3.1

Object

Representation ID: 7258

Received: 01/09/2021

Respondent: Wyboston Lakes Ltd

Agent: Brown & Co Barfords

The Borough Council’s June 2021 Development Strategy Topic Paper identifies the Local Plan
2040 will need to achieve a minimum of 1,275 dwelling completions a year to comply with
national planning guidance, which represents a ‘step change’ 33% increase on the current
adopted Local Plan annual target. Over the plan period this equates to at least 12,500
additional dwellings to be allocated in the new Local Plan. Taking account of the planned
population growth to 2040, a further 123 ha of new employment land will also need to be
allocated in the new Local Plan. In parallel with the preparation of the Local Plan review, the
Government is taking forward a spatial strategy for growth within the Oxford to Cambridge Arc.
Whilst the Topic Paper concludes that growth within the Bedford urban area would perform
best in sustainability terms, it also concludes this option would have unacceptable significant
impacts. The Strategy Options Consultation therefore focuses on 4 growth options with around
3,000 new dwellings and up to 51 ha of employment development within and adjoining the
Bedford urban area. To assist in meeting the additional growth requirement, 3 of the 4 options
identify a new settlement at Wyboston of 2,500 dwellings or/and a new settlement at Little
Barford of 3,085 dwellings along with up to 20 ha of employment, in proximity of the A421
transport corridor and a proposed new rail station at St. Neots/Tempsford.
The Development Strategy Topic Paper reviews the strengths and weakness of the different
growth options and in respect of the potential new settlements it identifies the following:
Key strengths:
 Opportunity to establish a new planned community at Wyboston and/or Little Barford in
proximity to the proposed EWR station at St Neots/Tempsford. Little Barford has a
stronger relationship and proximity to EWR (but there is a possibility that EWR may also
constrain development capacity – see weaknesses).
 Development in this location would create a second focus for major development which
could potentially impact positively on housing delivery rates.
Weaknesses and delivery challenges;
 In common with all new settlement proposals, a new settlement at Wyboston and/or
Little Barford would have a relatively long lead in time, with a very high risk of a housing
shortfall in the early to middle years of the plan.
 Four of the five EWR routes that are being consulted upon pass through the Little Barford
site and the deliverability of this proposal will require further assessment following the
decision on the route alignment.
 Both proposals will involve the loss of agricultural land, though development at Wyboston
would lead to the loss of higher grade agricultural land.
 The key challenge will be the delivery of two new settlements in close proximity to one
another and the ability of the housing market to deliver them simultaneously.
For the reasons justified by the Borough Council the new settlement growth options at
Wyboston and Little Barford are perceived to have benefits in contributing to meeting the
authority’s future housing and employment needs, which is reflected it their inclusion in 3 of
the 4 consultation options.

