3.16

Object

Representation ID: 5202

Received: 03/09/2021

Respondent: Mrs Julie Sellers

I strongly object to the development of a new settlement at Colworth (and, to a lesser degree at Twinwoods, for the same reason).

The most direct route from Colworth/Sharnbrook to Milton Keynes is through the Great Ouse valley riverside villages. Convenient A-roads don't exist for this purpose. Your Forecast (Traffic) Flow Charts show this but no mitigation measures are offered other than access to the A6.

Traversing Harrold High Street is a case of navigating one bottleneck after another. The anticipated substantial increase in traffic will exacerbate the existing pollution caused by vehicles queueing for access with their engines idling.

Support

Representation ID: 5309

Received: 03/09/2021

Respondent: Mr Jetinder Dhaliwal

I prefer option 2a for most of the reasons outlined in the supporting documents, the main one being the least negative impact on the environment. Unfortunately, air quality will suffer (especially during building periods), but it must be considered that the Covanta plant will negatively impact air quality well before the housing development begins. Weather analysis has shown that prevailing winds from the plant are towards Bedford and the old Brickworks had a similar impact. EWR will also not help. Building and running these projects will not be good for peoples health.

Object

Representation ID: 5374

Received: 03/09/2021

Respondent: Ms Jackie Brand

If there is a new East-West Train station (EWTS), I favour option 2c because:-
Development will happen organically around EWTS, its better to plan for development.
To maximise opportunities of EWTS building houses nearby: train travel is good for environment, to ease road traffic congestion, to provide return on investment for EW train.
Two new settlements near the new railway will maximise above benefits and provide economies of scale in terms of planning public services to support these new communities.
It would keep development to a minimum in the parishes, to protect their character and less traffic in the parishes.

Object

Representation ID: 5378

Received: 03/09/2021

Respondent: Catherine Bayliss

Development within the area should be restricted to urban areas, existing transport corridors & new settlements. Villages should be avoided unless suitable additional facilities can be provided so that village communities are maintained. Consideration must be given to potential for homeworking post Covid.

Object

Representation ID: 5417

Received: 03/09/2021

Respondent: Mr Steven Roper

Despite the comprehensive nature of this very long consultation document it is difficult to determine which areas are affected by "around the urban areas". I would object to further urban sprawl and coalescence into Renhold village which would further detract from the settled character and open countryside. Therefore, my preference would be minded towards 2c and with an objection to 2d.

Support

Representation ID: 5444

Received: 03/09/2021

Respondent: Mr Derek Armitage

Supportive of Option 2a and focus on urban and rail based growth.
Supportive of Option 2b and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.
Supportive of Option 2c and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams etc. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.

Object

Representation ID: 5447

Received: 03/09/2021

Respondent: Mr Derek Armitage

Strongly object to Option 2d as the proposed transport corridor (east) is unsustainable and will place irreparable strain and harm upon the A603 corridor. Furthermore, there is no clear requirement for the additional 28ha of employment land delivered by Option 2d due to the increase in home working and the already significant proposed employment provision with Option 2a - 2c.
Focus should remain with urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End and on new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.

Object

Representation ID: 5456

Received: 03/09/2021

Respondent: L&Q Estates Limited

Agent: Pegasus Group

The Sustainability Appraisal Framework should include quantifiable assessment questions in order for the SA to be able to assess the plan equally and fairly.

The transport SA objective assessment questions do not adequately reflect the objective particularly as they include whether sites are able to connect with the highway network which is at odds with trying to reduce the need to travel. Accessibility should also be quantifiable in order to assess sites equally and fairly. The site assessment questions should include consideration of a site's proximity to a nearby rail stations as it forms a part of the development strategy.

Support

Representation ID: 5558

Received: 06/09/2021

Respondent: Mr Robert Bellew

I am commenting on the short-listed four variations of spatial strategy option 2.

Option 2d

Option 2d refers to the transport corridor - east: land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington & Wyboston (750 dwellings) and up to 28 ha of employment land. The previous 2030 plan allocated 500 houses to Great Barford and 50 to Willington despite the existing traffic congestion and limited facilities in both villages. The emphasis on rural growth in option 2d rather than the planned expansion of urban areas runs contrary to the Bedford Borough Council’s own Sustainability Appraisal finding that urban growth was best for reducing emissions, providing for needs and access to facilities, reducing the need to travel and promoting sustainable travel. The worst performing … was the village related growth component. Adoption of Option 2d would result in a scale of development which is unsustainable with resulting pressure on the roads, on village facilities, on the landscape and on village identities.

Option 2a provides for high option rail based growth which would be both sustainable and contribute to the decarbonisation of Bedford Borough Council. Modern infrastructure already exists at Wixams to support an increased number of dwellings.

Option 2b provides for a lower level rail based growth within the parishes of Kempston Hardwick, Stewartby & Wixams. The proposed new settlements at either Little Barford or Wyboston would make best use of the new East-West rail station to support sustainable economic growth and employment opportunity within the Oxford-Cambridge Arc. Modern infrastructure would be provided within the proposed new settlements for the benefit of the communities living there.

