3.10

Object

Representation ID: 7257

Received: 01/09/2021

Respondent: Wyboston Lakes Ltd

Agent: Brown & Co Barfords

None of the development options acknowledge the benefits of mixed use development at the Wyboston Lakes Complex, which is well related to the potential new settlements at Wyboston and Little Barford and is in
proximity of the A421 transport corridor and a proposed new rail station at St. Neots/Tempsford.
The Complex has the ability to accommodate strategic scale mixed use residential and employment
development and its suitability for these uses has been acknowledged by existing planning permissions
granted by the Council.
A mixed use development will also realise:
• development in proximity to a range of services and facilities within easy walking distance;
• re-use of previously developed land;
• available access connections with scope for improved pedestrian crossings, though it is highlighted the
proposed realignment of the A428 will result in the current A428 road being re-trunked;
• avoid the loss of agricultural land;
• development without harm to the landscape or the setting of the wider area (reflected in the previous
permissions granted by the Council);
• readily available existing infrastructure and services already on the Complex;
• avoid land that is not constrained by flood issues etc.
The Borough Council’s June 2021 Development Strategy Topic Paper identifies the Council will have to make
a ‘step change’ in the delivery of new housing growth. However, a new settlement at Wyboston and/or Little
Barford will have a relatively long lead in time. Additionally, four of the five EWR routes being consulted upon pass through the Little Barford site, and the deliverability of this proposal and the potential number of dwellings it might deliver will require further assessment following the decision on the route alignment. Given these uncertainties, the Wyboston Lakes Complex proposal outlined in the attached Statement is readily available and can come forward now, without being dependent on strategic infrastructure decisions. The proposals are therefore able to assist in meeting the more immediate housing shortfall in advance of the potential longer term
settlements coming forward.
Brown & Co have been instructed to submit the following Statement on behalf of Wyboston
Lakes Limited in response to the Bedford Borough Council’s Strategy Options and Draft
Policies Consultation June 2021 and in support of the future allocation of land at the
Wyboston Lakes Complex, Great North Road, Wyboston for wider business and residential
development uses.
Over the past 30 years more than £45m has been invested at the Wyboston Lakes Complex
to create a unique business, training and leisure facility (including the largest training centre
in the country), which is now one of the major employers in Bedford Borough. The
development of the site has had the support of the Borough Council, which has granted
numerous planning permissions for a wide range of buildings and uses across the site. In
2012 Wyboston Lakes Limited acquired adjoining land from the East of England Development
Agency with planning permission for around 18,500 sq metres of business development,
which is now incorporated into the overall Wyboston Lakes Complex site.
Despite the Borough Council’s support for investment and development over many years, the
Wyboston Lakes development has historically been subject to the open countryside restraint
policies, and this has created an anomalous position. The Local Plan 2030 adopted in
January 2020 has provided more certainty for further growth on the site through Policy 73,
however, the policy refers specifically to development that ‘supports and enhances its role as
a regional centre for leisure, training and conferencing’. The supporting text also refers to the
opportunity for ‘small scale’ research and development “B1” use class employment, but this
is at odds with previous permissions granted by the Council and the inclusion of the former
East of England Development Agency land, which is now part of the site. Additionally,
residential planning permission has been granted for the development of a Continuing Care
Retirement Village comprising 128 care apartments and village care centre comprising 61
care bedrooms, 49 care suites, restaurant, dining rooms, lounges, cafe, shop, hairdressing
salon, activities rooms, gym, swimming pool and associated works. This permission has been
lawfully commenced and is therefore ‘saved’, and this has recently been acknowledged by
the Council with the grant of a Certificate of Lawfulness for Proposed Development (Ref.
21/00471/LDP).
Given the ‘saved’ and current planning permissions for business and residential development
uses on the site, and the strategic growth options identified in the Strategy Options and Draft
Policies Consultation, the Wyboston Lakes Complex is considered appropriate for allocation
within the Local Plan Review for a range of employment and residential uses. This will support
and complement the Plan strategy options to concentrate growth in proximity of the A421
transport corridor and a proposed new rail station at St. Neots/Tempsford and contribute to
the emerging policies for the Oxford to Cambridges Arc.
The purpose of this statement is to set out the background to the applicant’s proposals and
the key planning issues raised by them. The statement is structured as follows:
Section 2: describes the physical characteristics of the site context & background;
Section 3: reviews the emerging plan strategy key points;
Section 4: summarises the development options for the wyboston lakes complex;
Section 5: provides an overall assessment summary.
In location terms the Wyboston Lakes Complex is on the edge of St. Neots and with its already
developed form this is generally perceived to be part of the town’s urban conurbation. A
market town with a population of more than 30,000, St. Neots offers a wide range of local
services and facilities and is a focus for growth in the adopted Huntingdonshire Local Plan,
which identifies its potential to provide an additional 4,000 houses over the next 15 years.
The Complex has good access to the strategic road network having the A1 and A428 Trunk
Roads on the western and northern sides, and the East Coast Main Rail Line to the east
providing a 40 minute service to Kings Cross. The planned east-west new rail link is also
expected to include a new train station south of St Neots, within proximity of the Complex.
Situated adjacent to the Bedfordshire and Cambridgeshire County boundaries the Wyboston
Lakes Complex offers the opportunity for growth that will improve local job opportunities and
help stimulate sustainable economic growth in both Bedford Borough and Huntingdonshire,
as well as contribute to the Oxford to Cambridge Arc.
The Wyboston Lakes business & leisure village extends to an area of 15.42 ha (382 acres)
enjoying extensive riparian frontage to the River Great Ouse. Within the site there are three
self-contained training centres and hotel services with 406 on-suite bedrooms, full
catering/dining facilities and bars, conference suites, serviced office accommodation and a
supporting wide range of facilities arranged informally throughout the site. These sit amidst a
unique and extensive leisure and recreation centre that supports an 18 hole golf course,
driving range, putting green and practise area with golf instruction, fitness centre, indoor
swimming pool, spa, beauty treatments, restaurants, fishing and water sports centre with
skiing lakes, jogging trail and nature walks. The village is a gated area with a security lodge
and CCTV at the main entrance.
The training centres have a diverse client base drawn from local, regional, national and
European locations. The Home Office established a regional office of the National Crime
Agency (NCA) on the Village and Firebrand Training UK established their UK residential training
centre on the Village in 2009 that welcomes more than 20,000 delegates a year onto their
information technology and project management courses. Overall, the Complex employs more
than 650 people with support from a substantial number of local businesses.
Although the site is characterised by low density development with extensive and established
planting providing attractive riverside parkland, this exhibits a clear built-up character with a
diverse mix of developments, which will be consolidated by the already permitted proposals.
To the north west there is the Phoenix Business Park and further north there is the St Neots
administrative area with recent office, industrial and storage development on the Colmworth
Business Park and a substantial warehousing building and retail development on Alpha Park.
Beyond this there are the residential areas of the Eaton Socon and Eaton Ford, which are part
of St Neots. The County boundary between Bedfordshire and Cambridgeshire follows the eastwest
A428.
The site has a substantial planning history with the following ‘Saved’ Planning permissions
that have been initiated, but yet to be completed:
• 2,417 sq. m of knowledge centre planning permission granted in 2002 – LPA Ref.
01/02676/FUL.
• Three storey bedroom block granted in 2003 – LPA Ref. 03/03100/FUL
• 1,672 sq. m of training support offices granted planning permission in 2005 – LPA Ref.
05/00817/FUL
• Innovation Centre development with 11,305 sq.m of floor space - LPA. Ref.
01/00338/FUL.
• Medical Centre - LPA Ref. 10/00007/MAF
• 53 Holiday Lodges - LPA Ref. 13/00762/EXTM
• Continuing Care Retirement Village comprising 128 care apartments & a village care
centre providing 61 care bedrooms, 49 care suites with restaurant, dining rooms,
lounges, café, shop, hairdressing salon, activities rooms, gym, swimming pool &
associated works – LPA Ref. 10/02007/MAO & 18/01843/MAR
Although now time expired, it is highlighted permission has previously been granted by the
Borough Council for an Innovation and Technology Centre with 18,500 sq. m of Class B1 floor
space (LPA ref. 08/01890/MAO) on the land south of the A428 (former East of England
Development Agency land).
The locations of the approved development are identified on the plan below. (SEE ATTACHMENT FOR PLAN)
The Complex has clearly been regarded appropriate for a wide range of imaginative
development proposals and the current and permitted uses comprise a wide mix of
interrelated activities. By reference to the classifications in the Town & Country Planning (Use
Classes) Order 1987 (as amended), these include: Retail shop (Class E(a)); Restaurant (Class
E(b)); Innovation Centre and Offices (Class E(c)); Hotel (Class C1); Residential Training centres
(Class C2); Residential dwellings (Class C3); Medical Centre (Class E(e)) and Dance Hall &
Leisure (Class E(d)).

Object

Representation ID: 7414

Received: 03/09/2021

Respondent: Axiom Great Barford Limited

Agent: Axiom Great Barford Limited

Axiom are generally supportive of the rationale of future growth being focused around transport corridors, in particular along the A421 which is the key route through the Borough, connecting Milton Keynes and Cambridge, and is well related to Bedford as the areas main service centre.
We note from the Development Strategy Topic Paper 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.
In this regard, we do not consider Option 2c, which would focus development on the urban area plus two new settlements in the east of the Borough to be a realistic option. Whilst there may be scope for the inclusion of one new settlement in the Local Plan 2040, particularly given the new NPPF paragraph 22 requirement for the strategy to be set within a longer-term vision, to include two new settlements at the expense of other options would be unsustainable and a highly risky strategy to deliver much needed homes in the short to medium term.
Whilst growth in and around the urban area is clearly a sustainable option, particularly given Bedford is the main economic centre in the area, we have doubts whether the 3,000 homes (plus 51ha of employment land) is capable of being delivered in these areas over the plan period.
There may be small scale opportunities in the town, but finding land for 1,500 homes will be a challenge. Equally, finding suitable sites for 1,500 homes on the edge of Bedford – which is effectively limited to the north/north east of the town. Constraints to the south east which overlap with other options to the south – will also be a challenge, particularly given the character of the landscape and topography in this area.
Both of these considerations increase the importance of looking closely at all the options for the A421 corridor and reinforce the position that the A421 and rail corridors should play an integral part of any future development strategy.
It is encouraging to see that growth in the A421 corridor is included within three of the four options presented in the paper – with our thoughts of the fourth, two settlement option, noted above.
However, we have some concerns about the make-up of the three options which include A421 growth primarily being focused on the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period, and the ability to deliver the 5,500-7,000 homes directed to the rail corridor – also to the south of the town.

Rail related growth
Whilst focusing 50% of the required additional growth close to the rail stations to the south of the town is a laudable proposition, it is unclear how this would be delivered. Below is an extract of the call for sites map with the rail related growth area from the options consultation document overlaid in red. It can be seen that there are a limited number of sites put forward in the rail related growth area – with those large sites that have been put forward identified as having employment potential by their promoters, given the surrounding context.
(Refer to map in attachment)

Whilst additional opportunities may be available on the periphery of this area which could contribute to delivery (some of which may be classed as being in the A421 corridor), we would question whether there is suitable land available to deliver up to 7,500 homes in this area.
Along with concerns about the ability to deliver 3,000 homes in and around the urban area, this places further emphasis on the role of land in the A421 corridor within the development strategy

Whilst there is a role for a new settlement as part of the development strategy, we question the ability of any such allocation to deliver in the short to medium term. There will be a significant lead in time with any new settlement and first completions would not be realised until well into the plan period.
In the context of the requirement to have a long term, 30 year vision to satisfy Paragraph 22 of the NPPF, it is logical to plan for a new settlement through the Local Plan 2040. However, this shouldn’t be to the detriment of meeting housing requirements in the short to medium term, particularly when there appears to be sufficient suitable and deliverable sites available to meet the need in a timely manner.
We therefore suggest that if a new settlement is to be included in the strategy, the number of homes to be delivered in the plan period is realistic. At the current time, the options appear to assume the completion of either settlement option in the plan period. We don’t believe this to be a realistic assumption given the current stage of the plan and the lead in time associated with matters including land assembly, planning and infrastructure delivery.
Once delivery rates are looked at in more detail, we believe there will be a residual requirement that will need to be covered in the development strategy. Given the constraints with other elements of the strategy, we again put emphasis on the importance of the A421 corridor to deliver growth in the Local Plan 2040.
The Apportionment to the Southern Parishes
Aside from option 2c (the two-settlement option), which has been addressed above, each of the options include an element of growth in the A421 transport corridor. This level of growth varies from 1,500 dwellings in option 2b and 2d to 2,000 dwellings in option 2a. In our view, each of the options significantly downplay the potential of the area to deliver additional housing numbers.
As can be seen from the call for sites map below, there are a number key service centres in this corridor with the ability to expand and where sites have been put forward for consideration. This includes Wootton, Wixams, Wilstead, Shortstown and Great Barford, where Axiom are promoting land. In the adopted Local Plan, Key Service Centres were seen as suitable for 500 dwellings, and indeed higher levels of growth were assessed early in the process as being appropriate in some locations.
(figure 2 in attachment)
Given there are other settlements in the corridor that could also take growth, such as Willington and Cotton End, it is unclear why the options limit potential growth to 2,000 dwellings. This is particularly the case when the issues raised above with the other options are taken into account.
It is suggested that a finer grain assessment of site availability and suitability needs to be undertaken to inform the development strategy. In our view, if this is undertaken, it will identify a greater level of potential for growth in the area.
Within the three options, we are unclear why areas to the east (land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston) are only included in one of the options, despite being in the same transport corridor as Wootton, Wilstead, Cotton End and Shortstown, which are included in all three. A review of the evidence does not make this distinction clear.
We suggest that in developing the strategy further, the whole of the A421 corridor should be looked at as one, with no distinction between the eastern and southern parishes. This will allow a proper review of all settlements and sites on a comparable basis and avoid suitable sites being missed out of the development strategy based on an arbitrary decision to split the parishes along the corridor.

