3.10

Showing comments and forms 1 to 30 of 65

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3439

Received: 09/07/2021

Respondent: Mr Daniel Workman

Representation Summary:

I would like to register my objection to Options 2a and 2b which involve substantial development in the currently mainly rural southern parishes. Notwithstanding the demands of national policy for increased growth in housing I believe there are lower impact areas available for development as outlined in Options 2c and Option 2d.

Full text:

I would like to register my objection to Options 2a and 2b which involve substantial development in the currently mainly rural southern parishes. Notwithstanding the demands of national policy for increased growth in housing I believe there are lower impact areas available for development as outlined in Options 2c and Option 2d.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3445

Received: 11/07/2021

Respondent: Mr Gordon Message

Representation Summary:

The plans all indicate a station at Wixams. This does not exist. It should have been built more than a decade ago and there is no guarantee current planning will be complete in time to use set aside developer money before their revised deadline. Its completion is therefore in doubt.
This issue highlights the difficulty of enforcing planning aspirations. Any plan must be based on actual or realistic infrastructure considerations.

Full text:

The plans all indicate a station at Wixams. This does not exist. It should have been built more than a decade ago and there is no guarantee current planning will be complete in time to use set aside developer money before their revised deadline. Its completion is therefore in doubt.
This issue highlights the difficulty of enforcing planning aspirations. Any plan must be based on actual or realistic infrastructure considerations.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3458

Received: 15/07/2021

Respondent: Wootton Parish Council

Representation Summary:

Wootton Parish Council would like to place on record its support for Option 2c within paragraph 3.10 (Growth Strategy Options).

For the avoidance of doubt, Option 2c is entitled ‘Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements'. It can currently be located on page 22 of Bedford Borough Council's Local Plan 2040 Draft Plan - Strategy Options and Draft Policies Consultation.

Wootton Parish Council does not support any further development within the parish of Wootton, which has and is still facing ongoing significant development.

Full text:

Wootton Parish Council would like to place on record its support for Option 2c within paragraph 3.10 (Growth Strategy Options).

For the avoidance of doubt, Option 2c is entitled ‘Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements'. It can currently be located on page 22 of Bedford Borough Council's Local Plan 2040 Draft Plan - Strategy Options and Draft Policies Consultation.

Wootton Parish Council does not support any further development within the parish of Wootton, which has and is still facing ongoing significant development.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3551

Received: 11/08/2021

Respondent: Ms Claudia Dietz

Representation Summary:

The focus should be on brownfield sites first, such as Urban-based Growth, together with the potential to create one new, highly sustainable new settlement at Wyboston.

Full text:

The focus should be on brownfield sites first, such as Urban-based Growth, together with the potential to create one new, highly sustainable new settlement at Wyboston.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3631

Received: 16/08/2021

Respondent: Great Barford Neighbourhood Plan Group

Representation Summary:

Growth needs to be placed where optimum, not by NIMBYism

Full text:

Growth needs to be placed where optimum, not by NIMBYism

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3675

Received: 19/08/2021

Respondent: GB PC

Representation Summary:

Growth placement should be a best sustainable compromise, not by NIMBY rejection. There needs to be a long term stable strategy, not a flip-flop change of tack every few years

Full text:

Growth placement should be a best sustainable compromise, not by NIMBY rejection. There needs to be a long term stable strategy, not a flip-flop change of tack every few years

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3861

Received: 27/08/2021

Respondent: Oakley Neighbourhood Planning Group

Representation Summary:

Council supports the removal of new settlements in the north because the A6 would not be able to cope with the additional traffic but is unable to comment on the options 2a – 2d as they are based on housing calculations with which Council disagrees.

Full text:

Council supports the removal of new settlements in the north because the A6 would not be able to cope with the additional traffic but is unable to comment on the options 2a – 2d as they are based on housing calculations with which Council disagrees.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3873

Received: 27/08/2021

Respondent: Mr Richard Bates

Agent: Bletsoes

Representation Summary:

We support the approach to Growth Strategy Options and in particular we support a New Settlement at Wyboston.

