3.16

Support

Representation ID: 6256

Received: 10/09/2021

Respondent: Ms Rachel Chico

I wish to submit my comments on the draft Local Plan 2040.
First, I wish to say that - yet again -there appears to be no plans to build on the North side of the county. I would be interested to see a breakdown of building on a map over the last 2-5 years. It doesn't appear to be fairly spread out.
I would also like to ask where there are a substantial of amounts of 'brown belt' sites that are not being used? For example; why is Thurleigh airfield not being considered for development?
Of the options shown, I feel that option 2A or 2b would be good enough. However, I would still like my comments above to be taken into consideration.

Object

Representation ID: 6261

Received: 10/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in sustainable settlements in the north.

In setting an arbitrary distance from the edge of the urban area, the preferred strategy options remove opportunities for delivering growth in sustainable villages on the northern edge including Ravensden. The area considered to be adjoining the urban area should also include Parishes on the edge of the urban area to ensure these settlements benefit from some growth to stop them from stagnating, and for the vitality and viability of their existing services and facilities. These Parishes present an opportunity for growth in sustainable locations within reasonable proximity of the urban area. Our client would like to highlight that his site at Land East of Bedford Road/Oldways Road, Ravensden (Site 601) would be ideal for achieving this, and is available for up to 70 dwellings.

Sites adjoining or close to the main Bedford Urban area offer similar sustainability advantages to sites within it, whilst exhibiting far fewer viability / deliverability issues. We therefore consider that sites adjoining the urban area should be allocated a slightly higher proportion of the housing numbers (2000) than currently suggested.

The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process, a process that Ravensden Parish Council has embraced and is currently undertaking.

Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area.

Support

Representation ID: 6274

Received: 10/09/2021

Respondent: Mr Bernard Cornwell

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 Kempston Rural 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.

Kempston Rural is in an excellent location for growth and benefits from access straight onto the A428 link road. The Council should give full consideration to the opportunity for growth across the entire of the Parish, rather than simply limiting growth to a single strategic release.

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 Box End House (Site 18) as a suitable site for allocation to meet this delivery.

Object

Representation ID: 6297

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

It is, however, 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. The Council’s own Preferred Options substantially rely upon large-scale strategic sites which are particularly affected by these gaps in evidence.
In order to provide choice and flexibility as part of an appropriate strategy it is therefore critical that sites selected for development in the urban area secure the benefits of early delivery. This will help to address the risks of non- delivery from the other components that the Council relies upon in the emerging Local Plan 2040 and distinguishes additional urban sites (such as our clients’ Peacocks site) from existing Town Centre sites that have been subject to significant and historic delays. This renders support for growth in the urban area an important part of any approach to the strategy.
Please refer to our supporting representations for further information.

Object

Representation ID: 6347

Received: 10/09/2021

Respondent: Miss Joanne Halliwell

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 existing 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: 6358

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey generally support the approach advocated in the Draft Strategy Options document which directs future growth being towards transport corridors, particularly the A421. The A421 is well related to Bedford as the area’s main service centre, is a key route through the Borough and connects Bedford Borough to the key centres of Milton Keynes and Cambridge.
The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for commenters were the A421 corridor, the urban area and rail-based locations.
The A421 corridor and rail-based growth options are also said to have performed favorably against the new settlement options as part of the Sustainability Appraisal process, with only urban growth and urban edge growth, unsurprisingly, performing better in sustainability terms.

Object

Representation ID: 6359

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey do not agree that option 2c, which intends to focus development on the urban area and create two new settlements in the east of the Borough, is a realistic option. Whilst acknowledging that there is scope for the inclusion of one new settlement in the emerging Local Plan, to include two new settlements at the expense of other options would be unsustainable and a highly risky strategy to deliver much needed homes in the short to medium term, particularly given the new NPPF paragraph 22 requirement for the strategy to be set within a 30 year, long-term vision.
Taylor Wimpey agrees that growth in and around the urban area is a sustainable option. However, given that Bedford is the main economic centre in the area and a built-up urban area, Taylor Wimpey question whether the 3,000 homes and an additional 51 hectares of employment land can be delivered in this location over the plan period. Indeed, there may be small scale opportunities for growth in the town, however, it will be a challenge to find land for an additional 1,500 homes over the plan period. In a similar vein, finding suitable sites for 1,500 home 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.
As a result of the above constraints in directing growth towards new settlements and the urban area, it is important to look closely at the development options for the A421 corridor and rail corridors, and establish these as an integral part of any future development strategy.

Object

Representation ID: 6360

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Taylor Wimpey is encouraged to see that growth in the A421 corridor is included within three of the four options presented in the paper (for which commentary on the fourth option which focuses growth on two new settlements is discussed in more detail below), as well as rail-based growth being included in all four options identified.
However, Taylor Wimpey do still have some outstanding concerns about the detail behind Options 2a, 2b and 2d (the three options which contain growth in the A421 corridor); this primarily focuses on the level of growth directed to the ‘southern parishes’, the ability of a new settlement to deliver early in the plan period and the deliverability of 5,500-7,000 homes in the rail corridor. These are discussed in more detail below.