Object

Representation ID: 7431

Received: 03/09/2021

Respondent: Trakbak Racing Limited

Agent: WSP

When the Council previously withdrew the garden village settlement at Colworth (nearby to SPD), which was put forward as an allocation in the previously emerging Bedford Local Plan 2030, they recognised that the development of housing in close proximity to Santa Pod is inappropriate. Despite this, there is nothing in the ‘Growth Strategy Options’, on pages 19-23 of the emerging Local Plan 2040, to reflect that or to protect Santa Pod from the effects of alternative development proposals on its business.
Trakbak Racing Limited has concerns about this and, in particular, if the Council fall into a position of failing to demonstrate a five-year supply of housing land during the emerging plan period which could result in speculative housing applications being submitted nearby to SPR. At paragraph 3.9 of the document ‘Trakbak Racing LTD Regulation 19 Representations to the Bedford Borough Local Plan (October 2018)’ it is explained that there is a known noise issue in connection with Santa Pod. In consequence, there is a risk of unreasonable restrictions being placed on SPR because of new development.
In relation to this, paragraph 187 of the NPPF that “existing businesses should not have unreasonable restrictions placed on them as a result of development permitted after they were established” needs to be complied with to ensure that the emerging local plan is in accordance with policies of the NPPF (as required by paragraph 35 of the NPPF). The agent of change (the housing development) should be required to provide suitable mitigation where the operation of an existing business could have a significant adverse effect on new development.
Attached at Appendix 23 is a letter from MAS Environmental dated 25th October 2018. This makes it clear that any development within the previously proposed Colworth garden village development area (Site reference: 1002) would carry significant risks regarding noise impact. Development in the area indicated as the inner buffer zone (highlighted in red) would be subject to noise from the raceway for the majority of events and there is no evidence to suggest that mitigation could adequately resolve the issue. Trakbak Racing has been advised that such mitigation could not be satisfactorily provided within the inner buffer zone without its cooperation. The cooperation of Trakbak Racing has not been secured and it would not be appropriate for housing to be allocated in the inner buffer zone.
In the outer buffer zone it would be essential for the Council to be satisfied, before supporting the allocation of a site, that it would be possible for mitigation within the proposed development to provide an acceptable noise environment. This would need to be supported by robust evidence and the Council should provide guidance in the Local Plan as to what standard should be required.
Adoption of the MAS recommended exclusion buffer zone for residential development around Santa Pod would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with. The restriction would need to be in a strategic policy to ensure that it guides the Neighbourhood planning process adequately.
It is significant that in the case of the SPR there is no restriction on noise levels. The distance selected for the buffer zone has been identified based on the measured noise levels experienced in the relevant areas and so is based on a sound evidence base.
The introduction of housing into the inner buffer zone would represent a serious threat to the continuation of the business at Santa Pod, which makes a valuable cultural and economic contribution to the wider area. It would not accord with paragraph 187 of the NPPF and so would render the Plan unsound. Any housing within the outer buffer zone would need to be subject to robust mitigation measures to provide a specified satisfactory indoor and outdoor noise environment and sites should not be allocated unless that can clearly be demonstrated. In this case the plan does not, in the absence of clear policy guidance in relation to the location of housing to avoid noise issues from Santa Pod, provide a clear and adequate strategic framework and that omission goes to the soundness of the plan.
Summary
These representations are made on behalf of Trakbak Racing LTD to object to the allocation of four sites (references: 1002, 529, 531 and 532) submitted as part of the local plan consultation. The allocation of these sites would be contrary to paragraph 35 of the National Planning Policy Framework (NPPF) (2021) which explains that in order for local plans to be found sound, they must be in accordance with policies of the NPPF.
These representations also explain that the ‘Growth Strategy Options’ of the emerging local plan should be amended to protect Santa Pod from the effects of inappropriate housing development proposals on its business. These representations explain that an exclusion buffer zone for residential development around Santa Pod should be outlined in strategic policy, as this would represent a positive response to the issue of housing around SPR and would ensure that paragraph 187 (‘agent of change’) of the NPPF is complied with, and therefore ensure the soundness of the emerging Bedford Local Plan 2040.
We would be grateful if you could confirm safe receipt of this representation and we look forward to them being considered in the consultation process of the emerging plan. In the meantime, please contact me if you have any queries in respect of the matters raised in this letter.

Object

Representation ID: 7436

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

Our client has reviewed the discussion of those various growth options set out within
the DS document and is supportive of the conclusions which the document reaches,
particularly in respect of those growth options along the ‘Transport Corridor’ which do
not involve the creation of new settlements.
Whilst further commentary is provided in respect of the growth options later within this
submission, it is urged that the Council remain mindful, from the outset, of the
implications for the emerging LP arising from the recently published National Planning
Policy Framework which was revised in July 2021 after the launch of the current public
consultation.
Para 22 of the revised NPPF is clear; where a new settlement forms part of the
strategy, policies should be set within a vision that looks further ahead (at least 30
years) to consider the likely timescale for delivery. As such the client’s position is that
the emerging LP is not the correct document to allocate land for a new settlement and
any such proposals should be considered over the longer term and catered for within
a future LP or alternative DPD.
To this end, the client is largely supportive of growth Option 2a and the conclusions
of the DS confirm this to be a suitable option for the future strategic development of
the Borough. However, it is considered that minor revisions to the strategy posed by
Option 2a could be suitably undertaken to ensure that the overarching strategic growth
targets up to 2040 can be achieved.

Object

Representation ID: 7443

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

In considering the proposed spatial development options, the client has discounted
those which seek to deliver a new settlement as the time horizon of the plan is not in
alignment with the provisions of Para 22 of the NPPF. Furthermore, the Council were
right to discount preliminary options 1a and 1b due to the constraints such approaches
would face in and around the urban area of Bedford.
It is yet further clear that the approaches advocated within Options 2b-d, 3a-c and 5-
7 would not achieve the ambitious level of growth which is required in the Borough by
2040.
The client is largely supportive of the approach set out within Option 2a. However, it
is considered that this strategy could be revised to provide a more realistic and
positive approach to achieving the growth, which is required, particularly in terms of
residential development.
In assessment of Option 2a it is considered that the Rail Based Growth Parishes
should be revisited with a greater spatial analysis of those settlements which lie in
proximity to both existing and proposed rail terminals.
The option quite rightly highlights Kempston Hardwick, Stewartby and Wixams as
settlements which should be developed based on their proximity to existing and
proposed rail stations. However, in assessment, it appears that the sustainability
credentials of Wilstead have been overlooked along with its proximity to Kempston
Hardwick Train Station. Similar arguments could be made for Houghton Conquest and
Marston Moretaine which are comparable settlements with good public transport links
including proximity to the station.
Therefore, it is urged that the list of Rail Based Growth Parishes be re-assessed and
lengthened to allow for the inclusion of further settlement. Such an approach would
reduce reliance, and the resultant pressures, for residential housing growth at
Wixams, Kempston Hardwick and Stewartby.
Whilst it is acknowledged that a new station at ‘Stewartby Hardwick’ could be a
catalyst for growth, this realistically will not be achieved until later within the plan
period and development directly related to its delivery will be required for funding
purposes. To this end, an increased level of development at Wilstead could assist in
achieving the delivery of such infrastructure.
Wilstead itself is acknowledged within the settlement hierarchy as a sustainable Key
Service Centre and it is considered that its role could be elevated to account for its
spatial relationship with the Rail Based Growth Parishes. Notwithstanding the above, if Option 2a is carried forward into future iterations of the
LP, it is considered that the proposed levels of growth within the option should be reapportioned
to redistribute growth in a pattern which reduces reliance upon certain
settlements and provides a more positive pattern and subsequent approach to growth.
It is considered that Option 2a should be re-apportioned to acknowledge the
sustainability credential of those settlements in the southern part of the transport
corridor. The following table shows the current pattern of distribution within Option 2a
and the client’s revised approach which reduces reliance upon the urban area which
is already under significant pressure.

(see tables 1 and 2 in attachment)
Please note that the above figures are set against the backdrop of the housing target
contained within the emerging LP, 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 when appropriate revised 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 inputs are variable.

Support

Representation ID: 7872

Received: 23/09/2021

Respondent: Central Bedfordshire Council

We have reviewed the four emerging preferred options for growth and support the Council’s decision to consider their development strategy alongside the opportunities available to promote sustainable and healthy communities.

As stated in our previous response, CBC remains of the view that in the first instance, brownfield and previously development land should be utilised to its maximum capacity before looking to greenfield land to deliver growth. The urban based location options would offer huge benefits in terms of sustainability and growth could be successfully delivered without the need for new large-scale road infrastructure. Intensification of sites within Bedford should be fully considered in line with the estate regeneration objectives of the NPPF and the decisions around East West Rail that have now been taken, which provide confidence in terms of infrastructure in this area.

We are pleased to see that the Council has assessed the likely transport effects of four development scenarios, and we have reviewed the detail provided in the Transport Model Assessment Report and the Development Strategy Topic Paper. CBC would want to ensure that the full extent of planned growth within the recently adopted Central Bedfordshire Local Plan has been taken into account when considering the growth options and their potential impacts.

It is acknowledged in the Transport Assessment report that some of the existing roads are either close to/at capacity or in some cases exceeding capacity already. As such, it is absolutely essential that further, more detailed assessment is undertaken to ensure any potential growth locations do not have impacts on the network that cannot be mitigated. We note the Assessment Report makes no mention of capacity issues on the A1 or J13 of the M1, both of which are key connections to the A421 running through Bedford. These must be factored into any assessment when considering growth in BBC. Both were considered during the CBC Local Plan examination, and capacity constraints were acknowledged. Mitigation to accommodate the development proposed within the CBC Local Plan was agreed by Highways England for J13, but it is not clear that any additional capacity could be accommodated moving forward. This is a key junction, which will be impacted by growth within CBC, Milton Keynes (MK) and BBC. Joined up thinking is required to ensure we can all successfully achieve the growth required in each of our areas.

Some of the scenarios being considered in this plan are to create new settlements around Wyboston/Great Barford, which will be adjacent to the A1 and will clearly increase flows on that route. The capacity of the A1 must be a key part of any consideration of these sites and further work is required to fully understand its capacity and constraints, and potential solutions. Bearing in mind the known constraints here, this would likely involve the need for large-scale intervention, such as realignment. CBC would welcome the opportunity to be involved in such work. As stated in our previous response, we would question whether growth could be considered in these locations without a commitment to such interventions, which would undoubtedly require government funding.

It is also noted that these locations for growth are dependent on an EWR station coming forward in this location. Whilst considering locations in close proximity to rail infrastructure is welcomed, it should be noted that the plans for EWR are still at early consultation stage and a DCO application has yet to be submitted, as such, there can be no certainty attached to the potential location of any new stations.

Support

Representation ID: 7883

Received: 22/09/2021

Respondent: Mrs Anne Pape

As the urban area component performed best within the sustainability appraisal it was appropriate that this had been included in each of the four options.
Option 2A – The high option of the rail-based transport corridor allows the best use of the proposed new railway station at Wixams for both employment and housing purposes. The settlements in the rail-based growth and southern transport corridors already have infrastructure in place to support further growth. Option 2A would provide for residents’ needs and access to community services while reducing the need to travel and promoting sustainable modes of travel therefore, reducing carbon emissions. Option 2A would also support the development of brownfield sites.
Option 2B – as with 2A this option would allow use of the proposed station at Wixams and a second new railway station in the St Neots/Tempsford area which may be delivered with East West Rail. Once again, the settlements in the rail-based growth and southern transport corridors already have infrastructure in place to support further growth, providing for residents’ needs and access to community services while reducing the need to travel and promoting sustainable modes of travel. A new settlement would allow specific infrastructure to be developed to provide for residents needs and to support sustainable travel options. Option 2B would also support the development of brownfield sites
Option 2C - as with 2A this option would allow use of the proposed station at Wixams and a possible second new railway station in the St Neots/Tempsford area with the development of East West Rail. The settlements in the rail-based growth corridor already have infrastructure in place to support further growth, providing for residents’ needs and access to community services while reducing the need to travel and promoting sustainable modes of travel. Two new settlements would allow specific infrastructure to be developed to provide for residents needs and to support sustainable travel options. However, option 2C would have reduced use of brownfield sites over options 2A and 2B and would develop high quality agricultural land.
Option 2D – Transport corridor east has been included in Option D. All of the villages identified in this option transport corridor are small with limited infrastructure and already face challenges with excessive traffic movements on village roads, a poor bus service and limited opportunities for green travel, i.e. cycling and walking, to access services and facilities. Further development would exacerbate the challenges already faced by these villages. The rail-based growth transport corridor has a low option of 5500 dwellings in option D. Development of small villages and the low number of dwellings in the rail-based corridor would not be the best combination to meet the sustainability aspirations of the Borough. Road travel would be required to access railway stations and community services. Option D would also result in a reduced use of brownfield sites and a greater use of agricultural land. Development of high-quality agricultural land, open countryside and rural communities should be avoided.
Cople Parish Council would support the adoption of either Option 2A or 2B and feel that these would be best placed to deliver sustainable growth supported by appropriate infrastructure and limit the amount of unwarranted development on agricultural land, open countryside and rural communities.

