3.10

Object

Representation ID: 8875

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.10 and Preferred Options 2a-2d: Component of Rail-Based Growth ‘Pink’ Growth Strategy Options) – Object
2.9 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).
2.10 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.
2.11 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
2.12 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.
2.13 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)”
2.14 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.
2.15 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.”
2.16 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.”
2.17 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.
2.18 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.
2.19 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.
2.20 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.
2.21 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.”
2.22 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.
2.23 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).
2.24 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.
2.25 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.
2.26 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).
2.27 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).
2.28 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
2.29 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.

Support

Representation ID: 8969

Received: 03/09/2021

Respondent: East West Railway Company Limited

Agent: Mrs JANE PARKER

EWR Co welcomes the four emerging, proposed growth strategy options (2a, 2b, 2c and 2d) identified in
the consultation draft Bedford Local Plan 2040. These growth options are focused on the existing urban
areas and the A421 corridor and are proposed to be aligned with the possible new railway stations
proposed by EWR Co at the non-statutory round of public consultation earlier this year.
The emerging growth strategy options will assist and support EWR Co to meet the Department for
Transport’s Strategic Objectives for East West Rail which are as follows:
• Improve east-west public transport connectivity by providing rail links between key urban areas
(current and anticipated) in the Oxford-Cambridge Arc.
• Stimulate economic growth, housing, and employment through the provision of new, reliable, and
attractive inter-urban passenger train services in the Arc.
• Meet initial forecast passenger demand.
• Consider and plan for future passenger demand, making provision where it is affordable.
• Contribute to improved journey times and inter-regional passenger connectivity by connecting with
north-south routes and routes beyond Oxford and Cambridge.
• Maintain current capacity for rail freight and make appropriate provision for anticipated future growth.
• Provide a sustainable and value for money transport solution to support economic growth in the area.
In respect of the emerging strategy growth options, EWR Co comments as follows:
Growth around Stewartby and Kempston Hardwick
EWR Co supports the growth around Kempston Hardwick and Stewartby as part of growth options 2a, 2b,
2c, and/or 2d.
EWR Co is currently considering two service concepts for the way services will be configured along the
Marston Vale Line once EWR trains are operating. These are to retain and modify the existing ‘all-stations’
train service and introduce limited-stop EWR services (concept 1); or focused services on a smaller
number of consolidated stations to allow an increased number of stopping services (concept 2).
Concept 1 would retain the existing service (in a modified form) and introduce limited-stop Oxford –
Cambridge services. The existing hourly stopping service would continue to serve all Marston Vale Line
stations, with a new limited-stop EWR service calling at two stations – Woburn Sands and Ridgmont – four
times an hour. No changes are currently proposed to the location of the existing Stewartby and Kempston
Hardwick stations in this Concept.
Concept 2 would provide improved services focused on a consolidated number of stations. Stewartby
station would be relocated to a site in the vicinity of the current Broadmead Road level crossing and would
provide access to the railway for the users of the current Stewartby and Kempston Hardwick stations. The
precise location of the new station has not been determined yet but will include associated infrastructure
such as car parks and access roads.
The new station would be well placed to provide access to the railway from both the existing and new
residential areas at Wootton, the West side of Bedford, and the former Stewartby Brickworks site, and
thereby taking pressure off the road network linking these areas to Bedford station. This presents an
opportunity for a partnership with Bedford Borough Council and developers to ensure integrated transport
plans that encourage active travel and reduce traffic are incorporated.
Given the current position, EWR Co would like to be satisfied that any proposed land allocations coming
forward in the Local Plan do not preclude the proposed location under Concept 2 for the relocated
Stewartby station should this concept be selected. It therefore welcomes ongoing discussions with the
Council and advises that the emerging local plan strategy options, policies and proposals retain sufficient
flexibility to ensure that the final preferred strategy growth option aligns with the EWR options that are
ultimately preferred.
Strategic Growth in Bedford Urban Area
EWR Co is supportive of all strategy growth options that propose development in and around Bedford
Urban area. However, the addition of the proposed residential development would result in additional traffic
which would be best served by some upgrades to the east-west and north-south road connectivity near
Bedford station. Easing traffic and improving active travel connectivity into Central Bedford and Bedford
station would complement EWR Co’s aspirations in Central Bedford for first mile / last mile provisions.
EWR Co aspires to enable sustainable transport through new and improved pedestrian and cycle links as
part of its proposals, and therefore supports Bedford Borough Council's provision of new housing in the
locality, welcoming the opportunity to work together on a joined-up approach.
Bedford Station Proposals
Having regard to EWR Co’s preferred solution for the upgrade of the railway and improvements to the
existing Bedford station to the north of Ford End Road, it is recommended that Policy S10 in the existing
Local Plan be reviewed through the local plan review process and be strengthened to facilitate and support
improved pedestrian and cycling linkages in the vicinity of Bedford Station.
An alternative solution for a new station south of Ford End Road is also being considered. Policy 12 of the
existing Local Plan may need to be reviewed should this concept be selected.
Further detail on these proposals was presented as part of the Non-Statutory Consultation and can be
found in the Consultation Technical Report at section 8.4.
Relocation of Bedford St Johns Station
Option 1 proposes a new station a short distance to the West of the existing station site. Option 2 proposes
a new station to the South of the existing station. Both options are shown on Figure 1. Further detail on
these proposals was presented as part of the Non-Statutory Consultation and can be found in the
Consultation Technical Report at section 8.3.
New policy in the emerging Local Plan 2040 will be required to support the delivery of Option 1 if it is
selected. This new policy would need to focus future development in the area to the north-east of the
proposed rail alignment which would continue to support the Council’s aspirations to secure improvements
to the wider public realm and improved pedestrian and cycling connections to the town centre. Policy 14
of the adopted local plan proposes that land to the south of the river is developed for residential uses and
a mix of retail, business and community uses to support a new neighbourhood.
Option 2 is less advantageous in supporting development in the emerging local plan. However, should the
relocation of St John’s station to the south of the existing station emerge as EWR Co’s preferred option,
then land for the relocated St Johns station will need to be safeguarded in a new and/or amended local
plan policy and on the revised proposal map.
EWR Co therefore recommends that Bedford Borough Council includes a policy supporting EWR Co’s
proposals to enhance the rail network in Bedford in the emerging Local Plan, in particular proposals for
improvements to Bedford station to increase network capacity and to improve the design and quality of
facilities. The local plan’s proposals should retain sufficient flexibility at this early stage to allow for EWR
Co emerging proposals. In due course a policy will be required to safeguard land for the provision of a
relocated Bedford St Johns station in the Local Plan 2040. The policy requirement should require that any
development coming forward within the safeguarded area does not prejudice the delivery and
implementation of EWR Co’s proposals.