Object

Representation ID: 7292

Received: 01/09/2021

Respondent: Miss Laura Jones

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Support

Representation ID: 7413

Received: 03/09/2021

Respondent: Axiom Great Barford Limited

Agent: Axiom Great Barford Limited

This Issues and Options representation is made on behalf of Axiom Great Barford Limited (‘Axiom’) who have land interests in Great Barford. The Axiom site forms part of the Policy H1 housing allocation in the emerging Great Barford Neighbourhood Plan, which is currently at examination. The site is also put forward for consideration through the call for sites process in 2020.
Axiom are promoting land off Bedford Road, Great Barford on behalf of two landowners and their site can accommodate at least 350 new dwellings, community facilities, open space and landscaping.
The emerging Neighbourhood Plan Policy H1 allocation encompasses a wider area of land, to meet the 500 home requirement for Great Barford identified in the adopted Local Plan 2030. The reminder of the land within the emerging allocation is controlled by Countryside Properties, who will be making separate representations to this consultation.
Whilst Axiom continue to work closely with the Great Barford Barford Parish Council, Bedford Borough Council Assets and Countryside Properties to secure allocation of the site through the Neighbourhood Plan, Axiom continue to promote the merits of Great Barford in general as a location for growth, and the suitability of their land for development through the preparation of the Local Plan 2040.
It is worth noting that the Draft Strategy Options were prepared ahead of the publication of the revised NPPF, which introduced the requirement at Paragraph 22 for Local Plans which include new settlements or significant extensions to towns/villages, to be set within a vision which looks at least 30 years ahead. This policy clearly applies to the Bedford Borough Local Plan 2040 and it is considered likely that the Council will need to undertake additional work to establish a longer-term vision within which the policies for the Local Plan 2040 can be set.
Chapter 3 of the Strategy Options consultation document sets out that the standard method figure for Bedford Borough is 1,275 dwellings per year or 25,500 dwellings in total and that after existing commitments are taken into account, the Local Plan 2040 needs to allocate land to provide a further 12,500 new dwellings over the plan period.
It is unclear whether the existing commitments include allocations in the emerging Neighbourhood Plans which will satisfy the requirements of the adopted Local Plan 2030 Policy 4S. If these are included as commitments, it is important to note that the minimum level of growth that will need to be delivered via the Local Plan 2040 may need to increase should any of the emerging Neighbourhood Plans fail at examination or not pass referendum.
Should any Neighbourhood Plan not progress as expected it will be important that the Local Plan 2040 firstly allocates the growth directed to rural settlements such as Great Barford, before any consideration is given to the wider development strategy, which could include an additional level of growth at the Key Service Centres. It is also important to note that the 25,500-home requirement is the minimum number of homes that need to be delivered over the plan period. To ensure this figure is delivered, there will need to be an additional allowance made in the allocation of land to allow for slippage in the expected delivery of sites and any unforeseen delays.
Normal practice would suggest a 10% additional allowance should be made which would equate to a further 2,550 homes. Whilst reference is made to ‘choice and flexibility’ at paragraph 1.50, this is only in response to the potential additional growth that could come forward via Neighbourhood Plans. This is an unknown and it is therefore important that the level of growth planned for in the Local Plan 2040 is in excess of the required 25,500 to ensure the minimum number of homes are delivered.
We suggest this means planning for 28,050 homes (25,500 +10%) rather than the 25,500 currently being considered in each of the options. Subject to the strategy being adopted, this approach would also help ensure that the requirements of NPPF paragraph 68, which require a deliverable supply of land for years 1-5 of the plan, plus an appropriate buffer.
The Council will also need to consider the level of growth to be planned for in the Oxford to Cambridge Arc, where Bedford Borough sits in a key central area. If the economic benefits of the Arc are to be realised, it is likely that additional housing will be required to support a growing working age population. If the economy grows without the required housing, it may have knock-on impacts for existing residents in terms of increased house prices and worsening affordability.
Therefore, in addition to the need to plan for flexibility and contingency in setting the housing requirement, we would encourage giving full consideration to the impacts of longer-term economic growth to understand if there may be additional housing requirements.

Object

Representation ID: 7435

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

The DS rightly identifies the step change in housing delivery which is required in
Bedford Borough up to the horizon of the emerging plan period to 2040.
This step change results in an annual increase in housing delivery of 33% which
elevates the requirement for an annual delivery rate (within the adopted plan) of 970
additional dwellings per year to 1275 per annum for the emerging document.
It is however considered that this annualized requirement should be yet further
increased to allow for a contingency or buffer which will serve as a safety valve as
wider regional and national strategies are progressed.
A built-in contingency will allow for the LP to react to national and regional changes to
the planning system associated with Government’s agenda for planning reform and
the wider implications of the Oxford to Cambridge Arc, respectively.
The DS makes a case for the strategic target of 25,500 net additional dwellings over
the life of the plan. The document also states that current commitments are 13,000
with a balance of 12,500 dwellings to be planned for through the emerging LP – there
are concerns that the remaining requirement could be grossly under-estimated at the
point at which the LP will be adopted. As set out in the NPPG, the local housing need figure is calculated at the start of the plan-making process, but this number should be
kept under review and revised, when appropriate, until the document is submitted for
examination.
Importantly, and further to the thoughts above, the minimum local housing need figure
for the Borough may change as the LPA enter discussions with neighbouring LPAs
under the duty and as further information emerges in respect of planning reform and
the Oxford to Cambridge Arc. Whilst the evidence is not currently clear, it is
considered that ‘circumstances’ could potentially exist which would justify the adoption
of a significantly increased strategic housing target above and beyond that which is
contained within the consultation document.
Once again, it is accepted that the current position is such that the LP must
concentrate on meeting those evidenced growth requirements for the Borough and
that the plan is based on the most up to date available evidence. However, allied to
the above it is urged that the next iteration of the LP include a ‘safety valve’ which will
serve to meet any issues which arising from the aforementioned processes. The only
alternative to continued revisions to the strategic target will be yet another immediate
post-adoption review.

