3.15

Object

Representation ID: 8023

Received: 24/09/2021

Respondent: Mr Larry Gooch

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8128

Received: 03/09/2021

Respondent: Dr Emma Thompson

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8167

Received: 03/09/2021

Respondent: Mr Ross Thomson

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8206

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8265

Received: 03/09/2021

Respondent: Mr Daniel Francis

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8309

Received: 03/09/2021

Respondent: Miss Erin Francis

IStaploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation

Object

Representation ID: 8351

Received: 03/09/2021

Respondent: Mrs K Francis

Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,500 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8394

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The emerging preferred options put forward by the Council continue to have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the Borough.
2.26 Representations addressing our client’s interest elsewhere in the Borough endorse a ‘hybrid’ approach making provision for village-related development outside of the ‘east’ and ‘south’ corridor parishes. Reassessment of Option 3c provides an appropriate starting point for such an approach.
2.27 Within this strategy option the Council has applied arbitrary ‘one size fits all’ totals to Key Service Centres and Rural Service Centres but made no provision for a contribution towards the strategy totals from locations outside these settlements.
2.28 This is inconsistent with the approach to other strategy components where a more flexible approach is applied e.g., non-specific estimates of urban capacity. Utilisation of other appropriate sites would add flexibility to the strategy and reduce any of the harmful effects that the Council associates with testing non-specific levels of village-related growth. This includes incorporating defined settlements such as Felmersham within the testing of site options.

Object

Representation ID: 8438

Received: 27/09/2021

Respondent: Mrs G Hunt

Agent: DLP Planning Limited

The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north, which is where the preferred east-west rail link will go. Therefore, the proposed strategy does not provide for growth to the north of the town along the preferred east-west rail link.
The proposed strategy should include a more dispersed approach to growth to include the northern parishes of Bromham and Stagsden to ensure that the vitality and viability of the villages across the Borough are maintained. To neglect growth at smaller northern parishes is not appropriate, particularly where this can be provided sustainably. As such, a wider variety of suitable sites across the district should be identified for development in the new plan.
It is noted that at this stage there are significant gaps in the Council’s evidence base, particularly in terms of infrastructure delivery, viability, and development timescales.

Object

Representation ID: 8455

Received: 03/09/2021

Respondent: Mr Theodore Cassell

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8552

Received: 03/09/2021

Respondent: Mrs Claire francis

Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8624

Received: 13/09/2021

Respondent: Mr Henry Zwetsloot

in the Development Strategy Topic Paper) are below.
Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8645

Received: 28/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.21 The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the Borough.
2.22 Representations addressing our client’s interests elsewhere in the Borough endorse a ‘hybrid’ approach making provision for village-related development outside of the ‘east’ and ‘south’ corridor parishes. Reassessment of Option 3c provides an appropriate starting point for such an approach.
2.23 Within this strategy option the Council has applied arbitrary ‘one size fits all’ totals to Key Service Centres and Rural Service Centres but made no provision for a contribution towards the strategy totals from locations outside these settlements.
2.24 This is inconsistent with the approach to other strategy components where a more flexible approach is applied e.g., non-specific estimates of urban capacity. Utilisation of other appropriate sites would add flexibility to the strategy and reduce any of the harmful effects that the Council associates with testing non-specific levels of village-related growth. This includes incorporating defined settlements such as Souldrop within the testing of site options.

