3.16

Representation Summary:

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
5. RENHOLD IMPORTANT LOCAL FACTORS
The Parish Council feel it is important even at this early stage of the strategic development
framework process to outline some vital, important local factors, which will enable Planning
Policy and local authority colleagues to be more aware of the issues within the parish when
reviewing potential sites.
The construction of the Water End junction of the A421 and completion of the A421 between the
A1 and the M1 created a destination that attracted vehicles of all classes to use Renhold’s lanes
as a short-cut from the west of Bedford to the A421. This was recognised in the Public Inquiry
where it was stated that the bypass would have a detrimental impact on Renhold. Over a
number of years, the Parish Council worked with Bedfordshire County Council and Bedford
Borough Council Officers to reduce the volume and speed of traffic through the village. Firstly,
traffic lights were installed near the Church at a particular pinch point, then a Traffic Restriction
Order was implemented that bans through traffic between Wilden Road and the A421 junction in
the morning and afternoon peak periods. This also coincides with the main parent activity at the
village school on Church End. The TRO is not enforced, and the traffic volume data collected
before and after the installation of the TRO supported that this has had little effect, if any, on
traffic volumes. Thirdly, in 2016, average speed cameras were installed, again between Wilden
Road and the A421 junction, but in two separate installations, and, at last, vehicle speeds have
reduced significantly. Between these measures they have restored an element of peace to the
village. However, one consequence is that traffic now uses Hookhams Lane as a short cut
instead.
The above issues clearly identify that the Ravensden Road route is an established 'rat run'
which traffic comes into the village through. Previously traffic continued travelling through the
village onto the bypass junction through Church End. Since the installation of the average
speed cameras this has displaced the traffic and it now travels along Ravensden Road and onto
Hookhams Lane. As a result, the increase in volumes and speeds of traffic along this route is
very noticeable at peak flows.
In 2009, six days of data collection at Ravensden Road from 3rd June to 8th June showed total
number of vehicle movements as 16,430.
In 2013, seven days of data collection at the same location showed 19,545 vehicle movements
between 12th December and 18th December.
By 2015 this had further increased to 22,582 vehicle movements over seven days from 21st to
27th April.
(Please note all this data was provided by Bedfordshire Police and the detailed breakdown can
be provided to the Borough Council).
This data not only clearly demonstrates the high volumes of traffic on Ravensden Road, an
unclassified rural lane but also the significant increase in the volume of traffic in recent years.
The data provided also captured vehicle speeds during the data collection. The 2015 data
collection also showed a staggering 40.9% of the vehicles were travelling at 35mph and above,
this is 9,236 vehicles a week excessively speeding, so on average 1,319 vehicles per day.
Following the Parish Council purchasing a mobile Vehicle Activated Sign which collates volume
and speed data of vehicles, the Parish Council have located these devices along various village
highways. The results are staggering and show a total disregard for highways safety throughout
the parish. Below is an example of the issue.
BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
All the residents who live in Renhold Village along with all those motorists who use the
established rat run route from the B660 Kimbolton Road, Ravenden Road Crossroads, and
travel along Oldways Way, Ravensden, and into Ravensden Road, Renhold. They then
continue onwards either along Hookhams Lane, or to Church End in Renhold. Even with the
data collected from March, a period while the country remained in a lockdown with restricted
movement in place, it clearly shows a high level of usage for a rural village road. The VAS
summary for Hookhams Lane and Ravensden Road below.(Data table included)The Parish Council has vast data collection for this, and the other sites within the parish which
is available as evidence to support the highways issues being suffered throughout Renhold.
The popularity of Renhold V.C. School attracts pupils from a wide area. It is located in Church
End which is the route from the west of Renhold and from Wilden to the A421 junction. Many
travel to the school by car and on regular occasions more than 70 cars are parked on Church
End waiting for the end of the school day. This reduces virtually the entire length of Church End,
a lane with two blind bends, to a single carriageway road with passing places formed by the H
bars at domestic gateways. The resulting congestion is a regular and frustrating nightmare for
parents and residents. The situation has resulted in a bus provider withdrawing from running a
service through Renhold due to the inability to keep to the published timetables. The school has
been extended by two additional forms to create a primary school which has resulted in further
pressure for parking.
The Parish Council has well documented evidence of the constant issues with access through
Church End. As a result, a pedestrian crossing had to be installed to try and manage the
highways safety in this area.BBC Officers should also be mindful of the recent local authority planning decisions which were
robustly refused (applications 20/00345/MAF and 19/01974/MAO). Both were taken to appeal
and dismissed by the Planning Inspectorate.
Renhold is rightly proud of its outstanding local environment, wildlife and heritage assets fond
throughout the village. The Parish Council have a range of resources evidencing protected
species and local woodland which Renhold a unique parish. From the brook flowing through
Salph End, through to historic ancient woodland known as Little and Great Early Grove.
The brook attracts a number of wildlife species such as otters, with the various existing water
courses (i.e. drainage ditches - capacity and flow rates) provide an important habitat for
established Lepidptera (Butterflies and moths), Aeshnidae (Dragonflies and damsel flies) and
other aquatic invertebrates (water fleas, boatmen, fresh water leeches) which if impacted by any
change of use would have a knock on effect on fauna further up the food chain.
In recent years, particularly since the forming of the previous Local Plan, Renhold has seen a
significant change in the local landscape in terms of flooding and drainage. Reports of flooding
along Renhold Brook have not only become more noticeably frequent but also more widespread.
The Parish Council are able to submit addition information including evidence of the great
biodiversity within Renhold along with the increasing challenges with flood water in Renhold as
a result of Renhold Brook becoming under increasing pressure.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8403

