3.16

Object

Representation ID: 7543

Received: 21/09/2021

Respondent: Bates Bros (Farms) Limited

Agent: Phillips Planning Services

3.0 Emerging Preferred Options – 2a, 2b, and 2c
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.

Support

Representation ID: 7544

Received: 21/09/2021

Respondent: Bates Bros (Farms) Limited

Agent: Phillips Planning Services

3.0 Emerging Preferred Options – 2d
In respect of land south of School Lane, Roxton (site ID 685), our clients support growth Option 2d which seeks to distribute growth along the entire A421 corridor including in the Rural Service Centre of Roxton. This option will contribute towards the Governments strategy of delivering a growth corridor between Oxford and Cambridge.

Object

Representation ID: 7549

Received: 21/09/2021

Respondent: Luton Borough Council

In our response to the Issues and Options consultation in September 2020 we raised concerns with regard to the sustainability of the option which provided housing growth along the A421. In particular we considered that development along the A421 would promote reliance on the private car and result in development that fails to meet national and local objectives to reduce climate change and improve air quality. We suggested that housing and employment delivery options that can be directly served by the rail network should be given significant priority.
We note that the consultation document identifies four emerging preferred growth strategy options (Options 2a, 2b, 2c and 2d), with housing development in the A421 transport corridor with rail based growth as part of all four options.
The Development Strategy Topic Paper (June 2021) that accompanies the consultation document summarises the sustainability appraisal testing of the reasonable alternatives, including the four emerging preferred growth strategy options. Paragraph 3.19 of the Development Strategy Topic Paper states:
‘In summary the sustainability appraisal shows that options 2a, 2b, 2c and 2d collectively are the best performing options. All four sub-options have an urban focus in common. However, option 2a performs better than the others because it concentrates most growth at the rail based location at Stewartby/ Kempston Hardwick (60% of total growth). This means that there is a high probability that public transport and cycling will be an attractive alternative to private car use for a significant proportion of total new growth.’
The assessment of Options 2a, 2b, 2c and 2d against the draft plan theme ‘2. More accessible’ in the table that follows Paragraph 3.23 of the Development Strategic Topic Paper repeats this view:
‘Although the need to travel is expected to rise, the high concentration of development near to rail stations and the use of bus facilities in the transport corridor are likely to encourage the use of public transport and cycling.’
However, the Bedford Borough Transport Model Local Plan Assessment has not tested the ‘long list’ of options (Options 1a through to 7), including the emerging preferred growth strategy options, but has instead to date only tested the potential locations for growth identified in the 2020 Issues and Options Consultation (Options Grey; Pink, Yellow and Brown; Red & Orange; Brown) and the new settlement options.
The table following Paragraph 3.31 in the Development Strategy Topic Paper identifies those options which, on the basis of the analysis to date through the sustainability appraisal, assessment against the local plan themes and the transport modelling work, perform the most strongly. One of the ‘Key strengths’ identified for Option 2a in the table is:
 ‘Potential for higher density development around rail hubs at Wixams (MML) and Stewartby and Kempston Hardwick (EWR) facilitating active travel modes and accessible neighbourhoods in proximity to new business park/ science park development’.
However, significant ‘Weaknesses and delivery challenges’ are also identified for Option 2a including:
 ‘The A421 is a key link and additional growth is a challenge to its capacity.
 Viability and land assembly challenges for urban land and timing of delivery in some cases dependent on EWR delivery.
 Delivery of new rail stations is proposed, but not yet confirmed.
 Lead in times for remediation of the Kempston Hardwick area and delivery of new rail stations mean that development in this part of the transport corridor will occur later in the plan period.’
Luton Council remains concerned that housing development along the A421 would not be sustainable unless it will be directly served by the rail network and the delivery challenges can be overcome. Detailed consideration should be given to these matters as part of the next steps in the technical work for the Local Plan’s preparation.

Object

Representation ID: 7558

Received: 21/09/2021

Respondent: C Smith

3. Preferred Choices of Options Listed and Options Not Included
The consultation asks for suggested for most preferred options and to include 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 907 – option 2b) is by far the most appropriate alternative, but excluding Wyboston / Dennybrook (see section 5 below), which would provide additional 3,085 dwellings in the rail corridor, for the following reasons:
• A development in and around the urban area plus 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 833) or Colworth (site 1002)
A new development 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 has been needed for some time to provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in the future to provide sustainable transport for those in the north of the Borough.
Twinwoods (site 883) would provide a significant proportion of brownfield land and Colworth (site 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.

4. Government Planning Policy – Application and Relevance to These Proposals
Government planning policy requires that brownfield sites be selected as a much greater priority than greenfield sites for very robust reasons. One of those reasons they quote is that developments must recognise “the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land” and that “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”.
In further support of this a relevant definition within the National Planning Policy Framework is:
“Best and most versatile agricultural land: Land in grades 1, 2 and 3a of the Agricultural Land Classification”.
The land proposed for Dennybrook at Honeydon and Wyboston is mostly grade 2.
There are alternative, much more suitable, sites which are brownfield land at Twinwoods (site 883) and Colworth (site 1002) and much of the site at Little Barford.
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: 7561