Option 2c does not make best use of the housing, employment and sustainable transport opportunities within the parishes of Kempston Hardwick, Stewartby and Wixams.

Adoption of either option 2a or 2b would best support Bedford Borough Council’s policies of:
i) Delivering well planned, sustainable growth supported by appropriate infrastructure – schools, health facilities, community halls, green spaces and other services
ii) Creating strong, safe & resilient local communities
iii) Encouraging a change in travel behavior by focusing development on rail based growth within the A421 transport corridor
iv) Moving towards making Bedford Borough Council carbon neutral
v) Promoting economic growth and the provision of high quality housing and infrastructure within the Oxford-Cambridge Arc

Object

Representation ID: 5713

Received: 07/09/2021

Respondent: Mrs Elizabeth Sands

Option 2D refers to the transport corridor – East: land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston (750 dwellings) and up to 28ha of employment lane.
The previous 2030 Local Plan allocated 500 houses to Great Barford and 50 dwellings to Willington despite the existing traffic congestion and limited facilities in both villages.
The emphasis on rural growth in Option 2D rather than the planning expansion of urban areas seems contrary to the Bedford Borough Council’s own Sustainability Appraisal findings, that urban growth was preferable for reducing emissions, providing for needs and access to facilities, reducing the need to travel and promoting sustainable travel options. To quote the report “The worst performing … was the village related growth component”.
Adoption of Option 2D would result in a scale of development which seems unsustainable with resulting pressure on the existing road network, on village facilities where there are any, on the landscape and on village identities.
Option 2A provides for high option rail-based growth which would be both sustainable and contribute to the decarbonisation of Bedford Borough Council. Modern infrastructure already exists at Wixams to support an increased number of dwellings.
Option 2B provides for a lower level of rail-based growth within the parishes of Kempston Hardwick, Stewartby & Wixams. The proposed new settlements at either Little Barford or Wyboston would make best use of the new East-West rail station to support sustainable economic growth and employment opportunity within the Oxford-Cambridge Arc. Modern infrastructure could be provided within the proposed new settlements for the benefit of the communities living there.
Option 2C does not make best use of the housing, employment and sustainable transport opportunities within the parishes of Kempston Hardwick, Stewartby and Wixams.
Adoption of either Option 2A or 2B would best support Bedford Borough Council’s policies of: -
I) Delivering well planned, sustainable growth supported by appropriate infrastructure – schools, health care facilities, community halls, green spaces and other services;
II) Creating strong safe & resilient communities.
III) Encouraging a change in travel behavior by focusing development on rail based growth with the A421 transport corridor;
IV) Moving towards making Bedford Borough Council carbon neutral;
V) Promoting economic growth and the provision of high quality housing and infrastructure within the Oxford-Cambridge Arc

Object

Representation ID: 5728

Received: 07/09/2021

Respondent: Odell Parish Council

In the further detailed development of the 2040 Plan Odell Parish Council has a strong preference for option 2c and would encourage the Borough to focus on this option or 2a. Each of these take maximum advantage of the A421 dual carriageway and its connection to the M1 as a prime transport route to and from Bedford on the south west/north east axis, with the new / improved stations on the East West Rail route being complementary to both these options.
The Parish Council strongly disagrees with any inclusion in the 2040 Plan of the new garden village sites at Twinwoods or Colworth, which are 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 back at least 0.5 miles from the Sainsbury Roundabout along Paula Radcliffe Way and also extensively along Great Ouse Way. The latest proposals regarding road improvements/ traffic lights to address this issue are wholly inadequate and far more radical solutions need to be considered, including a potential park and ride facility with a dedicated lane for the shuttle buses that would be required. The bus station and rail station need to be adjacent to each other to provide an integrated transport solution, facilitating optimum use of a Park and ride/shuttle bus facility.
We note with considerable concern the proposal to accommodate up to 500 new homes in Sharnbrook, particularly relative to the already existing significant traffic constraints within the infrastructure of that village. The arterial roads from Sharnbrook, 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 effectively creates a single lane roadway. Further traffic is likely to be generated from the 2040 plan which will exacerbate an already unacceptable and challenging situation. With the growing volumes of traffic likely to emerge from the plan and years beyond, a more radical solution needs to be sought.

Object

Representation ID: 5771

Received: 07/09/2021

Respondent: Mr Frank Squire

I am a resident and speak only for myself and my remarks relate only to that part of the Dennybrook proposal which relates to Honeydon and Begwary.

You will have received from local people many objections to the above development. There is one objection which I wish particularly to emphasise which is that the proposed site for Dennybrook is open countryside comprising grade 2 agricultural land together with attractive relatively unspoilt countryside with its gentle undulations, its woods, copses and hedgerows, its ditches, ponds and streams, its abundant wildlife and pretty lanes.