Support

Representation ID: 7933

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council has carefully considered all of the options identified by the Borough Council. It wishes, at this point, to underline the fact that this response should not be viewed as a NIMBY response, and that by indicating a preference for a development option that looks to the east of the Borough, the Parish Council is also very conscious that the views of Parish Councils most likely to be affected by these options will quite properly carry considerable weight.

That said, Pavenham Parish Council’s preferred option is Option 2c, namely “Development in and around the urban area, plus A421 transport corridor with rail based growth parishes plus two new settlements.

By selecting Option 2c as its preferred option, the Parish Council should point out that such a preference is entirely consistent with the views that it has expressed over the past 5 years. Regardless of the route eventually consented for the Bedford to Cambridge rail link, it is entirely logical that any future growth within the Borough should be concentrated within the central urban area and along the rail and transport corridors for reasons of connectivity.

The Parish Council would in this context also point out that in terms of connectivity, growth to the north of the urban area and away from the urban centre must be viewed as both impractical and illogical in terms of connectivity. The A6 to the north of Bedford is patently sub-standard is already under pressure – even without the current Sainsbury’s et al road works.

Looking at the proposed objectives – indeed requirements if the Borough is to meet its targets - namely, some 151 hectares of employment land and 12,500 new dwellings, it is queried in any case whether land north of the urban centre in the Borough could actually support such development in terms of basic infrastructure ranging from transport, drainage, sewerage, highway connectivity to modern systems of communication. Whilst it is appreciated that developers will always be able to provide answers to such questions – the means of providing those answers usually comes at great cost to the environment leading often to irreparable damage to an already fragile countryside.

The Parish Council appreciates that option 2a and 2b would meet essentially the same objectives and indeed considerable thought was given to whether Option 2a should be the preferred option.

It was felt, however, that on the assumption that the proposed Bedford to Cambridge rail link will actually be delivered – a new town settlement supporting the proposed new station at Little Barford seems a logical first step.

As far as a new town settlement at Wyboston is concerned, the Parish Council feels that a second settlement would avoid the risk of random development sites being identified by developers which in light of the high residential allocation targets in the Local Plan 2040 could be difficult for the Borough Council to refuse.

As noted above, the Parish Council is reluctant to comment on options that will affect Parishes to the east of the Borough and not its own administrative boundary. From the perspective of Pavenham Parish Council, however, it is considered that natural growth along the rail and road Transport Corridors would enable the affected Parishes to participate more effectively in the selection and allocation of sites. That said, whilst the Parish Council believes that there is a logic in supporting a new town settlement at Little Barford to serve the new East-West Rail Station, it follows that if the Parishes along the Transport Corridor prefer Options 2a, 2b, or 2d, then Pavenham Parish Council would be happy to defer to their view.

Object

Representation ID: 8045

Received: 02/09/2021

Respondent: Ms Carrie Scott

I was rather pleased to see the proposals in a nice, glossy document. They all seem to focus mainly on urban area development, which makes sense. However, these proposals don’t match with those of East West Rail, apart from the alarming suggestion of new developments at Wyboston and/or Little Barford, and this is somewhat confusing. Is it time you consulted properly with EWR?

I cannot see the benefit to developing new settlements at all. What facilities will be provided for so many extra people? There appears to be a large area of “employment” included with these suggestions, but “employment” is, at best, extremely vague. Are you agreeing with EWR about a new science park? Whatever this “employment” is, has any study been carried out to see whether any “employment” would be used. Or would it become another cluster of empty buildings that nobody wants. Please take into account that since the Pandemic, many more people and businesses are actually working in office space, and this is not likely to grow, given it makes it cheaper for businesses who have woken up to the fact that most people can be trusted to work even if they’re not under employers’ noses!

Any developments away from urban areas will mean more traffic, not just on the main roads, but on the already-overused minor roads in surrounding areas. Your own Sustainability Appraisal found that urban growth was best for reducing emissions, providing needs and access to facilities, reducing travel needs, and promoting sustainable travel.

Therefore, the only sensible option in the nice, glossy document is 2a, where all expansion is around the urban area.

Support

Representation ID: 8047

Received: 02/09/2021

Respondent: Ms Pauline Woodward

I have just received your leaflet about the proposed building around Eastcotts. Obviously option 2c seems the best as there is no further building works. I moved here Novembe 2018 and have since seen all the new buildings in Cardington, which seem to be still getting more and more houses. As with all these new developments, at first there are plans to either enlarge schools,doctors, transport and facilities etc but in the end not much of this actually happens and they are over populated and not enough infrastructure to cope.

I presume its too late to do anything about this now as the cut off date is tomorrow but would like to be kept informed.

Object

Representation ID: 8048

Received: 02/09/2021

Respondent: Mrs Hilary Ashby

out of BBC ‘s preferred Options 2a, 2b, 2c and 2d, my preference is 2c.

I object large scale development in Wilstead following reasons:

Wilstead is a rural community and as such it is vital that it keeps its green spaces, strategic gaps and important views of the countryside from all angles of the village. It is important to keep Wilstead’s unique identity.

In Wilstead we are lucky enough to have wide variety of mammals and birds whose habitat will be threatened by development. I mention, in particular, barn owls, which are known to nest in the barns at Village Farm.
A draft Neighbourhood Plan has been put together for village on which there has been 2
consultations with residents. 90% do not want any more large-scale developments in the village.

There are around 1000 dwellings in Wilstead. We have already had to accept 105 new houses which is an increase of over 10%. Any further large-scale development would alter the character of the village and overwhelm local facilities.

Any substantial development would consist of estate-type housing which would be out of character with the rural, mixed-style and mixed age of the current houses in the village.

Wilstead is a village consisting of ribbon development. Any further development at its ‘ends’ would mean people having to get in their cars to access the centre of the village thus having an environmental impact. Adding to this, the infrequent bus service only covers part of the village with the route being more than 800m from most residents. Existing roads would also be swamped with an increase in traffic particularly at the start and end of the school day. Therefore, it would seem more logical for BBC to consider urban development in the town centre which would be much less environmentally damaging than expansion and development of villages.

Development at Wixams is still on-going therefore there is no need for more housing estates in Wilstead. There must be a gap between Wilstead and Wixams to avoid coalescence as well as between Wilstead, Elstow and Cotton End to preserve their separate identities.
Wilstead should not be designated as a Key Service Centre as there is insufficient infrastructure to support large scale development. Wilstead and Wixams are both included in the draft local plan as Key Service Centres. Nowhere else in the Borough are 2 Key Service Centres located next to one another.
The existing drainage ditches cannot cope now never mind the additional strain new developments would put on the current drainage. With insurers becoming more reluctant to insure houses liable to flooding and charging exorbitant premiums, would these new houses sell?

Finally, why is there no new development proposed in the north of the Borough where it is proposed to locate the East West Rail route?

Support

Representation ID: 8051

Received: 02/09/2021

Respondent: Shortstown Parish Council

In the proposed 2040 Local Plan there are several options proposing further
development within Shortstown parish but due to the high levels of development that
Shortstown has already seen further housing beyond what has already been built
would risk Shortstowns rural character, further diffuse its small and fragile centre,
and risk the future of the historic airship sheds and Cardington airfield.
Over the few years Shortstown has been targeted for massive development. Between
2014 and March 2021 901 houses have been built in the parish. When the
Cardington Airfield development to the North of the sheds has been completed
another 592 houses will have been added. Once that is complete that will be 1493
houses added to the parish since 2014.
While the development of RAF Cardington did include a notional village centre this
has been slow to develop and Shortstown is still severely deficient in key services for
the level of households now within the parish.

As can be seen in the included figure (see attachment) Shortstown has seen recent rapid change over
recent years and when the additional development to the North of the historic sheds is
included this pushes the developed area within the parish to roughly 25% of the
parish.
The proposed College Farm & Shorts Park developments would completely change
the character of the parish and ruin the future of the sheds and airfield for movie and
airship use. The Shortstown Parish Council objects to those proposals.
Shortstown Parish Council require a pause in further developments within the parish
so that the current situation following the existing large development completion can
become clear and be reviewed.

Object

Representation ID: 8062

Received: 03/09/2021

Respondent: Wilshamstead Parish Council

The NP Team fully supports the response from Wilshamstead Parish Council to the various Strategy options put forward by Bedford Borough Council for housing developments in the Borough.

These comments are made against the reported requirement of 12,500 dwellings in the Local Plan and we would wish to be given the opportunity to amend these comments if this quantity is adjusted in the future.

Specifically, the Parish Council and NP Team were surprised to read in the CPRE’s Bedfordshire Response Document that the planned allocation by Bedford Borough Council is larger, and in some cases much larger, than surrounding Local Authorities. The NP Team would seek confirmation that all these Local Authorities are using the same Government data in order to derive their particular housing needs. An explanation of why Bedford Borough is so much higher would be very useful for the Parish Council and NP Team in responding to queries from residents regarding the perceived Borough housing need and its allocation.

Wilstead NP Team would also need to be assured that Bedford Borough was working with other Local Authorities to ensure a coordinated approach. We would not want to discover, for instance, that Central Bedfordshire was proposing large-scale development on the edge of the village (e.g., south of Wixams) which would further impact on the unique character of our village.

In reviewing the Draft Local Plan 2040 the NP Team were conscious that they needed to promote the Vision and Objectives of the Draft NP. The Vision is as follows:

“To retain and enhance the countryside setting, friendly character, identity and relative tranquillity of the village of Wilshamstead.
Development opportunities will be sustainable and appropriate to the scale and nature of the village, respecting its historic, agricultural and rural character.”

There are only approximately 900 houses in the village (plus 196 park homes). Any substantial development would be totally counter to the above Vision.

In addition, substantial development would be contrary to almost all of the Objectives of the Neighbourhood Plan. Each is shown below with our comments against them, following review of the draft Local Plan:

1. To seek protection and enhancement of the countryside setting of the village, by ensuring separation from the urban edge whilst retaining access to the countryside.

Many of the sites identified on the edges of the village in the Development Policy Strategy Paper, if given planning permission, would reduce the green space between the village and neighbouring communities so that the unique character of Wilstead would be subsumed into an apparent large conurbation.

2. Identified green spaces, views and vistas and local wildlife habitats will be maintained and enhanced.
Most of the sites identified within the village in the Development Policy Strategy Paper are the very sites identified as important green spaces in the draft Neighbourhood Plan.

3. To identify, protect and enhance village heritage assets and key public spaces, ensuring that any future development is sympathetic to the existing rural character of the village.

Should there be any major development allowed It would most likely consist of estate-type development which would be out of character with the rural, multi-age, and mixed style of the current range of dwellings.

4. To ensure any future housing responds to local needs, is of a high standard of design, and fits well into the context of the village in terms of type, mix, scale and character.

Our experience with new housing, already permitted under the current Local Plan, has shown that the local community is not given preference for the allocation of housing. Indeed, the Housing Association managing the section of affordable housing within a new development has imported residents from Luton who, in some cases, have found it difficult to adjust to quiet village life.

5. To protect existing assets such as the school, village hall and other community buildings and spaces used for community events and encourage improvements in line with changing needs.
6. To improve the leisure and recreation opportunities for residents of all ages by maintaining and encouraging community activities and the provision of open space and children’s play facilities

Major development in the village would threaten the ability of these facilities and activities to respond to the increased demand. They were established by the village to suit the needs of the current size population.

7. To promote safe public streets and spaces; reduce traffic volumes through more accessible and beneficial sustainable transport links (including pavements, footpaths and cycle routes) and ensure appropriate parking solutions.
Any increase in traffic would overwhelm existing roads which already become very congested at school opening and closing times. Development would therefore be contrary to saved Policy 31 of the Bedford Borough Local Plan 2030.
A recent police survey of Cotton End Road, which is becoming increasingly congested by a combination of parked vehicles and speeding traffic, concluded that the number of vehicles in a week travelling at 35mph (the prosecutable limit) was 24.6% or 4,720 vehicles. It is understood that a large proportion of this traffic originates from outside the village and is an indication of how development outside of the village has in turn adversely affected the resources within the village.
No reference can be found in the Plan that would assist the Parish in this objective. Requests for assistance in improving pavements and introducing cycle routes have gone unheeded and parking on the roads and on pavements is becoming an increasing problem, resulting in single-track access in many locations.
8. To sustain and enhance the range of community and commercial activities and services in the village. Economic activity such as working from home and appropriate small-scale diversification of farm buildings will be encouraged.

We can see little in the Draft Local Plan to help with this objective


Wilstead is a rural community. It is vitally important to keep its rural feel by maintaining a large number of green spaces, strategic gaps between settlements and important views into the surrounding countryside.

Consultation on the Neighbourhood Plan demonstrated the value that local people place on the landscape and rural environment of the Parish. 95% of respondents agreed that the rural feel and access to the countryside are fundamental to the quality of life and community identity for Wilstead.

The village has consisted for centuries of separate “Ends” (e.g., Duck End, Church End, Littleworth). These should remain separate to preserve that heritage.