Received: 21/09/2021

Respondent: McCann Homes

Agent: Sir or Madam

I write on behalf of our client, McCann Homes, in response to the Council’s consultation on the Local Plan 2040 – Draft Plan: Strategy Options and Draft Policies document, and supporting documents, particularly in respect of the land at Bromham Road, Biddenham (shown on the enclosed site plan). McCann are a local, Milton Keynes based, developer and are currently in negotiations with the landowner in respect of purchasing the site at Bromham Road.
One of the Council’s objectives, set out at Section 2 of the Draft Plan document, is to “Provide appropriate amounts and types of housing to meet the needs of the borough’s urban and rural communities over the lifetime of the Plan making the housing stock more adaptable and resilient.” This is reflective of wider national objectives, with the Government seeking to significantly boost the supply of housing, and is key to responding to the ongoing housing crisis.
Section 3 identifies the need for an additional 305 dwellings per year from 2020 to 2040, representing a substantial increase (over 30% more) on the current local plan target of 970 dwellings per year. The Council itself recognises the considerable challenges this will bring, and the Council’s proactive approach to addressing this issue is welcomed.
The Council has identified a number of potential development strategy options for the quantum and location of growth in the Development Strategy topic paper, and the Council’s preferred options are set out in the Draft Plan document. All of the development strategy options include growth in and adjacent to the urban area, which was found to perform best in the sustainability appraisal, particularly in relation to reducing carbon dioxide emissions, promoting town centres, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel.
We too support growth within and adjacent to the urban area, considering this to be the most appropriate and sustainable way to meet local housing needs, and an approach entirely in accordance with the National Planning Policy Framework (NPPF). The land at Bromham Road is enclosed on three sides by the urban area boundary, which runs along Bromham Road to the north and east of the site and along the A4280 to the south. Development of the site to provide residential dwellings is therefore entirely in line with the Council’s preferred strategies, and accordingly it is respectfully requested that the Council consider this site for allocation in the new Local Plan.
It is acknowledged that a Call for Sites exercise has already been undertaken but given the location of the site, within an area identified as being the best way in which to meet development needs, it is considered appropriate to assess it even at this stage. Indeed, it would be remiss not to, and it is not beyond the Council’s ability to consider sites submitted
outside of a formal Call for Sites process.
It is not just the case that the site is bounded by the designated urban area; land to the north and south of the site is already visibly, and continues to be, developed for residential dwellings, and the development of the site would infill between other built development. To the north of the site there are existing residential dwellings along Bromham Road.
To the rear of these, outline planning permission has been granted (ref. 19/01394/MAO) for residential development, and the site is allocated by Policy 23 of the adopted Local Plan. To the south of the site, outline planning permission has been granted (ref. 18/00140/MAO) for up to 249 dwellings, with reserved matters approved (ref. 21/00236/MAR) for the first 119 of these. The site would be a logical infill between existing and emerging residential development to the north and south.
Situated between the A4280 and the existing development along Bromham Road, the site makes little contribution to the gap between Biddenham to the southeast and Bromham to the west, and will contribute even less once the emerging development set out above is complete. It is acknowledged that previous policies, including the 2002 Local Plan and the 1994 Biddenham Loop Development Brief, sought to keep the site and its surroundings free from development. However, its surrounding context has now changed so significantly, and the need to provide housing has become such a priority (the Inspector gave significant weight to the contribution to housing supply in determining the
application for development to the south of the site (ref. 18/00140/MAO)), that the development of this site for new residential dwellings should no longer be resisted. Built development would be contained by the River Great Ouse valley to the west, a highly defensible and also logical boundary, which will ensure a permanent gap between Biddenham and Bromham is maintained.
The site is relatively unconstrained: it is not in an area of flood risk; it is flat; and there are no trees or other significant features within it. It does not comprise a protected or high-quality landscape and is not particularly visually prominent within its surroundings. The site does not comprise quality agricultural land and is isolated from other agricultural land.
There are no listed buildings on the site or in close proximity.
The site can be easily accessed via an existing entrance in its northwest corner from Bromham Road. The site is highly accessible being located adjacent to the A428, 2km (2 mins drive) from the A422 to the west and 2.5km (3 mins drive) from the A6 to the east. Bus stops on Bromham Road, immediately adjacent to the site, provide access to services between Bedford town centre and Northampton. Bedford rail station is located approximately 3km (5 mins drive, 10 mins cycle) from the site and provides services towards London and Brighton, Bletchley and Corby. The site is a short
walk to both Biddenham (500m, 6 mins) and Bromham (800m, 9 mins), both of which provide a number of community facilities including schools, doctors’ surgery, supermarket, village hall, library, restaurants, pubs, recreational open space and sports pitches.
Development of the site would not require additional infrastructure and so could come forward quickly. The Council acknowledges that larger sites can have a significant lead in time before development commences, and Paragraph 69 of the NPPF recognises the important contribution that small and medium sized sites can make to meeting housing requirements. With the majority of the Council’s preferred development strategy options reliant on the delivery of at least one new settlement, the development of smaller, well-supported sites such as this will be necessary in order to meet housing need. This will be all the more important considering that the increased housing figure is being applied from 2020, but the Plan is not likely to be adopted until 2023 at the earliest; therefore, the delivery of sites quickly at the beginning of the plan period will be crucial in ensuring the increased housing need can be met without further delay.
Overall, the site is a highly sustainable location for development and is entirely suitable for new homes. It is situated between existing and emerging residential dwellings; its development would be in keeping with this surrounding context and a logical infill of the urban area. The site has little, if any, physical constraints, is accessible by public transport as well as the highway network, and is supported by existing community infrastructure. It is available and deliverable now
and will make a valuable contribution to the Council’s housing land supply. The development of the site would be wholly in line with the NPPF and the Council’s own preferred development strategies, and would enable other sites, which contribute to the economy, such as employment or retail space, or to the environment, such as protected landscapes, and rural areas to be protected from the pressures of development.

