic.
We are disappointed that talk of the River Great Ouse valley is related to parkland. We need, as a council, to put more emphasis on protecting and increasing biodiversity in the valley (as well as more broadly in the Borough).

Support

Representation ID: 8398

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

The proposed vision and objectives set out in Section 2 (pages 11 & 12) are supported,
including the statement:
“Good design will help to improve quality of life and to create safer, vibrant and more
sustainable places, both in the urban area of Bedford and Kempston and in surrounding
village communities.”
However, it may need to be updated to better reflect the chosen growth strategy,
especially if that is to include the delivery of one or more new settlements around a new
East-West Railway Station.

Object

Representation ID: 8435

Received: 27/09/2021

Respondent: Mrs G Hunt

Agent: DLP Planning Limited

This section addresses two main themes. It firstly sets out the shortcomings of the Vision in terms of reflecting comprehensive opportunities for sustainable development across the borough. Secondly, it addresses that while there are many positive aspects of outcomes sought under the vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options.
Reasoning
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. It is not proposed to allocate small housing sites in the plan and concern is expressed that this will delay housing delivery in the early part of the plan period.
The Vision further states:
"Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”
This would imply a requirement for additional growth, which the preferred options exclude for a significant number of centres. The draft Vision fails to address that it is part of the role of the Local Plan review (and resulting updates) to address strategic priorities deferred as a consequence of the Local Plan 2030 (for example expansion of primary healthcare and secondary education). The Vision also fails to reflect that the proposed development strategy is not looking to provide for any additional growth in rural areas as part of an uplift to meet housing needs in full before 2030. This is a significant shortcoming of the strategy and overlooks suitable and deliverable sites that could be prioritised now to meet these increased needs alongside the delivery of other substantial benefits.
The Vision makes limited reference to specific benefits that the Local Plan 2040 will secure in relation to the natural environment, including Country Parks north of Brickhill and west of Bedford.
The Vision is artificially constrained as a result of the Council’s current position on Preferred Options. There is no reason that other sustainable developments cannot achieve complementary and significant advantages for Green Infrastructure provision.

Object

Representation ID: 8448

Received: 03/09/2021

Respondent: Mr Theodore Cassell

“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: 8491

Received: 27/09/2021

Respondent: Gladman Developments Ltd

The proposed vision sets a series of ambitions for the borough over the plan period. At this stage final decisions have not yet been taken with regard to the spatial strategy and the location of key strategic developments across the borough that will need to be planned for over the plan period. Further consideration may therefore need to be given to the content of the vision to reflect the final policy choices that are made as the plan preparation process progresses. In particular, it will also be necessary to take note of Paragraph 22 of the NPPF, which requires a vision of at least 30 years where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area. It should be noted that the Housing Secretary has now confirmed in writing to the Planning Inspectorate that planning practice guidance will be updated to explain the way  local  authorities  should  reflect  the  recent  NPPF  paragraph  22  changes  in  their  local  plans to ensure that plan preparation can continue at pace whilst also ensuring that the government’s objectives are delivered.

Support

Representation ID: 8508

Received: 02/09/2021

Respondent: Bedfordshire Police

BP welcome and support the references to growth being supported by appropriate infrastructure and
designed to create safer places. However, the Vision would benefit from a much clearer commitment
to creating a safe, secure and low crime environment for all in the Borough. This would ensure
consistency with the following:
 Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July
2021) (NPPF);
 Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and
 Section 17 of the Crime and Disorder Act 1998 (as amended).
In view of the above, BP propose the following amendments to the Vision:
Good design and supporting infrastructure will help to improve quality of life and to create safer,
more secure, low crime, vibrant and more sustainable places, both in the urban area of Bedford and
Kempston and in the surrounding village communities.
Theme 4: Better places – Page 14
Although BP welcome the aim of creating a safe built environment, it would be significantly
strengthened through direct references to Secured by Design and reducing crime. In doing so, it would
being Theme 4 into much closer alignment with:
 Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July
2021) (NPPF);
 Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and
 Section 17 of the Crime and Disorder Act 1998 (as amended).
Furthermore, National Planning Practice Guidance (NPPG) is very clear that:
‘Planning provides an important opportunity to consider the security of the built environment, those
that live and work in it and the services it provides.
Section 17 of the Crime and Disorder Act 1998 (as amended) requires all local, joint and combined
authorities (as well as National Parks, the Broads Authority and the Greater London Authority) to
exercise their functions with due regard to their likely effect on crime and disorder, and to do all
they reasonably can to prevent crime and disorder. Crime for these purposes includes terrorism.’
Paragraph: 009 Reference ID: 53-009-20190722
Revision date: 22 07 2019
‘Good design that considers security as an intrinsic part of a masterplan or individual development
can help achieve places that are safe as well as attractive, which function well, and which do not
need subsequent work to achieve or improve resilience. However good security is not only about
physical measures and design, it requires risks and mitigation to be considered in a holistic way…
‘Good design means a wide range of crimes from theft to terrorism are less likely to happen by
making committing those crimes more difficult.’
Paragraph: 010 Reference ID: 53-010-20190722
Revision date: 22 07 2019
This has been expanded on by the National Model Design Code (July 2021) (Parts 1 and 2), which makes
the following points:
 Page 32 – Paragraph 63 (iv) – Safety and Security – ‘All schemes should aim to create a safe and
secure environment and provide a sense of security for all users. Where development is for or
has potential for a significant concentration of people schemes should also consider appropriate
and proportionate security measures.’
 Page 61 – Paragraph 144 – Secured by Design – ‘Neighbourhoods need to be designed to make
all people feel safe and to reduce the incidents of crime in accordance with the recommendations
of Secured by Design which includes guidance for housing, commercial space, schools, hospitals
and sheltered accommodation. Support and advice is available from the police through a network of Designing Out Crime Officers (DOCOs) across the UK. Secured by Design advice
incorporates proven crime prevention techniques and measures into the layout and design of
places and spaces.
In view of all of the above, BP requests that the following amendments be made to Theme 4:
‘Theme 4: Better Places – Developing high quality, well-designed, beautiful, safe and low crime
places for all to use and enjoy.
Objectives:
Support and create a high quality, inclusive and safe built environment that values local landscapes
and settlement character. This environment will experience low incidences of crime through the
application of Secured by Design. It will also be one where the historic environment is conserved
and enhanced to enable enjoyment by all.