Support

Representation ID: 7452

Received: 03/09/2021

Respondent: Phillip C Bath Ltd

Agent: DLP Planning Limited

Paragraph 61 of the NPPF2021 confirms that minimum annual local housing need calculated in accordance with the government’s standard method provides the starting point for assessment of the number of homes to be provided through plan-making. Positive plan-making should address those circumstances where it may be appropriate to make provision for a higher number of new homes than indicated by the result of the standard method (with a non-exhaustive list of potential reasons summarised in the Planning Practice Guidance at ID: 2a-010-20201216.
It is apparent from paragraphs 1.11 and 3.1 to 3.3 of the Council’s consultation proposals that the Council has not considered potential reasons to plan for a higher housing number as part of the current process. Instead, it has only tested an arbitrary 10% uplift to the calculation of LHN within the draft Sustainability Appraisal process. This approach is contrary to material considerations (including the Council’s own evidence base) that require more detailed assessment before selecting options for the submission draft Plan and setting the housing requirement in the Plan.

Object

Representation ID: 7472

Received: 21/09/2021

Respondent: North Hertfordshire District Council

Thank-you for the opportunity to comment on the above consultation.
We are currently anticipating that the examination into our own Local Plan for the period 2011-2031 will conclude this Autumn. Once complete (and without prejudice to any Inspector’s report or decision on adoption), this would – along with the Plans for neighbouring Luton and Central Bedfordshire – complete the statutory planning framework for addressing the housing needs of Luton over this period.
It is our understanding that Luton intend to commence a review of their own Local Plan once the issue of its housing needs over the period 2011-2031 have been fully resolved. Key decisions around that Plan are yet to be made, in terms of plan period, housing requirements, potential development capacity within Luton etc. Proposed Government reforms to the planning system are also anticipated. These may include successor arrangements to the current statutory Duty to Co-operate. However, I would presently anticipate that unmet development needs from Luton for the period beyond 2031 could well be an issue that requires further consideration in this next round of plans.
Under the agreements reached for the current round of plan-making it was acknowledged that, in the first instance, authorities within the functional Luton Housing Market Area (Luton, Central Bedfordshire, North Hertfordshire and Aylesbury Vale) would work together to meet any unmet needs to the best of their abilities. In the event unmet needs arising from Luton could not be met within the defined Luton Housing Market Area, it would be necessary to initiate a wider search within adjoining housing market areas with good links to the town.
It has been acknowledged by the authorities in the housing market area that North Hertfordshire has made the maximum reasonable contribution to unmet housing needs from Luton in its current Plan. Central Bedfordshire have faced significant challenges in accommodating unmet needs from Luton alongside their own needs that arise within areas of the authority that fall within the Luton Housing Market Area. However, between the two authorities, it is proposed that the identified unmet needs of Luton for the period to 2031 will be met.
As your current consultation identifies (paragraph 6.2):
Bedford benefits from good strategic connections to London and nearby economic centres, such as Milton Keynes and Luton, and planned improvements to connect to Cambridge.
We would therefore request that any detailed policies or draft plan for Bedford acknowledge that it may be necessary to give the issue of Luton’s future housing needs further consideration and are framed sufficiently flexibly to accommodate such an outcome (e.g. through a focussed or partial review of relevant policies should this prove necessary).

Object

Representation ID: 7501

Received: 21/09/2021

Respondent: Mr Doug & Liz Stapleton

Whilst the need for new homes in the country, and in particular affordable homes and homes for social rent, is recognised, the enormous target of 1,275 per year or 25,500 new homes over the 20 year Plan period, will destroy huge areas of countryside, causing immense environmental degradation at a time when, with the increasing effects of climate change, every hectare of agricultural land will be needed to grow food. With this need to preserve as much of the existing agricultural land as possible and at a time when the Government is seeking to take action to enhance and extend existing, and restore lost, wildlife habitats, it seems crazy to even think about building on large areas of green field sites.