Support

Representation ID: 7565

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

Before the individual options are addressed, some general points are made. The Council has expressed the total residual housing requirement as a single figure for Options 2a and 2c, and as two figures for Options 2b and 2d. In the case the second pair, the entire difference of 585 dwellings (equivalent to 4.7% of 12,500) is explained by the difference in the size of the potential new settlements at Wyboston and Little Barford, the latter being a much more significant 23% larger than the former. There is also an inconsistency in that new settlements both at Wyboston and Little Barford feature in Option 2c, with the same difference in size but within a total residual housing requirement of 12,500 dwellings, rather than 13,085 dwellings. Nor is there any explanation of the reason for the difference in the figures, either in overall terms or for example in terms of capacity or thresholds for the provision of services at the potential new settlements. In respect of thresholds, even the larger figure of 3,085 dwellings is well below that which would require the provision of a new secondary school, but both new settlements at the size proposed would need in the order of three to four forms of entry for primary schooling. Provision of open space and the need for primary health care would in contrast be proportionate to the size of the likely total population. We return to the question of thresholds below. There are clearly elements common to all the options. The first two bullet points for all options refer to 1,500 dwellings within the urban area and a further 1500 adjacent. We support these elements in the sense that they represent some kind of sequential approach. This will be a sustainable strategy in that it accommodates as much development as possible in or next to existing urban areas, reducing the amount of greenfield land taken and the total extent of incursion into the open countryside. Precisely the same can be said of Site 951, as it is effectively next to an existing urban area; it should therefore be regarded as a fixed or common element to all the options.
Despite the fact that the Council has left behind some of the less plausible or appropriate options put forward at the Issues an Options stage, there is nevertheless a significant degree of strategic choice both available and necessary.
Given the similarities between Options 2b and 2d, we address the options in this order: 2a, 2c, 2b and 2d.
Option 2a
Although this option is described as being based on transport corridors the illustration on page 20 of the Local Plan document makes it look much more like the peripheral expansion of Bedford, creating a much more asymmetrical shape to the town which may lead to a less sustainable pattern of transport than could be achieved.
One possible drawback of this option is that it does not take advantage of the potential new railway station on the East-West route as shown on the diagram south of St Neots, although we have doubts about the extent of modal shift that the completion of the rail link will bring about.
We conclude that Option 2a should be discarded at this stage.
Option 2c
This option involves a new settlement at both Wyboston and Little Barford, unlike Options 2b and 2d which involve just one. Eclipse Planning Services considers that to rely on new settlements to deliver 5,585 dwellings, representing 44% of the total residual requirement, is a strategy which may be difficult to deliver. The Plan document provides no explanation of the derivation of the figures. However, it is clear from an examination of the information submitted by the promoters of site 907 at Little Barford (which appears to include site 892 in its entirety) that the figure of 3,085 represents the total capacity of the land (3,955 dwellings) less the number (870) assigned to the period beyond 2040. In other words, the capacity and phasing figures are those provided by the promoters and they have not, it would appear, been subject to any kind of independent assessment or verification.
This option would also locate a high proportion of the residual housing requirement at a greater distance from existing employment opportunities and higher order services at Bedford than other options. We have argued that proximity to St Neots is a significant advantage for Site 951. This however is considered not to apply to Option 2c because of the significantly greater scale of the two potential new settlements, and they are not as close to St Neots as Site 951. Although St Neots is an important employment and service centre, with a population of a little over 30,000 it is significantly smaller than Bedford. Option 2c is therefore likely to result in greater numbers and aggregate distances of journeys to work and for other purposes, particularly shopping for comparison goods and for leisure.
We conclude that Option 2c should be discarded at this stage.
Options 2b and 2d
Attempting to depict each of the four options for the entire Borough on a small part of an A4 sized document imposes severe limitations on the level of detail possible. As things stand, and notwithstanding the limitations imposed by the scale of mapping, we infer that Site 951 is not included in either of these options. If this inference is correct, we would strongly urge the Council to reconsider this and to look in more detail at how these options could be properly shaped.
Both options involve a new settlement at either Wyboston or Little Barford. In the case of Wyboston, the origin of the capacity figure for the new settlement does not appear to be directly derived from the information supplied for site 977, where the claimed capacity is 5,150 dwellings in the Plan period with even more beyond. As with the figures for site 907, there appears to have been no independent assessment. However, in this case they are at least plausible, in the sense that the capacity of the land put forward far exceeds what will be needed.
Option 2d differs only from Option 2b in the location of a relatively small proportion of the residual housing requirement in the transport corridors. Of far greater significance is the choice between Wyboston and Little Barford as the location for a new settlement.
We consider that no significant difference would be made to the thresholds for facilities and services at any new settlement at Wyboston or Little Barford by the allocation of site 951 for among other things the 485 dwellings put forward at the Issues and Options stage. Such an allocation would however carry a significant advantage in terms of keeping incursion into the open countryside to a minimum. It would provide more convenient access to services, facilities and employment in St Neots. In this context we consider that a new settlement at Wyboston would be preferable as site 951 could provide almost as many dwellings as the difference of 585 between Wyboston and Little Barford.
Eclipse Planning Services therefore supports Option 2d subject to the inclusion of Site 951 as part of it.

Object

Representation ID: 7573

Received: 21/09/2021

Respondent: Mrs Claudette Slater

Options 2A and 2D

I object to both of these options insofar as they impact on Renhold. Both options bring the probability that Renhold will be significantly urbanised with a loss of character and a considerable increase in volumes of traffic. Renhold’s roads, especially around the school and church, cannot handle the traffic at today’s levels. Theres no prospect of the existing lanes being improved. Urban extensions would depend on access from Wentworth Drive or Norse Road, which would be difficult, if not impossible to achieve for significant numbers of dwellings or commercial units.

Object

Representation ID: 7575

Received: 21/09/2021

Respondent: Mrs . Eason

Dear Sir,

Re the local plan 2040 consultation. I received the leaflet that lists options 2a-d. I am horrified that development at Wyboston appears in 3 of them, surely Government planning policy states that brownfield sites should be selected in preference to greenfield sites. It also states; “where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those at a higher quality”? The land at Wyboston is grade 2 (almost the best), therefore I hope the planners will use the brownfield sites such as Twinwoods.
In view of the effects of the pandemic on retail outlets, surely there are now sites in the existing urban area that would provide opportunities for both housing and employment close to the services that don’t exist in rural areas.
There are many other negatives to squandering 700 acres of productive farmland and peaceful countryside so I hope the final plans will not include Wyboston (or the poorly named “Dennybrook”)

Yours Faithfully

Mrs Eason

Support

Representation ID: 7577

Received: 21/09/2021

Respondent: Mr Michael Jefferies

Option 2a clearly the option that would most benefit Bedford town and its amenities and my preferred option.