Rail related growth
Whilst in principle Taylor Wimpey support growth in the rail corridor to the south of Bedford, there are a number of key matters in relation to the approach taken to this growth by the Council which requires further consideration.
Firstly, it is unclear how it will be possible to deliver the scale of growth proposed by the Council (50% of the housing requirement). An extract of the Call for Sites map has been overlaid with the rail related growth area identified in Options 2a - 2d and is included at Figure 1 below. As can be seen from Figure 1, there are a limited number of sites which have been put forward to the Council as being available in this area – with the majority of the large sites that have been put forward having been identified for potential employment use.
Secondly, the justification for the extent of the catchment area for these rail station locations has not been properly elaborated on. Additional opportunities may be available on the periphery of this area, in settlements such as Wilstead, which could contribute to delivery (which is currently classed as being in the A421 corridor). Wilstead is a settlement with a range of services and is in easy commuting distance of Wixams including via sustainable modes of transport such as cycling. It is in close enough proximity to Wixams that a local gap is currently included within adopted policy in order to separate the two settlements.
Without expanding the catchment area for the rail-related growth, combined with concerns about the ability to delivery 3,000 in and around the urban area, further emphasis should be placed on the role of land in the A421 corridor within the development strategy, with a particular focus on those settlements, such as Wilstead, which can be classed as lying in both.

Delivery in New Settlements
Taylor Wimpey recognise that there is a role for a new settlement as part of the development strategy,
As previously noted, the NPPF 2021 includes the new provision that new settlements will need to present a long term, 30 year vision and a new settlement will therefore present the opportunity to deliver new homes later in the Local Plan period.
However, there will be a significant lead in time with any new settlement, with completions not likely to be realised until well into the Local Plan period. An over reliance on new settlements to meet housing need would therefore be a detriment to meeting housing requirements in the short to medium term, particularly when there appear to be sufficient suitable and deliverable sites available to meet the need in a timely manner. This issue would then be further exacerbated in a strategy which relies on the creation of two new settlements.
If a new settlement is to be included in the strategy, which would be a reasonable approach given the challenges in the area, the number of homes to be delivered in the plan period should be realistic. It is noted that the options currently assume the completion of either settlement option within the plan period. 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.
The Council will need to ensure that the residual requirement that has been identified above in the earlier plan period is picked up through the development strategy. Given the constraints with other elements of the strategy, emphasis should be placed on the importance of the A421 corridor to deliver growth and the wider catchment area around key rail locations and the approach taken in Option 2c reconsidered.

The Apportionment to the Southern Parishes
Aside from option 2c (the two-settlement option), which has been addressed above, each of the options include an element of growth in the A421 transport corridor. This level of growth varies from 1,500 dwellings in option 2b and 2d to 2,000 dwellings in option 2a. Taylor Wimpey consider that these options significantly downplay the potential of the area to deliver additional housing numbers and note that there is a need to rely on sites in this location given the issues identified above.
Figure 1(below), an extract of the Call For Sites map, identifies that there are a number Key Service Centres located within this corridor such as Wilstead (where Taylor Wimpey are promoting land), as well as Wootton, Wixams, Shortstown and Great Barford. These settlements are highly sustainable and have the ability to provide additional sites beyond the housing apportionment currently stated. In the adopted Local Plan, Key Service Centres were seen as suitable for 500 dwellings, and indeed higher level of growth in some locations were assessed early in the process as being appropriate.
There are also other larger settlements in the corridor that could take growth, such as Willington (where Taylor Wimpey have land interest) which have been excluded from the A421 Corridor, despite being in the same transport corridor as the likes of Wootton, Wilstead, Cotton End and Shortstown (which are included in three of the options). From a review of the evidence it is not clear why this is the case.
No justification has been given as to why the options limit potential growth to 2,000 dwellings and therefore this comes across as an arbitrary number that is not underpinned by the necessary evidence. This is particularly noticeable when the issues raised above with the other options are taken into account.
A finer grain assessment of site availability and suitability should be undertaken to inform the development strategy. Taylor Wimpey consider that this will identify a greater level of potential for growth in 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 all settlements and sites on a comparable basis and avoid suitable sites being missed out.

Neighbourhood Plans
It is noted that there are a number of emerging Neighbourhood Plans which seek to address the housing need requirements identified for certain villages in Policy 4S of the Local Plan 2030.
If a Neighbourhood Plan is made ahead of the adoption of the Local Plan 2040, this should not influence the strategy included in the emerging plan.
The emerging Local Plan should revisit the level of growth apportioned to each settlement as part of a review of the growth strategy for the area and allocations should be made in settlements, such as Wilstead and Willington, in order to ensure that the housing needs for Bedford Borough are met.

Location for Growth
− There is a concern that the assumed delivery of the settlement options may be being overstated.
● The assumed capacity of the urban area/urban fringe and the rail focused options to deliver the stated level of development should be reviewed.
● The two-settlement option is not a robust or sustainable approach to meeting housing need.
− A focus for growth within the A421 corridor is supported by Taylor Wimpey and it is asserted that there is a need to increase the level of development focused along the A421 corridor due to the constraints which effect other options. It is noted that the Council have created an unjustified split in the parishes along the A421 corridor and that a more appropriate approach would be to look at the area as a whole and identify the most appropriate available sites.

Object

Representation ID: 6383

Received: 13/09/2021

Respondent: Mr Sandy Gery

Agent: Phillips Planning Services

There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in sustainable settlements in the north of the Borough, which has been excluded from all four of the emerging preferred growth options.

The north of the Borough includes several highly sustainable settlements including Key Service Centres, Rural Service Centres, and many other sustainable smaller villages. Additional growth in the northern settlements can make a positive and meaningful contribution to the wider strategy going forward to 2040, improving the long term vitality, and the viability of existing services and facilities. We would argue that allocations should therefore be made proportionally across the Borough in the interests of long-term sustainability.

Our client would like to highlight that he has four sites in Colmworth which are suitable for development and can contribute towards the sustainability of the settlement. These are Land East Church Road (Site 759) which is available for up to 300 dwellings, Land West of Church Road (Site 758) which is available for up to 150 dwellings, and Land To The North Of The Cornfields Public House (Site 727) and Rear Of The Cornfields Public House (Site 3448) which are both available for up to 30 dwellings.

The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process. Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area.