Received: 27/09/2021

Respondent: WSP

Agent: WSP

Representation Summary:

The Draft Plan outlines four options for the future ‘Growth and Spatial Strategy’ and asks:
“What, in the context of the vision and objectives outlined earlier in the document, is the appropriate spatial strategy for the plan?”
Option 2d (development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes and east parishes, plus one new settlement) represents the optimal and most sustainable option for the borough’s growth and spatial strategy.
The Draft Plan outlines that Option 2d will provide between 12,500 and 13,085 dwellings. This is the one only option that provides over the requirement of the standard method and meets the uplift in housing need outlined in the Council’s LHNA. This therefore the option that complies with the requirement of Paragraphs 60 and 61 of the NPPF.
Paragraph 60 of the NPPF outlines the Government’s objective of significantly boosting the supply of homes. This suggests that Council’s should provide above the minimum housing need identified using the standard method and local housing need assessments (per Paragraph 61 of the NPPF), a view that was taken by an Inspector in a recent appeal1 concerning BBC (in April 2021). This reading of the NPPF suggests that it is clear that the upper limits of housing need should be supported and therefore provides justification for the adoption of Option 2d.
The Government’s objective for significantly boosting the supply of homes (Paragraph 60 of the NPPF) notes that in order to ensure that this can be supported, a sufficient amount and variety of land should come forward where it is needed. This is emphasised by Paragraph 69 which outlines the contribution that small and medium sized sites can make to meeting the housing requirement of the area, noting that 10% of housing delivery can be undertaken on these sites.
Paragraph 69 therefore supports the progression of Option 2d to be selected as the preferred option for the growth and special strategy of the draft Local Plan. This is as Option 2d while it
1 APP/K0235/W/20/3263447

provides much needed dwellings in large scale urban extensions and new settlements (which is supported by Paragraph 73 of the NPPF), it accounts for the parishes of Bedford, which are likely to be able to support smaller and medium sized sites with greater ease. Option 2d is therefore supported by both Paragraphs 69 and 73 of the NPPF as it would enable both small and large sites to come forward for development and significantly boost housing delivery.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8482

Received: 27/09/2021

Respondent: Richborough Estates

Agent: Fisher German LLP

Representation Summary:

Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.

In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.

The issue with the other options proposed is that they place significant emphasis on delivery in limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further pressure on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
Dispersed growth (or Village related as it is referred in the consultation material) should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. Any attempt to constrain dispersed growth is not supported.
Whilst it is recognised that the Adopted Plan makes some provision for dispersed growth, and growth in the sustainable rural settlements to the period 2030, if this pattern of development is not continued, it could result in 10-year + period where no growth occurs in such settlements. This could have a negative impact on the vitality and viability of these settlements.
A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts to online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.

Attachments:

Bedford Draft Options and Draft Policies - Final 03.09.21_Redacted.pdf (412.57 KB)

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8494

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

Representation Summary:

2.10 Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.
2.11 In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.
2.12 The issue with the other options (rail-based, east-west rail northern station and new settlement) is that they place significant an emphasis on delivery on limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further emphasis on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain
a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
2.13 Dispersed growth should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established at this point the significant harm such an approach has caused in recent years nationally, as reflected in matters such as declining public transport routes, closure of village pubs and shops and the decline in vitality of village life, generally where development has been withheld. Whilst the current Plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result in a 10-year period with no proposed growth which would be unacceptable and as such some provision must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.
Site Allocations and Call for Sites
2.16 The Council have previously evidenced that settlements such as Sharnbrook can deliver up to 500 dwellings in the period up to 2030. The emerging Neighbourhood Plan seeks to allocate 500 dwellings beyond the settlement of Sharnbrook, at Coffle End, another settlement within the Local Plan settlement hierarchy. As such it is considered that no growth has been directed to Sharnbrook itself over the adopted Plan period to 2030. Furthermore, the emerging Local Plan looks beyond 2030 to 2040, and thus commensurate additional further growth in the sustainable rural settlements must be delivered during this extended time period., The 500 dwellings allocated at Coffle End in the emerging Neighbourhood Plan will not be sufficient to meet the housing needs in Sharnbrook up to 2030, or 2040. It is considered that sustainable growth in settlements such as Sharnbrook, up to 2040, should be in the region of a minimum 100 dwellings (additional dwellings beyond the 500 allocated in emerging Neighbourhood Plan). This is consistent with the Councils previous evidence base, current housing targets, and commensurate to their sustainability and spatial role. As previously set out, we would object to any attempt to stifle appropriate rural growth.
2.17 In that regard, we consider the emerging Local Plan must make allocations in the Rural Service Centres to ensure a suitable distribution of deliverable development sites up to 2040. Within Sharnbrook it is clear through both the evidence supporting the Neighbourhood Plan and the previous assessments supporting the adopted Local Plan (whereby the Council’s 2017 Local Plan consultation paper sought to identify preferred sites for allocation, which included land at Kennell Hill), that the most suitable and deliverable site beyond those allocated in the Neighbourhood Plan is land at Kennell Hill, Sharnbrook. A range of evidence documents have been produced by Anwyl Land which demonstrate the deliverability of the site.
2.18 The Council have assessed the Kennell Hill, Sharnbrook site under ID reference 3231. We have a number of concerns with the scoring of this site. We also have a number of comments in respect of the emerging Neighbourhood Plan allocation, which whilst being allocated through a separate process is considered as part of this SHLAA assessment and will be a matter for the Council to consider. These are discussed in turn, followed by more general comments in respect of the settlement generally.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8495