In addition, the existing, very stretched, “Ribbon Development” of Wilstead would not tolerate further development on its edges without these developing into separate communities in themselves or necessitating car journeys to the centre. We have a settled community and would not wish development to introduce separation. Any development would have to be more central.

Major development in Wilstead would necessitate people travelling by car into other communities, as these resources do not exist locally. Examples include:
 Schooling (insufficient places available locally)
 Shopping (local store cannot supply the range of goods required)
 Health facilities (none locally)
 Onward bus or train travel

There needs to be a distinct gap between Wilstead village and Wixams (to prevent “coalescence”) and between the communities of Wilstead, Elstow and Cotton End so that their historically separate identities are preserved. The potential size of any major development would threaten the very heritage of a village that is described in the Domesday Book.

Over 94% of respondents to the Neighbourhood Plan Questionnaire considered that maintaining a gap between the village and Wixams was ‘essential’ or ‘important’.

The village has consisted for centuries of separate “Ends” (e.g., Duck End, Church End, Littleworth). These should remain separate to preserve that heritage.

SECTION 5: CAPACITY OF EXISTING RESOURCES

The village has already had to accept development of 105 houses as its contribution to the Local Plan 2030. This is an increase of over 10% which has already threatened to overwhelm local facilities – e.g., local school and secondary school at Wixams, both of which are at full capacity.

Development cannot be in the direct path of water draining from the Southern escarpment (Greensand Ridge) or in the lower levels north of the village centre, which are shown on Water Authority documentation as at risk of flooding from drainage ditches.

Object

Representation ID: 8070

Received: 03/09/2021

Respondent: Mr Mike Dixie

I am emailing you about the proposed housing development in Shortstown, which I am against, due to the fact of the size of New Cardington. Years ago ago we were informed that the size of the development would be 800 hundred abodes, then it was 900 abodes if I remember rightly due to decision I believe of Gordon Brown. Then if I'm right, we were told the Builders could not finish one of the hangar repairs unless they could build even more abodes. Now new Cardington is vast and to me a eyesore as driving along Carmichael Drive to me is like driving past a large social housing estate in London. I moved away from London to get away from this sort of thing.

In my opinion the people of Shortstown have been totally mislead by this scar on the environment, It was also stated their was also going to be a Public House, which never materialised. Also a Doctor's Surgery, which took years to appear.

When I first moved to Shortstown the surrounding area was green and pleasant, now it is just becoming a bricks and concrete. I see that more abodes are planned near the hangars, the buildings of now New Cardington have already ruined the look of them. When they build the other houses near them, as I see there are signs showing another 1600 abodes are to built there (probably more if New Cardington is anything to go buy). Then Shortstown will become just bricks and mortar as the greenery and nature will just disappear.

Also the health service will suffer as the Bedford Hospital is to small and in my opinion will not be able to cope, especially with covid being here for possibly forever.

I was also led to believe that the representatives of the liberals believed in the environment, well all this building seems to go against that.It has also taken years for the air to get cleaner after being polluted by the Brick factory now it is being polluted once again by the the equipment and materials required by abodes being built. Do the council believe in saving the local environment, in my opinion the answer is no.

Whilst emailing you, I was wondering if the builders are going to clean Carmichael Drive and the surrounding roads of the stones that are lying against the curbs and the middle of the road. Especially near roundabouts and crossing areas, these stones could be flicked up by vehicles and harm or even kill people as well as damage cars.
these costs should not be borne by the taxpayer.

I would like to mention, that not long after they started building New Cardington when I drove around there all I could here was stones hitting my car. So as I worked at a garage I asked the paint shop to quote me for the repair, they quoted 800 to 900 pounds. Every time I drive around Bedford you here stones hitting a car, people visiting
Bedford must thing why should I get my car damaged by stones. It makes you wonder if it stops people visiting Bedford and in my opinion should embarrass the council.

If anymore building takes place in the area around Bedford, the builders should be held responsible for cleaning all the roads at least 6 to 8 times a day. The builders should agree a stipulation to do this and be fined if they don't. All costs for harm to people mentally or physically and any damage or stone chips to cars should be paid for by the builders, definite not by the taxpayers in anyway. Also the builders large lorries cause more damage to road surfaces and cars, the builders should be made to accept this responsibility, no matter what the cost.

Object

Representation ID: 8075

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

1. Notwithstanding our comments on the overall housing and employment numbers proposed in the plan and the need to add an uplift associated with the Oxford to Cambridge Arc strategy, it is considered that the preferred spatial strategy (Options 2a, b, c, and d) have significant merit subject to the following qualifications.

2. Firstly, the strategy proposes development of 1,500 dwellings within the urban area.

3. Clearly there is merit in re-using urban sites and locating new homes close to key infrastructure, shops and services. However, concern is raised as to the deliverability of the levels of growth proposed.

4. The evidence base so far provided does not clearly demonstrate where the 1,500 homes would be accommodated within the urban area within the proposed plan period.

5. Urban sites are often constrained by existing uses, including commercial operations, car parks, supermarkets, government buildings etc. and / or have complicated ownerships and sitting tenants such that delivery is slow and uncertain.

6. As the Council will be aware a number of urban sites were previously identified as opportunity sites or ‘Areas of Change’ in the Town Centre Area Action Plan and so highlighted for potential development back in 2008. The majority of these have still not come forward some 13 years later.

7. There is also concern regarding the viability of urban sites to come due to higher existing use values but more specifically to come forward whilst delivering a full policy compliant level of affordable housing.

8. Subject to the level of certainty and viability assessment that the Council can place on the Urban Area sites it is submitted that the figure should be reduced to approximately 1,000 rather than 1,500 with the balance (500) being added to the ‘Adjoining the Urban Area’ category where sites are less constrained and very clearly deliverable.

9. Turning to the proposed ‘Adjoining the Urban Area’ category, it is assumed that any sites within Parishes adjoining the urban edge would qualify for consideration.

10. That is, sites for example in Renhold could be allocated as part of the 1,500 figures, it is not simply sites within the southern Parish’s which adjoin the urban area, that is a separate category. If that is a correct interpretation then this approach is supported.

11. All of the Option 2 spatial strategies include reference to the “A421 transport corridor with rail based growth parishes and southern parishes”.

12. The reference to the A421 transport corridor suggests that development close to the A421 would be favoured. This approach obviously has great merit as the A421 provides excellent linkages to the west and east and is also central to the Oxford to Cambridge arc.

13. However, the Transport Corridor options included in the list beneath the title seem to then reference only parishes south of the A421. This appears to ignore for example Renhold and its sustainable location close to a major junction onto the A421 (unless Renhold is considered to fall within the ‘Adjoining the Urban Area’ category as highlighted above).

14. Notwithstanding this it is considered that the corridor strategy should properly consider sites well related to the A421 but not necessarily only the southern parishes.

15. Of all of the Spatial Options the sustainability appraisal considers Option 2a the most sustainable.

16. This excludes new settlements. Whilst new settlements can be important in delivering new infrastructure, they are also prone to delay and uncertainty over delivery rates.

17. It was the proposal for the Colworth new settlement falling away which ultimately resulted in an unsatisfactory local plan to 2030 and a need for early review. Concern would again be raised as to the realistic deliverability of a new settlement option.

Conclusion
18. The Howbury Hall Estate broadly agrees with the Council’s assessment of the differing Spatial Development Strategy Options

19. Notwithstanding this general support, concern is raised in respect of what could be an over-reliance upon uncertain urban sites.

20. Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it whilst exhibiting far fewer viability / deliverability issues and as outline we submit should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

21. Our clients land on the east side of Bedford at Howbury Hall Estate is available and deliverable as set out in the Call for Sites submissions (Site 765) and in further representations now made in respect of the Call for Sites Assessment Proformas.

Object

Representation ID: 8087

Received: 02/09/2021

Respondent: Huntingdonshire District Council

Option 2a - Development in and around the urban area, plus A421 transport corridor with
rail-based growth – south
Huntingdonshire District Council in principle support this option as it would meet the identified
housing and employment needs of the Borough in full. It is also noted that the Draft Sustainability
Appraisal (June 2021) scores option 2a more positively in sustainability terms than options 2b, 2c
and 2d. SA Objective 5 ‘Promote strong, sustained and balanced economic growth, stimulating job
creation across a range of sectors’ and SA Objective 15 ‘Reduce the need to travel and promote
sustainable modes of transport’ were both scored more highly in option 2a than the other preferred
options.
Option 2a would also promote the vitality and viability of Bedford town centre as it concentrates
development in close proximity to the town centre along established transport routes. This option
utilises existing transport infrastructure, in particular the five railway stations located within and to
the south of Bedford which would facilitate public transport use assisting Bedford Borough in
contributing to the UK’s targets on carbon emission reductions. It would also coordinate strategic
growth with a potential/proposed new Bedford station built to the north to accommodate the East-
West rail line. Having development at scale within a contained radius improves opportunities to
incorporate and finance new and enhanced public transport routes to serve new and existing
communities and maximises the use of existing social and community infrastructure.
Option 2b - Development in and around the urban area, plus A421 transport corridor with
rail-based growth – south, plus one new settlement from a choice of either Wyboston (also known
as Dennybrook) or Little Barford
Option 2b causes Huntingdonshire District Council significant concern regarding the risk of
coalescence between St Neots and any growth in its surrounding area (including at Wyboston and
Little Barford) and impact of this growth on residents of St Neots in terms of access to and demand
for services, retail and social and community infrastructure. If a new settlement were located either
at Wyboston (Dennybrook) or Little Barford, landscaping and settlement breaks would be critical to
prevent physical coalescence and retain separate settlement identities. Huntingdonshire District
Council would wish to work very closely with Bedford Borough Council if a development strategy
option including one of these sites is pursued in order to understand potential impacts and if chosen
to ensure appropriate mitigation is put in place prior to any detrimental impacts being experienced
by St Neots’ residents and businesses.
As detailed assessments are yet to be published on the impacts on infrastructure and services in St
Neots and nearby villages arising from either the Wyboston (Dennybrook) or Little Barford new
settlements, Huntingdonshire District Council’s initial concerns relating to each of these sites are provided below. Once detailed assessments are undertaken, Huntingdonshire District Council would
wish to work with Bedford Borough Council to minimise and mitigate any detrimental impacts on St
Neots and nearby villages and to maximise any potential positive outcomes for Huntingdonshire’s
residents.
Option 2c - Development in and around the urban area, plus A421 transport corridor with
rail-based growth, plus two new settlements which would comprise both Wyboston (Dennybrook)
and Little Barford
Development option 2c is not supported by Huntingdonshire District Council as this is too reliant on
new settlements at Wyboston and Little Barford providing a significant amount of the additional
housing and employment growth in close proximity to one another (45% of the 12,500 new homes).
Furthermore, the concern of relying on strategic development to deliver a significant proportion of
housing are exacerbated when viewed in combination with the existing new settlement allocated in
the Bedford Local Plan to 2030 at Wixam for 4,500 new homes south of Bedford.
Moreover, the deliverability of this option is uncertain when considering the lead in times required
to invest and put in place necessary infrastructure. Market absorption is another concern as new
developments in close proximity to one another could slow delivery not just within Bedford but also
in St Neots which may result in fewer new homes being built to keep up with need. Indeed, the
Development Strategy Topic Paper (June 2021) highlights on page 32 the challenge of delivering two
new settlements in such proximity to one another. Huntingdonshire District Council reiterate these
concerns. Additionally, planning for new development alongside the timelines of major transport
infrastructure projects like the A428 and East-West rail are complex with factors that are out of the
control of the Local Authority and developers to consider.
The closest points of both new settlements (Wyboston and Little Barford) are within 1km of St
Neots, a key urban centre within Huntingdonshire so it is likely that they will look to St Neots for
services. No assessment has yet been published on the impacts on infrastructure and services in St
Neots, but it is likely that this scale of growth will lead to pressures on the residents, infrastructure,
town centre, established employment areas of St Neots as well as the townscape and landscape
character of St Neots and nearby villages. It is important to note that the construction of a new
settlement will take many years and potentially decades. It can take time for such a development to
provide enough services, shops, facilities etc in the initial phases to support its growing population
meaning there will likely be increased pressure for St Neots to accommodate these additional needs
during that time. This is a considerable concern if both new settlements are pursued but is also a
concern if one or the other site is brought forward.
Additionally, within the Draft Sustainability Appraisal (June 2021), option 2c scores less positively
than options 2a, 2b and 2d as it does not maximise development on previously developed land and
would lead to the loss of high quality agricultural land at Wyboston (Dennybrook).
Huntingdonshire District Council’s detailed concerns and observations on both potential new
settlements are included below.
Option 2d - Development in and around the urban area, plus A421 transport corridor with
rail-based growth – south and east, plus one new settlement from a choice of either Wyboston (also
known as Dennybrook) or Little Barford
Huntingdonshire District Council do not support development option 2d as there are concerns
regarding the cumulative impact of a new settlement and development within the eastern parishes
along the A421 and their proximity to St Neots and nearby villages in the south of Huntingdonshire
District. It is not clear on the size, quantity and potential locations of development sites along this
corridor but the option states that it would total 750 homes and 28ha of employment land. This
makes assessing their landscape impacts, transport impacts and impacts existing communities along
the A428 more difficult.
The scale of development is also unlikely to provide significant new services and infrastructure
resulting in future residents needing to travel to urban centres at Bedford and St Neots for service
provision. Furthermore, in the Draft Sustainability Appraisal (June 2021) option 2d scored less
positively on SA Objective 5 ‘Promote strong, sustained and balanced economic growth, stimulating
job creation across a range of sectors’ and SA Objective 15 ‘Reduce the need to travel and promote
sustainable modes of transport’. This option is likely to encourage private car use over more
sustainable modes of transport due to limited opportunities to utilise service provision via public
transport options.
Therefore, this option is likely to place extra demands on service provision within St Neots to the
detriment of their accessibility by local residents, particularly in combination with a new settlement
at either Wyboston or Little Barford. It is also likely to have a detrimental impact on the local and
strategic road network in order to access services within Bedford and St Neots. This may result in
additional vehicles on the transport network resulting in delays and congestion and implications on
air quality with a greater impact on climate change.