Object

Representation ID: 8657

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

3.45 Whilst our client’s first preference would be for a more dispersed approach to growth across the borough to ensure that sustainable development occurs in all settlements (i.e. Grey option in 2020 Issues and Options consultation), of the spatial strategy options the Council has indicated as ‘preferred’ the most appropriate in our client’s case is 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.)
3.46 However we cannot support this option as it erroneously omits Renhold/Salph End Parish as on of the ‘eastern parishes’. There is no clear evidence to support which Parishes have been selected as either ‘southern’, ‘eastern’ or ‘rail-based’ parishes. If parishes are to be identified in this way, there should be a clear and justified rationale for inclusion/exclusion.
3.47 The Parish of Renhold/Salph End should be included within Option 2d) as it offers a sustainable location for growth that is both edge of Bedford Urban Area and within easy reach of the A421. This is evident from the Council’s own Settlement Hierarchy Study (September 2018) which confirmed that when combined as Renhold incl. Salph, Green and Church End Parish, it scores as the 11th most sustainable settlement in the Borough (Table 2, Iteration 2) equal with Stewartby Parish (a parish taking a significant amount of growth). In the assessment Renhold incl. Salph, Green and Church End Parish scores higher than the settlements of Kempston Rural (=22nd), Cardington (=24th), Cople (21st), Little Barford (=62nd), Roxton (=18th), Willington (14th), Wyboston (20th) and Wixams (17th), yet falls to be categorised as a ‘Group 3’ settlement in the hierarchy, whereas many of those listed above fall into Group 2. This is a clear inconsistency and must be readdressed in the update to the Setttlement Hiearchy Study the Council is intending to undertake.
3.48 The evidence shows that Renhold incl Salph End is a sustainable location for growth. Given its proximity to both the Bedford Urban Area and A421 it should be identified within Option 2d).

Object

Representation ID: 8691

Received: 13/09/2021

Respondent: Mr J Francis

in the Development Strategy Topic Paper) are below.
Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,500 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8740

Received: 29/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

2.28 The emerging preferred options put forward by the Council continue to have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the borough.

2.29 Representations addressing our client’s interest elsewhere in the Borough endorse a ‘hybrid’ approach making provision for village-related development outside of the ‘east’ and ‘south’ corridor parishes. Reassessment of Option 3c provides an appropriate starting point for such an approach. Within this strategy option the Council has applied arbitrary ‘one size fits all’ totals to Key Service Centres and Rural Service Centres

2.30 A number of KSC’s and RSC’s have sites which have been identified as potentially suitable through the Councils Call for Sites (Summer 2020) and have been assessed as such by the Council through Local Plan Site Assessments. Milton Ernest is one of those RSCs which is in the process of producing a Neighbourhood Plan and was apportioned a housing target through the Local Plan 2030. The MENP is currently at examination stage with the Examiners


report recently being published which has recommended the Plan proceed to referendum subject to modifications.

2.31 Milton Ernest was identified in the Local Plan 2030 Policy 4S as a centre suitable for the delivery of between 25 to 50 dwellings. Local Plan 2030 Policy 4S also states that “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”.

2.32 The Neighbourhood Plan currently includes one housing allocation Policy ME H1: Rushden Road comprising our client’s interests. The land has been promoted through various Local Plan and Neighbourhood Plan consultations.

2.33 Policy ME H1 was originally published stating the proposed delivery of a “maximum of 25 dwellings”. However, this point has been addressed through the Examiner’s suggested modifications in that it is advised that maximum be replaced by minimum to reflect policy and potential future housing need.

2.34 Our client intends to bring the scheme forward for residential development within the amended Settlement Policy Area (SPA) as set out in the MENP policy ME H1. This does not preclude the Borough Council, within its assessment of site options, considering the potential for additional growth within the wider site area outside of the Neighbourhood Plan’s proposed amendments to the SPA boundary, at this sustainable location. Similarly, the Neighbourhood Plan Examiner’s Report does not preclude a sensitive extension of the site area outside of the proposed SPA boundary amendment in order to provide for additional built or non-built uses (e.g., open space) associated with residential development upon the site.

2.35 Given the above, we would ask that Bedford Borough Council, reconsiders their proposed development strategy to test a ‘hybrid’ approach including ‘village-related’ development outside of the ‘east’ and ‘south’ corridor parishes. This could readily be achieved through allocating an additional amount of development to those northern parishes previously considered suitable for additional housing development, thus addressing the substantial risks to non-delivery associated with the Council’s Preferred Options and helping to sustain and enhance the role of the most sustainable settlements in the hierarchy.