Around 70% of the 25,500 new homes are to be built to encourage a huge population migration into the Borough from elsewhere in the UK as part of the Government’s Oxford Cambridge Arc proposals and this is totally unsustainable. We understand that, as is now agreed by all except Government, the Standard Method algorithm is based on inaccurate and outdated 2014 ONS Housing Formation data – if up to date 2018 data is used the Target would be reduced to around 900 new homes per year or less. We also understand that the Mayor of Bedford has said that he is not happy with the Standard Method but he appears to have done absolutely nothing to challenge the Government on this matter. Possibly this is because he has already signed up to the Government’s Oxford Cambridge Arc proposals, including this massive housing target, without telling the electorate of Bedford Borough. There is a need for the Mayor and the Borough Council to explain exactly where they stand on this issue and If they are opposed to the Government’s Standard Method housing target, to indicate what they intend to do about it as it is essential to preserve our countryside and biodiversity for existing and future generations.
During a recent debate on the Spatial Framework for the Oxford Cambridge Arc in the House of Commons, the MP for North Bedfordshire, Richard Fuller, questioned why the government was continuing to pursue a policy of trying to connect our great university cities when there is no evidence of such a strategy successfully driving economic growth anywhere in the world. He quite rightly argued that our focus should be on driving infrastructure, innovation and growth in and around the centres of educational excellence in Oxford, Cambridge and Cranfield, not between them. He pointed out that this was not a plan for helping our region to develop and unify us into an identity that can have meaning on the ground for local residents but a top-down plan to be imposed on people in the region whether they like it or not. It would take away the ability of the Arc’s 23 Local Authorities to plan separately because then they would be unable to take an Arc-wide view. However an Arc-wide view was not something which his constituents wanted. They wanted to take a local view, a neighbourhood view.
He therefore argued that we should remove the top-down, state-imposed approach that characterises the Spatial Framework, and replace it with more control vested to local parishes and towns, where decisions can be made locally in the interests of, and with the positive engagement of local communities.
We hope that the Government will give serious reconsideration to this whole concept and decide to abandon the whole idea including the proposal to build the east west railway which if still proceeded with, will in all probability, given the changes in passenger rail use brought about by the pandemic, become predominately a freight line, which would prove the stupidity of routing the line through Bedford Midland Road Station
We understand that a comparison of Bedford Borough Council’s (BBC) Housing Target, which has been calculated by using the Government’s much discredited Standard Method algorithm, to the Housing Targets of other surrounding Local Authorities (LAs) reveals that the Borough Council’s Housing Target of 1,275 new homes per year for the next 20 year duration of its new Local Plan 2040, has been revealed as:
• One of the highest of any LA in the South East of England outside of the Greater London Metropolitan area.
• It is higher than that of the city of Cambridge or any LA in Cambridgeshire.
• Higher than the Housing Target of the city of Oxford or any LA in the county of Oxfordshire – in fact, it is almost double the Target of each LA in Oxfordshire • BBC’s housing target is over 30% higher than that of Huntingdonshire District Council, part of Cambridgeshire, and around 18% higher than that of South Cambridgeshire Council. Both of these Cambridgeshire LA’s have similar populations to that of Bedford Borough.
• The counties of Oxfordshire and Cambridgeshire are more than twice the size of Bedfordshire which is one of the smallest counties in England.
• BBC’s Housing target is 31% higher than that of North Hertfordshire, 180% higher than East Northamptonshire, 142% higher than Kettering and 266% higher than Wellingborough. The actual numbers for each local authority and the extent by which they are exceeded by Bedford Borough’s are as follows:-

Bedford Borough Council’s target is 1,275
Cambridgeshire LAs
Cambridge City 658 93% higher
East Cambridge 597 114% higher
Fenland 538 137% higher
Huntingdonshire 976 30.6% higher
East Cambridgeshire 1,085 17.5% higher
Oxfordshire Las
Oxford City 603 111% higher
Cherwell 756 69% higher
South Oxfordshire 608 110% higher
Vale of White Horse 661 92% higher
South Oxfordshire 563 126% higher
North Hertfordshire 973 31% higher
Northamptonshire LAs
East Northamptonshire 457 180% higher
Kettering 526 142% higher
Wellingborough 348 266% higher

We understand that your Council is already achieving growth rates in housing well above the national average and that in the North Bedfordshire Parliamentary Constituency that growth is 3 times the national average.

In the light of the above figures, rather than continue with the existing plans for the very high annual housing growth rate when compared with many other local authorities in the Oxford Cambridge Arc, we consider that your Council should be urgently making representations in this matter to the Government with a view to the annual growth rates being reduced to a more realistic level comparable to those other Councils and in this respect would suggest that that annual level should be a maximum of 600.

For the reasons set out above we are unable to support any of the four options in the plan at the proposed levels but would support Option 2a if the annual level of housing growth in the plan is reduced to a more realistic level.