Support

Representation ID: 8093

Received: 02/09/2021

Respondent: G Morroll

Agent: Phillips Planning Services

Our clients support the proposed growth along the A421 corridor. This accords with the Government’s strategy of delivering a growth corridor between Oxford and Cambridge which includes the building of one million high quality new homes, and over one million new jobs across the corridor by 2050, in order to maximise the areas economic potential.

However, although the four growth options being consulted upon all include the A421 corridor, only Option 2d includes the eastern parishes and fully explores the potential of this corridor and its settlements to accommodate growth. We contend that the eastern parishes should be included in the selected growth strategy otherwise an important part of the Oxford To Cambridge arc, namely the villages around the Black Cat interchange, will be left out. The eastern area of the corridor includes several sustainable settlements including Key Service Centres, all with good links onto the A421 and the A1. Allocations should be made across the entire corridor to ensure its economic potential is maximised.

Our clients therefore raise objection to Growth Options 2a, 2b, and 2c as they have omitted a crucial part of the A421 corridor, and wish to elevate option 2d as the preferred option for growth.

Of the selected growth options, our clients support growth Option 2d which seeks to distribute growth along the entire A421 corridor. This option will contribute towards the Governments strategy of delivering a growth corridor between Oxford and Cambridge. We would also state that the quantum of development identified in option 2d is too low and would not fully utilise sustainable sites available within the eastern parishes including Wyboston.

Object

Representation ID: 8136

Received: 03/09/2021

Respondent: Carmen Hardisty

I am a rural resident in Colmworth- , and have being for the last 30 years.
In these three decades we have being witness to the increase traffic that he present road infrastructure has to endure.
After the improvements to the Black Cat round about, at pic time, drivers still have to wait for 20 minutes or more to access the A1 or the 421-428
The rural lanes, which has access to only one car at the time, are getting more and more dangerous as drivers without experience and knowledge of the proper code to give way or how to overtake tractors is used.
The plans for these new town with an over extensive number of new residents are not upgrading the Infrastructures of the A1 or 421- 428.
My first point to object to the Local plan 2040 is that, the new number of drivers will elevate the Main roads infrastructure to a chaotic situation.
Rural communities have an unspoken code of conduct. During lock down we have an increase number of people from other towns exercising the right of using the countryside.
These have turn into the abuse of the countryside. People walking their dogs in our Country Park or the country lanes have made a mess of it, leaving dog and food waste everywhere.
Dogs let to run free, attaching wild life and farm animals.People leaving the footpaths and wondering in private land, destroying crops.
My second point to object to the Local plan 2040 is that, the new number of town people, with no understanding of the country life will cause irreparable damage to a precarious ecosystem.
My third point to object to the Local plan 2040 is that, this agricultural land is extremely productive, you are taking away prime arable land from food production. I know there is a need for housing but it is short sighted to build in the green belt, when the world is leading to a shortage of food production, also increased with climate change. I am sure there is less productive land available to build on.
My final point, and I could carry on, is that, this consultation has not being democratic and included every house hold affected by these planning proposal. I talk to people in my village who are total unaware of their right to object to these plans, other people who would like to make a point are unable to do so because they do not have computer skills.
The number of responses you are receiving are not a real representation of the feelings in the villages affected.
A house to house consultation by post is needed, in order for the consul to consolidate a democratic right of each resident in the area.

Object

Representation ID: 8381

Received: 03/09/2021

Respondent: Ms Linda Hiscott

Wilstead is in the process of developing a neighbourhood plan, currently there are only just over 1000 houses in the village. Further substantial development would completely alter the character of the community.
It is a rural community and in order to keep the rural feel it is important to maintain the large number of green spaces, and gaps between settlements which facilitate the open views into the surrounding countryside., which includes the Greensand ridge.
Wilstead has already had to accept development of 105 houses as its contribution to the current Local Plan. This is an increase of over 10% which has already threatened to overwhelm local facilities, local school and secondary school at Wixams are at capacity. There is no easy access to local healthcare, unless residents drive. Any increase in traffic would overwhelm existing roads which already become very congested, and speeding is a worry to local residents. The existing very stretched “Ribbon Development” of Wilstead would be lost if further development took place on the edges
There needs to be a distinct gap between the village and Wixams (to prevent “coalescence”) and between the communities of Wilstead, Elstow and Cotton End so that their historically separate identities are preserved. A number of the proposed options would impact on this. Wilstead should remain a village not become a “suburb of Bedford” or an “extension of Wilstead” The village has consisted for centuries of separate “Ends” (e.g. Duck End, Church End, Littleworth). These should remain separate to preserve that heritage. The proposed developments would impact on this.
Wilstead is still listed as a key Service centre, however there is no longer a local doctors’ surgery and only one local shop which incorporates a post office. Public transport is very limited and only covers the main road through the village linking Bedford to Luton. Both Wixams and Wilstead are included in the draft Local Plan as “Key Service Centres”. Nowhere else in the Borough are there 2 Key Service Centres located next to one another
The plan seems to indicate that all development should be to the south of the Borough consideration should be given to an equal distribution across all villages within the borough both North and south as well as the urban area.

Object

Representation ID: 8382

Received: 03/09/2021

Respondent: Ms Alison Field-Foster

I have considered the Development Strategy Topic Paper and reviewed the Bedford Borough Local
Plan 2040 and comment below.
I am pleased to see that the draft plan has been developed with greater strategic vision related to
the wider infrastructure needs of the Borough and am pleased to see proposed largescale
development south of Bedford and along the A421 transport corridor.
I do support the aspiration to be a greener, more accessible and prosperous Borough and also the
use of brown-field sites south of Bedford rather than development on farming land for new housing.,
whilst recognising that some lower grade agricultural land could potentially be developed. I strongly
support options 2b to 2d in the development of the 2040 Plan. It makes perfect sense to take
maximum advantage of the A421 transport corridor with its connection to the Ml, A428 and to the
Al with its easy to other main arterial road networks such as the A14. If the proposed East West Rail
Oxford to Cambridge rail route goes ahead these developments along the A421, A428 and Al, will
give easy access to the new stations proposed south of Bedford and to the Tempsford/St Neots
options. This should avoid further stress on the Bedford town road network in particular the A6 and
Great Ouse Way bringing traffic on to the Sainsbury's roundabout and from there to Bedford station.
I object strongly to any inclusion in the 2040 Plan of the large sites at Twinwoods and Colworth,
which are completely unsustainable because of the already congested and overloaded road network
north of Bedford. The A6 coming from North Bedfordshire into Bedford is already completely
overloaded in the morning peak with traffic queuing 0.5 miles and more from the Sainsbury
Roundabout along Paula Radcliffe Way and also extensively along Great Ouse Way.
I note with concern the proposal to accommodate up to 500 new homes in Shambrook. particularly
considering the existing constraints mentioned above on the A6. I am also concerned that the roads
from Shambrook, passing through Odell and Harrold between the A6 and the A428 have existing
congestion problems, particularly in Harrold where historical road widths and extensive roadside
parking creates single lane passage. Further traffic is likely to be generated from the 2040 plan which
will exacerbate an already unacceptable and challenging situation.
I am also have considerable concerns regarding the proposed new East West rail route from Bedford
to Cambridge with the vast infrastructure constructions that will be needed to be provided to cross
the River Great Ouse valley and the A6. It will also make a major detrimental change to the intrinsic
beauty of the north Bedfordshire countryside, destroying a beautiful part of what remains of our
precious countryside.
I support the development strategy with its proposal for development options 2b to 2d and would
encourage the Borough to select for its large scale development one or both of the two sites at
Wyboston and Little Barford since both of these sites would provide potential for further
development in future local Plans.

Support

Representation ID: 8389

Received: 27/09/2021

Respondent: 1 Grosvenor Holdings Ltd

Agent: WSP

The Draft Plan outlines four options for the future ‘Growth and Spatial Strategy’ and asks:
“What, in the context of the vision and objectives outlined earlier in the document, is the appropriate spatial strategy for the plan?”
Option 2d (development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes and east parishes, plus one new settlement) represents the optimal and most sustainable option for the borough’s growth and spatial strategy.
The Draft Plan outlines that Option 2d will provide between 12,500 and 13,085 dwellings. This is the one only option that provides over the requirement of the standard method and meets the uplift in housing need outlined in the Council’s LHNA. This therefore the option that complies with the requirement of Paragraphs 60 and 61 of the NPPF.
Paragraph 60 of the NPPF outlines the Government’s objective of significantly boosting the supply of homes. This suggests that Council’s should provide above the minimum housing need identified using the standard method and local housing need assessments (per Paragraph 61 of the NPPF), a view that was taken by an Inspector in a recent appeal1 concerning BBC (in April 2021). This reading of the NPPF suggests that it is clear that the upper limits of housing need should be supported and therefore provides justification for the adoption of Option 2d.
The Government’s objective for significantly boosting the supply of homes (Paragraph 60 of the NPPF) notes that in order to ensure that this can be supported, a sufficient amount and variety of land should come forward where it is needed. This is emphasised by Paragraph 69 which outlines the contribution that small and medium sized sites can make to meeting the housing requirement of the area, noting that 10% of housing delivery can be undertaken on these sites.
Paragraph 69 therefore supports the progression of Option 2d to be selected as the preferred option for the growth and special strategy of the draft Local Plan. This is as Option 2d while it provides much needed dwellings in large scale urban extensions and new settlements (which is supported by Paragraph 73 of the NPPF), it accounts for the parishes of Bedford, which are likely to be able to support smaller and medium sized sites with greater ease. Option 2d is therefore supported by both Paragraphs 69 and 73 of the NPPF as it would enable both small and large sites to come forward for development and significantly boost housing delivery.

Support

Representation ID: 8396

Received: 03/09/2021

Respondent: NHS

am writing to provide a response on behalf of Bedfordshire, Luton and Milton Keynes Clinical Commissioning Group (BLMK CCG) in relation to the Council’s consultation on the Local Plan Strategy Options, and to re-confirm our commitment to working in partnership with the Council to jointly plan the necessary infrastructure to help local communities in Bedford Borough thrive.

Council colleagues will recall that the CCG worked closely with Bedford Borough Council to support the development of the Infrastructure Delivery Plan (IDP) for the currently adopted Local Plan to 2030, which sets out the health infrastructure requirements associated with the current housing growth ambitions.

In addition, the CCG worked with the Council to carry out a detailed assessment in 2019 of the future need for primary healthcare services across the Borough, including as a result of projected housing growth. These pieces of work have been incorporated into the CCG’s existing Primary Care Estates Strategy, enclosed for your information.

The CCG/ICS (or successor NHS body as appropriate) would expect to similarly work closely with the Council to fully assess the health infrastructure requirements associated with delivering the additional target of 12,500 additional homes by 2040, over and above the existing Local Plan commitments. In particular, health partners would hope to engage with the Council next year as the revised IDP is developed as a supporting document to the 2040 Local Plan.

It is important to raise that the cumulative effect of housing developments across the Borough, and surrounding Local Authorities, is having a significant impact on demand for community, mental health, Acute Trust and Ambulance Trust services. Whilst the previous infrastructure discussions have primarily related to primary healthcare services, it is important for Planners to note the wider health infrastructure impact and for this to be factored into infrastructure planning. We hope this will enable us to jointly continue to develop ourapproach to securing adequate contributions from developers – to ensure that the new and growing communities proposed can be adequately served by local health services.

Whilst we expect you may receive responses directly from other partner organisations within the Bedfordshire, Luton & Milton Keynes Integrated Care System, this response summarises the impact of the proposed development sites for the healthcare system across Bedford Borough.

We welcome further discussions with the Council around how we collectively can mitigate the cumulative impact of housing developments across the health infrastructure serving Bedford Borough, in a way which complies with the statutory tests in CIL regs 122, i.e.
A planning obligation may only constitute a reason for granting planning permission for the development if the obligation is—
(a)necessary to make the development acceptable in planning terms;
(b)directly related to the development; and
(c)fairly and reasonably related in scale and kind to the development.

Every effort is made to ensure every CCG request for a S106 developer contribution is tailored to each individual development. The methodology has been accepted by all the Local Authorities the CCG works with and at Appeal stage.

Impact of Proposed Strategy Options
All of the proposed options are expected to have a significant impact on community, mental health, Acute Trust and Ambulance Trust services. The full impact will require further detailed assessment next year.

Acute Trust
The cumulative effect of housing developments across the Borough are placing strain on the capacity of Bedford Hospital. As a result, Bedfordshire Hospitals Foundation Trust expects to need to bring forward a number of projects to increase capacity over the next 5-10 years and beyond, related to:

• Increasing the capacity of Urgent and Emergency Care services
• Expanding the number of surgical theatres
• Accommodating growth in demand for outpatient appointments and diagnostics.

We would expect acute contributions to be secured via the larger proposed developments within the new Local Plan to contribute to these key health infrastructure projects.