As Mark Twain, the American journalist and novelist said about land, they are not making any more of it. In particular they are not making any more relatively unspoilt English countryside.. The proposed Dennybrook site as well as comprising beautiful, if undramatic, countryside is also productive agricultural land and now that we are beginning to see globalization (costly and environmentally harmful) coming to an end and being replaced by a trend towards self-sufficiency, this land could become even more productive by the introduction of crops other than cereals..

Current trends suggest that there will be even more demand for agricultural land in the future and as Mark Twain suggested, they are not making anymore land, particularly unspoilt countryside land so it would be folly to develop this greenfield land to make room for Dennybrook.

In its Vision Statement Taylor Wimpey talks lyrically of the benefits, particularly the environmental and ecological benefits, that would accrue if Dennybrook went ahead. My response to that is that even more benefits would accrue if Taylor Wimpey kept away altogether from the proposed Dennybrook site, leaving alone the relatively unspoilt English countryside.and instead concentrated on the existing brownfield land nearby.

Finally, were Dennybrook to go ahead I have little doubt that in 20 years time looking back at that development, it would be regarded as a folly and that it would therefore be appropriate to change its name from Dennybrook to Follybrook to remind everybody not to be so stupd again.

Object

Representation ID: 5779

Received: 07/09/2021

Respondent: Mr Mark Wooding

I strongly OBJECT to the 2040 Local Plan proposals to develop more housing south of Bedford.
There is a significant amount of green belt space north of the town which should be prioritized.

It already appears that the Planning Dept’ have identified their preferred choices – Options 2A / 2B / 2C / 2D

This is disappointing and presents a biased view “in-favour” of more development south of the town.

Again….. I OBJECT to all development proposals south of the town.


In the event that one of the preferred options is to be selected, then Option 2C would be most “favourable”.

This excludes any proposed development in the village of Wilstead whose resident’s way of life has already been significantly impacted (negatively) by the recent Wixams development – Which is yet to complete.

The volume of traffic passing through the village has become an A600 rat run and with the absence of any average speed cameras is an on-going safety concern.

The increase in the local Wixams population has put stress on previously dedicated Wilstead amenities (shops / bottle banks / pubs / schools / play areas / sport clubs etc etc)…… We have already suffered enough change to our rural way of life !

Future proposals for change need to be shared by other parishes either NORTH OF THE TOWN or via Options 2A / 2B or 2D.

Support

Representation ID: 5798

Received: 07/09/2021

Respondent: Mr Timothy Taylor

I would strongly support options 2a – 2d identified in your Local Plan 2040 along the A421 corridor and in particular option 2b.

However, I would strongly object to the inclusion of any new proposed development of garden village sites at Twinwoods and/or Colworth. The A6 north of Bedford is already extremely congested and any new proposed developments to the north of Bedford will only exacerbate this problem. In particular traffic passing through Milton Ernest in front of the primary school already creates a potential hazard to young children and their parents.

Support

Representation ID: 5812

Received: 07/09/2021

Respondent: Mrs Susan Randell

OPTION 2C would be my choice if there has to be development on the A421 corridor.

I have lived in the village of Wootton since 1975. My children were born here and attended local schools. In the last ten years Wootton has seen development like no other village. The village has doubled in size with an excess of 1200 houses being built but the infrastructure has not grown in proportion.

Promised doctor’s surgery never materialized and until Covid struck, waiting times for appointments was up to 4 weeks.

Schools are full to capacity with the threat of bussing 4-year-old children across the borough to schools that may have places. The new build lower school was at capacity by the time it was opened and now has to have extensive repair work done to it to make it fit for purpose.

Planning Applications for more houses keep being applied for, objections from residents are ignored and the applications get passed. A recent one for 85 houses by the upper school got rejected on the grounds the road was too narrow to take the extra traffic and it was a danger to school children walking to and from school. The developers refused to accept the rejection and have now taken this to the secretary of state in a bid to get it passed.

Warehouses have been built on the edge of the village running alongside the A421 bypass, these were never in the original plans for development and have brought added problems with LGV’s mis reading signs and driving through the village. New signage has been introduced now but still many drivers miss these and come through the village. You should see a 40 ton lorry trying to turn round on a mini roundabout because they realize they have come the wrong way to access the warehouses. We now have the added delight of a hotel and pub promised alongside these monstrosities while local run pubs in the village are struggling to make a living and a Premier Inn sits about three miles up the road from Wootton.

Our green spaces around Wootton are gradually being concreted over at a time when only weeks ago Mayor Dave was celebrating all the green spaces to be had in Bedford Town. Not so many years ago this area was designated for a new community forest but most probably the trees planted then have been buried under said warehouses. Please leave what few green spaces we have left alone for us to enjoy, there are other areas that may benefit from building but no more in Wootton.