In addition we also support growth along the A421 corridor and highlight that Roxton provides a suitable location for appropriate levels of growth to support the existing service base in the settlement and to provide quality housing to meet local needs and the wider employment growth expected in the Oxford Cambridge Arc.

Full text:

We support the approach to Growth Strategy Options and in particular we support a New Settlement at Wyboston.

In addition we also support growth along the A421 corridor and highlight that Roxton provides a suitable location for appropriate levels of growth to support the existing service base in the settlement and to provide quality housing to meet local needs and the wider employment growth expected in the Oxford Cambridge Arc.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4406

Received: 31/08/2021

Respondent: Mrs Gerardine Meola

Representation Summary:

Brown - urban growth. Land west of Wyboston and the hamlet of Duloe are not urban they are open countryside.

St Neots is not in Bedford Borough and it does not/will not plan services for the residents of land west of Wyboston and Duloe.

There is a danger that large scale development in these areas will have a massive impact on St Neots and it will mean residents of theses areas will become second class citizens in terms of well planned services.

The urban area of Bedford is too far away to access services on a daily basis.

Full text:

Brown - urban growth. Land west of Wyboston and the hamlet of Duloe are not urban they are open countryside.

St Neots is not in Bedford Borough and it does not/will not plan services for the residents of land west of Wyboston and Duloe.

There is a danger that large scale development in these areas will have a massive impact on St Neots and it will mean residents of theses areas will become second class citizens in terms of well planned services.

The urban area of Bedford is too far away to access services on a daily basis.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4410

Received: 31/08/2021

Respondent: Wayside Farm Park Resident's Association

Representation Summary:

Any major housing developments should be along the A421 corridor and the proposed East West Rail should be built accordingly avoiding Bedford Town Centre. The new developments would then be serviced by a Parkway station to the south of the town.

Full text:

Any major housing developments should be along the A421 corridor and the proposed East West Rail should be built accordingly avoiding Bedford Town Centre. The new developments would then be serviced by a Parkway station to the south of the town.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4563

Received: 01/09/2021

Respondent: Miss Andrea Witham

Representation Summary:

Staploe Parish Council believe that the Issues and Options consultation was invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2). We call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.
A rail based growth strategy policy may be required if growth is to be located around rail

Full text:

Staploe Parish Council have made the following comments. I have read, understood and wholly agree with them:
Staploe Parish Council did not agree that this consultation was sound or fair. We responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or under utilised land. Our whole parish is classed as open countryside for planning purposes. Our three tiny hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land
is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.
We believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots (as we already do) which are already under pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here
to make sustainable travel choices – we have one bus on Thursday and it would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would not improve viability of retail and leisure in Bedford Borough. People would go to St. Neots.”
We still feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.
In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses...

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4607

Received: 01/09/2021

Respondent: Mr Denis Ivins

Representation Summary:

adopt a ‘brownfield first’ approach to the spatial strategy and a focus on transport corridors, subject to the need to avoid
development intrusion on high quality agricultural land, open countryside, and rural communities as far as possible.

Full text:

adopt a ‘brownfield first’ approach to the spatial strategy and a focus on transport corridors, subject to the need to avoid
development intrusion on high quality agricultural land, open countryside, and rural communities as far as possible.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4753

Received: 01/09/2021

Respondent: Mr David Rawlins

Representation Summary:

I believe that the Issues and Options consultation was invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2). We call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.

Full text:

Staploe Parish Council have made the following comments. I have read, understood and wholly agree with them:
Staploe Parish Council did not agree that this consultation was sound or fair. We responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or underutilised land. Our whole parish is classed as open countryside for planning purposes. Our three tiny hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land
is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.
We believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots which are already under pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here to make sustainable travel choices – we have one bus on Thursday and it would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would
not improve viability of retail and leisure in Bedford Borough. People would go to St. Neots.”
We still feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.
In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses...

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4755

Received: 01/09/2021

Respondent: Mrs Francessa Frew

Representation Summary:

There should be more focus on developing brownfield sites as opposed to building on high grade agricultural land such as the proposed development of 10,000 houses at Wyboston. As a nation we produce only about 50% of our food requirements. Fourteen years of food rationing ended in the UK in 1954, the recent pandemic has highlighted the necessity to be more able to meet domestic food requirements which will not be achieved by building on grade A agricultural land.