Support

Representation ID: 6390

Received: 13/09/2021

Respondent: Mr Humphrey Chetwynd-Talbot

Option 2a: Proven Most Suitable Alternative
Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations south of Bedford are planned and the A421 has capacity for additional traffic.
Option 2b: Alternative Preference
Of the other options that have been presented in the consultation Little Barford (site ID 907 – option 2b) is by far the most appropriate alternative, but excluding Wyboston / Dennybrook, which would provide additional 3,085 dwellings in the rail corridor, for the following reasons:
• A development in and around the urban area plus A1 and A421 transport corridor with rail-based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Further Alternatives Not Proposed in the Consultation – Twinwoods (site ID 833) or Colworth (site ID 1002)
A new development of up to 3,000 homes at Twinwoods (site ID 883) or Colworth (site ID 1002) could provide the infrastructure funding to support improvements to the A6 which has been needed for some time to provide residents with access to the east west rail station in Bedford. A northern parkway station or guided busway could be considered in the future to provide sustainable transport for those in the north of the Borough.
Twinwoods (site ID 883) would provide a significant proportion of brownfield land and Colworth (site ID 1002), which was supported in the 2035 plan, includes lower quality grade 3 agricultural land and so would comply with the NPPF requirement to use brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre.
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead of greenfield land (open countryside)

Support

Representation ID: 6392

Received: 13/09/2021

Respondent: Mr Brian Smith

The consultation asks for suggested preferred options, including other alternatives not included in the consultation:

Option 2a: Proven Most Suitable Alternative
Bedford Borough Council’s own sustainability appraisals demonstrated and concluded that the alternative Option 2a is the preferred and most suitable option because urban development is more sustainable than rural.
Importantly, development within urban areas performed best particularly in reducing carbon emissions, promoting town centres (which incidentally are in decline), encouraging physical activity, delivering residents’ needs, access to community services (which are so important to mental wellness) and reducing the need to travel and promoting sustainable types of travel. New stations south of Bedford are planned and the A421 has capacity for additional traffic.
Option 2b: Alternative Preference
Of the other options that have been presented in the consultation Little Barford (site ID 907 – option 2b) is by far the most appropriate alternative, but excluding Wyboston / Dennybrook, which would provide additional 3,085 dwellings in the rail corridor, for the following reasons:
• A development in and around the urban area plus A1 and A421 transport corridor with rail-based growth parishes
• Access to a large number of services and facilities including existing employment which would reduce the need to travel by car
Further Alternatives Not Proposed in the Consultation – Twinwoods (site ID 833) or Colworth (site ID 1002)
A new development of up to 3,000 homes at Twinwoods (site ID 883) or Colworth (site ID 1002) could provide the infrastructure funding to support improvements to the A6 which has been needed for some time to provide residents with access to the east west rail station in Bedford. A northern parkway station or guided busway could be considered in the future to provide sustainable transport for those in the north of the Borough.
Twinwoods (site ID 883) would provide a significant proportion of brownfield land and Colworth (site ID 1002), which was supported in the 2035 plan, includes lower quality grade 3 agricultural land and so would comply with the NPPF requirement to use brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre.
On these grounds alone, as a further alternative to Dennybrook or even an urban development, the brownfield site on Twinwoods is much more suitable particularly as:
• It does not flood
• It has no major watercourses and is distinct from other settlements – so no loss of identity for existing settlements
• Government planning policy seeks to develop brownfield land ahead of greenfield land (open countryside)

In conclusion, the proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with many narrow, single-track roads and no settlement policy area. The proposed site would destroy the hamlets of Begwary and Honeydon. It is interesting that there have been no proposed incremental benefits to any of the existing villages. The site is all on grade 2 (high quality) agricultural land and is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Accordingly, and for the reasons outlined, the proposed new settlement should be discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.

Object

Representation ID: 6449

Received: 13/09/2021

Respondent: Ms Donna Thompson

Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.

Staploe Parish Council consider that the dispersed growth strategy is still applicable which would include housing growth to existing serviced settlements, plus A421 transport corridor and rail growth, as well as the proposed new settlement of Little Barford (option 2b, in part). Such a strategy would provide 13,085 dwellings, including at least an additional 10% allowance for growth to small and medium scale housing sites associated with the existing key and rural serviced settlements. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor.
In support of a dispersed growth strategy, it makes clear at Paragraph 68 of the NPPF that the Council’s Local Plan should identify a supply of housing covering ‘years one to five, specific developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15 of the plan’. Paragraph 69 goes on further to state that ‘Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.’ The development around existing served settlements would provide for these small and medium sites, which could deliver early in the plan period negating the reliance of large urban extensions and new settlements which inevitably are built out towards the end of the plan period, and potentially beyond. It is noted within the Settlement Hierarchy (September 2018) that the main urban settlement of Bedford/Kempston provides the most services, employment, public transport and facilities, and it is therefore where additional urban development should be focused. In addition to this, further sites can be allocated to key and rural serviced settlements as identified in sections 3 and 4 of the Settlement Hierarchy report, which identifies six key service centres and 10 rural service centres. Further development in and around these settlements would support existing services and facilities. It is also noted that the report is currently being reviewed. Staploe Parish Council would like to highlight that our parish has always been classified as open countryside in the settlement hierarchy so we are surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook (site 977) would form part of the first phase of a large new town of up to 10,800 homes in an entirely rural, unserviced location.
In terms of the proposed settlement at Dennybrook (site 977) (site land west of Wyboston), this ‘new settlement’ does not provide a suitable alternative. This proposed settlement provides for around 2,500 homes. It is located very close to the existing settlement of St Neots and Wyboston and entirely engulfs the existing hamlets of Honeydon and Begwary. It appears to offer very little separation causing potential coalescence. This new settlement would also be car dependent with limited access to the wider road network due to the existing narrow roads. There is poor connectivity in terms of a choice of sustainable modes of transport, including the train. Further details in respect of the proposed development at Dennybrook are addressed in the site assessment for Dennybrook (site 977).
It is evident that the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.
Another option may be a new settlement of 2,500 homes at Twinwoods or Colworth. The Parish Council believe that the problems on the A6 north of Bedford are going to need to be resolved anyway in order to support the housing development proposed in the 2030 plan and for residents to access the east west rail station in the centre of the town. We believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre. Colworth was the site supported in the 2035 plan which was later reviewed. The A6 was not a considered sufficiently problematic to prevent this site being adopted – the site was dropped because it was difficult to mitigate against the noise from Santa Pod. So we find it hard to understand why the A6 is deemed such an insurmountable problem now.