Support

Representation ID: 5813

Received: 07/09/2021

Respondent: Mr Glen Moore

Agent: Phillips Planning Services

Our client supports the strategies identified in Options 2a, 2b and 2d of the consultation, in which land in the southern Parishes, which includes Wootton could be identified for between 750 dwellings and 2000 dwellings. It is evident from the Call for Sites Proformas that there are several sites available across these Parishes that could make a meaningful contribution towards the delivery of these strategies.
It is further noted that the Sustainability Appraisal identifies Option 2a as the most sustainable option, and this proposes 2000 dwellings be identified in the Transport Corridor – South. If this Option, or indeed 2b or 2d, is eventually selected, our client wishes to put forward his sites at 66 Hall End Road, Wootton (Site 699), and Tippins, Hall End Road (which has recently been submitted to the Call For Sites process and is awaiting a Site ID) as suitable sites for allocation to meet this delivery.

Support

Representation ID: 6003

Received: 08/09/2021

Respondent: Helen Ricketts

Following the local plan information which has been circulated I would like to support options 2a - 2d to ensure the development is along the a421 where I believe development is more appropriate and this approach will retain the rural character of the Ouse valley.

Support

Representation ID: 6037

Received: 08/09/2021

Respondent: Leonora Field-Foster

I have considered the draft Local Plan 2040 options and write to let you know that options 2b to 2d in the draft 2040 Plan have my full support. Large scale development one or both of the sites at Wyboston and Little Barford will have capacity for further development in future plan years after 2040.
With the East West Rail Oxford to Cambridge rail route these development options south of Bedford are clearly the most sensible given that there will be a new station along the A421 and at either Tempsford or St Neots close to the A1.
I object to any development at Twinwoods and Colworth both of which are unsustainable.
I would encourage the Borough to proceed with one of the development options 2b to 2d and support.

Support

Representation ID: 6038

Received: 08/09/2021

Respondent: Ms Barbara Libiszowski

My preferences for development of the options would be 2c, 2b or 2a, but not 2d,1a or 1b - without knowing what route the East-West Rail route will take! I might feel differently depending on the outcome of that decision. As so many others, we moved to Renhold for its rural nature and easy accessibility to Bedford. I feel it is important to protect this aspect of the village and maintain the green areas in and around the village as much as possible. Unfortunately, we do get a lot of through traffic, particularly to and from the A421, which we feel spoils the character by its noise, pollution and danger of speeding vehicles. We do not need nearby developments of either housing or industry to exacerbate that problem.

Object

Representation ID: 6039

Received: 08/09/2021

Respondent: Mr Barry Wootton

When planning housing and commercial expansion some broad principles need to be followed to ensure quality development preserving the essential character of the area. Broadly these are:-
• Wherever possible, use brown field sites first of all.
• Ensure adequate social (eg shopping, medical access etc.) and physical (eg modern water, electricity and internet services, roads etc.) infrastructure at an acceptable cost.
• Good accessibility.
• Preserve distinctive villages and avoid coalescence.
• Avoidance of urban sprawl along highways and over accessible greenfield sites (attractive to speculative builders and landowners but destructive of amenity and local landscape).
Of the strategic options proposed, Option 2c seems best suited to meet these criteria with its focus on urban and semi urban locations, extensive use of the brown field sites south west of Bedford and new nucleated settlements in Little Barford and Wyboston.
Although Option 2d ticks some of the above boxes, it maximises urban sprawl. This will in turn and over time expand into the surrounding countryside as speculative building and land sales erode amenity and degrade the local landscape. As a result, it is the least acceptable option.

Support

Representation ID: 6040

Received: 08/09/2021

Respondent: Mrs Andree Brough

I understand that despite there being significant capacity already in either unsold or not yet built properties that this is a plan to 2040. And whilst I do not like it or agree with it, I know there will be a proposal put forward.

My preference is Option 2c and the least impactful to Wilstead’s current community. I support the creation of whole new settlements that can have their identity rather than be absorbed into our existing village. Wilstead is already in danger of being swallowed up by the Wixams development and will merge with not just Elstow and Houghton Conquest also Kempston Hardwick and conceivably Shortstown eventually.

This is followed by Option 2d but with Wilstead’s development taking place at sites 686 and 819 as they will not continue to join up to neighbouring villages and will continue to allow Wilstead to exist with a separate identity without changing the existing roads, properties, and appearance by affecting the existing village.

Options 2a&b are to me unnecessary in this area as there are far more suitable solutions namely 2c outlined above.

The infill between neighbouring settlements is already reducing the green space for all communities and continues ever increasing like ripples on a lake. For mental wellness, physical wellness, and aesthetics these spaces and boundaries are essential. Separate identities are paramount to successfully delivering additional housing. If identities and separation were not important then the whole area could just be called Bedford and no planner developer or person with a social conscience would promote that as the dream or their marketing proposal. They know community and belonging are important and this will be at the centre of the councils many other projects. This should be part of the decision making when creating new areas and not having to react to the complications that could have been avoided.

You have to have a social conscience. Creating new settlements does not impact an existing settlement directly as there obviously is not one. Therefore, this is of course less impactful for community DNA and objections from the existing community and is the best course of action as outlined in Option 2c.