Option 2b and 2d – A new settlement at Wyboston previously put forward as Wyboston Garden Village in the 2030 consultation has all the disadvantages which were put forward before. Particularly the inadequate roads which would be extremely detrimental to Chawston, also the majority of new residents would use Eton Socon and St Neots for its amenities, both of which already suffer from traffic overload and not Bedford. If either of these options were adopted then a settlement at Little Barford would be the least worst of the two being on the East side of the A1 with better access to the new Black Cat to Caxton Gibbet road and the new East West rail station if that does happen.

Option 2c – like 2b and 2d only twice as bad. A nightmare for Eaton Socon, Eynesbury and St Neots which are already dealing with large scale housing developments. Also with Mid Beds considering development on the old airfield site at Tempsford, this is too great a concentration of development in one area.

Support

Representation ID: 7578

Received: 21/09/2021

Respondent: Mr Michael Wadsworth

Page 21 Option 2b

I fully support this above option.

Object

Representation ID: 7770

Received: 22/09/2021

Respondent: Amanda Quince

Paragraph 16
Flawed Consultation – Time limited to Summer Holiday period is far from ideal.
-ONS presents unjustified growth for Bedford
-Conflict/additional demands of Ox-Cam. Arc and EW Rail – Why is there no joined-up thinking?
-Inconsistency
-Lack of clarity – Options is etc are buried deep within the paperwork.
PARAGRAPH 3.1 – Far too many houses in one of the smallest counties
-No surety that houses will be built to meet local needs.
PARAGRAPH 3.15 – Object to Dennybrook (coloured brown in original consultation)
This is NOT brown but green-open space. Arable land.
Object to 2d – 421 corridor will spill out into Renhold even though Renhold is not included at this stage.
Object to 1a – Urban sprawl will affect rural nature of Renhold.
Support 2a – Rail growth development to South of Bedford.
EWR to the North of Bedford gives residents in Renhold nothing – other than loss of open countryside.

Object

Representation ID: 7772

Received: 22/09/2021

Respondent: Mrs B Dearman

As a resident of Renhold I have chosen to live in a Rural setting. I object to Option 2d
Option 1a
Reasons are:
1. If you should build on brownfield sites rather than green spaces and arable
2. Development on agricultural land is against Government policy
3. We have ancient woodland and rich biodiversity which we must protect at all costs.

Support

Representation ID: 7774

Received: 22/09/2021

Respondent: Lance Feaver

The inclusion in the 2040 plan of the new garden village sites at Twinwoods or Colworth are, in my view, unsustainable because:
• Significant infrastructure would be needed to support such developments
• The surrounding villages have already accepted increased housing requirements, some of which have been reflected in the adopted Neighbourhood Development Plans (“NDPs”) so there will already be increased capacity issues (and makes one question what the point of the NDP was, if simply overridden by settlements of this size)
• The main road network North of Bedford is already heavily overloaded, and increasingly dangerous; things are likely to get far worse in any event.
• The smaller village roads (where historical road widths and excessive roadside parking already create blockages/single lane passage) will also become more congested, possible being used as rat runs in an effort to avoid traffic.
• New settlements away from the EWR proposed route will only increase car travel, and efforts to encourage walking and cycling from these locations is unlikely.
• They are not near any rail or bus hubs; without new ‘hubs’ being built, these areas will be poorly integrated.
• The character and amenity of the Great Ouse Valley, already potentially damaged by the EWR route will suffer further harm with the addition of new settlements of the size proposed.
The A421 corridor seems to represent a much better location for growth and should be prioritised.
Opportunities for growth option 2c would appear best placed to do this.

Support

Representation ID: 7781

Received: 23/09/2021

Respondent: National Highways

The LP currently has four emerging preferred options for its spatial strategy;

Option 2a:
• Within the urban area (1,500 dwellings);
• Adjoining the urban area (1,500 dwellings), up to 51 ha employment;
• Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (high option) (7,500 dwellings), up to 80 ha employment;
• Transport corridor – south: land within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton (2,000 dwellings); and
• Total 12,500 dwellings and up to 131 ha employment

Highways England broadly welcomes developments within the existing urban area in principle. Trips generated by developments within this area have the possibility to remain internal to the town and/or make use of sustainable transport options and therefore may have a smaller impact on the wider Strategic Road Network (SRN) than development in alternative locations.
Furthermore, Highways England supports development on the rail transport corridor as this could encourage longer distance trips to make use of more sustainable methods of transport. It should be noted that the areas of proposed development are also located adjacent to the A421 corridor and will have a notable impact on a number of junctions, in particular the A421/A6 and A421/A428 junctions.
Option 2b includes the following:
• Within the urban area (1,500 dwellings);
• Adjoining the urban area (1,500 dwellings), up to 51 ha employment;
• Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (low option); (5,500 dwellings), up to 80 ha employment;
• Transport corridor – south: land within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton (1,500 dwellings);
• New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings), up to 20 ha employment; and
• Total between 12,500 and 13,085 dwellings and up to 151 ha employment.

Option 2b is similar to Option 2a, and therefore the conclusions reached for that option broadly apply to option 2b. However, Option 2b also includes a proposed new settlement at either Wyboston or Little Barford, which are remote from the other development locations proposed within this Option. Whilst, as with Option 2a, there are potentially benefits of proposed development locations in the town centre and in rail based growth parishes, the development in Wyboston or Little Barford will have significant impacts on the SRN. Highways England, therefore considers that a well-integrated and significant sustainable transport provision is essential to ensure that these relatively isolated development does not become overly reliant on car use.

Option 2c includes the following:
Within the urban area (1,500 dwellings);
Adjoining the urban area (1,500 dwellings), up to 51 ha employment;
Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (extra low option; this being the residual required to meet need) (3,915 dwellings), up to 80 ha employment;
New settlements at Little Barford (3,085 dwellings) and Wyboston (2,500 dwellings), up to 20 ha employment; and
Total 12,500 dwellings, up to 151 ha employment.