Object

Representation ID: 8510

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

This section addresses two main themes. It firstly sets out the shortcomings of the Vision in terms of reflecting comprehensive opportunities for sustainable development across the borough. Secondly, it addresses that while there are many positive aspects of outcomes sought under the vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options
Reasoning
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 without specifying a further contribution towards the increased need from development at Great Barford.
The Vision further states:
"Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”
This would imply a requirement for additional growth, which the preferred options exclude for a significant number of centres. The draft Vision fails to address that it is part of the role of the Local Plan review (and resulting updates) to address strategic priorities deferred as a consequence of the Local Plan 2030 (for example expansion of primary healthcare and green infrastructure).
The Vision also fails to reflect that the proposed development strategy is not looking to provide for any additional growth in rural areas as part of an uplift to meet housing needs in full before 2030.
The Vision makes limited reference to specific benefits that the Local Plan 2040 will secure in relation to the natural environment, including Country Parks north of Brickhill and west of Bedford.
The Vision is artificially constrained as a result of the Council’s current position on Preferred Options. There is no reason that other sustainable developments cannot achieve complementary and significant advantages for Green Infrastructure provision (e.g., specifically the provision for a Countryside Park within our client’s Willoughby Park proposals).

Object

Representation ID: 8545

Received: 03/09/2021

Respondent: Mrs Claire francis

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: 8577

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

3.1 The first statement contained within the Local Plan’s Vision (Chapter 2) rightly sets an aim of tackling climate change and adapting to and mitigating its effects being at the heart of new development in the Borough.
3.2 This is then reinforced, with Theme 1 (p.13) setting an objective to making Bedford Borough a carbon neutral Borough. The draft Local Plan, however, does not currently carry this commitment through in such a way as to suggest meaningful action.
3.3 Firstly, the Local Plan does not include any proposed strategy or approach concerning renewable energy development. If the Borough is serious about becoming carbon neutral and tackling climate change, it is essential that the Local Plan includes positive policies which encourage both renewable energy developments, and net zero carbon developments, to come forward.
3.4 The NPPF is clear (Chapter 14 – para 152 in particular) that the planning system should, inter alia, support renewable and low carbon energy and associated infrastructure. Para 153 states that Plans should take a proactive approach to mitigating and adapting to climate change.
3.5 Moreover, para 155 states that Plans should both provide a positive strategy for energy from renewable and low carbon sources and consider identifying suitable areas for such developments.
3.6 The Local Plan fails to tackle this issue. As currently drafted, it lacks any meaningful proposals or aims in order to meet these requirements of national policy.
3.7 In the same fashion that the Local Plan has considered issues and options around future growth (scale, location, pattern etc), this iteration of the Local Plan should have also included options proposing a positive strategy for energy from renewable and low carbon sources, including potential locations.
3.8 It must also encourage growth that comes forward where renewable energy goes hand in hand with development proposals, with positive policies encouraging such developments (be they as allocations and/or applications) to be considered favourably. The NPPF makes particular reference (para 155 c) to identifying opportunities for development to draw its energy supply from decentralised, renewable, or low carbon energy supply, and for co-locating heat customers and suppliers.
3.9 Of particular concern is the lack of any focused evidence base document(s) addressing these matters. The list of Local Plan 2040 Supporting documents provided by the Council is absent any topic papers, studies or the like which address these matters.
3.10 It is essential that BBC undertake such work as a matter of urgency to inform the next stage of the Local Plan. AWG propose that the Local Plan will need to
include policies allocating sites for renewable energy, as well as allocating strategic developments which could come forward alongside renewable energy.
3.11 The Sustainability Appraisal (‘the SA’) should also be updated to reflect this requirement. The climate crisis is a significant, national issue and the SA methodology must be amended to provide greater weighting to matters relating to climate change and energy.