Support

Representation ID: 6051

Received: 09/09/2021

Respondent: x Gates/Kitchiner

Agent: Phillips Planning Services

Our client supports the strategies identified in Options 2a, 2b and 2d of the consultation, in which land in the southern Parishes, which includes Wootton could be identified for between 750 dwellings and 2000 dwellings. It is evident from the Call for Sites Proformas that there are several sites available across these Parishes that could make a meaningful contribution towards the delivery of these strategies.

It is further noted that the Sustainability Appraisal identifies Option 2a as the most sustainable option, and this proposes 2000 dwellings be identified in the Transport Corridor – South. If this Option, or indeed 2b or 2d, is eventually selected, our client wishes to put forward his site at land south of Keeley Lane, Wootton (Site ID 682) as suitable site for allocation to meet this delivery.

Support

Representation ID: 6058

Received: 09/09/2021

Respondent: Mrs V Bates

Agent: Phillips Planning Services

Our client supports 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 for smaller development in 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 client supports preferred growth options 2b, 2c and 2d which include at least one new settlement. In particular, our client supports the proposed inclusion of Dennybrook Garden Village, which they have an interest in, (a new settlement west of Wyboston) which is being promoted through the Call for Sites process (Site 977) by Taylor Wimpey. This new settlement proposal could deliver 2500 dwellings in the identified plan period, and bearing in mind the requirements of paragraph 22 of the Framework, it offers the Council the opportunity to build its 30-year vision on the delivery of up to 10,000 dwellings and associated employment and social infrastructure at this strategically important location.

We would also argue that if Dennybrook is not allocated, there is significant capacity in the eastern parishes to accommodate future growth. With particular reference to the growth proposed in Option 2d, and the lack of growth proposed in options 2a, 2b and 2c for the east of the Borough; it is disappointing that the opportunities in the eastern parishes and in particular in respect of sites in Chawston, are not being taken advantage of. With regards to our client’s site in Chawston, while not part of the Dennybrook proposal, it sits separately and will be served by the introduction of a new relief road that will be constructed shortly as part of the Black Cat proposals. The relief road will provide a high-quality access back to the Roxton Road due south of this location.

Finally, within the various options, the sustainability merits of growth being located in and around the urban area are recognised, but there are questions as to whether the identified level of growth can be delivered. A better balance could be achieved by elevating the numbers to be identified in the eastern area, and delivering growth in and around the A421/A1 interchange (the Black Cat).

Object

Representation ID: 6066

Received: 09/09/2021

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

3.1 It is noted that The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for commenters were the urban area, the A421 corridor and rail-based locations. Further, the Sustainability Appraisal process identified that urban growth and urban edge growth are the most sustainable approach to new development.
3.2 The Call for Sites Extract shows a snippet of the sites that have been submitted for consideration by the Local Authority as potential development sites. A substantial number of these have been submitted for consideration as residential housing schemes as opposed to employment land. As flagged in Chapter 3 of the consultation document, the Council wishes to utilise both larger and smaller sites for use as employment sites, thus meaning a substantial number of sites would need to be allocated to meet the identified demands of employment land in the Borough. [Call for sites map inserted here.]
3.3 Of the sites that have been promoted thus far, it cannot be assumed that all the sites will be suitable and there may be constraints that limit what can be delivered, such as neighbouring uses, access, ecological considerations etc. This, therefore, makes it all the more essential that the Council give proper consideration to all the sites that have been put forward for development.
3.4 In a similar vein to the above, finding suitable sites for up to 51 hectares of employment (outlined in all options) on the edge of Bedford will be a challenge. Development on the edge of Bedford is realistically limited to the north/north-east of the town due to landscape, topography, flood plain constraints as well as the close proximity of the boundary of Bedford town to smaller settlements. Much of this land, whilst potentially suitable for residential development, aside from discrete parcels, is unlikely to be suitable for employment use.
3.5 Option 2d includes development in the eastern area of the A421 travel corridor which is supported by the clients as this provides a more flexible approach to development alongside not limiting this to a certain area of the Borough. It is, however, a concern that a number of the approaches are only limited to the south-western area of the District thus not utilising the important roles of the strategic transport links elsewhere and their associated roles, particularly for employment uses which rely on access to the strategic highway network. The close proximity of this site to the A421 and the A1 should be recognised within the site analysis that is to be undertaken, thus meaning that the site should be in a strong position for allocation.
3.6 In our view, for employment uses, given the relationship with the A1, the strategy outlined in Option 2d should be taken forward for further detailed consideration. It is important that there is a distinction made in the development of the strategy between the needs for employment uses and residential requirements. Whilst there is land with potential in the wider A421 corridor with the potential to accommodate both uses, from an employment perspective, the link to both the A421 and A1 sets option 2d apart.
3.7 We consider that a finer grain assessment of site availability and suitability should be undertaken to inform the development strategy. It is considered that this will identify a greater level of potential for growth along the whole of the A421 corridor. The whole of the A421 corridor should be looked at as one moving forward, with no arbitrary distinction between the eastern and southern parishes. This will allow a proper review of employment locations on a comparable basis and avoid suitable sites being missed out because they did not fall within the favoured growth area.
3.8 It can be noted, that the A421 has seen considerable growth in employment floorspace over recent years given its locality in both the Oxford to Cambridge Arc and the M1 corridor. In the future, it is predicted that this demand will remain, particularly for logistics given the ever-increasing emphasis on online sales alongside the significant investment in the A428 improvements.
3.9 The road improvements to the A428 / Black Cat roundabout and the East-West Rail are the key infrastructure investments in the area over the plan period and it is important that the opportunities associated with this significant investment are maximised. They will provide important connections between Oxford and Cambridge as well as linking to the wider train network. The village of Roxton is ideally located to maximise these opportunities and attract significant investment to the Borough.
3.10 This land is ideally located at the important interchange between the A428, A421 and the M1. In addition, it will be in close proximity to the East-West Rail. It is therefore considered that this site is ideally located for proposed employment land. this additionally supports the assertion in Paragraph 6.7 of the consultation document that outlines that sites should be well connected.
3.11 The proposed development at Roxton would not prohibit or curtail any of the planned infrastructure coming forward.
3.12 The inclusion of a new settlement in the strategy would present the opportunity to deliver new employment sites. However, there is a significant lead time associated with the development of new settlements, which would mean the release of employment land much later in the plan period with this potentially leading to a shortfall in the development of these employment areas in the short and medium-term stunting the growth of the Boroughs economy. This issue would be exacerbated should two new settlements be proposed within the plan.
3.13 If a new settlement is to be included in the strategy, the amount of employment land that they would deliver in the plan period should be realistic and sufficient, with other employment land also identified to meet immediate and medium-term demands. It is noted that the options currently assume the completion of either settlement option within the plan period. We would suggest that this is not a realistic assumption given the stage the plan is at and the lead-in time on matters such as land assembly, planning and infrastructure delivery.