Support

Representation ID: 6561

Received: 13/09/2021

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

1.1 On behalf of our client FCC Environment (UK) Ltd (FCC), we set out our comments to the Bedford Local Plan 2040 Draft Plan Strategy Options and Draft Policies Consultation Document. Where necessary, these representations draw on the comments previously made to the 2020 Local Plan Issues and Options and Call for Sites submissions.
1.2 These comments relate to the Council’s growth and spatial strategy options as set out within Chapter 3 of the Draft Plan, reference is also made to the Development Strategy Topic Paper where relevant. It is acknowledged that there are an infinite number of growth locations/options which the Council could have considered. We believe a broad range of locations have been considered to enable the key issues of delivering growth across the Borough to be tested.
1.3 We support the growth based options which would allow growth in locations which already have existing infrastructure and good connections to Bedford town centre. Urban locations and those in close proximity to existing road and rail routes have the greatest potential for sustainable travel choices and the urban and rail based growth options would therefore target growth within the most sustainable locations.
1.4 The Development Strategy Topic Paper defines the five broad components of growth as follows:
• Within the urban area (sites within the urban area boundary).
• Adjoining the urban area (all or part of the site is within 0.5 miles of the urban area boundary).
• Village related (Key Service Centres and Rural Service Centres).
• New settlements (Wyboston, Little Barford, Twinwoods, Colworth).
• A421 transport corridor with rail based growth (stations at Kempston Hardwick, Stewartby, Wixams and at a location between St Neots and Tempsford).
− Transport corridor –growth focused on Kempston Hardwick, Stewartby and Wixams1 (rail-based growth)
− Transport corridor – south (the parishes of Wootton, Kempston Rural, Elstow, Wilstead, Shortstown, Cotton End)
− Transport corridor – east (the parishes of Cardington, Cople, Willington, Great Barford, Roxton, Wyboston and Little Barford)
− Transport corridor – growth focused on new settlements in the A421 corridor (Wyboston and/or Little Barford).
1.5 It is assumed for the purposes of our comments that FCC’s site at Elstow is located within the rail based growth parishes area. All of FCC’s site is within 0.5 miles of the urban area boundary, however the diagrams shown in the Draft Local Plan show the site within the rail based growth parishes and our comments are therefore provided on this basis.
1.6 We have reviewed all 7 growth options put forward within the Development Strategy Topic Paper and provide our comments below.
1.7 Option 1 (a and b) seeks to only propose growth within the urban area and does not seek to maximise growth within the transport corridor which we consider should be delivered. We therefore do not support this growth option.
1.8 Our preferred growth strategy is option 2 (2a-2d) which the Council have taken forward and included within the Draft Plan. This option seeks to deliver development in and around the urban area plus A421 corridor with rail based growth. It is supported that all development options focus development within the south of the borough where there is better rail and road infrastructure. This is in line with the sustainability appraisal which identified that the urban component of growth performs most strongly and the worst performing component was the village related growth component.
1.9 Of the Option 2 growth options, we support options 2b, 2c and 2d which seek to deliver the highest level of employment growth within the transport corridor.
1.10 These options seek to benefit from the existing and proposed infrastructure and would allow growth in locations which already have existing infrastructure and good connections to Bedford town centre. Urban locations have the greatest potential for sustainable travel choices and this growth option would therefore target growth within the most sustainable locations.
1.11 The Council should recognise that the delivery of new infrastructure is crucial to the development of Bedford as an economically prosperous, attractive and healthy borough. In order to maximise the delivery of growth the Council should seek to deliver a broad range of new infrastructure, including improving rail and public transport accessibility and improving / providing new link roads.
1.12 FCC’s site at Elstow, has been assessed and could provide land for a link road from the Bedford Business Park in the west to the A6 in the east which provides a direct connection to the south and the A421 in the north. The provision of this link road shown in Figure 1 could help to mitigate congestion on the edge of the urban area and would facilitate additional economic development in the surrounding area. FCC is aware of the highways concerns for the proposed business park development to the west. A link road through FCC’s site could alleviate and address those concerns. FCC has been working with surrounding landowners to ensure a holistic approach is taken to the development of the area.
1.13 We do not support the Option 3 growth options which seek to deliver high levels of growth within the rural area and within new settlements. We have previously commented on the disadvantages of this, the majority of rural areas would not have the existing infrastructure in place to accommodate growth if it was evenly dispersed throughout the borough. An even spread of growth across the borough and a lack of focused critical mass would make providing strategic infrastructure more difficult, as the locations would not benefit from economies of scale. As such, the growth options which target growth within areas of the borough with existing infrastructure or the ability to provide enhanced infrastructure should be supported.
1.14 Options 4-6 provide growth within the A421 transport corridor with rail based growth plus a range of dispersed growth across the borough. These growth options provide lower levels of employment across the borough than our preferred growth option (option 2). As set out above, we consider that growth should target the areas with existing services and infrastructure and not the more rural areas which do not benefit from high quality infrastructure.
1.15 Option 7 seeks to provide growth in two new settlements, plus key service centres, plus rural centres. We do not support this growth option as it does seek to deliver any growth in locations which benefit from existing and improving infrastructure.
1.16 As set out above, growth should be focused along intersections with existing major infrastructure which will create new opportunities for logistics and distribution industries, and are also most likely to support new settlements. The preferred option should ensure sufficient flexibility to meet the changing economic needs over the plan period.