Object

Representation ID: 8617

Received: 13/09/2021

Respondent: Mr Henry Zwetsloot

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: 8656

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

3.38 This section addresses two main themes. It firstly sets out the shortcomings of the Vision in terms of reflecting comprehensive opportunities for sustainable development across the borough. Secondly, it addresses that while there are many positive aspects of outcomes sought under the vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options.
Reasoning
3.39 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.”
3.40 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 settlements from the spatial strategy and do not seek to provide for the additional development required to secure balanced communities.
3.41 The Vision further states:
“Rural communities will embrace appropriate development, in many instances through
the preparation of their own neighbourhood plans.”
3.42 This would imply a requirement for additional growth, which the preferred options exclude for a significant number of villages including Renhold/Salph End. The draft Vision fails to address that it is part of the role of the Local Plan review (and resulting updates) to address strategic priorities deferred as a consequence of the Local Plan 2030 (for example expansion of primary healthcare and secondary education). The Vision also fails to reflect that the proposed development strategy is not looking to provide for any additional growth in rural areas as part of an uplift to meet housing needs in full before 2030. This is a significant shortcoming of the strategy and overlooks suitable and deliverable sites that could be prioritised now to meet these increased needs alongside the delivery of other substantial benefits.
3.43 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.”
3.44 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 sufficient to secure the opportunities identified.

Object

Representation ID: 8684

Received: 13/09/2021

Respondent: Mr J Francis

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: 8716

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

3.37 This section addresses two main themes. It firstly sets out the shortcomings of the Vision in terms of reflecting comprehensive opportunities for sustainable development across the borough. Secondly, it addresses that while there are many positive aspects of outcomes sought under the vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options.

Reasoning
3.38 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.”

3.39 This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options without specifying a further contribution towards the increased need from development at Great Barford.

3.40 The Vision further states:

“Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”

3.41 This would imply a requirement for additional growth, which the preferred options exclude for a significant number of centres. The draft Vision fails to address that it is part of the role of the Local Plan review (and resulting updates) to address strategic priorities deferred as a consequence of the Local Plan 2030 (for example expansion of primary healthcare and green infrastructure).

3.42 The Vision also fails to reflect that the proposed development strategy is not looking to provide for any additional growth in rural areas as part of an uplift to meet housing needs in full before 2030.


3.43 The Vision makes limited reference to specific benefits that the Local Plan 2040 will secure in relation to the natural environment, including Country Parks north of Brickhill and west of Bedford.

3.44 The Vision is artificially constrained as a result of the Council’s current position on Preferred Options. There is no reason that other sustainable developments cannot achieve complementary and significant advantages for Green Infrastructure provision (e.g., specifically the provision for a Countryside Park within our client’s Willoughby Park proposals).

3.45 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.”

3.46 The principle of these objectives is supported but in the case of Great Barford is reliant on confirming support for the allocation of additional growth given that the emerging Neighbourhood Plan will not deliver these aims.

Object

Representation ID: 8746

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

2.1 The Draft Plan’s ‘Vision’ is set out at paragraph 2.1, which states that its purpose is to demonstrate the focus and direction of the Local Plan.

2.2 The second paragraph of the Vision states that by the end of the plan period “well- planned growth supported by appropriate infrastructure… will enable the creation of strong, safe and resilient communities in environments that facilitate healthy and independent living for all.” However, there is no specific reference to healthcare infrastructure and we are of the view that this is an important element that should be included within the Vision.

2.3 The fourth paragraph of the Vision briefly makes reference to the transformation of “brownfield sites on the western side of the town and south of the river”, the latter of which we assume relates to the Policy 14 Area including some of the South Wing site and wider car parking land etc, in the Britannia Road area. Again, we are of the view that explicit reference to the Bedford Hospital sites should be made within the Vision, as these are key locations for development and improvement during the local plan period.

Object

Representation ID: 8776

Received: 29/09/2021

Respondent: Staploe Parish Council

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) and Eaton Bank (new site submitted 2nd Sept). 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), 931 (Top Homes) and Eaton Bank (new site). 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: 8811

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

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.

Support

Representation ID: 8856

Received: 29/09/2021

Respondent: Woodland Manor Hotel

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 we 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.