Full text:

There should be more focus on developing brownfield sites as opposed to building on high grade agricultural land such as the proposed development of 10,000 houses at Wyboston. As a nation we produce only about 50% of our food requirements. Fourteen years of food rationing ended in the UK in 1954, the recent pandemic has highlighted the necessity to be more able to meet domestic food requirements which will not be achieved by building on grade A agricultural land.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4871

Received: 02/09/2021

Respondent: Kirstin Rayner

Representation Summary:

Option 2b offers expansion of the urban area south of Bedford, to tie in with planned infrastructure improvements and good transportation links, being less constrained by complexities of existing development and the river/floodplain. The option also provides a mix of development between the existing urban areas of Bedford/Kempston and the planned new settlement which is likely to be south of St Neots.

The Little Barford proposed new settlement not only links with the planned Black Cat to Caxton Gibbet improvement plan, but also has potential to provide a location [an] East West Railway station, encompassing not only housing but employment opportunities. This is my preferred option.

Options which add further development pressure on Bedfordshire’s rural settlements, without significant infrastructure investment are not sustainable and will create higher carbon living, creating further congestion and environmental damage which cannot be mitigated.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4897

Received: 02/09/2021

Respondent: Mr Kevin Morrall

Representation Summary:

The Brown option included Staploe Parish which is rural

Full text:

The Brown option included Staploe Parish which is rural

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5394

Received: 03/09/2021

Respondent: Mrs Gwendalyn Selo Skingley

Representation Summary:

Too much growth focussed around A421 which at times is extremely busy and does not flow freely. Logistic based employment in areas which are not accessible by public transport are exacerbating the situation.
Rail growth strategy is poor - there is no Wixams station and trains to and from Kempston Hardwick and Stewartby are infrequent and most regularly replaced by busses. Minimal parking provision at these stations for those who may need to drive to the station as poor cycling / footpaths in the vicinity
Too much of dwelling based growth does not have the infrastructure to support it

Full text:

Too much growth focussed around A421 which at times is extremely busy and does not flow freely. Logistic based employment in areas which are not accessible by public transport are exacerbating the situation.
Rail growth strategy is poor - there is no Wixams station and trains to and from Kempston Hardwick and Stewartby are infrequent and most regularly replaced by busses. Minimal parking provision at these stations for those who may need to drive to the station as poor cycling / footpaths in the vicinity
Too much of dwelling based growth does not have the infrastructure to support it

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5421

Received: 03/09/2021

Respondent: Mr Peter Norris

Representation Summary:

By reflecting back to the 2030 consultation and using different colours for some of the options to those in the present consultation, ambiguity is being introduced. That study included a new E-W Rail station to the north of Bedford - coloured orange and the associated comment indicated support for such a station with associated development (3.11). Such a station is not feasible due to topographic constraints and has not been brought forward to the current consultation This should have been clarified as you do now include an orange station option in the St Neots/Tempsford area - hence potential confusion.

Full text:

By reflecting back to the 2030 consultation and using different colours for some of the options to those in the present consultation, ambiguity is being introduced. That study included a new E-W Rail station to the north of Bedford - coloured orange and the associated comment indicated support for such a station with associated development (3.11). Such a station is not feasible due to topographic constraints and has not been brought forward to the current consultation This should have been clarified as you do now include an orange station option in the St Neots/Tempsford area - hence potential confusion.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5520

Received: 06/09/2021

Respondent: Mrs Clare Szczepanski

Representation Summary:

3.0 Emerging Preferred Options – 2a, 2b, 2c and 2d

It is not clear whether the Parish of Staploe falls within eastern parishes and is therefore within preferred strategy 2d, or the northern parishes which are not part of any of the preferred strategy options. As it not specifically mentioned our client assumes it is not part of this strategy.