Support

Representation ID: 6624

Received: 14/09/2021

Respondent: Mr Nicholas Flynn

We have all been invited to submit our preferences for the 4 Options 2a, 2b, 2c and 2d set out in your recent flyer.
My preferences are, in order ;-
2a (least bad of the 4)
2c
2b
2d (worst of the 4)

Object

Representation ID: 6673

Received: 14/09/2021

Respondent: Milton Keynes Borough Council

Thank you for consulting Milton Keynes Council on Bedford’s Draft Local Plan 2040. At this stage in your local plan process, our comments are limited to those matters which have potential to give rise to cross-boundary impacts upon Milton Keynes, namely the quantum and location of housing and employment growth and the corresponding impacts these have on transport and movement between Bedford and Milton Keynes.
Milton Keynes is a regional service centre as a destination for work and leisure for communities living in Bedford and further east along the A421 corridor (and planned EWR rail corridor). Having considered the Draft Plan document, and those documents made available alongside it, we do not raise any objection to the Draft Plan in relation to these matters. However, we have some concerns and have provided comments where it is considered necessary in the interests of Milton Keynes borough in order to inform further work and iterations of the plan. We look forward to working with Bedford as and when needed during this process as part of the Duty to Cooperate and in the interests of good planning.
Housing and Transport Strategy
It is encouraging to see that the Draft Plan (in addition to the Local Plan 2030) is seeking to meet the Local Housing Need (LHN) of 26,000 dwellings for the period to 2040 in full. As outlined below, there appears to be potential appropriate spatial options available for meeting LHN. However, there are some concerns with respect to certain options being consulted upon, and it is clear that further evidence is needed to justify any chosen spatial strategy for meeting housing needs.
Our main interest lies in how the different spatial options may affect car-based trips to Milton Keynes versus trips made by other modes (principally rail-based). The effects of different strategies on how people living beyond Milton Keynes may travel to Milton Keynes for work or leisure could have consequential impacts for Milton Keynes.
Planning and Placemaking
Civic, 1 Saxon Gate East, Central Milton Keynes, MK9 3EJ
01908 691691
www.milton-keynes.gov.uk/planning-and-building
It is noted that the Draft Plan includes four preferred strategy options (options 2a-d). These appear to be a hybridisation of the seven strategy scenarios set out within the Development Strategy Topic Paper June 2021 that accompanies the consultation, primarily by combining new settlement options with growth along with A421 and/or rail corridor-based and urban based growth. However, it is noted that the higher density urban-based option (1b) has not been reflected in the Draft Plan options. It is understandable that seeking to meet the LHN in full from urban sites may result in significant impacts to existing communities. However, there may still be opportunities for higher density on an area by area, or site by site, basis. This would help to reduce the amount of housing that needs to be met through a more dispersed strategy that is likely to result in greater car-borne trips. This is particularly the concern with options 2b and 2d which have significant amounts of growth (1500 dwellings) that are likely to rely on private vehicles for greater than local trips to regional service centres, including Milton Keynes.
The Bedford Borough Transport Model Local Plan Assessment (BBTM) reports provide a high-level appraisal of the impacts of four development scenarios. These BBTM scenarios do not all correlate with the four preferred options set out in the Draft Plan or the seven scenarios set out in the Development Strategy Topic Paper June 2021. It appears that only one of the four options has been assessed (option 2a). It is of some concern that the cumulative impacts of Draft Plan options 2b and 2d, which blend new settlements to the east of Bedford with A421 corridor and rail corridor-based growth have not been assessed in the BBTM. The BBTM therefore cannot be seen as a direct assessment of the Draft Plan options, although some results and conclusions could be inferred from the BBTM scenarios and applied to the Draft Plan options at a more granular level. For clarity, our comments are based on the understanding that:
• The Grey BBTM scenario equates to the proportionately-based ‘dispersed growth’ option put forward during the Issues and Options consultation in 2020. This appears to have been discarded as an option in its own right as no ‘dispersed’ option is described in either the Development Strategy Topic Paper or in the Draft Plan being consulted upon.
• The Pink Yellow and Brown BBTM scenario most closely resembles Option 2a set out in the Draft Plan and Development Strategy Topic Paper, with most growth focussed on the EWR corridor and lower but still significant levels of growth along the A421 corridor and within or adjoining the Bedford urban area.
• The Red and Orange BBTM scenario (consisting of four new settlements and growth in/adjoining the Bedford urban area)) seems to equate to Option 3a set out in the Development Strategy Topic Paper, however it does not match any of the four preferred scenarios set out in the Draft Plan itself.
• The Brown BBTM scenario appears to resemble Option 1b, higher densities of growth within and adjoining Bedford. However, the BBTM scenario also appears to include growth at St Neots. If so, this scenario does not correlate with any of the scenarios in the Draft Plan or Development Strategy Topic Paper.
The BBTM scenarios are assessed against a range of metrics. It is clear from the assessment that options which have a rail-based and/or urban-based focus perform best across the metrics overall, but in particular traffic growth. This is understandable and to be expected, as a greater proportion of trips generated by growth in those locations will be capable of using new rail services provided by EWR. Whilst new rail stations have been represented in the model, it is not clear how the new services themselves have been represented and whether this is a factor in how the model assign trips and to what extent this is limiting traffic growth. It is noted there are some differences in the number of jobs included in each of the BBTM scenarios, but it is not clear to what extent the quantum is a factor in the results, as opposed to where they are located.
Nonetheless, the indications from the BBTM reports indicate that a rail and urban-centric strategy for housing (more than the 1500 dwellings in the Bedford urban area indicated in the Draft Plan) would mitigate against traffic growth and support a more sustainable mode share and modal shift. Such a strategy would likely result in a lower proportion of car-borne trips to Milton Keynes and a greater proportion of rail travel into Milton Keyes than other strategies with greater growth along the A421 corridor or in new settlements. This creates greater opportunity for sustainable first/last mile connectivity within Bedford but also at destinations like Milton Keynes, visited for work and leisure by residents and businesses within Bedford. Given the possible implications for Milton Keynes, we consider a rail and urban-centric strategy would be preferable in this regard.