Object

Representation ID: 7506

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

There is a query about the ONS algorithm to calculate the growth figures, so basing the housing number requirements on this needs to be challenged before the Borough set about fulfilling such housing demands.

Support

Representation ID: 7547

Received: 21/09/2021

Respondent: Luton Borough Council

Luton Council notes that the consultation document identifies that Bedford Borough Council must follow the standard method for calculating future housing requirements and that as a result of the government’s recent revisions to the standard method the figure for Bedford borough is 1,275 dwellings per year, giving a total of 25,500 dwellings from 2020 – 2040. Furthermore, it is acknowledged in the consultation document that this figure may change during the preparation of the Local Plan. As highlighted in our response to the Issues and Options consultation in September 2020, if the Bedford Local Plan does not meet its own housing need, Luton given its own constraints, will not be able to help to meet Bedford’s housing needs. The revised Local Plan will need to ensure that it is able to meet Bedford’s minimum annual housing requirement for the Plan period in accordance with Government guidance.
Luton Council intend to formally commence a review of the Luton Local Plan in due course once the issue of meeting our unmet housing need over the period 2011-2031 has been fully resolved. The adopted Central Bedfordshire Local Plan contains a commitment to deliver 7350 homes of Luton’s unmet need by 2031 and we await the Inspectors report into the North Hertfordshire Local Plan examination. For Luton Council and the Luton Local Plan review, key decisions such as the plan period, housing requirement, potential development capacity with in Luton etcetera have not currently been made. Unmet housing need from Luton for the period beyond 2031 could be an issue for the duty to co-operate (or its successor) which requires further consideration in this new round of local plans.

Object

Representation ID: 7563

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

We note that the proposed total housing requirement for the period 2020 to 2040 of 25,500 dwellings, is derived from the annual requirement of 1,275 dwellings set by the Government’s standard method. Looking ahead to the way in which the options are presented, we consider that the total housing requirement for the Plan period should be expressed as a single figure, qualified by such phrases as “at least” or “a minimum of” to reflect national guidance and indeed paragraph 3.2 of the current Plan document. This is because of rather than despite the uncertainties briefly referred to at paragraph 3.3.

Object

Representation ID: 7611

Received: 01/09/2021

Respondent: Miss Nicola Tagg

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 7658

Received: 01/09/2021

Respondent: Mr Simon Goodship

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 7756

Received: 22/09/2021

Respondent: Mr Michael Thompson

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 7815

Received: 03/09/2021

Respondent: Mr Emilio Meola

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 7854

Received: 03/09/2021

Respondent: Mr Mark Ibbett

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which I believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. I believe the Borough Council should continue to campaign against such large increases.

Support

Representation ID: 7896

Received: 24/09/2021

Respondent: Home Builders Federation

2. We agree with the Council that the minimum number of homes that the Council should be planning for per annum is 1,275. As the Council note this has reduced slightly on the basis of the latest available data and as such officers will be aware that a further assessment of the Borough’s local housing needs will be required prior to submission in the summer of next year. In addition, the Council will need to consider, as set out in paragraph 2a-010 of PPG, whether there is sufficient housing being provided in this plan to support the future economic growth of Bedford given the likely impact of the Arc Spatial Framework during the plan period. The Council state that due to the timescales for the preparation of the local plan 2040 the Council will not be able to take account of the Oxford Cambridge Arc Spatial Framework. Whilst the timescales do not align it will be important for the Council to recognise the Government’s drive to support the Arc in delivering substantial economic growth. Bedford is a key part of the Arc, with the Government already investing in major new rail link that will provide improved connections between Bedford, Oxford, Cambridge, and Milton Keynes. The Council will need to consider the likely impacts of economic growth arising from such improvements on population growth and housing needs in Bedford.

Object

Representation ID: 7912

Received: 24/09/2021

Respondent: Sharnbrook Parish Council

Thank you for inviting us to respond to the above Consultation; Sharnbrook Parish Council (SPC), as you will be aware, is at the final stage of the Neighbourhood Plan process and has found a site to accommodate 500 houses. We express the following views and/or observations.

• It is very clear that the data sets used to calculate the housing need for development are out of date. We acknowledge that Governemtn set the date of 2014, however we challenge this vehemently as there are data sets of 2018 that should be used. It is understood the current method formulae would not then result in the high expectations as described by the Bedford Borough LPA.
• It is reported that Bedford Borough are significantly disadvantaged over several neighbouring planning authorities in the Eastern Region – we ask that a clear statement is made in respect of this, in the evolving Local Plan.