Object

Representation ID: 6069

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.11. We 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.

3.12. 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.

3.13. We 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 to maximise the delivery of new homes through the sites allocated in the current local plan

3.14. In respect of those options reliant on the delivery of either one or two new settlements, our clients would argue that the Borough should be cautious in relying upon such a strategy to meet the required delivery rates for housing. As the Borough Council know from their experience with the Wixams, new settlements are difficult to deliver and take time to start making a contribution. New settlements can be part of the strategy, but a realistic view, a cautious view should be taken on the rate of growth these proposals can deliver, and plan accordingly.

3.15. In contrast urban and village extensions with one landowner and direct access to the existing highway network can deliver much quicker within the plan period, but are big enough to deliver new infrastructure in the form of schools and community facilities. Our client’s land in Great Barford offers that potential, is large enough to accommodate new strategic growth while having the land to deliver the necessary infrastructure. It can also build upon the current release of land at Great Barford West, as well as take advantage of the ability of the existing Primary School to accommodate expansion. A further 500 dwellings would take the education requirement at Primary level to a 3-form entry. We would argue there is sufficient capacity to achieve that and a 3 form entry primary school is of an appropriate size to deliver high quality education provision.

3.0 - Growth Option 2d
3.16. Of the selected growth options, our client’s 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.

3.17. Great Barford is the largest settlement in the eastern parishes, and a Key Service Centre and it would therefore be logical that it be proportionally allocated the larger share of the identified growth.

3.18. 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, particular in Great Barford, where our client’s control land suitable for a further 500 dwellings or more and directly adjoining the high frequency bus route provided by the X5 linking between Milton Keynes, Bedford and Cambridge. Countryside have experience of procuring new bus services and routes through direct engagement with bus providers such as Stagecoach and First.

Object

Representation ID: 6081

Received: 09/09/2021

Respondent: Mr J Wright

Agent: Phillips Planning Services

We 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.

We 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 client’s 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: 6124