Object

Representation ID: 8783

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8819

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8874

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Comment
2.2 The identification of growth in the ‘south’ corridor as part of the Council’s Preferred Options 2a, 2b and 2d is welcomed in principle. This is considered to form an important component of any appropriate strategy option albeit this will require recognition of the benefits of ‘village-related’ growth across the settlement hierarchy.
2.3 The identification of Kempston Rural parish within this corridor is also welcomed. This is considered to reflect the excellent links between the development pattern within the parish (particularly at Green End) and services and facilities within the urban area. Where the Council identifies figures of 2,000 and 1,500 respectively for ‘south’ corridor parishes in Options 2a and 2b without specifying any settlement-specific or site-specific distribution it is assumed that this recognises the capacity to sustainably support growth at Green End.
2.4 Reservations are expressed, however, in terms of the Council’s treatment of Kempston Rural for the purposes of apportioning village-related growth, where the parish is excluded from the relevant total of 4,280 units as a result of not comprising a designated Rural Service Centre. Further reservation is expressed in terms of the distribution of growth in the Council’s Preferred Options where this refers only to dwellings and not the approach required to deliver the housing needs of different groups, including specialist housing for older people.
2.5 The Council’s own evidence base identifies a substantial need for housing for older people, including a net demand for over 1,500 units of Extra Care accommodations (owned and rented) over the Plan period. However, the Council’s Sustainability Framework (Appendix 1 of the draft Sustainability Appraisal findings) indicates that the positive effects associated with meeting particular housing needs will only be weighed when testing site-specific development options.
2.6 The implication of this is that the Council intends to reject altogether strategy options providing for ‘village-related’ growth outside of the ‘east’ and ‘south’ corridor parishes and may opt for lower levels of development in the ‘south’ corridor prior to assessing all site
specific reasonable alternatives.
2.7 Our client’s land at Green End, Kempston, is a good illustration of why a flexible approach to testing needs to be adopted and why the parish has correctly been identified as an area with overall potential for development. At this stage the Council’s evidence has no regard to whether its Preferred Strategy options - heavily reliant on large-scale strategic growth with potential constraints to land availability, viability, and development timescales – would be capable of meeting specialist housing needs for older people over the Plan period.
2.8 In contrast, our client’s land at Green End (in-keeping with other opportunities in the rural area) satisfies the key characteristics of sites suitable to provide for retirement village schemes in terms of its scale, location, and accessibility. The benefits of the potential to provide specialist housing for older people in this location should remain subject to further assessment (alongside general needs housing) due to the ability to contribute towards overall development needs. This is irrespective of the strategy options selected by the Council to meet the minimum need for new residential allocations. Recognition of this underpins our clients broader argument that meeting the requirements for preparation of the Local Plan 2040 must rely upon a flexible, ‘hybrid’ approach.

Object

Representation ID: 8894

Received: 30/09/2021

Respondent: Mr Peter Mills

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8906

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.26 The emerging preferred options put forward by the Council continue to have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the Borough.
2.27 Representations addressing our client’s interests elsewhere in the Borough endorse a ‘hybrid’ approach making provision for village-related development outside of the ‘east’ and ‘south’ corridor parishes. Reassessment of Option 3c provides an appropriate starting point for such an approach.
2.28 Within this strategy option the Council has applied arbitrary ‘one size fits all’ totals to Key Service Centres and Rural Service Centres but made no provision for a contribution towards the strategy totals from locations outside these settlements e.g., on previously developed rural sites.
2.29 This is inconsistent with the approach to other strategy components where a more flexible approach is applied e.g., non-specific estimates of urban capacity. Utilisation of other appropriate sites would add flexibility to the strategy and reduce any of the harmful effects that the Council associates with testing non-specific levels of village-related growth.