Support

Representation ID: 7930

Received: 20/09/2021

Respondent: Pavenham Parish council

As indicated above, the Parish Council recognises the challenges facing the Borough Council in terms of the required 33% increase in housing provision above the allocated provision in the Local Plan 2030, the Oxford-Cambridge Arc and even the promised improvements to the Black Cat junction on the A1. The Parish Council is concerned, however, that – although probably unavoidable – the Borough Council is having effectively to speculate and plan for what only might happen.
The Parish Council has noted the substantially increased housing provision target leading to the need to allocate 12,500 new dwellings – in simplistic terms 1,275 new dwellings a year – as opposed to the figure of 970 dwellings a year as contemplated by the Local Plan 2030.

Whilst the Parish Council notes the possible option of a “stepped trajectory approach” and indeed recognises the underlying logic, the Parish Council would caution whether such an approach brings with it serious attendant risks. To achieve a target provision of 970 dwellings a year up to 2030 and then increasing the target somewhat radically to 1,580 dwellings a year for the last 10 years of the Plan period would make the Borough Council entirely dependent on the successful implementation of both the East West Rail section through Bedford Borough (including new and remodelled stations) and the completion of the Black Cat junction improvements. The Parish Council does not currently see the successful completion of either project within the Borough Council’s contemplated timescale as a certainty. It is acknowledged that practicality and what can actually be achieved on the ground enters the equation, but the Parish Council believes that a stepped trajectory approach should not be adopted as a core principle.

The Parish Council notes that Policy 58S (Affordable Housing) and 59S (Housing mix) will be updated once the draft Plan’s viability exercise has been completed and the Parish Council, in light of its own proposed residential allocation, will be happy to assist in terms of comment.

As far as identifying the locations for future growth is concerned, the Parish Council notes that the Borough Council has identified seven options, ranging from growth in the urban area, growth in villages and/or new town settlements in the A6 or A421 corridor.

The Parish Council also, however, notes from the wording of this Consultation Document that whilst the Borough Council has identified a number of preferred options, all or a mix of the identified options remain open for consideration. In this context, the Parish Council has carefully reviewed the Borough Council’s Issues and Options paper (June 2021) and fully supports the conclusions that have been drawn from that earlier consultation.

Object

Representation ID: 7960

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

There is a query about the ONS algorithm to calculate the growth figures, so basing the housing number requirements on this needs to be challenged before the Borough set about fulfilling such housing demands.

Object

Representation ID: 8016

Received: 24/09/2021

Respondent: Mr Larry Gooch

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 8122

Received: 03/09/2021

Respondent: Dr Emma Thompson

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 8161

Received: 03/09/2021

Respondent: Mr Ross Thomson

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 8200

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Support

Representation ID: 8226

Received: 26/09/2021

Respondent: Sharnbrook Parish Council

Thank you for inviting us to respond to the above Consultation; Sharnbrook Parish Council (SPC), as you will be aware, is at the final stage of the Neighbourhood Plan process and has found a site to accommodate 500 houses. We express the following views and/or observations.

• It is very clear that the data sets used to calculate the housing need for development are out of date. We acknowledge that Governemtn set the date of 2014, however we challenge this vehemently as there are data sets of 2018 that should be used. It is understood the current method formulae would not then result in the high expectations as described by the Bedford Borough LPA.
• It is reported that Bedford Borough are significantly disadvantaged over several neighbouring planning authorities in the Eastern Region – we ask that a clear statement is made in respect of this, in the evolving Local Plan.

Object

Representation ID: 8259

Received: 03/09/2021

Respondent: Mr Daniel Francis

Staploe Parish Council believe it would be appropriate to prepare twin track local plans based on housing requirement figures calculated from 2014 and 2018 figures and argue for the use of the more up to date 2018 figures which give a lower number of homes required. The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural.

Object

Representation ID: 8303

Received: 03/09/2021

Respondent: Miss Erin Francis

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 8345

Received: 03/09/2021

Respondent: Mrs K Francis

Staploe Parish Council believe it would be appropriate to prepare twin track local plans based on housing requirement figures calculated from 2014 and 2018 figures and argue for the use of the more up to date 2018 figures which give a lower number of homes required. The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural.