We would therefore highlight that some development is advisable in this location in order to prevent the existing villages stagnating and to maintain the vitality and viability of existing services. Local needs housing could be considered in villages such as Duloe which is situated adjacent to the A1 and is due north of Wyboston which has been identified as a potential location for growth.

While this is small village it has the potential to offer sustainable rural growth, either connected with the neighbouring town of St Neots or with the possible new settlement west of Wyboston.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6115

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

Representation Summary:

3.25 The Council’s own evidence demonstrates that the level of rail-based growth at Kempston Hardwick/Stewartby and Wixams relied upon as part of its Preferred Options is unsound. National Planning Practice Guidance ID: 68-020-20190722 states that a pragmatic approach should be taken when considering the intended phasing of sites, where the authority may need to provide a greater degree of certainty than those in years 11-15 or beyond. The PPG expands on this by stating that where longer-term sites are relied upon evidence must be available to demonstrate that they will come forward within the timescales envisaged and at a rate sufficient to meet needs over the plan period.
Reasoning
3.26 The Bedford Local Plan 2040 should be more realistic in the delivery timescales for strategic / complex sites. The delivery of large strategic sites is complex with long lead times; especially when dependent upon delivery of infrastructure such as rail or transport schemes. These issues with existing sites will be compounded in the Council’s trajectory for the Local Plan 2040 (meaning that even its proposed ‘stepped approach’ against a requirement of 970dpa to 2030 will not be effective). These representations further demonstrate the lack of evidence to consider rail-based growth in the A421 corridor as developable any earlier than years 11-15 of the plan period (if not beyond) thus rendering the Council’s Preferred Options entirely unsound.
3.27 The Council’s own Development Strategy Topic Paper identifies multiple risks to the rail-based component of growth in the A421 corridor, including:
• Delivery of new rail stations is proposed, but not yet confirmed.
• Lead in times for remediation of the Kempston Hardwick area and delivery of new rail stations mean that development in this part of the transport corridor will occur later in the plan period.
• Detailed analysis of context and density / storey heights to establish appropriate place making for the rail based growth at Kempston Hardwick and Stewartby has yet to be undertaken.
• The land at Kempston Hardwick is currently being promoted for employment development.
3.28 These points confirm that the Council’s extremely wide range of potential quanta for the development of rail-based growth are not currently informed by evidence of site-specific opportunities assessed as suitable, available or achievable. This means that there is no justification whatsoever for the levels of development summarized at paragraph 3.12 of the Council’s Topic Paper:
“Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams. On the assumption that new rail stations will be delivered at Wixams and Stewartby / Kempston Hardwick, ambitious growth is assumed at both Wixams and Stewartby / Kempston Hardwick in the range of 1,500-3,000 dwellings at Wixams and 2,500-5,000 dwellings at Stewartby / Kempston Hardwick by 2040. Within the options two levels of development are tested: a lower option total figure of 5,500 dwellings (2,000 at Wixams and 3,500 at Stewartby / Kempston Hardwick) and a higher option of 7,500 dwellings (3,000 at Wixams and 4,500 at Stewartby / Kempston Hardwick)”
3.29 There is no evidence to indicate these totals as developable in the period to 2040. In the absence of site-specific testing the Council can have no grounds to suggest how constraints might be overcome, when infrastructure will be provided and whether the extremely high levels of development required to meet these totals over a very short period between sometime after 2030 and 2040 can be achieved.
3.30 The extent of this uncertainty is summarized in footnote 1 on pp.8 of the Development Strategy Topic Paper:
“East West Rail are currently consulting on two options for the Marston Vale Line; one which retains the current stations at Stewartby and Kempston Hardwick, and another that replaces them with a new station (tentatively named “Stewartby Hardwick”) at Broadmead Road. This component of growth is based on development around the new or existing stations in conjunction with development around the new station at Wixams. These stations could provide a focal point for higher density growth supported by the sustainable travel options offered by new and enhanced rail services.”
3.31 The potential for residential development to occur in conjunction with the delivery of new stations as intended by the Council is likely to require a substantially longer lead-in timeframe.
3.32 However, the delay potentially associated with provision of strategic infrastructure could be mitigated through the delivery of modest growth at Key Service centre villages, particularly those are well related to growth corridors and have the ability to provide sustainable growth withing the period, even early in the plan period.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6373

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Representation Summary:

Paras 3.10 to 3.14 – COMMENT
The spatial strategy options put forward in the draft plan offer a helpfully wide range of choices for consultees to comment on.
The following principles should apply to consideration of the Council’s preferred development options:
• The plan should adopt a ‘brownfield first’ approach to the spatial strategy.