Object

Representation ID: 6867

Received: 13/09/2021

Respondent: Mrs Joanna Ibbett

Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.

I consider that the dispersed growth strategy is still applicable which would include housing growth to existing serviced settlements, plus A421 transport corridor and rail growth, as well as the proposed new settlement of Little Barford (option 2b, in part). Such a strategy would provide 13,085 dwellings, including at least an additional 10% allowance for growth to small and medium scale housing sites associated with the existing key and rural serviced settlements. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor.
In support of a dispersed growth strategy, it makes clear at Paragraph 68 of the NPPF that the Council’s Local Plan should identify a supply of housing covering ‘years one to five, specific developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15 of the plan’. Paragraph 69 goes on further to state that ‘Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.’ The development around existing served settlements would provide for these small and medium sites, which could deliver early in the plan period negating the reliance of large urban extensions and new settlements which inevitably are built out towards the end of the plan period, and potentially beyond. It is noted within the Settlement Hierarchy (September 2018) that the main urban settlement of Bedford/Kempston provides the most services, employment, public transport and facilities, and it is therefore where additional urban development should be focused. In addition to this, further sites can be allocated to key and rural serviced settlements as identified in sections 3 and 4 of the Settlement Hierarchy report, which identifies six key service centres and 10 rural service centres. Further development in and around these settlements would support existing services and facilities. It is also noted that the report is currently being reviewed. I would like to highlight that our parish has always been classified as open countryside in the settlement hierarchy so I am surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook (site 977) would form part of the first phase of a large new town of up to 10,800 homes in an entirely rural, unserviced location.
In terms of the proposed settlement at Dennybrook (site 977) (site land west of Wyboston), this ‘new settlement’ does not provide a suitable alternative. This proposed settlement provides for around 2,500 homes. It is located very close to the existing settlement of St Neots and Wyboston and entirely engulfs the existing hamlets of Honeydon and Begwary. It appears to offer very little separation causing potential coalescence. This new settlement would also be car dependent with limited access to the wider road network due to the existing narrow roads. There is poor connectivity in terms of a choice of sustainable modes of transport, including the train. Further details in respect of the proposed development at Dennybrook are addressed in the site assessment for Dennybrook (site 977).
It is evident that the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.
Another option may be a new settlement of 2,500 homes at Twinwoods or Colworth. The Parish Council believe that the problems on the A6 north of Bedford are going to need to be resolved anyway in order to support the housing development proposed in the 2030 plan and for residents to access the east west rail station in the centre of the town. I believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre. Colworth was the site supported in the 2035 plan which was later reviewed. The A6 was not a considered sufficiently problematic to prevent this site being adopted – the site was dropped because it was difficult to mitigate against the noise from Santa Pod. So I find it hard to understand why the A6 is deemed such an insurmountable problem now.

Object

Representation ID: 7231

Received: 17/09/2021

Respondent: Ms Sally Tookey

As explained in your documents the call for sites generated a very large number of potential plots - far in excess of the 12,500 plots that are deemed to be required by 2040. These plots are scattered all over the borough allowing development to be widely distributed, thus placing a minimum burden on all existing infrastructure and negates the need to develop new "Garden villages" .
New large scale developments will bring so much burden on existing infrastructure and misery to the local residents for many many years.
Since there has and continuing to be much improved development of Bedford town centre, new home owners should be encouraged to use Bedford. The proposed housing suggested at Wyboston and/or Little Barford are closer to St Neots, Sandy & Biggleswade all within a short drive, so it will be these town centres that will prosper from the spending power of the new residents rather than Bedford.
It is far more practical to invest in the infrastructure of our existing towns & villages to improve the lives of all residents of the borough rather than a small select group.
None of the chosen 4 schemes include any development in the NW of the borough when the A6 like the A421 is described as vital transport corridor and therefore should carry some of its fair share of development.

Object

Representation ID: 7364

Received: 20/09/2021

Respondent: St Neots Town Council

The plan is predominantly inward-looking and does not adequately address cross border planning issues. Settlements of the scale proposed at Wyboston and Little Barford cannot exist in isolation. These settlements will be located only a kilometre from the St Neots border and about 3km from the town centre. For comparison, they will be over 10km from the Bedford Town Border. Despite this the proposed Bedford Borough Local Plan 2040 makes no mention of St Neots, neither has Bedford Borough Council made any effort to engage with the Town Council or our residents.

The projections for the Wyboston development in this plan also appears to significantly underestimate the eventual size of the settlements. While the plan states that Wyboston development has a size of 2500 homes, the same site is openly being marketed by Taylor Wimpey as “Dennybrook Garden Village” with an eventual size of 10800 homes.

Central Bedfordshire Council’s Draft Local Plan also includes a 7000 home development in Tempsford in addition to the new Wyboston and Little Barford settlements proposed here.

It is the view of St Neots Town Council that building up to 20,000 new homes this close will have a far-reaching impact on St Neots residents and services but without the economic benefits such as community infrastructure levy and council tax receipts.