Ambulance Trust
The East of England Ambulance Service Trust (EEAST) are in the process of developing an evidence-based formula to identify the impact of population growth for housing developments on ambulance services. This will include key projects to enable delivery of their services, such as changes to road infrastructure and developments for nursing and care homes or over 55 developments. The CCG and EEAST would welcome further discussions around how the infrastructure impact of the Borough’s 2040 Local Plan can be collectively addressed.

Primary Care
A significant transformation programme is underway across primary care in Bedfordshire, Luton and Milton Keynes (BLMK) in line with national strategy; for primary care at scale, improved patient access to services, workforce expansion to enable a wider and effective skill-mix for integrated multi-disciplinary working and delivery of personalised and proactive care to reduce referrals into hospitals to support the delivery of the NHS long term plan.

This means that the preferred Commissioning Strategy for Bedford Borough (as part of the Bedfordshire, Luton and Milton Keynes system)for areas of significant housing growth has changed over the last 5-10 years. It is generally less viable as an operating model to commission a new primary care provider in addition to the existing primary care providers who within their Primary Care Networks (PCNs) are able to collectively employ a wider skill-mix of clinicians to enable the multi-disciplinary working and personalised and proactive care as described above. Estates solutions need to support the development of integrated teams of GPs and other clinical professionals, community health and social care staff and with other community-based services that can positively impact on health and wellbeing (e.g. via social prescribing and voluntary sector).

Therefore, requests for contributions from developers need to be seen in the context of primary care operating at scale in an integrated manner with other health and social care partners. Providing appropriate infrastructure for new and/or growing communities will often require the relocation of an existing provider from their current premises, or extensions/reconfigurations of existing premises, as opposed to the establishment of new GP practices.

This means that to address the impact of the proposed developments in the Local Plan Strategy Options consultation on health services, some schemes may require land allocations but for others a capital contribution will be more appropriate. It is worth noting that given the complexity of the NHS capital regime, land allocations without capital contributions are not of great value to the health service. Generally, some form of capital contribution will always be required to ensure the deliverability of the proposed infrastructure mitigation.

Community and Mental Health Services
As set out above, community and mental health services are being increasingly organised around Primary Care Networks (PCNs – groupings of GP practices working in collaboration). Estates solutions will increasingly be designed around this way of working. We would expect the capacity impact of the proposed housing growth in the next iteration of the Borough’s Local Plan to be partly mitigated through relocation of existing services into multi-purpose Hub facilities also serving primary care, providing the additional capacity required.
In addition, local community and mental health providers have a number of critical infrastructure projects planned to support the growing demand for their services. These include a proposed new mental health inpatient unit in Bedford, and the relocation of the county’s wheelchair service to Bedford Borough.
The CCG will expect to work with the Council to seek contributions from developers to support these important infrastructure projects in a way that it is reasonable and proportionate to the size of each development.

Assessment of Strategy Options
This section provides further assessment of the impact of each of the proposed options on primary healthcare services across the Borough, and the likely mitigations to be considered as part of the Infrastructure Delivery Plan next year.
(see tables in attachment)
e hope that this information provides a useful indication of the expected impact on health services of the proposed Strategy Options set out in the Local Plan 2040 consultation document. We look forward to working with the Council throughout the development of the Local Plan and associated Infrastructure Delivery Plan.

Support

Representation ID: 8400

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

For the new local plan to meet the tests of soundness at examination it will be extremely
important for the growth strategy to be both deliverable and flexible without an
overreliance on strategic scale allocations such as new settlements. It is worth noting that
the St Albans Local Plan was withdrawn in November 2020 following a number of serious
concerns raised by the Inspectors which included an overreliance on a small number of
large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller
scale subareas. The Inspectors noted that a range of sites, including smaller and medium
sites, can provide benefits, in that they can be delivered more quickly without requiring
additional infrastructure, provide choice and flexibility in the housing market , and secure
affordable housing more immediately. They also referred to paragraph 68 (now paragraph
69) of the NPPF which indicates that small and medium-sized sites can make an important
contribution to meeting the housing requirement of an area and are often built out relatively
quickly.

The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local
Plan were similar. In that particular case, the Inspector considered it was highly ambitious
to rely on three new Garden communities (Easton Park, North Uttlesford and West of
Braintree) and not include a wider range of small and medium sized sites as advocated
by paragraph 68 of the NPPF.

Accordingly, it is considered the correct strategy for the emerging Local Plan 2020 – 2040
will be to avoid any short term reliance on strategic scale developments such as the new
settlements at either Wyboston or Little Barford and instead to include a significant and
extensive range of small and medium-size sites.

Paragraph 6.8 of the Strategy Options and Draft Policies consultation document indicates
that the new plan should provide three new business park sites, each of about 30 ha with
the remaining 63 ha of employment land allocated in smaller sites. However, it is noted
that potential employment sites are still being assessed. The employment sites will then
be identified to align with the preferred growth strategy. Again this suggests that a more
flexible strategy with a wider choice of potential site allocations should be followed.

The four growth strategy options are listed as follows:
Option 2a: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes.
Option 2b: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and southern parishes, plus one new settlement.
Option 2c: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes and, plus two new settlements.
Option 2d: Development in and around the urban area, plus A421 transport corridor
with rail based growth parishes, southern parishes and eastern parishes, plus one new
settlement.

It is noted that all four options will deliver the same amount of dwellings within the urban
area and adjoining the urban area (3,000 dwellings) along with 51 ha employment land.
It is assumed that the employment land provision will predominantly be made up of
existing commitments and therefore the sites for new business parks will need to be found
elsewhere. It is also noted that all four options include up to 80 ha of employment land
within the transport corridor, rail based growth. It is therefore considered that the extent
of employment land should be increased to 90 ha to allow for the identification of three
new business park sites of 30 ha each.

It is also noted that all four options aim to deliver a similar total number of dwellings, 12,500
or 13,085 if a new settlement at Little Barford is included. It is however considered that a
blended option should be the preferred choice, which is more aspirational, with the
potential to deliver a higher number of dwellings along with the maximum amount of
employment land to better reflect the national growth aspirations for the Arc.

In respect of the growth options, clearly the opportunities for accommodating any
significant further growth within the urban areas of Bedford and Kempston are limited,
having already been extended up to their boundaries with the A428. However, the urban
areas remain the focus for employment and retail activity and transport connectivity within
the Borough. It therefore seems logical and sustainable to identify opportunities for future
growth in close proximity to the urban areas, not only in the rail based transport corridor
around the five stations and A421, but also in the southern parishes where sites can be
identified close enough to the urban areas to allow active travel modes and the use of
public transport to be a realistic alternative.

The inclusion of Kempston Rural Parish as one of the transport related southern parishes
is therefore strongly supported and the site, the subject of this representation, is one such
location. The land at Gibraltar Corner is located only 600 m (0.3 miles) walk from
Kempston (at its nearest point). The road from Gibraltar Corner to Kempston has a
pavement on both sides and a dedicated cycle and pedestrian route exists under the A428
which provides very safe, quick and easy access to the Lidl supermarket and Kempston
High Street. The key service centre of Wootton is only 2 km to the south of the site and a
pavement exists along the full length of the road between the site and the cent re. Wootton
provides an alternative range of services and facilities.

Bus stops are located approximately 330 m to the south of the site and regular buses are
provided to Bedford, Wootton, Kempston, Bromham, Cranfield and Milton Keynes (Buses
53, 53A, A2 and C1). This also means there is convenient access to Bedford train station
(Buses 53 and C1) connecting Bedford to London and the wider south-east region. The
site is also located conveniently for connections to the wider highway network with easy
access to the A421 and A428.

Allowing growth in the southern rural parishes not only represents a sustainable location
for housing delivery close to the Borough’s main source of employment within the Bedford
urban area, but will also allow new homes to be provided in a high quality environment,
where future occupiers will also have opportunities to access the countryside for leisure
purposes, improving their health and well-being. Furthermore, development in these well
located parishes is less reliant on upgrades to infrastructure and will be deliverable early on in the plan period. It is therefore considered vital that the selected growth options
include the opportunity for growth in the southern parishes and especially Kempston
Rural.

Of the settlements within the Kempston Rural Parish, Gibraltar Corner benefits from being
located the closest to Kempston and therefore is a logical settlement within the Parish to
allocate for new growth.

In respect of the specific options we comment as follows:
Option 2a: Strongly Support – this option delivers the greatest range of sites
including small and medium-size sites, which will ensure that housing delivery, and
importantly affordable housing delivery can be maintained. However, it is considered
that the employment allocation should be increased to a minimum of 90 ha in the
transport corridor. This is also in line with the findings of the Development Topic Paper,
which concluded that the sustainability appraisal found option 2a to perform best out of
the four options as it concentrates most growth at the rail based locations at Stewartby
/ Kempston Hardwick, which means a high probability that public transport and cycling
will be an attractive alternative to the private car.
Option 2b: Support – this option delivers a range of sites including small and mediumsize
sites, which will help housing delivery, however the inclusion of a new settlement
presents a risk to delivery given the lead time associated with such development. The
housing numbers in the two transport corridors should therefore be increased to those
in option 2a. Accordingly, this is considered to be a more suitable option if the local
plan period is extended. It is also considered that the employment allocation should
be increased to a minimum of 90 ha in the transport corridor.
Option 2c: Strongly Object – this is the least flexible of all options and includes an
overreliance on new settlements. Furthermore, both settlements are in close proximity
to each other, and as such delivery is likely to be further delayed as a result of
competition in the local housing market. If this option were to be pursued it is
considered that the new plan would fail at examination for the reasons set out above,
having regard to the recent St Albans and Uttlesford Local Plan examples.
Option 2d: Neutral would support with appropriate modification – This option
delivers a range of sites including small and medium-size sites which will help housing
delivery, however the inclusion of a new settlement presents a risk to delivery given
the lead time associated with such development. The housing numbers in the two
transport corridors should therefore be increased to those in option 2a. Accordingly,
this is considered to be a more suitable option if the local plan period is extended. It
does however, provide sufficient employment land and a greater choice of locations for
new business parks.

Accordingly, we would recommend that the new local plan pursues a blended option
based on a mix of Options 2a and 2d as set out below, with a focus for approximately
2000 dwellings within the Southern Parishes. This will provide a sufficient range of sites
across the entire plan period without an overreliance on a new settlement being completed
by 2040. Such an option is more likely to be considered in line with Paragraph 22 of the NPPF, which requires plans to contain strategic policies which should look ahead over a
minimum 15 year period from adoption and, where larger scale developments such as
new settlements are proposed, policies are required to set out a vision that looks further
ahead at least 30 years to take into account the likely delivery timescales.
Proposed Option: Development in and around the urban area, plus A421
transport corridor with rail based growth parishes, southern parishes and east
parishes, plus one new settlement.
 Within the urban area (1,500 dwellings).
 Adjoining the urban area (1,500 dwellings), up to 51 ha employment.
 Transport corridor – rail based growth: land within the parishes of Kempston
Hardwick, Stewartby and Wixams (low option) (7,500 dwellings), up to 90 ha
employment.
 Transport corridor – south: land within the parishes of Cotton End, Elstow,
Kempston Rural, Shortstown, Wilstead and Wootton (2000 dwellings).
 Transport corridor – east: land within the parishes of Cardington, Cople, Great
Barford, Little Barford, Roxton, Willington and Wyboston (750 dwellings), up to 30
ha employment.
 New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings),
up to 20 ha employment.
 Total between 15,750 and 16,335 dwellings, up to 191 ha employment.

Support

Representation ID: 8409

Received: 03/09/2021

Respondent: Fisher German LLP

In respect of the proposed growth strategy options, at this stage we consider the distribution of housing should be displayed as a percentage, that way it can more quickly respond to changes in housing requirement for example, whilst maintaining the spatial distribution of housing.

In respect of the proposed options, we consider it almost inevitable that the spatially optimal solution is likely to be a hybrid of a number of the referenced options. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, deliver higher growth on key transport corridors, particularly the A421, but retains an apportionment of growth to be disbursed to the rural area. The issue with the other options is that they place too significant an emphasis on delivery on limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further emphasis on a more limited pool of settlements. Dispersed growth as well as assisting delivery, encouraging a wider range of housebuilders into the market delivering concurrently, also has the benefit of supporting rural communities remain vibrant and ensuring a healthy demographic composition, preventing issues such as village ageing.

Dispersed growth (or Village related as it is referred in the consultation material) in our opinion should form part of every spatial option, albeit the level to be delivered could of course differ option to option. We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established at this point the significant harm such an approach has caused in recent years nationally, as reflected in matters such as declining public transport routes, closure of village pubs, closure of shops and the general decline in vitality of village life generally where development has been withheld. Whilst the current plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result in a 10-year period with no proposed growth which would be unacceptable and as such some provision must be provided to ensure sufficient provision is made over the extended Plan period.

A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles, which by the end of the Plan Period are likely to be highly prevalent, with new petrol and diesel car sales ending in 2030. Post lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.

Whilst we do not object to the principal of identification of a new settlement as a facet of future delivery, we would urge caution be applied if the Council are to rely heavily on delivery arising from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. Our preferred approach in this scenario is to positively allocate such sites above and beyond the sites needed to meet housing needs. If work is underway and delivery has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which should provide the confidence needed to the market to commit to the works and evidence necessary to obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn’t come forward at all. We would not object if Strategic Sites were used to facilitate an increase in housing requirement, to provide delivery later in the Plan period. This should not be delivered through a stepped trajectory, with sufficient land needing to be allocated to deliver Local Housing Need in full through the Plan period.

