2.1

Object

Representation ID: 8871

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Section 2 (Draft Vision) – Object
3.27 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
3.28 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.”
3.29 This aspect of the Vision will not be achieved in the context of the Council’s Preferred Options
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
16
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.
3.30 The Vision further states:
“Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”
3.31 This would imply a requirement for additional growth, which the preferred options exclude for a significant number of settlements. Also, for Roxton, the previous lack of willingness of the community to prepare a neighbourhood plan is also relevant to achieving the Vision.
3.32 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.

Object

Representation ID: 8892

Received: 30/09/2021

Respondent: Mr Peter Mills

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, Little Staughton and other neighbours 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.

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. It is considered that there are valued local landscapes that would be eroded by such urbanised development.

Object

Representation ID: 8909

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Section 2 (Draft Vision) – Comment
2.8 The recognition of tourism and recreation as part of the Council’s Vision to 2040 is supported in principle as is recognition that enhancement to the Borough’s green infrastructure network and natural environment are key components of this offer. The delivery of new multi-functional green spaces and Country Parks is also appropriate in principle as a means of securing these benefits.
2.9 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.
2.10 This is reinforced by the ‘Themes’ underpinning the Plan (notably Theme 1 ‘Greener’ and Theme 4 ‘Better Places’). However, we consider that the approach to the preparation of strategy options and in-particular focusing potential benefits on large-scale strategic growth in the Milton Keynes-Bedford Waterway south of the town (and at existing commitments in Brickhill) means that the Vision is not effective and not positively prepared.
2.11 This principally results from the failure to identify a contribution from any village-related growth outside of the ‘east’ and ‘south’ corridor parishes as part of the Council’s Preferred Options. This fails to recognise that at locations in the north of the Borough the aims of the Council’s Vision can be secured sustainably through appropriate village extensions, complemented by opportunities for rural recreation and tourism such as our client’s land at Radwell Lakes.

Object

Representation ID: 8940

Received: 01/10/2021

Respondent: Mr James Browning

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: 8947

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

3.32 Firstly, there is a shortcoming in the Vision in terms of it reflecting comprehensive opportunities for sustainable development across the Borough. Secondly, while there are positive aspects for outcomes sought under the Vision these will not be addressed as part of the strategy due to the Council’s selected Preferred Options.
Reasoning
3.33 The draft Vision sets out that:
“Rural communities will embrace appropriate development, in many instances through the preparation of their own neighbourhood plans.”
3.34 This would imply a requirement for additional growth. However, the draft strategy apparently exclude such growth from 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 BLP2030 (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 and overlooks suitable and deliverable sites that could be prioritised now to meet these increased needs alongside the delivery of other substantial benefits.
3.35 Theme 4 (Better Places) of the Council’s proposed Objectives states:
“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
3.36 The principle is supported but is reliant on delivering diverse opportunities for development across the settlement hierarchy. The draft strategy as it stands renders this highly unlikely.
Remedy
3.37 There should be demonstrable scope to alter the distribution of the housing requirement to sustain continued appropriate levels of growth in the rural hierarchy and recognise the sustainable capacity of the higher order rural settlements to continue to accommodate further development.

Object

Representation ID: 8998

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

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.
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 feels 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 (e.g., our
client’s proposals to provide a Riverside Park as part of the development opportunity at
Stoneyfields, Sharnbrook).

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.

Object

Representation ID: 9011

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

The 30-year Vision
4.1 The publication of the changes to the NPPF on the 20th July 2021 introduced the requirement for policies for larger scale development, including new settlements, to be set within a vision that looks at least 30 years ahead to take into account likely timescales for delivery. See the full paragraph extract below.
“22. Strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” (emphasis added)
4.2 As BBC is including larger scale developments in its emerging spatial strategy, such as new settlements, the changes to the NPPF 2021 now mean that BBC will need to set these policies within a vision that looks at least 30 years ahead; this means a further ten years at least from the end of the Plan period.
4.3 Whilst the Rt Hon Robert Jenrick MP made clear in his letter to the Chief Executive of the Planning Inspectorate on the 2nd August 202115 that guidance on this issue would be available shortly, there is currently no specific indication from MHCLG on how this paragraph can be addressed. The NPPF infers that any vision for BBC would need to cover the strategic site in question and its immediate geography, be that an existing town it will be extending or if it is a new settlement it’s wider hinterland, including how it will interact with it. However, it is impossible for BBC to divorce this visioning exercise from the wider strategic matters at play in the OxCam Arc concerning sustainable growth (housing and jobs) and specifically the ambition to plan for growth in a more sustainable and strategic way as set out in the live MHCLG consultation ‘Creating a vision for the Oxford-Cambridge Arc’. However, alongside this, there will be a requirement to deliver the levels of housing that are necessary to facilitate this growth, and ensure that growth of business can be accommodated in a sustainable fashion, with shorter commuting times, and co-location of businesses and housing.
4.4 On face value, it would appear that the additional evidence required to inform the 2040 Local Plan and to address paragraph 22 of the NPPF would be a vision for BBC’s location in the OxCam Arc and its ability to accommodate strategic growth to 2050 and beyond. The long-term vision could be framed in a way that supports the case for the various strategic sites to emphasise why they are needed and the benefits they bring to their respective areas and borough as a whole, both in this plan period and beyond. The vision may address issues such as the below in a short topic paper:
1 The likelihood of ongoing growth needs associated with the location of Bedford in the OxCam Arc (particularly housing but also other forms of development) over the long-term including beyond the Plan period, to 2050 and beyond as per the emerging OxCam Spatial Framework;
2 The role of larger allocations in achieving key aspirations for the area it is within (e.g. delivering infrastructure to facilitate sustainable development including public and active
transport, supporting inward investment, addressing local and Arc wide housing pressures, etc); and
3 Place shaping and managing how the area will change over the long term (e.g. reducing the need for future piecemeal approaches).
4 Changes to sustainable transport over that longer-term period, meaning that the predict and provide, capacity-constrained approach currently framing the local Plan’s current spatial choices is unlikely to be compatible with longer term approach.

Object

Representation ID: 9037

Received: 04/10/2021

Respondent: Historic England

Fifth paragraph: We welcome the reference to the need to respect and protect the boroughs built and wider historic environment. For greater consistency with the NPPF, we suggest that instead of valued you use the word ‘enhanced’.

Replace valued with ‘enhanced’ in line with NPPF

Support

Representation ID: 9062

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

5.1. We consider the draft Vision and Objectives to contain a number of important elements for guiding the Local Plan. However, we do consider that the Vision and Objectives, whilst mentioning some local names and places, should be more locally distinctive to give a greater ‘sense of place’ of the borough and the clear vision for its future. It is important it does not read as an ‘anywhere’ place.
5.2. In terms of the important elements of the Vision and Objectives we note that the Vision rightly has considerable focus on the urban areas with a particular focus on Bedford (and Kempston) as sustainable locations to deliver growth, infrastructure and place-making. We also note that there is no mention of the new settlements or urban extensions in the Vision for the borough.