Received: 27/09/2021

Respondent: Gladman Developments Ltd

Representation Summary:

Growth and Spatial Options
A combined approach is needed in order to sustainably meet the challenge of delivering against identified development needs over the plan period to 2040. To meet housing need and capture the socio‐economic benefits of the infrastructure associated with the Oxford‐Cambridge Arc throughout the period to 2040 and beyond, proportionate levels of growth should be directed across the settlement hierarchy. This will complement growth from sustainable urban extensions and new settlements, ensure choice and competition in the market and those communities to improve their levels of sustainability. It will therefore be necessary for the housing requirements of neighbourhood areas to be revisited and/or for the Council to allocate land in these locations through the Local Plan Review. An approach that takes a pro‐active approach towards enabling development in sustainable locations is required, which will include a combination of strategic scale sites and growth adjacent to existing settlements. Gladman are promoting land in locations including, Renhold, Shortstown, Willington and Wootton, all of which are well related to the existing built form and the A421 corridor and can be delivered as part of a sustainable and comprehensive strategy for growth across the borough to 2040.
The Planning Practice Guidance (PPG) highlights that “A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness6.” All settlements within the borough boundary have the potential to contribute further towards the overall development requirement and there is a need to plan to ensure that services can be maintained and enhanced in these locations to meet the day to day needs of residents. A study of the sustainability credentials of settlements across the hierarchy should therefore be undertaken to fully explore the potential of these settlements to accommodate appropriate levels of growth, factoring in demographic information over the duration of the plan period and the availability of day‐to‐day services and facilities. Indeed, the NPPF 2019 sets out that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services7. Furthermore, the retention and development of accessible local services and community facilities should be enabled by planning policies and decisions8.
The spatial strategy, SA and site assessment scoring criteria must also fully recognise the sustainability benefits of village development and in doing so reflect the changing habits of people over the plan period including the increased role of working from home and the associated need for social and community infrastructure improvements in settlements across the hierarchy.
It is important that the local plan enables the delivery of a wide range of sites in order to support the delivery of housing at the levels that are required by the Standard Method. The approach should embrace the need to support sites of all sizes. It is important not to overly rely on large scale strategic locations for growth; by enabling the widest range of sites across settlements throughout the hierarchy, Bedford will maximise delivery and satisfy housing need in the borough.
As the Planning Practice Guidance (PPG) highlights, “A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”9.
Whilst the Draft Plan explains correctly that work on the Local Plan 2040 should not be delayed in anticipation of the progression of the Oxford Cambridge Arc Spatial Framework, the plan making process represents an opportunity to fully explore a range of growth and spatial strategy options that will have the ability to support economic growth in a manner that aligns with the wider ambitions of the Oxford Cambridge Arc.

Attachments:

Draft Plan representation (1.07 MB)

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8518

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Representation Summary:

PROPOSED APPROPRIATE STRATEGY– OPTION 2D AND A ‘HYBRID’ APPROACH
This section of our representations should be read alongside the standalone Review of the Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review support the Modifications in this part of the representations. This section also reinforces our specific comments on the Council’s Preferred Strategy Options.
Paragraph 3.17 and Option 2d – Comment
These representations endorse the inclusion of the ‘east’ corridor parishes as part of Preferred Option 2d but in practice indicate that this is illustrative of a need for a ‘hybrid’ approach to provide for an appropriate strategy in accordance with national policy and guidance (NPPF2021 paragraph 35(b)).
These representations conclude that any selected strategy option that does not include growth in the ‘east’ corridor parishes would be unsound and fail to comprise an appropriate strategy or genuine reasonable alternative for the purposes of the Sustainability Appraisal. This is due to soundness issues identified with the delivery of large-scale strategic growth comprising other components of the Council’s Preferred Options.
The benefits of Option 2d reflect the ability to promote and maximise the benefits of what is in-effect village-related growth at the Key Service Centre of Great Barford, which is very sustainably located within the A421 corridor. Growth at Key Service Centres is an approach that the Council has accepted as sustainable in the spatial strategy of the adopted LP2030, and the evidence base for the Local Plan 2040 indicates no in-principle constraint to capacity for further development at Great Barford that could not be adequately mitigated.
Endorsement of growth at Great Barford under Option 2d in the context of a ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’ growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of their capacity to contribute towards sustainable development. The benefits of ‘village-related’ development do not suddenly materialise only where Key Service Centre and Rural Service Centres are located in the A421 corridor and do not evaporate altogether outside of it.
To achieve the objectives of the emerging Local Plan 2040 it is necessary to support further village extensions to the settlement of Great Barford, incorporating our client’s Willoughby Park proposals, to secure contributions to sustainable development that are assessed favourably in the draft Sustainability Appraisal (including new green infrastructure, community facilities and opportunities for recreation). The potential to secure these benefits should be reflected within the Council’s conclusions on site selection and evidence base for the submission draft version of the Plan, once finalised, including the Infrastructure Delivery Plan and Settlement Hierarchy Review, which both remain awaited.
Draft Sustainability Appraisal – Suggested Appropriate Strategy Alternative
A ‘hybrid’ option would assign the ‘village-related’ growth component only to those settlements outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an indicative distribution, have been retained at 500 units in Key Service Centres and 35 units in Rural Service Centres albeit these are arbitrary figures and should be determined on a case-by-case basis. Wixams has been excluded from the total for Key Service Centres (reflecting its inclusion in the locations for rail-based growth). The only exception, taking account of this, is an increase of 215 units in the distribution to Oakley (based on its suggested reclassification as a Key Service Centre set out in representations on behalf of other clients submitted to this consultation).
For the A421-based components of the strategy the total distribution to the ‘east’ corridor parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d. This marginally exceeds the Council’s arbitrary figures applied for the purpose of testing Great Barford, Roxton and Willington as ‘village-related’ growth but would in our view represent a more realistic starting point taking account of the capacity for growth at Great Barford and in-particular our client’s Willoughby Park site. There is no site-specific justification or settlement-specific justification as to why this figure should be limited to 750 dwellings.
In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of large-scale strategic growth included in the strategy options. We have included the Council’s minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic timescales for development.
Including both components, if required (New Settlements and rail-based growth) would comfortably exceed the minimum 12,500 units required from additional allocations, with an appropriate buffer for flexibility and contingency (particularly in terms of the prospects for meeting increased needs before 2030). There is no reason higher quanta could not be included as part of an extended plan period. Equally, this could allow some settlements outside of the transport corridors to be excluded from further village-related growth. We would, however, not recommend this where Neighbourhood Plans being prepared have failed to address important strategic priorities (as at Oakley and Sharnbrook, for example).
The ‘hybrid’ strategy based on these components are summarised in Table 1 below:
SEE PARA 5.11 IN ATTACHMENT
We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with the standalone findings for growth components and the Council’s Options 2d and 3c, as well as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable development are enhanced.
This is as a result of recognising that the potential negative effects the Council assigns to village-related growth are incorrect and, in any event, inaccurate because it ignores the location of some Key Service Centres and Rural Service Centres within the A421 corridor. It also recognises that some the benefits of what is in reality ‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across settlements elsewhere in the hierarchy. Likewise, the assessment of positive effects for strategy options including the ‘east’ transport should be increased due to the ability to provide for sustainable village extensions at Great Barford. The results are summarised in Table 2 below:
SEE PARA 5.13 AND TABLE 2 IN ATTACHMENT

Attachments:

09.03.JG.BE1719-4P Bedford LP2040 Response - Willoughby Park Great Barford obo ORS vf + Appxs (1)_Redacted.pdf (19.30 MB)

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8578

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Representation Summary:

4.1 The previous Issues and Options consultation outlined six potential approaches to growth as follows: urban based; A421 based growth; rail growth; East West
Rail northern station growth; dispersed growth; and new settlement based growth.
4.2 These six options have now been progressed and as set out in the Local Plan and Development Strategy Topic Paper (June 2021); BBC now seek views on four ‘preferred options’ to meet the (proposed) level of growth set out in the Local Plan.
4.3 The options put forward in the Local Plan are as follows:
1. Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes and southern parishes;
2. Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes and southern parishes, plus one new settlement;
3. Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, plus two new settlements;
4. Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth parishes, southern parishes, and eastern parishes, plus one new settlement;
4.4 All four proposed options include development along the A421 transport corridor, and rail-based growth in the south of the Borough. It is of note that the map alongside each image fails to recognise the proposed new East-West rail station that would be located north of Stewartby (potentially alongside Bedford Business Park). This station would further justify the choice to progress a growth option focused on the A421 and rail corridor.
4.5 AWG supports the proposed strategy of growth along the A421 and rail corridor. However, AWG consider that each of the proposed options fail to identify
sufficient land to meet the employment needs of the Borough (as set out in Section 2 of these representations and in the Cloud Wing representations).
4.6 The Development Strategy Topic Paper states (para 3.13) that 123ha is proposed to be allocated to 2040, based on the Employment Land Study. For the reasons
set out in Section 2, that figure is not considered to be sound and needs to be increased. This would, in turn, result in a requirement for the proposed Development Options (and the final selected Option) to identify further areas for employment growth.
4.7 As well as an insufficient quantum of employment land, AWG contend that 3 of the 4 options may result in insufficient delivery within the Plan period. Firstly, Option 2c is not considered a sound approach. As has been evidenced1, the development of large sites (2,000+ dwellings) takes many years. The average time quoted from validation of the first planning application to the first dwelling being completed on schemes of 2000+ dwellings is 8.4 years. Whilst this relates to dwellings, Option 2c proposes up to 20ha of employment as part of a new settlement. It is reasonable to assume that the 20ha would come forward as part of a holistic approach to a new settlement. The employment could, therefore, be constrained by the delivery of the new housing and associated infrastructure demands.
4.8 The same report also finds that the average annual build-out rate for a scheme of 2000+ dwellings is 160dpa.
4.9 Working on the basis of a plan led system, any application for a new settlement would, in theory, not be validated until after the Local Plan is adopted, thus 2024 at the earliest. This means that any new settlement is unlikely to begin delivering homes until 2032 at the earliest, and potentially employment land until a similar time.
4.10 The approach set out in Option 2c may not meet the Borough’s employment needs in the short term and could result in employment delivery beyond the plan period and should be discounted as a result.
4.11 The criticisms of Option 2c would apply, to a lesser extent, to Options 2b and 2d, with the same quantum of employment proposed for one settlement (as opposed to two in the case of Option 2c).
4.12 The option which has the greatest likelihood of delivering growth within the Plan period, as required by national policy, is Option 2a. This option would focus growth in the south along the major transport corridors of the A421, A6 and railway line, and in turn would focus development in the most sustainable locations.
4.13 The Development Strategy Topic Paper finds (para 3.19) that Option 2a is the best performing option. It also finds Option 2c to be the worst performing of these 4 options, and that is without considering the issue of delivery as set out above.
4.14 Whilst Option 2a is the best of the options put forward, for the reasons set out in Section 2 of these representations, the proposed level of growth in Option 2a is not sufficient to meet the identified needs for the Borough.
4.15 A new Development Option is therefore required which meets the identified growth needs and, in particular, the opportunity presented by Bedford Business Park to maximise growth in the A421 rail-based growth corridor. This Option would then be the favoured one to progress in the Local Plan, being for some 222ha of employment growth in this location.
4.16 The next section of these representations puts forward a case as to why the land at Broadmead, and in turn the Bedford Business Park, would deliver growth in accordance with the Development Strategy outlined above (in fact according with 4 of the 4 development options).

Attachments:

Draft Plan representation (1.27 MB)

These representations have been prepared on behalf of and in respect of their land interests to the north of the A4280, south of Bromham Road, Biddenham, as illustrated on Figure 1 below.
Figure 1: Site Location Plan
1.2 The site has been submitted to the Local Planning Authority as part of the May 2021 Call for Sites.
1.3 Biddenham is demonstrably a sustainable settlement and the site is located between significant approved development south of the A4280 (policy 18- Land at Gold Lane, Biddenham) and proposed allocation north of existing residential development north of Bromham Road (Policy 23 – Land to the rear of Bromham Road, Biddenham). As such the land forms an infill location between proposed
2
development. The land is well contained by existing mature vegetation which would be largely retained, save for that which would be removed to facilitate an appropriate access onto Bromham Road, which will be replaced as part of any eventual developments landscaping strategy.
1.4 The site can deliver circa 33-45 dwellings, depending on eventual matters such as density, housing mix and layout.
1.5 In terms of impacts on the historic environment, the nearest designated asset is Bromham Bridge, which is a scheduled ancient monument located 150m west of the site. The site will not bring development closer to Bromham Bridge, with existing development north of Bromham Road being located far closer to this historic asset. A distance in excess of 150m will exist between the proposed housing and this Scheduled Ancient Monument. The existing mature planting to the north of the site, will be complemented by new boundary planting, meaning views towards the bridge will be largely unaffected. As such, it is not considered that the proposed development will have a tangible impact on this historic asset. There is a Grade II Listed building (66, Bromham Road) located 400m to the east. Existing mature vegetation however acts as a visual screen between this asset and the appraisal site and it is considered that the development of the site would have a negligible impact on this asset.
1.6 The site does not contain or adjoin any designated environmental asset. The site is located within Flood Zone 1, low probability of flooding.
1.7 Whilst detailed access proposals are currently being explored, it is assumed that a suitable access will be possible on the site having regard for the allocation to the north. The site is adjacent to existing bus stops which are served regularly by the 41 service which runs between Bedford and Northampton. Services begin at 7am and run hourly until 9pm in the evening. This would reasonably enable those traveling for commuting, education, retail, leisure and health, sustainably and easily from the site. Improvements to the existing bus stops could be provided as part of development proposals in accordance with neighbouring sites, to encourage their use.
1.8 The site is also considered to be logical when looking at the close proximity of Bedford Railway Station. This is located circa 2.5km to the east, with easy access for pedestrians, cyclists and public transport. Significant weight should be afforded to this connection, not least with planned improvements to the station through the development of East West Rail, providing ready access to other key Arc destinations on this new rail infrastructure, not least better connectivity to Cambridge and Oxford. This connection will help elevate Bedford’s role within the Arc, with significant economic and social benefits to the town
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and wider area, in particular Biddenham.
1.9 With regards to pedestrian access, there is existing footpaths north of Bromham Road which provides access east of the site towards Biddenham and Bedford via an existing underpass under the Great Ouse Way to the east.
1.10 The site can deliver a mix of house sizes, types and tenures, as well as a policy compliant level of affordable housing. As referenced, the site sits between two extant housing allocations (one with planning permission), demonstrating the site’s sustainability. The site is within walking distance of the range of services and facilities contained within Biddenham, with Bedford within easy reach by bus or cycle. The development of the site would therefore clearly constitute sustainable development and would have a strong synergy with existing commitments.
1.11 The site therefore is considered to be entirely logical having regard for existing residential site allocations to the south-east and north, which demonstrates the area is clearly considered to be sustainable and suitable for residential development. The site lacks constraints that would reasonably preclude development and as such is considered to be entirely appropriate. In this context it is considered this site is a logical allocation for future development in the area commensurate with existing levels of planned growth.
1.12 For ease of reference these representations follow the order of the policies in the Consultation Document.