• The focus on transport corridors is supported, subject to the need to avoid development intrusion on high quality agricultural land, open countryside, and rural communities as far as possible.

• Developments should be delivered in a way that maximises environmental protection and enhancement opportunities

• Full weight should be given to the views of parish councils and local residents

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6506

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

Representation Summary:

Growth and spatial strategy options (Growth strategy options paragraph 3.10)
We are pleased to note that each of the four preferred spatial options identified at paragraph 3.10 of the plan are consistent in their identification of the Bedford/Kempston urban area and its periphery as a principal location for new allocations. What is questioned, however, is why such a low number of dwellings are to be directed towards the town and the urban fringe in particular (only 1,500 of a minimum 12,500 new dwellings by way of allocation).
Firstly, on the proposed allocation of 1,500 dwellings in the urban area (that is within the existing built-up area boundary of both Bedford and Kempston) it is entirely unclear where so many deliverable or developable sites will come from. On the basis that the current Local Plan, which was only adopted 18 months ago, comprises an urban-focused approach to growth it would have been expected that in the instance that significant deliverable sites within Bedford were available at the time of its adoption they would have been identified as allocations. In which case this leads to a suggestion that the additional sites sufficient to yield a minimum of 1,500 homes have either been identified by the Council since this time or are hopefully to be identified through the call for sites process. We consider the presence of such a stock of additional reliable brownfield urban sites to be extremely doubtful, especially bearing in mind both the historic and ongoing issues faced by some of the existing town centre allocations at Ford End Road and Land South of the River in respect of land assembly, availability, and viability.
Then, in all scenarios the allocation of only 3,000 dwellings at Bedford and Kempston then leaves a minimum of 9,500 dwellings to be delivered elsewhere in a Borough with few other large and sustainable settlements. Whilst it is appreciated that each of the four strategies seek to direct these towards specific growth points or corridors it represents a significant move away from the urban focused approach taken by the Local Plan 2030. Whilst we feel that a balance must be struck – the direction of quite so many homes to Bedford’s urban sites currently is one of the main weaknesses of the Local Plan 2030 strategy – it is our clear view that there are ample opportunities on the fringe of the town that would enable growth to be delivered at the most sustainable locations in the Borough. None of the edge of the town is characterised by any restrictive landscape designations and indeed much of the local landscape character is unremarkable. In which case the delivery of unconstrained greenfield sites adjacent to the town and easily accessible to the strategic road and rail networks must present a strategic priority to the Council.
By way of an example our client’s land at Salph End represents one such strategic opportunity at a site described by our previous Call for Sites submissions as one which is entirely suitable for a new urban edge community on land which is devoid of any technical or legal constraints. The merits of the site were neatly but emphatically summarised by an Inspector presiding over a recent appeal at the land1 in respect of a proposed development for 400 dwellings and a new school site (the level and mix of development once again proposed in respect of the Call for Sites) who confirmed:
“Nevertheless, the appeal site is not without its intrinsic merits in terms of the spatial strategy; it is adjacent to the defined Settlement Policy Area of Salph End; within walking distance of a local grocery store and post office, a public transport route and some other local facilities; and it would provide that settlement with education provision and open space facilities. Most of the site was included as an allocation in a consultation version of the Local Plan before its adoption. The eventual decision to exclude the site from the plan was judged by the Inspectors who examined the plan to be a reasonable one, although they note that the matter was clearly finely balanced. It is again included in options being considered in the current review of the Local Plan and so, it is not unreasonable for the appellant’s advocate to imply, as he does in his closing remarks, that it is a matter of when, not if, the site is to be developed.”
Sites such as that of our client must be a focus and a priority in meeting what is a significant additional housing need that must be met by way of further allocations as they were upon the publication of the Council’s ‘Consultation Paper’ in 2017 (the document referred to in the Inspector’s quote above). This was prior to the more intense focus of the Council on complicated urban sites and a subsequent shortening of the plan period from 2035 to 2030 and the resultant reduction of the plan’s housing target. As such we urge the Council to significantly increase the number of homes to be directed towards the edge of Bedford within each of the four growth scenarios described in Section 3 of the draft plan with the identification of our client’s land as one of its key strategic allocations the obvious starting point.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6627