Option 2c includes proposed new settlements at Wyboston and Little Barford, as opposed to option 2b, which indicated that just one of the two new settlements would be brought forward. Furthermore, this option would include no development in the southern parishes. As per Option 2b, there is the potential that these proposed new settlements could have a notable impact on the SRN. As with Option 2b Highways England recommends that a well-integrated and significant sustainable transport provision is essential to ensure that these relatively isolated developments do not become overly reliant on car use. This option appears less sustainable than other options outlined.

Option 2d includes the following:
• Within the urban area (1,500 dwellings);
• Adjoining the urban area (1,500 dwellings), up to 51 ha employment;
• Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (low option) (5,500 dwellings), up to 80 ha employment;
• Transport corridor – south: land within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton (750 dwellings);
• Transport corridor – east: land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston (750 dwellings), up to 28 ha employment;
• New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings), up to 20 ha employment; and
• Total between 12,500 and 13,085 dwellings, up to 179 ha employment.

Option 2d is similar to Option 2b, although there is also development proposed within the A421 corridor to the east of Bedford. Therefore, Highways England’s comments regarding Option 2b are also applicable here, however the additional proposals on the transport corridor: east could result in a wider impact on the A421 junctions. Similar to other Options a well-integrated and significant sustainable transport provision is essential to ensure that these relatively isolated developments do not become overly reliant on car use.

Object

Representation ID: 7787

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

3.11. It is assumed that any sites within Parishes adjoining the urban edge would qualify for consideration in the Adjoining the Urban Area’ category. That is, sites for example in Renhold could be allocated as part of the 1,500 figures, it is not simply sites within the southern Parish’s which adjoin the urban area, that is a separate category. If that is a correct interpretation then our client supports the preferred growth options which all include sites adjoining the urban area. 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.

3.12. All the preferred strategy options also propose development of 1,500 dwellings within the urban area. Clearly there is merit in re-using urban sites and locating new homes close to key infrastructure, shops and services. However, concern is raised as to the deliverability of the levels of growth proposed. The evidence base so far provided does not clearly demonstrate where the 1,500 homes would be accommodated within the urban area within the proposed plan period.

3.13. Urban sites are often constrained by existing uses, including commercial operations, car parks, supermarkets, government buildings etc. and / or have complicated ownerships and sitting tenants such that delivery is slow and uncertain. As the Council will be aware a number of urban sites were previously identified as opportunity sites or ‘Areas of Change’ in the Town Centre Area Action Plan and so highlighted for potential development back in 2008. The majority of these have still not come forward some 13 years later. There is also concern regarding the viability of urban sites to come due to higher existing use values but more specifically to come forward whilst delivering a full policy compliant level of affordable housing.

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

3.15. All of the preferred growth options include reference to the “A421 transport corridor with rail-based growth parishes and southern parishes.” The reference to the A421 transport corridor suggests that development close to the A421 would be favoured. This approach obviously has great merit as the A421 provides excellent linkages to the west and east and is also central to the Oxford to Cambridge arc. However, the Transport Corridor options included in the list beneath the title seem to then reference only parishes south of the A421. This appears to ignore for example Renhold and its sustainable location close to a major junction onto the A421 (unless Renhold is considered to fall within the ‘Adjoining the Urban Area’ category as highlighted above). Notwithstanding this, it is considered that the corridor strategy should properly consider all sites well related to the A421 but not necessarily only the southern parishes.

3.16. Of all of the Spatial Options the sustainability appraisal considers Option 2a the most sustainable. This excludes new settlements. Whilst new settlements can be important in delivering new infrastructure, they can also take longer to start making a contribution towards housing supply. It was the proposal for the Colworth new settlement falling away which ultimately resulted in an unsatisfactory Local Plan to 2030 and a need for an early review. Concern would again be raised as to how a new settlement(s) may come forward and if they are to be part of the strategy, then a realistic trajectory must be considered, with adequate sites identified to meet the projected requirements, with new settlements coming forward in parallel and delivering in addition and as part of our suggested uplift.

Object

Representation ID: 7882

Received: 23/09/2021

Respondent: Terry & Maureen Wright

Agent: Bidwells

1.1 This Issues and Options representation is made on behalf of Mr and Mrs Wright who have land
interests in Chawston in Bedford Borough.
1.2 The site has not been previously put forward through the Call for Sites, however, the Call for
Sites form is included within this submission.
1.3 The Strategy Options document that is being consulted on was prepared ahead of the publication
of the revised National Planning Policy Framework 2021 (NPPF). A requirement was introduced
within Paragraph 22 of the revised NPPF for Local Plans proposing new settlements or urban
extensions to towns/villages to be set within a vision which looks at least 30 years ahead.
Paragraph 22 will apply to the Bedford Borough Local Plan based on the transitional
arrangements that have been put in place and as a result, the Council will need to undertake
additional work to establish a longer-term vision for the Local Plan 2040.
1.4 This representation sets out a number of comments and concerns in relation to the proposed
strategy set out in the Draft Strategy and Options Document.
1.5 Land off Chawston Road, Chawston
1.6 The site outlined in red is circa 5.117 hectares and is located to the north of Chawston Lane.
There are currently three access points off of Chawston Lane to the south The site comprises
agricultural land currently. To the west and south of the site is employment land utilised by a
range of different businesses alongside some residential dwellings. As outlined below, the new
A428 link road will be located immediately to the eastern boundary of the site. Between the
proposed road and the current A1, are located some residential properties including a listed
building with the A1 lying to the east of this.
1.7 It should be noted that there are plans for a new link road that will lie adjacent to the site
boundary on the east. Highways England have submitted a Development Consent Order in
February 2021 with the examination stage commencing on 18th August 2021. It is anticipated that
the required land sale, off Mr and Mrs Wright, and the commencement of this construction will
start in 2022. This new road will provide an access point to this site maintaining the number of
access points.
1.8 The site is located in a strategic position, to the north-east of the Black Cat Roundabout between
Chawston Road and the Great North Road (A1). It would be anticipated that the site access
would be provided off of either Chawston Road (to the south) or the road to be constructed (to
the east).
1.9 The construction of this proposed road will lead to the site being opened up and being a prime
development site located adjacent to the strategic highway network with this being a logical place
for an employment allocation due to the surrounding uses being primarily industrial areas thus
meaning this is not a typical rural location due to the hustle and bustle of the locality.
1.10 The site is largely unconstrained with there being no current policy allocations or designations on
the site. There are no significant trees or vegetation on the site, no topographical constraints. No Public Rights of Ways or landscape/heritage designations have been identified on the site. The
site is located within Flood Zone 1 and therefore would be appropriate for development. If any
constraints are identified these can be appropriately addressed through mitigation methods.
1.11 Due to its proximity to the strong road infrastructure, including the current A1 and A421, and the
surrounding developments, it is thought that this site would be suitable for employment uses as
opposed to residential development. The proposed improvements to the A428 and A1 at the
Black Cat Roundabout will additionally further increase the sites proximity to the strategic road
network. The new intersection will mean the site will be within circa 1 mile of this facility meaning
easy connections to the A1 (leading north and south) and the A428/A421 (leading to the east and
west).
1.12 This site is available for development.