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

4.10 The Bedford Local Plan 2040 examines a total of 13 development strategies but have focussed on 4 as being preferential.
• Option 2a: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes & south parishes (2000 dwellings).
• Option 2b: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, south parishes (1500 dwellings), plus one new settlement.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, south parishes (750 dwellings) and east parishes, plus one new settlement.
4.11 The four strategies identified as preferential for delivering growth are broken down into different locations and spatial options. Within the A421 corridor, existing and planned railway stations and 1 or 2 new settlements are considered alongside village-related growth in ‘east’ and ‘south’ corridor parishes. The following observations are key:
o Whilst the Local Plan 2030 identifies a need for 970 dwelling completions a year, the Local Plan 2040 must be based on a minimum of 1,275 dwelling completions a year (based on the standard method). This is a significant (33%) increase. This higher number will apply across the plan period (2020-2040) resulting in the need for a ‘top up’ for the period 2020 to 2030 (an additional 305 dwellings each year / 3,050 across the ten years), followed by the full 1,275 for each year between 2030 and 2040.
o Over the plan period, in total, the strategy will need to allocate land to enable a minimum of 25,500 dwellings to be delivered (20 x 1,275). Current commitments amount to around 13,000 dwellings which means that land to accommodate in the region of 12,500 dwellings must be allocated in the new local plan.
o The Council’s strategy states that to make provision for this level of growth it will require allocation of land at a strategic scale which in turn will rely on the timely delivery of strategic infrastructure. For that reason, one option is for the plan to be based on a “stepped trajectory” which would mean, for example, that the delivery target could be kept at 970 per year until 2030 and then increased to 1,580 dwellings per year to make up the rest of the plan requirement over the remaining 10 years.
o To what extent have the preferred options taken account of circumstances where it may be appropriate to plan for a higher number of dwellings that indicated by the government’s standard method for the calculation of local housing need? This is a key consideration the Borough’s key location within the Oxford-Cambridge Arc.
Strategic Dependencies
4.12 The preferred strategy of the proposed Local Plan 2040 has a number of strategic dependencies and influencers which are beyond the decision making, time scale and delivery of the Borough Council. These strategic dependencies are the Ox-Cam arc, East-West rail improvements, strategic road schemes including A1 and Black Cat junction.
4.13 None of the preferred strategy options include other village-related or New Settlements outside of the A421 corridor.
4.14 While there are four elements to the strategy for the A421 corridor there is a heavy reliance on ‘rail focused’ growth in the preferred options (as highlighted) and thus a need for significant investment to deliver a high proportion of the strategy options.
4.15 The Council indicates that by 2030 the Black Cat Junction improvements will be complete, the East West Rail section through Bedford Borough will be complete (including new and re-modelled stations) and sufficient lead-in time will have been available for strategic projects to be planned in detail, enabling these higher numbers to be achieved. The Council suggests forward planning will include arrangements for new sustainable travel links, with the intention that these are available from day one in order to embed and promote sustainable travel choices.
Rail focused growth comprises between 31% and 60% of units required to meet the total allocation of 12,500 additional dwellings.
4.17 Meeting the housing targets is also dependant on at least a single if not two new settlements. For this reason, the strategy is looking to back load the delivery to the later stages of the plan. New settlements are a notoriously high risk and take a substantial time to get delivered. Indeed, even delivery towards the end of the plan period can be viewed as optimistic. The delivery of the proposed new settlement options thus requires further examination.
4.18 Additional flexibility in delivery, particularly where this has potential to complement growth along the A421 corridor, is therefore a key component of any appropriate strategy option to be selected by the Council. This is necessary in order to demonstrate compliance with national policy and guidance.
4.19 There is no evidence available to the Council to reject village-related growth in the ‘south’ corridor parishes as part of the selected strategy option. We would endorse that the minimum figure of 1,500 units identified in the Council’s Option 2b would represent an appropriate starting points as part of a wider ‘hybrid’ strategy.
4.20 While the Council’s Preferred Options are not based on settlement-specific assumptions for the distribution of growth within this 1,500 unit total we would urge the Council to adopt a flexible approach. Within this scenario some settlements may be subject to less growth. In the case of Wootton, given its important role as a Key Service Centre and good accessibility strategic scale village extensions would form part of an appropriate strategy thus making a potential capacity in excess of 500 units a useful starting point for testing site options.

Object

Representation ID: 6161

Received: 09/09/2021

Respondent: Savills

Agent: Savills

A range of emerging preferred options for the spatial strategy also known as development strategy are
provided in the consultation local plan comprising 2a to 2e. We consider the preferred strategy will to
continue with a focus on the urban area of Bedford and Kempston with additional growth that is spatially well
related to the urban rea. The definition of well related should include land adjoining and land not adjoining
the urban area but which has good connectivity potential such as walking, cycling and public transport. This
would be consistent with paragraph 73 of the NPPF.
Out of the preferred options we consider that Option 2a: Development in and around the urban area, plus
A421 transport corridor with rail based growth parishes and southern parishes, is the most sustainable and
appropriate, followed by options 2b and 2d.
We consider option 2c is least sustainable and least deliverable because of the strategic nature of some of
the locations identified. We do not of course object to the principle of new settlements but rather consider the
complexity in delivery is often underestimated in plan-making.
We do not necessarily agree with the number of dwellings included in brackets within the preferred options.
There is no explanation as to whether this is new going forward or there is an element of deduction to allow
for commitments and/or windfalls although the total figure tallies with the amount given at paragraph 3.2.
This is where more detailed explanation is necessary along with a delivery trajectory. There is no explanation
of land availability and deliverability to understand the wider context. We consider a minimum figure of 2,000
dwellings for all options for the southern parishes is an appropriate starting point.
Land at Box End, West of Bedford is capable of delivering some 1,150 dwellings being well related to the
urban area of Bedford and Kempston. The figure of 12,500 dwellings is not agreed at this stage and even if it
were to be, then this should be seen as a minimum and land identified capable of delivering more than this
minimum. This would be consistent with the NPPF paragraph 68.
Oxford-Cambridge Arc
The consultation draft provides an explanation of the Oxford-Cambridge Arc as it stood at that time.
However, since then the Government has published consultation on a vision for the emerging spatial
framework and therefore this should be taken into consideration in discussions with MHCLG and other
stakeholders.
The spatial framework for the Arc is expected to sit alongside the NPPF as national planning policy.
Therefore the assumption should be that the emerging local plan will need to be consistent with the spatial
framework, being one of the tests of soundness under paragraph 35 of the NPPF.
1.13 in the consultation local plan provides a description of the timeline for both plans and shows that the
spatial framework is likely to be published ahead of examination into the local plan.