In addition to a written response to the points raised here, St Neots Town Council requests
that a presentation is made to councillors to further discuss the points raised here and what
mitigations will be introduced to both reduce impact and realise the benefit to St Neots.

Object

Representation ID: 7424

Received: 20/09/2021

Respondent: Ms Barbara Beard

Dear Sirs, I am concerned about the future planning of Bedford Borough for the village of Wilstead and wish to express my objections for the following reasons,

1. Many people have bought homes in Wilstead because they wish to live in a village , but if the Borough build 1424 houses within the village and 4790 outside the boundary , we will no longer be a village.

2. Over 90% of people living within the village have stated that they do not want massive developments.

3. Where will children from these houses go to school? There is no space to extend the existing school therefore children will be denied places.

4. There is no doctor's surgery in the village. Currently a doctor attends the village one morning a week or residents have to go to Ampthill. Trying to get an appointment is currently almost impossible so will become even worse if so many houses are built. Numbers at the Ampthill surgery have recently doubled - there is no room for more patients.

5. The main road through the village is already getting filled with parked cars, making travel through the village difficult. If there are more residents, Cotton End Road will become impassable.

6. When our group of houses were built, a special drainage system was installed. If all the threatened houses are built , the risk of flooding will become inevitable. The drainage will become overloaded and people moving in to the village will not be able to get insurance.

7. Why is development being threatened on the South of the borough and not the North. There is surely more room for development round the villages such as Bletsoe, Thurleigh, North of Sharnbrook etc.

8. The Wilstead Village Plan has not identified and areas for new developments. Although this has not yet been adopted, the views of the existing villages should still be honoured. Already there have been developments in the village of 105 new properties, which is an increase of over 10%. This is enough. let the village remain a village community.

Support

Representation ID: 7455

Received: 20/09/2021

Respondent: Ms Helen Lawton

Preferred Option 2A

Object

Representation ID: 7457

Received: 20/09/2021

Respondent: sue solomon

This is my preferred option for development as adding to the urban areas makes more sense because everyone who lives in urban area has chosen to do so for many reasons. Urban and brownfield sites should always be the first option when planning for development. The government have stated that this should be the case. This option is the only option where St Neots and Cambridgeshire would not be badly affected from thousands of homes and people using their facilities and infrastructure, therefore putting more pressure on this council (St Neots) and not being paid for this (Council Tax would be paid to Bedford Borough Council and being too far away from Bedford town centre) All other options should be scrapped and Twinwoods should again be considered/brownfield site).

Option 2b 2c 2d (Proposed Development Sites)

All three of these options propose a massive development on the border with Cambridgeshire called Dennybrook. I strongly object to this development on greenfield land, it is grade 2 (good quality) agricultural land so it is against Government policy. It will not benefit Bedford, everyone will go to St Neots putting pressure on their roads and services.
There is a severe risk of adding tot he flooding that already happens in Honeydon regularly in the Winter. Most of the roads around Honeydon are totally unsuitable for more traffic with ditches that flood, single track and some roadside nature reserves with protected species of plants i.e. Bath Asparagus and Sulpher Clover.
We have wonderful wildlife in this area which would be devastated if building went ahead. Red Kites, Owls, Bats, Egrets, Badgers and many more species would be lost if the area was developed. All who love the open countryside moved here to existing limited homes to be part of and respect this way of life. More housing would devastate this area.

Support

Representation ID: 7459

Received: 20/09/2021

Respondent: Mrs Tilly Bartens

Lowest impact, however creates employment. Have the areas for residential development been designated? It is key that infrastructure is also developed including highways, schools/other educational establishments and medical services (Including GP surgeries).

Any developments in Stewartby must be in keeping with the village and the character maintained.
A design guide would need to be developed in consultation with the Parish Council.

Support

Representation ID: 7461

Received: 20/09/2021

Respondent: Ms Pauline Jefferies

My preferred option is 2a. The other options include 2,500 at Wyboston. When you come and drive our little village roads you will see that they wouldn’t take the extra traffic from new houses and employment, neither would the water courses. If the railway station comes to Tempsford, then houses should be built there. The new road would be in place for traffic from the houses.

St Neots doesn’t want to be overwhelmed by 2,500 houses, nor do the people who are in fear of flooding. The railway will cause enough chaos through the villages that would probably never use it. The A1 is impossible already. I don’t envy your task.

Kind regards

Support

Representation ID: 7462

Received: 20/09/2021

Respondent: Rebecca Bolt

I do not believe that the Borough (or Country) needs to build all of these new houses, but I realise the pressure comes from Central Government to do so. I have read through the Development Strategy topic paper draft alternatives and am very pleased that Option 2 is the most viable way forward. Development in urban areas and along the railway line is sensible as transport connections are already in place.
I do think that new settlements are a good option. Please do not allocate 500 houses to key Rural Service Villages!