Object

Representation ID: 7885

Received: 23/09/2021

Respondent: Pippin Enterprises Ltd

Options 1A and 2D

Renhold is not identified as a parish to take growth, but Options 1A and 2D have the potential to fundamentally change its character, which is a collection of ‘ends’ separated by tongues of farmland.
Option 1A supports development adjacent to the urban area. Renhold adjoins the urban area and any development here would cause the rural village to coalesce with the town, changing its character altogether. I object to this possibility.
Option 2D supports development along the A421 corridor. This seems sensible but the diagram includes an area in Renhold even though it is not identified as a development location. At the very least the shading in Renhold around the A421 junction should be removed.
In respect of both of these options, apart from the urbanisation of a rural village, a principal concern is traffic. Renhold has only rural roads, in places nearly single carriageway. There are already heavy traffic loads and the village is doing everything it can to reduce both volumes and speeds.
Significant development everywhere in the village has the probability of greatly increasing volumes and numbers of HGVs to the detriment of the entire village population.
If option 2D is eventually selected the area shown to the Renhold and Wilden side of the A421 should be excluded and consideration given to closing the Green End access to the village.
If Option 1A is selected, Renhold should be identified as an exclusion area.

Object

Representation ID: 7886

Received: 23/09/2021

Respondent: Mr J Dearman

I object to Option 1a and 2d.
My reasons are:
1. Renhold is a small rural village with limited facilities.
2. Although we are close to Bedford, we want to protect local gaps and keep the green buffer zone.
3. Our school is over-prescribed.
4. The local GP practice has closed its list.
5. The roads are crumbling, the village is a rat run, so speeding and volume of traffic is a problem.

Support

Representation ID: 7887

Received: 23/09/2021

Respondent: Mr Anthony Tuxill

Para 3.0 – Growth and Spatial Strategy Options.
I am supportive of Option 2C. This will be the only option that will maintain the separation between the villages and hamlets especially in the Southern area of Bedford.
Already Shortstown has had large development with further building in the pipeline.
The A600 is not mentioned in your plans but it would require significant upgrading to cope with increased traffic. Schools and other facilities would also require upgrading.
I am not supportive of options 2a, 2b and 2d.

Object

Representation ID: 7888

Received: 23/09/2021

Respondent: Mr Anthony Moran

Thank you for your letter plus enclosures dated 6th August.
I am writing re ‘Design Guide’
I have to say, I write more in sorrow than in anger. I don’t like any of your indicated choices. What is proposed in Options 2a, 2b, 2c and 2d is a sprawl of new housing estates, which will destroy tracts of the countryside at the cost of environmental damage. It is a case of putting the cart before the horse: Improved transport links are needed e.g. the restoration of the railway between Bedford St. Johns and Sandy. There is no need of more houses. Milton Keynes was built to provide for regional demand.
I appreciate having been given this opportunity to comment, even though I suspect this ‘consultation’ follows what is already a done deal: for instance, the East-West railway company is already planning to demolish Spenser Road to make way for six tracks going North form Bedford.
These proposals come at a huge cost to the taxpayer, but also with huge profits for developers and builders (who of course have no connection with local elected officials.)
Since the war, various elected vandals have inflicted hideous ugliness on Bedford, especially on the riverside. The latest outrage is the Riverside North development.
Sorry, but that had to be said. Please excuse my handwriting.
Yours faithfully
Mr A T Moran

Object

Representation ID: 7894

Received: 23/09/2021

Respondent: Mr and Mrs Trevor and Susan Stewart

All sites in Ravensden, Renhold and Wilden
We are greatly concerned about the amount of misinformation that appears to have been submitted in respect of most of these sites.
It appears that applicants and agents have been over elaborate with the supporting statements. For example, a number of sites listed appear to suggest that public transport from these three villages into Bedford consists of one bus per hour. This is totally untrue for all these sites as they are actually only three buses per day. Fewer on Saturday and none on Sunday. Therefore, any of these sites, if approved, will cause an increase in private vehicular traffic onto already substandard simply surfaced former green lanes. In addition, there are no public service facilities in any of the three villages, no surgery, no chemist, no clinic and in the case of Wilden and Ravensden, no shop of any kind.
How would these proposed new developments be supported without the use of private cars. Similarly, the submissions do not identify the absence of footways on very busy, yet narrow roads. Perhaps as to be expected, applicants have been less than honest with their supporting statements.