Object

Representation ID: 6241

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

4.1 The previous Issues and Options consultation outlined six potential approaches
to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based
growth.
4.2 These six options have now been progressed and as set out in the Local Plan
and Development Strategy Topic Paper (June 2021); BBC now seek views on
four ‘preferred options’ to meet the (proposed) level of growth set out in the
Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes and southern parishes;
2. 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;
3. Option 2c: Development in and around the urban area, plus A421 transport
corridor with rail-based growth parishes, plus two new settlements;
4. 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;
4.4 The four options put forward share many common components. In all but one
option (Option 2c), growth is proposed to the south of Bedford, including the
southern parishes. The only option that omits this approach is Option 2c, which
instead proposes the delivery of two new settlements.
4.5 Firstly, Option 2c is not considered a sound approach. As has been
evidenced3, the development of large sites (2,000+ dwellings) takes many years.
The average time quoted from validation of the first planning application to the
first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. The
lead in period to starting on site for new settlements is many years, being further
complicated by matters such as creating the necessary utility infrastructure for a
new settlement.
4.6 The same report also finds that the average annual build-out rate for a scheme
of 2000+ dwellings is 160dpa.
4.7 Working on the basis of a plan led system, any application for a new settlement
would, in theory, not be validated until after the Local Plan is adopted, thus 2024
at the earliest. This means that any new settlement is unlikely to begin
delivering homes until 2032 at the earliest. The proposed new settlements are
3,085 dwellings at Little Barford, and 2,500 dwellings at Wyboston. Little Barford
would take 19.3 years to build out at that rate (almost the entire Plan duration),
and Little Barford 15.6 years.
4.8 If the Plan period runs until 2040, both new settlements would only deliver, at
best, half of their housing numbers within the Plan Period.
4.9 The approach set out in Option 2c would not, therefore, meet the Borough’s
housing needs within the Plan Period and should be discounted as a result.
4.10 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d,
albeit the effect of only having one new settlement would lessen the delivery
issues.
4.11 The option which has the greatest likelihood of delivering growth within the
Plan period, as required by national policy, is Option 2a. This option would
focus growth in the south along the major transport corridors of the A421, A6
and railway line, and in turn would focus development in the most sustainable
locations.
4.12 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the
best performing option. It also finds Option 2c to be the worst performing of
these 4 options, and that is without considering the issue of delivery as set out
above.
4.13 AWG strongly argue that Option 2a should be the preferred Option for growth
that is taken forward in the Local Plan. Option 2a is the best performing of the
various growth options as shown by the evidence base.
4.14 The next section of these representations puts forward a case as to one such
location for growth within the southern parishes, which would deliver growth in
accordance with Option 2a (in fact according with 3 of the 4 development
options).

Object

Representation ID: 6255

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Growth Strategy Options
We recognise that options 2a-d are the best performing options in the Sustainability Appraisal and in terms of the high transport work, as well as in terms of the Local Plan themes. We have reviewed these options, as well as options 3 to 6 in the Development Strategy Topic Paper, however, these options do not take account for the potential for development to be located adjacent to alternative ‘urban areas’ (other than Bedford) such as our Site at Land at Rushden Road, which is located within Bedford Borough but adjacent to the southern boundary of Rushden (located within the local authority area of North Northamptonshire Council).
The North Northamptonshire Joint Core Strategy 2011-31 (adopted July 2016) recognises Rushden as a Growth Town (the highest tier of settlements), and defines its ‘spatial role’ as “to provide the focus for major co-ordinated regeneration and growth in employment, housing, retail and higher order facilities serving one or more districts”. Rushden is therefore a highly sustainable settlement suitable for major growth. There is no reason that growth should not be located the south of the settlement, within the administrative area of Bedford Borough. On this basis, we consider that the Site would perform positively against the greener, more accessible and more prosperous themes that inform the overall vision for the BBLP 2050.
Whilst ongoing or future infrastructure improvements, such as Black Cat Junction improvements and the East West Rail section through the Borough, are due to be completed later in the plan period, and this may inform the overall growth strategy and trajectory, there also needs to be consideration of sustainable sites (without extensive infrastructure requirements) that can come forward earlier in the plan period and take pressure off the delivery of a high number of sites and homes between 2030 and 2040 (especially those reliant on the delivery of infrastructure).