Growth Strategy Options
2.10 Having regard to the concerns raised in respect of the housing requirement and the need to ensure that the Plan is sufficiently flexible to meet the Borough’s own needs and those arising through the Arc, it is considered the distribution of housing should be displayed as a percentage. This would ensure that the Plan is able to respond quickly to changes in housing requirement, whilst maintaining the spatial distribution of housing.
2.11 In respect of the proposed options, it is considered that the spatially optimal solution is a hybrid of a number of the options presented. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, delivers higher growth on key transport corridors, particularly the A421, but also retains an apportionment of growth across to the rural area.
2.12 The issue with the other options proposed is that they place significant emphasis on delivery in limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further pressure on a limited pool of settlements. As well as assisting delivery, dispersed growth, across the borough, will encourage a wider
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range of housebuilders into the market delivering concurrently; it also has the benefit of ensuring rural communities remain vibrant and maintain a healthy demographic composition, preventing issues such as ageing village populations and falling rolls at village schools for example.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) should form part of every spatial option proposed, albeit the level to be delivered could of course differ option to option. Any attempt to constrain dispersed growth is not supported.
2.14 Whilst it is recognised that the Adopted Plan makes some provision for dispersed growth, and growth in the sustainable rural settlements to the period 2030, if this pattern of development is not continued, it could result in 10-year + period where no growth occurs in such settlements. This could have a negative impact on the vitality and viability of these settlements.
2.15 A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts to online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles (by the end of the proposed Plan Period petrol and diesel car sales will have ceased). In addition, following the recent periods of lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.16 Whilst we do not object to the principal of identification of a new settlement as a mechanism of future delivery, caution should be applied to overreliance on the delivery from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. The preferred approach in this scenario is to positively allocate new settlement sites above and beyond the sites needed to meet the Borough’s identified housing needs, with new settlements delivering towards the latter part of the Plan i.e. 2040 onwards. Smaller sites should be identified and allocated for delivery in the early years of the Plan to ensure that delivery of the Borough’s housing needs is not constrained.
Site Allocations and Call for Sites
2.17 Biddenham forms part of the continuous urban area of Bedford and as such should be considered as part of the Urban Area when satisfying the level of allocations required to meet the eventual scale of development as distributed through the chosen spatial strategy. Whilst the Local Plan allocates a
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number of sites within the Biddenham, these allocations are only to cover a period up to 2030. It is therefore necessary to ensure sufficient land is allocated to the period up to 2040.
2.18 Having regard for the clear benefits of the residential development of land north of the A4280 (Figure 1), its inherent sustainability located between existing allocations (which were both found to be sustainable and sound as part of the adopted Local Plan examination) and lack of constraints which would preclude development of the site, we consider this site should be positively allocated as part of the emerging Local Plan.
2.19 This site can deliver circa 35-45 dwellings, including policy compliant levels of affordable housing and a suitable housing mix.

Attachments:

Bedford Draft Options and Draft Policies - Representations_Redacted1.pdf (317.21 KB)

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8658

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

Representation Summary:

3.49 The opportunity for transformative change resulting from the delivery of East-West Rail within Bedford Borough is not disputed. However, the Council’s own evidence demonstrates that the level of rail-based growth at Kempston Hardwick/Stewartby and Wixams relied upon as part of its Preferred Options is unsound. National Planning Practice Guidance ID: 68-020-20190722 states that a pragmatic approach should be taken when considering the intended phasing of sites, where the authority may need to provide a greater degree of certainty than those in years 11-15 or beyond.
The PPG expands on this by stating that where longer-term sites are relied upon evidence must be available to demonstrate that they will come forward within the timescales envisaged and at a rate sufficient to meet needs over the plan period (ID: 68-019-20190722).
3.50 While these sections of the PPG post-date the NPPF2012 it is the case that the Council has historically failed entirely in setting out realistic timeframes for the development of complex sites. These shortcomings have particularly affected Town Centre sites in the past, which the Council will now unsuccessfully rely upon to sustain completions against the housing requirement in the Local Plan 2030. We argued at the previous Local Plan Examination that such sites should be identified as developable no earlier than the 11-15 year period.
3.51 These issues with existing sites will be compounded in the Council’s trajectory for the Local Plan 2040 (meaning that even its proposed ‘stepped approach’ against a requirement of 970dpa to 2030 will not be effective). These representations further demonstrate the lack of evidence to consider rail-based growth in the A421 corridor as developable any earlier than years 11-15 of the plan period (if not beyond) thus rendering the Council’s Preferred Options entirely unsound.
Reasoning
3.52 The Council’s own Development Strategy Topic Paper identifies multiple risks to the railbased component of growth in the A421 corridor, including:
• Delivery of new rail stations is proposed, but not yet confirmed.
• Lead in times for remediation of the Kempston Hardwick area and delivery of new rail stations mean that development in this part of the transport corridor will occur later in the plan period.
• Detailed analysis of context and density / storey heights to establish appropriate place making for the rail based growth at Kempston Hardwick and Stewartby has
yet to be undertaken.
• The land at Kempston Hardwick is currently being promoted for employment development.
3.53 These points confirm that the Council’s extremely wide range of potential quanta for the development of rail-based growth are not currently informed by evidence of site-specific opportunities assessed as suitable, available or achievable. This means that there is no justification whatsoever for the levels of development summarised at paragraph 3.12 of the Council’s Topic Paper:
“Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams. On the assumption that new rail stations will be delivered at Wixams and Stewartby / Kempston Hardwick, ambitious growth is assumed at both Wixams and Stewartby / Kempston Hardwick in the range of 1,500-3,000 dwellings at Wixams and 2,500-5,000 dwellings at Stewartby / Kempston Hardwick by 2040. Within the options two levels of development are tested: a lower option total figure of 5,500 dwellings (2,000 at Wixams and 3,500 at Stewartby / Kempston Hardwick) and a higher option of 7,500 dwellings (3,000 at Wixams and 4,500 at Stewartby / Kempston Hardwick)”
3.54 There is no evidence to indicate these totals as developable in the period to 2040. In the absence of site-specific testing the Council can have no grounds to suggest how constraints might be overcome, when infrastructure will be provided and whether the extremely high levels of development required to meet these totals over a very short period between some time after 2030 and 2040 can be achieved.
3.55 The extent of this uncertainty is summarised in footnote 1 on pp.8 of the Development Strategy Topic Paper:
“East West Rail are currently consulting on two options for the Marston Vale Line; one which retains the current stations at Stewartby and Kempston Hardwick, and another that replaces them with a new station (tentatively named “Stewartby Hardwick”) at Broadmead Road. This component of growth is based on development around the new or existing stations in conjunction with development around the new station at Wixams. These stations could provide a focal point for higher density growth supported by the sustainable travel options offered by new and enhanced rail services.”
3.56 The consultation referred to recently closed in June 2021 and final decisions on the ‘Concept’ for stations on the Marston Vale line are awaited. For the avoidance of doubt, the expected timeframes set out in the most recent Consultation Document indicate that a
Development Consent Order may be obtained by 2024 and construction on the rail works may commence in 2025. However, this does not provide a clear timetable for the delivery of individual projects and upgrades. Stage 05 (‘Construction’) is summarised as follows:
“Once we’ve complied with any initial conditions or requirements included in the Development Consent Order, the government will consider the full business case for the Project to make the final decision to proceed. Following further conversations with the public and stakeholders, can start to construct your new railway.”
3.57 The potential for residential development to occur in conjunction with the delivery of new stations as intended by the Council is likely to require a substantially longer lead-in timeframe.
3.58 The Council has previously acknowledged that longer lead-in timeframes must be allowed for as part of redevelopment of the Stewartby Brickworks (Policy 25) development plan allocation as it exists in the LP2030. The Local Plan trajectory anticipates delivery of only (at most) 100 units in 2029/30 before the end of the current plan period. The scheme is in effect accepted as an 11-15 year developable site.
3.59 Application proposals under reference 18/03022/EIA (validated November 2018) benefit from
an Officer recommendation to grant planning permission subject to S106 agreement. In practice, this does not alter any conclusions regarding the deliverability/developability of the site and likely timescales. Discussions surrounding the draft S106 obligation would be anticipated to be extensive. This is reflective of the constraints of the site and gaps in the evidence base for the LP2030, notably:
• Around 19ha of the site falls within Flood Risk Zone 2. Furthermore, a small proportion (around 1ha) is located within Flood Risk Zone 3a/3b.
• A requirement to confirm costs and timescales for the requisite link from the new development across the railway could be achieved (notwithstanding ongoing
deliberations regarding East-West Rail). whilst Network Rail is identified as a key stakeholder for preparation of the Council’s Infrastructure Delivery Plan (December
2018) no project associated with the rail crossing is identified, costed or phased over the course of the plan period.
• The Council’s Local Plan Viability Assessment (BNP Paribas, November 2017 (paragraph 6.16)) notes the requirement for significant investigations to assess onsite constraints for this complex site, with a view to preparation of a development brief, all prior to detailed viability work taking place.
3.60 It is our experience from monitoring the delivery of the nearby Wellingborough East Urban Extension that the construction of crossings over rail lines can take significant periods of time and are unpredictable.
3.61 The Officer Report in relation to the current position on securing a policy-compliant (and CIL122-compliant) package of contributions towards the site’s ability to enhance use of railbased transport states:
“Policy 25 iv. Sets out a need for enhancements to the existing railway station environment including accessibility, provision of facilities and security. If the railway station stays in its current location the increased permeability of the site will improve connections from the village to the station. The Railway Station however does not fall within the application site and is under review as part of the wider East West Rail scheme,
details of which are not confirmed at this time.”
3.62 Given this uncertainty we would anticipate it is highly likely that a S106 obligation may not be entered into until these uncertainties are resolved or that otherwise it would be expected that this would be subject to future Deeds of Variation or revisions to the scheme resulting in delays to the delivery of housing.
3.63 The Council’s Preferred Options also identify a contribution of around 2,000-3,000 further units to be allocated at Wixams, to correspond with eventual delivery of a further new station as part of the wider scheme. These units will be additional to the remaining capacity identified in the Bedford Local Plan 2030 trajectory and units to be delivered as part of committed
development in Central Bedfordshire’s Local Plan (which already includes a Southern Extension to the scheme).
3.64 The longstanding issues with delivery of the Wixams New Station are illustrative of the impacts upon rates of development likely to be experienced at Stewartby/Kempston Hardwick. Evidence presented at LP2030 Examination demonstrated that the build-out rate of Wixams within Bedford Borough has been 96 dwellings per annum over the 10-year period to 2018. Development has since commenced in Central Bedfordshire, increasing the overall build-rate but corresponding with a reduction of activity in Bedford Borough.
3.65 Delivery of the Station has been delayed by over 11 years with the project still not expected to commence construction until 2023 at the earliest. Commissioning of a detailed design scheme for the proposed station was able to progress earlier in 2021 contingent on the basis
of consultation on the proposed northern alignment of East-West Rail.
3.66 While any final decision is awaited on the outcome of the Bedford-Cambridge phase of East- West Rail there remains a risk that the time-limited period for funding available from the lead developers of the Wixams scheme will expire and result in the project not being delivered (or requiring additional monies to address the shortfall in project costs).
3.67 In the context of the above delays and uncertainty and in the absence of a clear timeframe for delivery of the station the Council’s Preferred Options present no site-specific evidence of how the additional capacity at Wixams could be achieved over the plan period and at an appropriate build-out rate (in addition to the delivery of extant commitments).
3.68 The characteristics of any potential increase in allocations at Wixams also represents an issue of cross-boundary strategic importance, given that the scheme is being delivered across local planning authority boundaries and the requirement for partial review of the
Central Bedfordshire Local Plan 2015 to 2035. This could lead to any potential for additional development being required to address the unmet needs of neighbouring authorities (or affecting the administrative boundaries within which the most appropriate land should be identified).
Remedy
3.69 These representations demonstrate that the rail-based growth component of the Council’s Preferred Strategy Options requires substantial further refinement and site-specific testing. This is likely to substantiate a significant reduction in assumptions regarding the potential for development within the plan period, which can be effectively mitigated through pursuing a ‘hybrid’ strategy for development in sustainable locations across the borough.