Object

Representation ID: 7466

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

5.5 It is clear that the Bedford Business Park proposals have the potential to deliver substantial social, economic and environmental benefits for both Bedford and the wider region.
5.6 Due to the nature of the proposals and the opportunity presented, there has been a significant amount of market interest in the site for employment uses. It is envisaged that the provision of much needed high quality employment space in this location will be attractive to both new businesses relocating to the area and existing local businesses looking to grow. This includes large scale industrial and logistics occupiers, advanced manufacturing and research and development companies which are increasingly seeking high-spec new build premises, rather than second-hand stock. SEMLEP has confirmed that Cloud Wing’s proposals fit well with the strategic economic vision for the area (Appendix 1).
5.7 Furthermore, due to the unique scale and locational characteristics of the site, there is potential to capture regional and national opportunities that would not be possible on a smaller site. Indeed Cloud Wing has been approached by SEMLEP and the DIT to explore the potential for the site to accommodate an EV Gigafactory to support the Country’s transition to electric vehicles which would deliver significant high-quality employment opportunities for Bedford and secure major international investment in high-tech manufacturing.
5.8 It is also being explored whether the site might be well-placed due to its size and location to contribute to the wider modal shift of logistics from road to rail through rail freight opportunities being promoted by the NIC. This modal shift is being driven by wider challenges facing the UK’s freight system including decarbonisation, congestion and how technological advancements can assist in meeting increasing societal demands. The role of rail freight in addressing these challenges has recently been endorsed by the Government in its response to the NIC’s Report ‘Better Delivery: A Challenge for Freight’ which confirms that the ‘Future of Freight’ Strategy is due to be published by the DfT later this year.
5.9 This therefore demonstrates the substantial benefits and opportunities afforded by the Bedford Business Park, which will not only boost local job creation and economic growth, but provide the ability for Bedford to contribute to, and benefit from, national growth objectives and opportunities, shaping Bedford’s identity as a new hub of prosperity at the heart of the Arc.
6.45 The PPG states that a site is: “considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.46 Cloud Wing control the site and therefore there are no legal ownership or other technical impediments to delivering development on the site.
6.47 Furthermore, the site is being actively promoted for economic development and is the subject of an outline planning application currently pending determination.
6.48 Accordingly, the site is available now in NPPF terms.
Availability
“considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.49 As per the NPPG, a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in term, including an assessment of the economic viability of a site.
6.50 Given the scale of development proposed for the site, the development will be delivered over several phases. This will include ground remediation works and the delivery of transport infrastructure in the first phases, as set out below:
Achievable
Phase 1 – ground remediation works in the location of the former Kempston Hardwick brickworks
Phase 2 – construction of bridge proposed over the railway line and main road infrastructure
Phase 3 – construction of employment uses in areas where no ground remediation works are required
Phase 4 – construction of employment uses on the former Kempston Hardwick brickworks location
Phase 5 – construction of employment uses in the south of the site.
6.51 Whilst the timings for delivery are dependent on achieving a planning permission and identification of a Development Partner, both of which are currently ongoing, it is anticipated that it would be possible to start on site with site clearance, remediation and enabling works within 6 months of receiving an outline planning permission, following the discharge of any relevant planning conditions. It is anticipated that works to deliver the primary infrastructure for the first phase would then commence approximately 6 months later, following the grant of reserved matters, with the aim of the first phase being complete and ready for occupation within 18 months. 6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
6.52 As set out above, there are no significant site constraints that might prevent development or make the development unviable.
6.53 Therefore, it is considered that the site is achievable for development as there is a realistic timeframe for development and there are no economic viability constraints that would hinder delivery.
Deliverability Summary
6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
Changes requested:
– That the Council recognise the substantial benefits and opportunities presented by the Bedford Business Park by identifying it as a proposed allocation in the emerging Local Plan.
– We request that the site is formally allocated for economic development within the emerging Local Plan and that the Site Selection Methodology be amended to better reflect the range of factors and key characteristics that are relevant for assessing the merits of employment land.
See 59 page attachment relating to Bedford Business Park.

Object

Representation ID: 7471

Received: 21/09/2021

Respondent: Mr Aaron Keep

Hello. I’m a resident within Stevington and live on Park Road I’ve had a view on the 2040 planning and especially the “call for sites”
I’m writing to express concern in any major developments within Stevington. Our infrastructure can not cope with volume of new houses and I see a couple of sites have been listed.
Stevington is a true Saxon village with charm and still a true village feel, this is becoming rare within the U.K. and whilst I see that more housing is needed, there is a need and necessary protection of Bedfordshire villages and keeping them as original as possible
I really hope that you see and understand the views and help to protect proper villages from mass housing.

Object

Representation ID: 7475

Received: 21/09/2021

Respondent: Ms Sally Gilpin

I have received a letter through my door – I am resident of Cople, Bedfordshire regarding the 2040 local plan.
I notice in the letter it states that “All residents have received a summary of the consultation document….” I have never received this.
I would like to object to the large amount of houses proposed under options 2d 3c and 4 of over developing the lovely Bedfordshire villages, Cople, Cardington, Willington and Great Barford among others.
Where has option 1 gone to develop the Urban areas? You will be ruining the nature of these villages, which do not have the infrastructure for roads and services to cope with more houses. We need to be preserving our countryside villages, not merging them all into one.
You will be ruining what is the nature of Bedfordshire as a rural environment – why are you so set on Rural Growth? Have you really asked everyone and given them chance to properly understand what you are proposing? This is not what people who have chosen to live in Villages want to see.
Why has option 1 been rejected?

Support

Representation ID: 7477

Received: 21/09/2021

Respondent: Ms Rachel Chico

First, I wish to say that - yet again -there appears to be no plans to build on the North side of the county. I would be interested to see a breakdown of building on a map over the last 2-5 years. It doesn't appear to be fairly spread out.
I would also like to ask where there are a substantial of amounts of 'brown belt' sites that are not being used? For example; why is Thurleigh airfield not being considered for development?
Of the options shown, I feel that option 2A or 2b would be good enough. However, I would still like my comments above to be taken into consideration.

Support

Representation ID: 7516

Received: 21/09/2021

Respondent: Gene Murrell

I would favour 2A planning.

Question:
Why is there no building (again) in the North villages?
Why has not Thurleigh airfield been considered in the spirit of Brown belt development?

Support

Representation ID: 7530

Received: 21/09/2021

Respondent: EF Wootton and Son

Agent: Phillips Planning Services

Our client strongly 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 (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 Wybsoton, are not being taken advantage of.

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).

We would therefore suggest a more refined assessment is undertaken on capacity and that the opportunities found in the eastern parishes are examined more closely. We would strongly object to any strategy that ignores the eastern parishes.