The above approach is potentially beneficial in that it means the Council can retain an element of control, meaning they can ensure the new settlement/s comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery. If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence and appropriate planning consents, then the Council can begin to rely on delivery to meet base Local Housing Need. Given the likely lead in times, it is considered unlikely any development will be forthcoming until the latter end of the Plan period. As such if a higher housing requirement is assessed as being necessary, additional smaller sites will need to be identified in the early years of the Plan. This approach however could provide supply in the long term and an important avenue for future delivery, particularly towards 2050.

Object

Representation ID: 8515

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

The section of the representations provides observations on the soundness of the Council’s overall approach towards preparation of the Local Plan 2040 and identification of the strategic priorities it is required to address. Comments specifically relate to Chapter 3 of the consultation document.
Notwithstanding these comments, the next section (Section 5) of these representations deals with our client’s in-principle support for those components of the Preferred Options that include growth within the ‘east’ transport corridor parishes and principally Great Barford.
Issues relating to the ability of the Council’s approach to maintain a rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped trajectory) are dealt with separately in Section 6.
Paragraphs 3.10 and Preferred Options 2a-2d: Component of Rail-Based Growth ‘Pink’ Growth Strategy Options) – Object
The opportunity for transformative change resulting from the delivery of East-West Rail within Bedford Borough is not disputed. However, 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 (ID: 68-019-20190722).
While these sections of the PPG post-date the NPPF2012 it is the case that the Council has historically failed entirely in setting out realistic timeframes for the development of complex sites. These shortcomings have particularly affected Town Centre sites in the past, which the Council will now unsuccessfully rely upon to sustain completions against the housing requirement in the Local Plan 2030. We argued at the previous Local Plan Examination that such sites should be identified as developable no earlier than the 11-15 year period.
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.
Reasoning
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.
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 summarised 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)”
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.
The extent of this uncertainty is summarised 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.”
The consultation referred to recently closed in June 2021 and final decisions on the ‘Concept’ for stations on the Marston Vale line are awaited. For the avoidance of doubt, the expected timeframes set out in the most recent Consultation Document indicate that a Development Consent Order may be obtained by 2024 and construction on the rail works may commence in 2025. However, this does not provide a clear timetable for the delivery of individual projects and upgrades. Stage 05 (‘Construction’) is summarised as follows:
“Once we’ve complied with any initial conditions or requirements included in the Development Consent Order, the government will consider the full business case for the Project to make the final decision to proceed. Following further conversations with the public and stakeholders, can start to construct your new railway.”
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.
The Council has previously acknowledged that longer lead-in timeframes must be allowed for as part of redevelopment of the Stewartby Brickworks (Policy 25) development plan allocation as it exists in the LP2030. The Local Plan trajectory anticipates delivery of only (at most) 100 units in 2029/30 before the end of the current plan period. The scheme is in effect accepted as an 11-15 year developable site.
Application proposals under reference 18/03022/EIA (validated November 2018) benefit from an Officer recommendation to grant planning permission subject to S106 agreement. In practice, this does not alter any conclusions regarding the deliverability/developability of the site and likely timescales. Discussions surrounding the draft S106 obligation would be anticipated to be extensive. This is reflective of the constraints of the site and gaps in the evidence base for the LP2030, notably:
 Around 19ha of the site falls within Flood Risk Zone 2. Furthermore, a small proportion (around 1ha) is located within Flood Risk Zone 3a/3b.
 A requirement to confirm costs and timescales for the requisite link from the new development across the railway could be achieved (notwithstanding ongoing deliberations regarding East-West Rail). whilst Network Rail is identified as a key stakeholder for preparation of the Council’s Infrastructure Delivery Plan (December 2018) no project associated with the rail crossing is identified, costed, or phased over the course of the plan period.
 The Council’s Local Plan Viability Assessment (BNP Paribas, November 2017 (paragraph 6.16)) notes the requirement for significant investigations to assess on-site constraints for this complex site, with a view to preparation of a development brief, all prior to detailed viability work taking place.
It is our experience from monitoring the delivery of the nearby Wellingborough East Urban Extension that the construction of crossings over rail lines can take significant periods of time and are unpredictable.
The Officer Report in relation to the current position on securing a policy-compliant (and CIL122-compliant) package of contributions towards the site’s ability to enhance use of rail-based transport states:
“Policy 25 iv. Sets out a need for enhancements to the existing railway station environment including accessibility, provision of facilities and security. If the railway station stays in its current location the increased permeability of the site will improve connections from the village to the station. The Railway Station however does not fall within the application site and is under review as part of the wider East West Rail scheme, details of which are not confirmed at this time.”
Given this uncertainty we would anticipate it is highly likely that a S106 obligation may not be entered into until these uncertainties are resolved or that otherwise it would be expected that this would be subject to future Deeds of Variation or revisions to the scheme resulting in delays to the delivery of housing.
The Council’s Preferred Options also identify a contribution of around 2,000-3,000 further units to be allocated at Wixams, to correspond with eventual delivery of a further new station as part of the wider scheme. These units will be additional to the remaining capacity identified in the Bedford Local Plan 2030 trajectory and units to be delivered as part of committed development in Central Bedfordshire’s Local Plan (which already includes a Southern Extension to the scheme).
The longstanding issues with delivery of the Wixams New Station are illustrative of the impacts upon rates of development likely to be experienced at Stewartby/Kempston Hardwick. Evidence presented at LP2030 Examination demonstrated that the build-out rate of Wixams within Bedford Borough has been 96 dwellings per annum over the 10-year period to 2018. Development has since commenced in Central Bedfordshire, increasing the overall build-rate but corresponding with a reduction of activity in Bedford Borough.
Delivery of the Station has been delayed by over 11 years with the project still not expected to commence construction until 2023 at the earliest. Commissioning of a detailed design scheme for the proposed station was able to progress earlier in 2021 contingent on the basis of consultation on the proposed northern alignment of East-West Rail.
While any final decision is awaited on the outcome of the Bedford-Cambridge phase of East-West Rail there remains a risk that the time-limited period for funding available from the lead developers of the Wixams scheme will expire and result in the project not being delivered (or requiring additional monies to address the shortfall in project costs).
In the context of the above delays and uncertainty and in the absence of a clear timeframe for delivery of the station the Council’s Preferred Options present no site-specific evidence of how the additional capacity at Wixams could be achieved over the plan period and at an appropriate build-out rate (in addition to the delivery of extant commitments).
The characteristics of any potential increase in allocations at Wixams also represents an issue of cross-boundary strategic importance, given that the scheme is being delivered across local planning authority boundaries and the requirement for partial review of the Central Bedfordshire Local Plan 2015 to 2035. This could lead to any potential for additional development being required to address the unmet needs of neighbouring authorities (or affecting the administrative boundaries within which the most appropriate land should be identified).
Remedy
These representations demonstrate that the rail-based growth component of the Council’s Preferred Strategy Options requires substantial further refinement and site-specific testing. This is likely to substantiate a significant reduction in assumptions regarding the potential for development within the plan period, which can be effectively mitigated through pursuing a ‘hybrid’ strategy for development in sustainable locations across the borough.

Object

Representation ID: 8572

Received: 03/09/2021

Respondent: Mr Nick Chapman

Agent: Barton Willmore

The general strategy running through all four development options is noted in terms of the need to distribute growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements.

Urban Centre and Edge
A total of 3,000 homes are proposed within and adjoining Bedford Town Centre with 1,500 homes
specifically targeted in the urban area alone. Pursuing this level of growth will require careful selection of sites to protect the town’s character and avoid excessive densities and heights. To achieve this the Council will need to consider not only making best use of previously developed land but identifying sustainable, undeveloped sites within or adjoining the urban area that can integrate well with existing communities. Such sites will also need to be supported by new community facilities and services to meet the demands of new residents and ensure existing infrastructure is not overburden.
Such a proposal has been put forward by Bedfordia Property in the previous Call for Sites (Site 884) consultation and includes development of a community centre with accompanying residential development to help cross fund the centre. Land opportunity within Kempston for community uses is limited and demand for such facilities is expected to grow with an increasing population. Allocating mixed use development on this Site would follow the NPPF (paragraph 92) objective of planning positively for the provision and use of shared spaces, community facilities and other local services to enhance the sustainability of communities and residential environments taking into account local strategies to improve health, social and cultural well-being for all sections of the community.
The submitted site at Cemetery Road, Kempston provides a suitable location for this complementary provision, along with supporting residential development, which should not be held back by artificial constraints, such as the historic Urban Open Space policy. This is not to say that the aims and objectives of such designations should be ignored, especially where there is scope to accommodate some open space within the site, which can be enhanced, along with the retention of key views, enhancement of biodiversity and protection of designated heritage assets. We believe the submitted site at Kempston has scope to achieve these objectives whilst making an important contribution to the urban growth agenda set out in the draft Local Plan.

Support

Representation ID: 8580

Received: 03/09/2021

Respondent: Mr - Barber

option 2C no development

Object

Representation ID: 8582

Received: 03/09/2021

Respondent: Mr Brian Thompson

• We object to the proposal for Denybrook. We like the ruralness of Colmworth and the surrounding areas and we don’t want being spoilt by the development of 10,500 houses.
• The amount of agricultural land that will be lost due to this development is sacrilege. We can’t believe that people’s livelihoods won’t be affected by this and puts even more pressure on not buying locally.
• The infrastructure required for a development such as this will cause complete upheaval to the surrounding areas; including noise, pollution, road closures and the loss of yet more land.
• We don’t feel that St Neots or Bedford are able to cope with the significantly increased volume of traffic. This will also put enormous strain on the Black Cat roundabout, which is already a notoriously bad bottleneck.
• This will also see the loss of vast areas of natural habitat for our wildlife. As this development will be ripping right through the rural land, this will completely devastate woodland, trees and bushes.