Support

Representation ID: 7895

Received: 23/09/2021

Respondent: Mr and Mrs Trevor and Susan Stewart

General Development Proposals
We support the future development of the borough on existing brownfield sites tot eh South of the town. Sites of the former brickworks, ministry of Defence establishments, Wixams etc.
We do not support further large-scale development to the North of the town, which is already over developed and has almost conjoined existing villages in the town.
We believe that Wentworth Drive, which was intended as a barrier of development of that part of the town into the country, should be sustained.
We do not support development within the arc of the proposed East/West rail link to the North of the town as we believe that this would eventually result in over-development of the rural area of North Bedfordshire and the loss of agricultural land and the beautiful part of North Bedfordshire. Not to mention valuable wildlife habitats. Any proposed development has to be on existing brownfield or already ruined sites.
We do not support the proposed East/West rail link as we believe it will desecrate valuable rural areas and the need for this has not been justified.

Object

Representation ID: 7898

Received: 24/09/2021

Respondent: Home Builders Federation

5. When considering the growth strategy to be delivered in this local plan the Council will need to ensure that there is sufficient variety of sites to either avoid or minimise the stepped requirement as well as ensure flexibility in its supply to make certain planned needs are met in full. This will require the Council to adopt a spatial strategy that enables it to allocate a wide range of sites in terms of both size and location with small and medium sites delivering in the early years of the plan allowing sufficient time for large strategic sites to come forward to meet needs in the second half of the plan period.
6. In our experience local plans that rely too heavily on large strategic sites within their local plans to meet needs can struggle to show their local plans are deliverable. In order to meet needs and show a five-year land supply councils often include overly optimistic delivery rates on larger sites which are often revised before or at examination as these are challenged. This can leave shortfalls in supply that need to be addressed through additional allocations or an early review. For example, at the recent Brentwood Local Plan examination where the Council went from having to a 10% buffer in supply to a shortfall of 5% from submission to hearings as delivery trajectories on strategic sites were revised.
The Council is also no doubt is aware of the Uttlesford Local Plan that was withdrawn by the Council on the recommendation of the Inspectors examining that plan. The Uttlesford Local Plan relied heavily on three new towns which delivered the vast majority of their housing needs at the end of the plan period. As well as considering two of these settlements to be undeliverable they also concluded that the trajectories for delivery were overly optimistic and that, even if all the new settlements were delivered, they could not show a five-year land supply with significant shortfalls against the requirement in the middle of the plan period. The inspectors noted in their overall conclusions that the strategy would lead to a stepped trajectory that unreasonably delayed addressing the issue of housing affordability and failed to test options with fewer homes in new settlements with more homes in other settlements.
8. This is not to say that a new settlement, or the strategic expansion of an existing settlement, should not be a key element of the land supply in this local plan. Such allocations provide a secure supply of land for development well into the future. However, in making such allocations we would advise the Council to take a cautious approach recognising the complexity of delivering such development and the impact this has on the point at which such schemes will start delivering new homes. Too often Councils are overly optimistic about the delivery of new settlements in the early stages of plan preparation ultimately leading to trajectories being pushed back later on in plan preparation once the strategy has been decided upon in order to maintain a five-year land supply. In some cases, this can lead to plans being found unsound.
9. A sound approach is therefore one that seeks to balance the delivery of larger strategic sites with the allocation of small and medium sized sites that come forward in the forward in the first half of the plan period. Such an approach can provide a consistent supply of homes that will help meet housing needs earlier than if the Council rely on new settlements to deliver the majority of their housing towards the end of the plan period.
10. In our experience local authorities can rely too heavily on larger sites within their local plans to meet their needs in full and fail to allocate sufficient smaller sites as contingency against the delays in delivery on larger strategic sites. This often leads to local authorities reaching examination and having to revise delivery expectations as they no longer have a five-year land supply or sufficient developable sites in years 6 to 10 of the local plan.
We also note that none of the options expect to deliver much beyond the Council’s housing requirement. The HBF recommends that the Council includes a substantial 20% buffer in supply to ensure that it can meet needs and that any sudden changes in delivery expectations are compensated for in the local plan and limit the need for amendments to be made to the plan at a later date in order to include further allocations.

Support

Representation ID: 7913

Received: 24/09/2021

Respondent: Sharnbrook Parish Council

In respect of the Local Plan 2040 review, this Council considers that all options would be acceptable, with a preference for Option 2a as giving the best results for Bedford Borough given the figures that BBC must work with. This option offers a range of housing and employment which is crucial in any plan, along an already proven highway network and potential new rail line upgrade. The Council recognises the potential of a new settlement, however, as such development of large settlements as described would be as a useful addition to the housing stock. Our observation is that it would be quite distant from the town centre and therefore may cause some lack of cohesion within the Borough. Further, it does bring into question the issue around deliverability. We accept this should be tested through the Plan process.

Object

Representation ID: 7914

Received: 24/09/2021

Respondent: Sharnbrook Parish Council

With regard to future development in the villages north of Bedford, development should be kept away from the A6 and north Bedfordshire villages, as the current infrastructure is already at capacity and there are no proposals to improve this under the current proposals, which is regrettable. Whilst we accept that all communities need some development over time, an allocation of 500 dwellings in Sharnbrook through our Neighbourhood Plan and LP2030 was, as we have previously stated, based on flawed methodology. While the Parish has worked hard to accommodate the requirement through the Neighbourhood Plan, any further development in the foreseeable future would be unacceptable. Any future development in villages should be considered very carefully, and not be imposed within the next term of the Local Plan, ie, after 2040, if not even later. Growing organically is far better for residents, allowing facilities to develop to cope with their needs and wants, rather than forcing an arbitrary number or percentage of growth. No community should be forced to grow by more than 10% in any decade to allow for cohesion and planning of facilities to meet the requirements of any area. SPC is glad to note that there has been no proposal to allocate housing in Sharnbrook or other North Bedfordshire villages, however it should not be overlooked in terms of the provision of facilities where they are required

Support

Representation ID: 7967

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

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 (AT LITTLE BARFORD)
• Within the urban area (1,500 dwellings).
• Adjoining the urban area (1,500 dwellings), up to 51 ha employment.
• Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (low option) (5,500 dwellings), up to 80 ha employment.
• Transport corridor – south: land within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton (1,500 dwellings).
• New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings), up to 20 ha employment.
• Total between 12,500 and 13,085 dwellings and up to 151 ha employment.
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 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.