Object

Representation ID: 8378

Received: 02/09/2021

Respondent: Bedford Borough Councillor

We reject the Government’s assessment of “housing need”. In a country with more bedrooms per head of population than ever before, the issue is one of distribution of housing, not overall supply. Large scale inward movement of population into Bedford Borough from other parts of the country will increase demand for housing, work against needed improvements in affordability here and increase inequality within the country.
The picture is further complicated by the Government’s spatial framework for the OxCam Arc expected in January 2023. There is a severe danger that that special framework will undermine this proposed Local Plan. In addition, the Council is a member of the Central Area Growth Board. If the Central Area Growth Board is trying to “provide the strategic leadership that will enable planning for economic transformation across the central area of the Oxford to Cambridge Arc.”, it would be expected that this Draft Plan would relate its proposals to the ideas of the unmentioned Central Area Growth Board. Again, the possibility that the plan will be undermined by such a Board is very worrying.
However, we recognise that, unless it successfully challenges them, the council is compelled to work within central Government targets, and thus all that can be done locally is to make the best of the resultant requirement to provide opportunities for housebuilders to make unwarranted profits.
As part of this, we support Neighbourhood Plans. Unreasonable central Government pressure should not result in large numbers of houses being added to village-after-village in the face of local opposition.
We explicitly reject talk of the “A421 transport corridor”. Such road-based development is fundamentally inconsistent with Theme 4 of the policy and the objectives it outlines, or what would truly be required by Theme 1, let alone the apparent high priority given to “Tackling climate change and adapting to and mitigating its effects”. The resource used by private road transport (whatever energy source is used) is greater than that which is consistent with “a borough where everybody has appropriate access”, let alone tackling climate breakdown and its impacts.

On this basis, our assessment is that Option 2c appears to be the least-worst of the options, with more scope for rail-based transport, however, of the elements of this option, development at Wyboston looks the least likely to be associated with good public transport, particularly if the A428 is redirected to be south and east of Little Barford.
There may, further, be concerns about flood risk in low-lying land, especially as climate breakdown brings about extra severe weather events.
Paragraph 3.23 outlines “principles [that] provide a framework for Bedford’s existing transport policies”, yet they fail to mention public transport. While principles 1, 2 and 4 all actually imply public transport, the failure to mention public transport is a glaring omission.
Principle 1 risks being self-defeating. Working towards reduced congestion is likely to work against delivery of low carbon transport. Congestion provides vehicle owners an incentive to use other methods of transport, or to keep journey lengths down. To deliver low carbon transport requires provision for public transport, and low energy consumption forms of transport, such as cycling, walking and rail.
Principle 2, “Promote connectivity and accessibility” can only truly be met by providing connectivity that is accessible to all, including those with financial constraints and impairments that preclude them using private cars.
Thus, to truly meet “Principle 4 – Promote and support infrastructure development”, the infrastructure that needs to be developed is public transport, walking and cycling infrastructure, in communities that are designed whereby the norm is walkable neighbourhoods.
The claim under 3.24 that “The current polices … do not need to change” does not withstand scrutiny. They are not compatible with the vision of “Tackling climate change… at the heart of new development throughout the borough”, they are not compatible with Theme 4: Better Places, and its objectives, and they are not compatible with Theme 1 if there is an honest desire to make the borough “Greener”.

Support

Representation ID: 8388

Received: 27/09/2021

Respondent: 1 Grosvenor Holdings Ltd

Agent: WSP

HOUSING NEED
The draft Local Plan asks the question:
“How many homes will be needed to be provided across the plan period?”
As outlined in Paragraph 61 of the NPPF, the standard method should be used to calculate future housing requirement and Councils must follow this. Bedford Borough Council (BBC) state a result of the government’s recent revisions to the standard method, the housing requirement for BBC is 1,275 dwellings per year, resulting in a total of 25,500 dwellings for the 20-year period from 2020 to 2040. The Draft Plan indicates that is the current starting point for the Local Plan housing requirement.
When considering existing commitments (planning permissions, allocations from current local plans and an allowance for windfall, which together total 13,000 dwellings), based on the standard method requirement figure of 1,275 dpa, the Draft Plan will need to allocate land to provide a minimum of 12,500 new dwellings.
Further detail is set out in the evidence base document Local Housing Needs Assessment (LHNA), this provides evidence the standard method number for the borough has been altered by recent affordability figures and the LHNA was produced in relation to the previous requirement of 1,305 dpa (a total 26,100 dwellings between 2020 and 2040) and this should therefore be considered as the figure for BBC’s housing requirement per the stand method as defined in the NPPF.
The annual requirement in the adopted Local Plan 2030 is 970 dwellings per year. The 1,305 required dwellings for this new plan represent a substantial increase to the adopted plan and will therefore result in the requirement to allocate additional sites (such as the land off Great Barford High Street) for housing development.