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

Representation Summary:

Taylor Wimpey are generally supportive of the Council’s propose approach to allocation land for development, with the options focusing generally on Bedford, the transport corridors to the south of the town and the proposal for a new settlement(s).
The Development Strategy Topic Paper indicates that the A421 corridor, urban area and rail-based options set out at the Issues and Options stage were the most popular options for those who commented.
We also note that the SA process showed that the A421 corridor and rail-based growth options performed favorably against the new settlement options with only urban growth and urban edge growth performing better in sustainability terms. However, in general, the SA does not appear to indicate that there is a significant amount of difference in the sustainability of the options under consideration.
We consider that greater clarity is needed as to the realism of deliverability of a number of the strategy options still under consideration. Whilst we agree that the final strategy is likely to be a combination of each of the options, there appear to be a number of difficulties in delivering the numbers assumed from each area. Indeed, it is noted that at paragraph 3.11 of the Housing Topic Paper that the targets for the urban area are ‘deliberately ambitious’, which suggests that the 3,000 homes assumed for Bedford town may not be realistic.
Whilst growth in and around the urban area is clearly a sustainable option, particularly given Bedford is the main centre for services and facilities in the area, there are a number of constraints around the town (landscape, flood plain, potential coalescence to name three) which mean that development will be difficult in the area.
There may be small scale opportunities in the town, but the delivery of 1,500 homes will be a challenge as will finding suitable sites for a further 1,500 homes on the edge of Bedford – which is effectively limited to the north/north east of the town.
These constraints increase the importance of looking closely at the deliverability of the other options including the transport corridors and opportunities for new settlements.
Whilst we are supportive of the role of the A421 is supporting growth and development and considered that the quantum of growth in the corridor is realistic moving forward. However, we do have some concern regarding the ambition for up to 7,500 (alongside up to 80 hectares of employment land in the ‘rail based growth parishes’ to the south of Bedford, as is proposed in option 2a.
This level of residential growth does not appear to be realistic when consideration is given to the sites submitted in the area through the call for sites, which have been promoted for employment use. Even the lower level of growth in this area (5,500 homes) is likely to be undeliverable.
Given there are also capacity constraints with the delivery of significant development in and around Bedford town, this indicates that the options which require a new settlement should be looked at favorably. Whilst we suggest that the two settlement option (2c), which is at the expense of allocations in and around some of the existing settlements, is unlikely to be realistic given the impact this would have on the short term delivery of housing in the area, a single new settlement should form an integral part of the strategy.
A new settlement at Denybrook would complement the allocation of a range of small/medium sized sites around Bedford and other settlements in the A421 corridor, that would help to meet immediate housing need. Whilst we would expect a new settlement option to be built out by the end of the plan period (if not shortly afterwards), depending on its final capacity, such an allocation would fit with the revised expectations in the NPPF that allocations within an area with strategic scale growth should be set within a longer-term vision for the area. Therefore, whilst the delivery of a new settlement may extend beyond 2040, it is important that the expectations are set out now to allow wider plans – both short term and in the longer term to factor in the contribution it will make to housing and employment land supply, and on the infrastructure of the area.
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Attachments:

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6645

Received: 14/09/2021

Respondent: Bedford Borough Councillor

Representation Summary:

3.10 – 3.17:
As we have noted above, we are concerned that only 4 options have been put to residents and that each of those 4 has only 1500 dwellings proposed for the urban area. This approach necessitates, once again, an unacceptable impact on the rural area which we regard not only as lazy planning but irresponsible planning. As previously pointed out the Council’s own sustainability appraisal clearly states that urban growth is the most sustainable on virtually all criteria and village related growth the worst. The Council has declared a Climate Change emergency and there is a position statement on Climate Change at para 8.2 et seq, yet it is disappointing to note how little that has influenced this draft plan; it is a lost opportunity
We believe that properly planned urban development, inevitably entailing some expansion, albeit retaining green spaces between communities, and including areas of enhanced density housing, is not only the most sustainable, as confirmed by the Sustainability Appraisal, but more closely meets the needs of the main growth sectors as noted in the Local Housing Needs Assessment. Accordingly we believe that a variant of Option 1b, the variation to include some expansion and some rural growth is strongly to be preferred.
For those reasons we are strongly of the view that the listed 4 preferred development options fail to live up to the aspirations set out in the Council’s own Visions and Objectives referred to above.
Apart from the inadequacy of the urban growth element our objections to the various options are :
i) They all entail excessive loss of agricultural land, particularly grades 1 &2.
ii) The so-called corridors are tenuous concepts that may seem coherent on a map but embrace differing villages of various sizes with little or no linking infrastructure capable of supporting significant growth.
iii) They all will increase reliance on non-sustainable modes of travel for all purposes.
iv) They all entail a further erosion of the open countryside which is one of Bedford’s most valuable assets.
We are strongly of the view that Options 3b, 3c, 4, 6 & 7 should be dismissed. The “key service centres” are already being changed beyond recognition and the strain on their immediate and surrounding infrastructure cannot sensibly be added to within the time span of this plan. In each case the loss of agricultural land that would follow the further expansion of these settlement areas and the dependence on unsustainable travel for all purposes plainly breaches all relevant sustainability criteria.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6680

Received: 14/09/2021

Respondent: Willington Parish Council

Representation Summary:

5. The recently adopted Local Plan 2030 makes mention of protecting agricultural land of grades 1-3a within its section on Resources and Climate Change, however there is no mention of this in the Local Plan 2040 draft plan strategies options and draft policies consultation. Furthermore there is no reference to the Borough prioritising the development of land that has been previously used rather than higher grade land. Farming is an important part of the economic and community in the Borough and the Local Plan should seek to protect high grade agricultural land.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6683

Received: 14/09/2021

Respondent: Cardington Parish Council

Agent: Cardington Parish Council

Representation Summary:

para 3. Growth and spatial strategy options. 3.10 – 3.17 Growth strategy options.

The (Draft) Sustainability Appraisal Report Evidence Base document clearly shows in Appendix 5 that the Spatial Strategy Options differ significantly in the feasibility, extent or even possibility of achieving the Vision and Objectives, Theme 1: Greener, and Environmental Net Gain. The Appendix does not attempt to rank the Options overall, however, and as this is not a task within the competence of Cardington Parish Council, we are unable express a preference.

We hope that such an analysis is carried out as a response to this consultation but from what we can see from the preliminary work of the (Draft) Sustainability Analysis, none of the options is able to deliver the Plan Objectives Theme 1: Greener or Environmental Net Gain.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6690

Received: 14/09/2021

Respondent: The British Horse Society

Representation Summary:

The Society does not express any opinion as to which of the four options presented is preferable.

But we do note that all options will impact on the existing equestrian routes network within the non-urban parishes and particularly within the new settlements, if developed. These routes must be protected and ideally enhanced.

Please also see my comments relating to site allocations below and my suggestion that greater focus be given to the enhancement of the bridleway/multiuser network would be beneficial.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6923

Received: 15/09/2021

Respondent: Bromham Parish Council

Representation Summary:

Locations for Growth
The consultation outlines a number of options for the focus of future development in the
period to 2040 and specifically identifies the need to build in the region of 12,500 new
dwellings over and above existing allocations during this period.
It is acknowledged that many of the consultation options recognise the importance of the
A421 corridor for future growth opportunities, recognising that the significant infrastructure
proposals will provide a well-connected, accessible and sustainable location for growth. The
Parish Council supports this approach and concurs that the A421 corridor is a significantly
better location for growth and better able to meet housing need. This will, in particular, help
maintain the character of the Great Ouse Valley, without the pressure of additional levels of
growth, thus making residents lives more miserable through increased traffic and pressure on
local services.
The Parish Council remains very keen to ensure that well respected and valued rural
communities in North Bedfordshire are not subjected to further inappropriate scale of
development given the inadequate infrastructure that exists to support growth, including the
already congested A6 infrastructure. The Parish Council, therefore, supports the removal of
new settlements identified in the north because the A6 would not be able to cope with the
additional traffic.
Further sizeable allocations in Key and Rural Service Centres, identified in some of the
consultation options, should be avoided. The Parish Council acknowledges, with
encouragement, that the report to the Executive did state that the Local Plan strategy must
recognise the significant contribution to growth that is already being provided in the
Borough’s larger villages (the Key and Rural Service Centres). As far as possible, the
emerging range of options steer additional growth away from villages that have a Local Plan

2030 allocation although the Parish Council is concerned that, for some options, additional
strategic development land may need to be allocated in those parishes. This is most
unacceptable as further growth in villages like Bromham would put unprecedented strain on
the local road networks. The inevitable rat runs through the villages would also be
compounded if unacceptable levels of growth were allocated in North Bedfordshire. The
A421 corridor, by contrast, represents a much better location for growth and must be
exploited.
In summary, opportunities for growth in the Oxford to Cambridge corridor must, therefore, be
exploited and the Parish Council supports development growth option 2(c).

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7027

Received: 17/09/2021

Respondent: James Fogarty

Number of people: 178

Representation Summary:

Local voices of Gibraltar Corner re. 2040 Local Plan.
We object to the proposals to build on arable and livestock land in this area. The land includes meadows and is a vital pathway for a range of deer species to access Buttons Ramsey and the Kill. There are local flora and fauna and the land currently forms part of a natural bridge to larger areas of open spaces now recognised as vital to the mental wellbeing of all. Any local building and the resulting extra use of land will be detrimental to wildlife such as foxes, rabbits, hares, owls, bats and new bird species in the area.
In recent years the area has had a bypass, a Lidl store and a Covanta incinerator imposed. The area of Home Rd Wood End Lane and Wootton Rd suffers flooding from surface water deluge, which is more frequent now and Anglian Water has to repair the breakages at regular intervals. The natural surroundings of land do at present soak up the excess successfully, even so in Ibbett Close behind Home Rd there is a pumping station for sewage which has to be attended by sewage lorry workers, and which recently failed causing many lorries to attend for 24 hours to clear out the resulting overflow. The lay of the land slopes down and with clay underlying it is not porous so any building including roads driveways etc will only exacerbate the situation.
The local roads are currently experiencing an increasing volume in heavy traffic which includes large freight trucks. The result is that our roads are rapidly falling into disrepair. Further building in this area can only increase the traffic flow. [This is petition - 178 signatures]

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7045

Received: 17/09/2021

Respondent: Little Staughton Parish Council

Representation Summary:

> Little Staughton is a small, less than 200 dwellings, village with limited accessibility located on the boundary of Bedfordshire and Cambridgeshire. Amenities are limited to a small farm shop/ caravan park, village hall, two churches and a playing field. Access to further amenities, e.g. doctors, schools, shops, requires the use of personal transport with public transport limited to restricted services between Bedford and surrounding villages. This public transport is of limited use as most of the amenities, except schools, are located in Cambridgeshire.
>
> Any significant expansion would need to recognise the existing deficiencies in the present infrastructure and accommodate these accordingly. The call for site assessments are limited to the specific sites and do not recognise the potential impact of more than one of these locations being developed. There are presently eight locations with up-to 350 houses under the call for sites review. This would nearly treble the size of the existing village, leading to increased pressure on roads, doctors and the primary school at Kymbrook.
>
> There has been ongoing development of individual plots within the agreed settlement area, with up to 20 houses in construction and or planned at the present time. This level of moderate expansion is welcomed for the health and well-being of the village. As part of the 2040 a similar increase could be considered reasonable.
>
> As a Parish Council we have objected to all individual sites on the basis that these are outside the established Settlement Policy Boundaries.