Object

Representation ID: 8982

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for growth were within the existing urban area, the A421 corridor and rail-based locations. The Sustainability Appraisal identified that urban growth and urban edge growth are the most sustainable approach to new development. This position is supported by Hampton Brook.

However, a substantial number of the sites that have been submitted to the Local Authority for consideration as potential development sites are being promoted as residential housing sites as opposed to employment land.

Additionally, it is noted in Chapter 3 of the consultation document that the Council wish to utilise both larger and smaller sites for use as employment sites. This indicates that opportunities outside those large sites in the A421 corridor will need to be identified moving forward. The Manton Lane site promoted by Hampton Brook, within an existing industrial site, is prime example of the type of site the Local Planning Authority should be looking to allocate to complement the inevitable strategic allocations.

The four Growth Options put forward by the Council all intend to deliver up to 51 hectares of employment on the edge of Bedford. Development on the edge of Bedford is constrained to the north/north-east as a result of issues such as landscape, topography, flood plain and potential coalescence with smaller settlements. There is also a pressure to deliver residential development within and on the edge of Bedford also and many of the available sites will be more suited to this use. This pressure reinforces the essential need to fully assess all available opportunities in the urban area and a finer grain assessment of site availability needs to be undertaken to inform the development strategy.

For example, Hampton Brook’s site in Manton Industrial Estate was historically used for playing fields, however, as noted above, the site is now the only opportunity available to increase the employment provision on this existing employment area due to the recent appeal decision to grant planning permission for a school on surrounding land. Given its surrounding context, the land is an ideal site for employment use with limited environmental constraints. There are options for mitigating the loss of the playing fields and indeed the current playing fields are not publicly accessible.

Object

Representation ID: 9004

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

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 railbased
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 onsite
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 railbased
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.

Support

Representation ID: 9028

Received: 03/09/2021

Respondent: Mr and Mrs Trevor and Susan Stewart

Future development of Bedford should be to the south and west of the town. The northern boundary has already been extended a number of times.
Any development in Renhold especially Ravensden Road, Hookhams Lane and Top End would increase existing traffic problems on already narrow roads.
Absence of any community or public service provision in the village.
Absence of road width on footpaths in many parts of the village.