Object

Representation ID: 8910

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.12 The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the Borough.
2.13 Recreation and leisure growth are focused on either historic strategies or within the Council’s urban centres, including Bedford Town.
2.14 In setting out options within the Council’s Development Strategy Topic Paper the Council makes no allowance for the potential delivery of green infrastructure and benefits for tourism, recreation and leisure associated with each proposed approach. This means that the potential positive effects for village-related growth north of the Borough have not been assessed in site-specific or settlement-specific detail prior to rejecting this as component of the strategy. This is compounded by failing to assess other opportunities for tourism and recreation outside of the Council’s preferred strategic locations.
2.15 Embracing these opportunities is necessary to ensure that the selected strategy option is consistent with national policy to support a prosperous rural economy. Specifically, Paragraph 84(c) of the NPPF2021 notes that policies and decisions should enable sustainable rural tourism and leisure developments which respect the character of the countryside. Paragraph 85 of the Framework recognises that sites suitable to meet these needs will not necessarily be within or adjacent existing settlements but warrant support where improvements to non-car access ca be secured and severe impacts on the highway network can be avoided.
2.16 The Site Land off Moor End Lane, Radwell (Radwell Lakes) is unique in the Borough and represents an optimal location to provide a bespoke leisure and recreation venue. The
development of this facility would support healthier communities, complement the leisure infrastructure available to current and future residents.
Remedy
2.17 Therefore, as part of a ‘hybrid’ approach recommended by our clients as an appropriate strategy it is necessary to reassess levels of development within the northern KSC and RSC, where there is both demand for development and also the available sites to aid in the delivery of housing post 2030. These strategy options should also aim to support rural tourism and rural leisure opportunities. The Site Land off Moor End Lane, Radwell is an exceptional asset in the countryside. It offers an optimal location to provide a bespoke outdoor sports, leisure and recreation facilities potentially linked with innovative visitor accommodation. Currently, there are certain projects referred to in the Local Plan, but these only cover a small number of parcels mainly south of the Borough.
2.18 This has important implications for the assessment of effects in the Council’s draft Sustainability Appraisal. For example, the ‘uncertain’ findings for rejected Option 3c incorporating village-related growth for Objective 7 (encourage physical activity) and Option 13 (community facilities) should be amended in recognition of the potential benefits and opportunities to be considered as part of site selection. Such an approach would also allow the identification of suitable opportunities for biodiversity enhancement and mitigation to overcome potential negative effects that the Council identifies as part of more dispersed approaches.

Object

Representation ID: 8949

Received: 01/10/2021

Respondent: Mr James Browning

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8952

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

3.38 Whilst paragraph 1.47 refers to acknowledging the role of NDPs in meeting a small element of current housing needs it is unclear at that point the future role of such settlements where planning by NDP appears to be default approach. Turning to the Spatial Strategy Options, none appears to allow for further rural development whether secured by reviews of NDPs or otherwise. As such the LP2040 strategy appears to focus all of the development around the urban area of Bedford, the A421 and the A1 transport corridors, leaving the northern and western areas of the Borough relatively untouched.
Reasoning
3.39 Where the intention is that the LP2040 rolls forward the Local Plan (and for the reasons set out above, needs to be significantly more ambition if it is not intended that it should fail) then it is essential that positive planning should occur in the rural parts of the Borough. That is both for their own sustainability and also as a means of ensuring deliverability of new homes particularly in the earlier years of the Plan – see 3.6 above.
3.40 Accordingly, none of the options proposed are adequate to address either the delivery needs
of the Borough or indeed its actual spatial housing requirement. Despite the lack of northern development in the Borough through the preferred options, the Rural Service Centres (RSC) such as Turvey, are capable of delivering development within the plan period up to 2040, with emerging Neighbourhood Plans and suitable sites being identified in the Call for Sites event that Bedford Borough Council undertook in the Summer of 2020
3.41 For the reasons set out in the following part of these representations, land opportunities exist at Turvey which can make a material contribution to supply, without being exceptional and which can help deliver a sustainable mix of development not reliant on deferring growth on large strategic sites.
3.42 In all cases however it is noted that the Council’s work remains at this time at a relatively early stage with significant ‘gaps’ in the evidence presented – particularly in terms of development timescales, infrastructure delivery and viability. Notably:
• Infrastructure Delivery Plan – to be prepared alongside site allocations
• Settlement Hierarchy (September 2018) – review underway
• Plan-wide Viability Assessment – yet to be commissioned.
Remedy
3.43 It is therefore our expectation that any future draft of the LP2040 will properly address the role of the designated rural settlements reflective of the role which they can and should play in delivering the spatial objectives as well as supporting the overall delivery of growth for the extended plan period.