Object

Representation ID: 8397

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

This section provides our formal consultation response in relation to the Issues and
Options and Growth Options Consultation. It sets out our response in relation to chapters
of the consultation that are of relevance in respect of the land that is being promoted at
Gibraltar Corner.
Level of Growth

Based on the ‘standard method’ the new Local Plan will need to identify sites to deliver
over 25,500 new homes to meet the Council’s housing needs for the period 2020 – 2040,
which equates to a delivery 1,275 dwellings per year . To maintain their housing trajectory,
the Council will need to identify a range of sites, so that this housing delivery rate can be
achieved. Currently, existing commitments total 13,000 dwellings which means the new
local plan will need to allocate land for a minimum (emphasis added) of 12,500 dwellings.

Effective housing delivery is essential for the social, economic and environmental
prosperity of the District and the wider spatial area of the Oxford – Cambridge Arc.
Accordingly, it is critical that the assessment of sites submitted through this Call for Sites
process is undertaken in a positive and aspirational manner (NPPF para 16) , and in
accordance with NPPF paragraph 69, allows the identification of a sufficient level of
deliverable and developable sites with sufficient flexibility to react to market trends and
economic changes.

The use of the standard method is supported, however, it is considered that the minimum
number of dwellings for the period to 2040 should be increased to 15,000 to allow the
inclusion of a 20% buffer to build in greater flexibility and more certainty that housing
delivery will actually be achieved. While currently housing delivery is meeting the adopted
local plan target, this only requires an annual requirement of 970 dwellings per year .
There will be a considerable uplift of 280 dwellings per year to meet the 1,275 dwellings
required for the new plan.

Based on planned population growth to 2040 the employment land requirement is
calculated to be 171 ha. The current supply in the Borough is 48 ha leaving the
requirement for a minimum (emphasis added) 123 ha to be allocated in the plan. As with
housing, it is considered equally important that a buffer of 20% should be applied to ensure
the provision of employment land keeps pace with demand, especially given the economic
importance of the Borough within the heart of the Oxford – Cambridge Arc. Accordingly,
it is therefore considered that the Plan should be seeking to allocate 148 ha of employment
land for the period to 2040.

Plan Period
While this consultation does not specifically seek views on the proposed plan period, it is
considered that a longer plan period would be more appropriate. National planning policy
requires a minimum 15 year plan period from adoption (emphasis added) and whilst the
current programme anticipates adoption in Winter 2023 it is a clearly established fact that
local plan preparation nearly always takes longer than anticipated at the outset.
Assuming the local plan is actually adopted at the beginning of 2024 this will only
establish a plan period of 16 years. Paragraph 22 of the NPPF requires a minimum 15
year period, however, the paragraph was also updated in the July 2021 version to suggest
that plans should have a vision of at least 30 years where new settlements or significant
extensions to existing villages and towns form part of the strategy for the area. Clearly,
as set out in the current four options, such developments are likely to form part of the
strategy and, as such, a longer plan period would seem more appropriate. Furthermore,
the nationally emerging Oxford – Cambridge Spatial Framework also seeks to guide
growth to 2050. Accordingly given the current early stage of plan preparation it is
considered that the Bedford Borough New Local Plan should adopt a plan period to 2050
as well.

Extending the plan period by a further 10 years will require further growth locations to be
identified including sites for a minimum additional 12,750 dwellings and a further 62
hectares of employment land. As referred to above, these would be minimum
requirements and a buffer should also be imposed, although given the extended length of
plan period a reduced buffer of 10% may be considered more reasonable. Adopting such
a strategy will allow the plan to consider a wider range of options and contain more
flexibility around delivery in the future. This will sensibly allow for the inclusion of new
settlements which, whilst slow to deliver, are likely to represent the most sustainable longterm
option for economic growth supported by a sufficient delivery of new homes. Such
flexibility will be essential to allow the District to maintain housing land supply at an
increased rate of 1,275 new homes per year over the plan period.