3.17 100 word summary
I consider that option 2b with a new settlement at Little Barford is the best option. The East West rail station south of St Neots will provide a truly sustainable form of development at Little Barford. It will be better connected to the new station than Dennybrook. The latter does not provide a suitable alternative – too far from the rail station, risk of coalescence, good agricultural land. Our second preference if Little Barford were deemed unsuitable would be Twinwoods at Thurleigh as a significant part of the site is brownfield land. See above and site assessments for reasons.

Support

Representation ID: 8040

Received: 24/09/2021

Respondent: North Northamptonshire Council

In respect of spatial options, firstly the Draft Plan appears to have moved away from the ‘Brown’ and ‘Red’ options that would have had the most potential negative impacts on North Northamptonshire (NN). The four preferred options set out in the Draft Plan are centred around Bedford town and the A421 with nothing presented further north towards the NN boundary in the vicinity of the A6. Growth around Bedford town and the A421 would have significantly less cross-boundary impacts on NN in comparison with the other previously considered options.

It is noted that since the publication of the Issues and Options consultation Bedford Borough Council (BBC) have developed the Bedford Borough Transport Model (BBTM) which has been used to test options initially put forward and to therefore inform the preferred options presented in the latest plan.

The production of the BBTM is welcomed and it is noted that the modelling has shown that the preferred options presented in the Draft Plan are those that result in the least impact on the highway network compared to the others tested. This modelling including testing of the option at Colworth Garden Village (CGV), which when tested concluded that any new settlement(s) in this location would result in significant congestion and delay on the A6. More detailed observations on the BBTM are outlined in the North Northamptonshire Council (NNC) Highways comments, which are set out overleaf.

As mentioned, the Plan’s move away from exploring options of significant development at CGV, Rushden and areas around the A6 to the north of the BBC authority area, means there are likely to be fewer significant implications for NN. This is not only in terms of impacts on traffic and congestion on the highways network, but also with regard to other issues previously identified such as coalescence with Wymington, sustainable transport routes and impacts on Green Infrastructure corridors and the SPA, the latter of which will help reduce the impact of wider growth. Natural England (NE) are becoming increasingly concerned regarding functionally linked land to the SPA. There is a need to understand the interaction with the SPA and surrounding land as well as the impact from visitors. Officers from NNC and BBC are engaged in proactive discussion with NE regarding the SPA and it is considered that the move away from growth close to the NN border is likely to release some pressures on it.

Conversely, the absence of any significant development towards the NN boundary would negate the need for a new railway station at Wymington Loop. As per the North Northamptonshire Joint Planning Committees (NN JPC) response to the Issues and Options consultation a new deliverable station here could have presented future opportunities that may have benefitted NN in light of Policy 17 of the JCS North Northamptonshire’s Strategic Connections which identifies investigating the longer-term potential for a railway station at Irchester. Notwithstanding this, it is noted that page 29 of the Development Strategy Topic Paper suggests that there is an ‘absence of currently deliverable railways stations’ within this location.

Despite the above, given the greater housing need in BBC due to the increase on its Local Housing Need (LHN) consideration will need to be given to future iterations of the Plan, particularly when it comes to the allocation of housing sites. It is noted that the annual housing requirement for BBC will increase from 970 dwellings p/a to 1,275 dwellings p/a and therefore, discounting existing commitments, the new local plan will need to allocate land for a minimum of 12,500 dwellings. It will be important for NNC to continue to engage with the BBC Local Plan 2040 as it progresses through the plan-making process to consider whether any potential future housing allocations may be of significance to NN due to their proximity to the authority boundary.

It is recognised that the BBC Local Plan 2040, Draft Plan is still in its early stages in terms of its development and there is still scope for it to change. Notwithstanding this, current proposed growth options illustrated within this consultation are considered to no longer present NN with any significant negative implications with regards to potential cross-boundary issues. On this basis NNC supports the alternative development scenarios presented.

Object

Representation ID: 8044

Received: 23/09/2021

Respondent: Terry & Maureen Wright

Agent: Bidwells

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 have to be allocated to meet the demands of the Borough.
Of those sites that have been forward, it cannot be assumed that all the sites will be suitable and there may be constraints that limit the size of the site to 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 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 (considered within all the proposed 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 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 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 on employment uses that 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 the view of the Wrights, given the relationship with the A1, A428, A421 and the proposed employment uses, 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 set Option 2d apart.
3.7 It is considered that a finer grain assessment of site availability and suitability needs to be undertaken to inform the development strategy. It is determined that this assessment 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. Chawston 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. Aforementioned, the development of the A428 improvements will facilitate opening up this site, allowing it to be apt for development with there not being issues with the highway's capacity. 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 Chawston would not prohibit or curtail any of the planned infrastructure coming forward, with the landowners leading to the facilitation of the construction of the Roxton Road Link (North).
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 number of employment land 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.

Support

Representation ID: 8081

Received: 20/09/2021

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: 8083

Received: 25/09/2021

Respondent: Miss Gina Rigby

Local Plan 2040 and Call for Sites.

2d and 1a are a particular concern for those who live in Renhold. As the village is a small group 3 settlement with very limited facilities it is far better to build and develop brownfield sites. 2d and 1a would destroy the intrinsic character, green spaces and its high quality agricultural land. Many roads in Renhold village are in a poor state of repair and are quite unsuitable for large volumes of traffic or HGVs and there is a traffic restriction order and a weight restriction in place. The primary school is oversubscribed and Church End comes to a standstill during drop off and pick up times as it is a single carriage road. Widening roads and development in open countryside would destroy wildlife corridors and valuable habitats. My preference for the local plan would be 2C and 2B.