Object

Representation ID: 8710

Received: 28/09/2021

Respondent: Hollins Strategic Land

Agent: Emery Planning

4.2 Our first concern is that none of the four options deliver LHN+10% (15,060 dwellings). The Table in
7.14 of the draft SA shows that whilst two (Options 3a and 6) come closer to meeting that
requirement by delivering 14,480 dwellings it is still not meeting LHN+10%.
4.3 Our second concern is that new settlements form part of the strategy in 3 of the 4 options.
However, paragraph 2.6 of the Development Strategy Topic Paper states:
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“The results are reported in full in the Issues & Options Consultation - summary
and responses document and the key point was that the (brown) urban,
(yellow) A421 and (pink) rail-based growth development locations were the
most strongly supported and were twice as likely to be selected as suitable
locations for growth as dispersed and new settlement based growth.
4.4 Therefore, the results of the Issues and Options showed that the options for new settlements and
dispersed growth were most unpopular. Despite this, they formed part of 9 of the 13 options in
the draft SA, and 3 of 4 preferred options in the consultation paper. We question the merit in
undertaking consultation at the Issues and Options when at this early stage in LP2040 no
meaningful account has been given to the public responses.
4.5 The third is that paragraph 3.11 recognises that urban growth comes with deliverability issues and
significant investment and the level of development in each of the 4 options for the urban area
are a constant. In that context paragraph 3.6 is clear where it states that:
“the urban area and adjoining urban area perform the best, particularly
because of reducing carbon emissions and reducing travel”.
4.6 Therefore, development in and adjacent to urban areas performs best, yet paragraph 3.7 states:
“The worst performing component was the village related growth component.
It was likely to have a more negative effect than the other components,
particularly in relation to reducing carbon dioxide emissions, protecting water
resources, and reducing the need to travel and promoting sustainable modes
of travel. It was likely to have fewer positive effects than any of the other
components of growth.”
4.7 This conclusion must be read in the context that the Development Strategy Topic Paper which
has a Village Related Growth Option were all based on over 4,000 new homes ranging from 29%
to 47% of the total requirement. We do not advocate such a dispersal strategy but clearly
recommend that there should be growth at Key Service Villages and Rural Service Centres.
4.8 Therefore the options should have assessed a lower total percentage of the total requirement for
the Village Related Growth Option and also distinguished between Key Service Centres and
smaller villages, particularly for Wootton which lies close to Bedford town and close to Milton
Keynes. Whilst other villages may be more remote with fewer facilities, more realistic options/s for
growth at Key Service Centres and Rural Service Centres should have been considered.
4.9 The fourth is that we note that of the 4 preferred options; 3 of which include growth in certain
parishes. These are Options 2a (2,000 dwellings), 2b (1,500 dwellings), 2d (750 dwellings). We note
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that these options state within the parish area rather than within or adjacent to parish settlement.
Paragraph 3.12 states that “development in parishes within the ‘Transport corridor”…. “will not
necessarily adjoin existing villages but could be at new locations between a
parish”. Development on the edge of existing settlements, and closer to services, are important
factors and we consider that the Plan needs to clarify development within a Parish should be
located adjacent to settlement boundaries of existing settlements as that is the most sustainable
option.
4.10 This would also meet the aims and objectives in the Framework, for example;
• Para 16: “Plans should: a) be prepared with the objective of contributing to the
achievement of sustainable development”;
• Para 79: “To promote sustainable development in rural areas, housing should be
located where it will enhance or maintain the vitality of rural communities. Planning
policies should identify opportunities for villages to grow and thrive, especially where
this will support local services. Where there are groups of smaller settlements,
development in one village may support services in a village nearby”. (our emphasis)
4.11 The fifth concern is that the LHN Assessment has been published but there has been no
assessment of housing market areas and commuting patterns to help inform strategy and
location of growth. Generally, Bedford borough has a strong geographical association with
Milton Keynes to the south-west and Central Bedfordshire to the south. This was recognised in the
SHMA (2018) where Bedford is within the Milton Keynes HMA and a commuting association with
Central Bedfordshire. This context should inform the location for new growth in a sustainable
way. Instead, the preferred options appear to focus growth with new settlements in the northeast
of the borough which the SHMA (2018) suggested was closer/within the Huntingdon HMA. We
are concerned that this approach may exacerbate unsustainable travel patterns particularly
where housing growth in more remote parts of the borough may force residents to take longer
journeys into Bedford town for jobs. Higher-order settlements closer to Bedford town should be
prioritised for housing growth in preference to more remote areas.
4.12 The sixth is that it is Intended that if the favoured strategy involves additional development in and
around villages, that parish councils will be asked to allocate land in accordance with
LP2040. This is for non-strategic scale sites but if this is carried forward into LP2040, then each Parish
should be given a housing requirement as required by paragraph 66 of the Framework which
states:
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“66. Strategic policy-making authorities should establish a housing requirement
figure for their whole area, which shows the extent to which their identified
housing need (and any needs that cannot be met within neighbouring areas)
can be met over the plan period. Within this overall requirement, strategic
policies should also set out a housing requirement for designated
neighbourhood areas which reflects the overall strategy for the pattern and
scale of development and any relevant allocations. Once the strategic policies
have been adopted, these figures should not need retesting at the
neighbourhood plan examination, unless there has been a significant change
in circumstances that affects the requirement.” (our emphasis)
4.13 In light of the above we answer paragraph 3.17 which asks:
“If you think that there are other strategies we should be considering, please let
us know. These may be ones set out in the Development Strategy Topic Paper
or completely different alternatives.”
4.14 We consider there are reasonable alternatives that should be considered. They are:
(1) greater growth in larger villages including Key Service Villages alongside urban
growth and transport corridor growth.
(2) an expansion of Option 6, with more growth in Key Service Villages, and to include
urban growth.
4.15 Both these options should distinguish between larger more sustainable villages (KSCs and RSCs)
and smaller ones. In the evidence base there is the Settlement Hierarchy Paper dated September
2018 although we note that there is a “review underway” and is one of the documents “not yet
available for comment, but will be finalised in order to support the plan for submission (2022)”. It
is important that this is the subject of consultation prior to the Submission Plan being published so
that any issues are considered prior to the spatial strategy evolving and reducing any potential
objections to a key part of LP2040.
4.16 Our specific interest is Wootton which is one of the 8 Key Service Centres. Policy 4S of the LP2030
sets out the aim to deliver 970 dwellings per annum across the borough, with a minimum of 3,169
dwellings to be distributed across the various settlements. Part iv states that a minimum of 2,000
dwellings should be located at Key Service Centres of which Wootton is one. The policy then
continues when it states:
“it will be necessary to identify sites to meet the following levels of development,
generally in and around defined Settlement Policy Area boundaries. Other than
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in Roxton, all sites will be allocated in Neighbourhood Development Plans. In
rural service centres allocations may exceed 50 dwellings where specific local
justification is set out in Neighbourhood Plans demonstrating that it would be
appropriate in terms of the scale, structure, form and character of the
settlement and the capacity of local infrastructure”
4.17 Criteria xi to xvi then set out a specific housing requirement for each settlement. However, there
is no specific requirement proposed for Wootton. This was explained in the 2017 version of the
LP2030 because Wootton had expanded in recent years. This should not be seen as further
development at Wootton not being appropriate; rather it confirms its suitability and capacity as
a location for growth. We consider that going forward Wootton should be identified as a location
for growth and given a specific requirement. This should be at least 500 dwellings as set out in
Options 3b, 3c, 4, 5 and 6. That should not mean that all other Key Service Centres are also
required to deliver 500 dwellings as they are already required to deliver 500 dwellings in LP2030
and form part of the committed 13,000 dwellings. These settlements could get less or as was the
case at Wootton zero in LP2030 as LP2040 progresses. What is clear is that Wootton should have
a specific requirement of at least 500 dwellings especially due to its sustainability credentials and
its close relationship to Bedford town.
4.18 Indeed paragraph 2.8 of the committee report of Application 19/00894/MAO (land west of
Wootton Upper School) the LPA states:
“2.8 Despite the lack of allocation for Wootton, this does not mean that
development should not occur.”
4.19 In that context, Policy W2 of the emerging Wootton Neighbourhood Plan states:
“Provision will be made over the plan period for up to 105 homes as proposed
within site specific policies W3 to W6. Development in excess of this figure will
only be permitted where the proposal relates to a site within the SPA in
accordance with Policy W1.”
4.20 That plan is to 2030, yet is not meeting the full need as explained in paragraph 60 of the Wootton
Neighbourhood Plan which states:
“Public consultation was carried out in June/July 2018 on the proposed scale
of development in the WNDP, with 73% of respondents strongly
agreeing/agreeing with the allocation of sites sufficient to accommodate a
total of 145 residential units within the plan period, on the basis of need
ascertained by the Housing Needs Survey. This survey aimed to assess the need
of local people for either affordable housing or market housing in Wootton, at
the time when it was envisaged that the Bedford Borough Local Plan would
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cover the period to 2035. The quantum of development has been marginally
reduced in response to further resident feedback and to reflect the reduced
Local Plan period to 2030.”
4.21 Therefore, the housing need from the evidence base is 145 dwellings. It should be noted that the
105 homes proposed in Policy W2 is seeking to address existing and potential housing needs of
the existing residents of Wootton and it takes no account of the newly forming households and
the increase in households in the plan period across Bedford that the standard method
calculates. This is a particularly important point as the LP2040 consultation confirms that capacity
within Bedford town for housing is limited and the Plan will rely on growth outside of this to meet
needs of which Wootton can play an important role. However, it demonstrates a continuing
need for new housing in Wootton which LP2040 should plan to meet.
4.22 To conclude, there should be changes to the Spatial Options and we propose:
• A greater level of housing to be planned for of LHN+20%;
• Greater recognition of the housing market areas and extensions to existing established
settlements with closer relationships to Bedford town should be prioritised;
• Clarity that extensions to Key Service Centres and other sustainable villages form part
of the strategy. This may be a refinement of the transport corridor criteria or a specific
requirement as set out in part iv and v of Policy 4S of LP2030; and,
• Each neighbourhood plan area to have a requirement set out. For Wootton we
consider at least 500 dwellings.

Object

Representation ID: 8717

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

4.1 The section of the representations provides observations on the soundness of the Council’s overall approach towards preparation of the Local Plan 2040 and identification of the strategic priorities it is required to address. Comments specifically relate to Chapter 3 of the consultation document.

4.2 Notwithstanding these comments, the next section (Section 5) of these representations deals with our client’s in-principle support for those components of the Preferred Options that include growth within the ‘east’ transport corridor parishes and principally Great Barford.

4.3 Issues relating to the ability of the Council’s approach to maintain a rolling five year supply of deliverable sites (including as part of its proposed use of a ‘stepped trajectory) are dealt with separately in Section 6.

Paragraphs 3.10 and Preferred Options 2a-2d: Component of Rail-Based Growth ‘Pink’ Growth Strategy Options)–Object
4.4 The opportunity for transformative change resulting from the delivery of East-West Rail within Bedford Borough is not disputed. However, 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 (ID: 68-019-20190722).

4.5 While these sections of the PPG post-date the NPPF2012 it is the case that the Council has historically failed entirely in setting out realistic timeframes for the development of complex sites. These shortcomings have particularly affected Town Centre sites in the past, which the Council will now unsuccessfully rely upon to sustain completions against the housing requirement in the Local Plan 2030. We argued at the previous Local Plan Examination that such sites should be identified as developable no earlier than the 11-15 year period.


4.6 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.

Reasoning
4.7 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.

4.8 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 summarised 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)”

4.9 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.

4.10 The extent of this uncertainty is summarised 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.”

4.11 The consultation referred to recently closed in June 2021 and final decisions on the ‘Concept’ for stations on the Marston Vale line are awaited. For the avoidance of doubt, the expected timeframes set out in the most recent Consultation Document indicate that a Development Consent Order may be obtained by 2024 and construction on the rail works may commence in 2025. However, this does not provide a clear timetable for the delivery of individual projects and upgrades. Stage 05 (‘Construction’) is summarised as follows:

“Once we’ve complied with any initial conditions or requirements included in the Development Consent Order, the government will consider the full business case for the Project to make the final decision to proceed. Following further conversations with the public and stakeholders, can start to construct your new railway.”

4.12 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.

4.13 The Council has previously acknowledged that longer lead-in timeframes must be allowed for as part of redevelopment of the Stewartby Brickworks (Policy 25) development plan allocation as it exists in the LP2030. The Local Plan trajectory anticipates delivery of only (at most) 100 units in 2029/30 before the end of the current plan period. The scheme is in effect accepted as an 11-15 year developable site.

4.14 Application proposals under reference 18/03022/EIA (validated November 2018) benefit from an Officer recommendation to grant planning permission subject to S106 agreement. In practice, this does not alter any conclusions regarding the deliverability/developability of the site and likely timescales. Discussions surrounding the draft S106 obligation would be anticipated to be extensive. This is reflective of the constraints of the site and gaps in the


evidence base for the LP2030, notably:

□ Around 19ha of the site falls within Flood Risk Zone 2. Furthermore, a small proportion (around 1ha) is located within Flood Risk Zone 3a/3b.
□ A requirement to confirm costs and timescales for the requisite link from the new development across the railway could be achieved (notwithstanding ongoing deliberations regarding East-West Rail). whilst Network Rail is identified as a key stakeholder for preparation of the Council’s Infrastructure Delivery Plan (December 2018) no project associated with the rail crossing is identified, costed, or phased over the course of the plan period.
□ The Council’s Local Plan Viability Assessment (BNP Paribas, November 2017 (paragraph 6.16)) notes the requirement for significant investigations to assess on- site constraints for this complex site, with a view to preparation of a development brief, all prior to detailed viability work taking place.

4.15 It is our experience from monitoring the delivery of the nearby Wellingborough East Urban Extension that the construction of crossings over rail lines can take significant periods of time and are unpredictable.

4.16 The Officer Report in relation to the current position on securing a policy-compliant (and CIL122-compliant) package of contributions towards the site’s ability to enhance use of rail- based transport states:

“Policy 25 iv. Sets out a need for enhancements to the existing railway station environment including accessibility, provision of facilities and security. If the railway station stays in its current location the increased permeability of the site will improve connections from the village to the station. The Railway Station however does not fall within the application site and is under review as part of the wider East West Rail scheme, details of which are not confirmed at this time.”

4.17 Given this uncertainty we would anticipate it is highly likely that a S106 obligation may not be entered into until these uncertainties are resolved or that otherwise it would be expected that this would be subject to future Deeds of Variation or revisions to the scheme resulting in delays to the delivery of housing.

4.18 The Council’s Preferred Options also identify a contribution of around 2,000-3,000 further units to be allocated at Wixams, to correspond with eventual delivery of a further new station as part of the wider scheme. These units will be additional to the remaining capacity identified in the Bedford Local Plan 2030 trajectory and units to be delivered as part of committed development in Central Bedfordshire’s Local Plan (which already includes a Southern Extension to the scheme).


4.19 The longstanding issues with delivery of the Wixams New Station are illustrative of the impacts upon rates of development likely to be experienced at Stewartby/Kempston Hardwick. Evidence presented at LP2030 Examination demonstrated that the build-out rate of Wixams within Bedford Borough has been 96 dwellings per annum over the 10-year period to 2018. Development has since commenced in Central Bedfordshire, increasing the overall build-rate but corresponding with a reduction of activity in Bedford Borough.

4.20 Delivery of the Station has been delayed by over 11 years with the project still not expected to commence construction until 2023 at the earliest. Commissioning of a detailed design scheme for the proposed station was able to progress earlier in 2021 contingent on the basis of consultation on the proposed northern alignment of East-West Rail.

4.21 While any final decision is awaited on the outcome of the Bedford-Cambridge phase of East- West Rail there remains a risk that the time-limited period for funding available from the lead developers of the Wixams scheme will expire and result in the project not being delivered (or requiring additional monies to address the shortfall in project costs).

4.22 In the context of the above delays and uncertainty and in the absence of a clear timeframe for delivery of the station the Council’s Preferred Options present no site-specific evidence of how the additional capacity at Wixams could be achieved over the plan period and at an appropriate build-out rate (in addition to the delivery of extant commitments).

4.23 The characteristics of any potential increase in allocations at Wixams also represents an issue of cross-boundary strategic importance, given that the scheme is being delivered across local planning authority boundaries and the requirement for partial review of the Central Bedfordshire Local Plan 2015 to 2035. This could lead to any potential for additional development being required to address the unmet needs of neighbouring authorities (or affecting the administrative boundaries within which the most appropriate land should be identified).

Remedy
4.24 These representations demonstrate that the rail-based growth component of the Council’s Preferred Strategy Options requires substantial further refinement and site-specific testing. This is likely to substantiate a significant reduction in assumptions regarding the potential for development within the plan period, which can be effectively mitigated through pursuing a


‘hybrid’ strategy for development in sustainable locations across the borough.