Attachments:

1.9.21 Bedford LP 2040 Consultation DLP for Mr & Mrs Box - Submission Redacted.pdf (4.47 MB)

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8692

Received: 13/09/2021

Respondent: Mr J Francis

Representation Summary:

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 the A421 transport corridor. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe.

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.
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. 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.
We do also recognise that the Little Barford site may be affected by the East West rail line, it might put pressure on services in St Neots (although it is a much smaller site than Dennybrook and only 2,500 of the potential 3, 085 are required) and it would not benefit Bedford town centre. Therefore, another option may be a new settlement of 2,500 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.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8718

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

Representation Summary:

5.1 This section of our representations should be read alongside the standalone Review of the Council’s Draft Sustainability Appraisal (copy at Appendix 6). The conclusions of the review support the Modifications in this part of the representations. This section also reinforces our specific comments on the Council’s Preferred Strategy Options.

Paragraph3.17andOption2d–Comment
5.2 These representations endorse the inclusion of the ‘east’ corridor parishes as part of Preferred Option 2d but in practice indicate that this is illustrative of a need for a ‘hybrid’ approach to provide for an appropriate strategy in accordance with national policy and guidance (NPPF2021 paragraph 35(b)).

5.3 These representations conclude that any selected strategy option that does not include growth in the ‘east’ corridor parishes would be unsound and fail to comprise an appropriate strategy or genuine reasonable alternative for the purposes of the Sustainability Appraisal. This is due to soundness issues identified with the delivery of large-scale strategic growth comprising other components of the Council’s Preferred Options.

5.4 The benefits of Option 2d reflect the ability to promote and maximise the benefits of what is in-effect village-related growth at the Key Service Centre of Great Barford, which is very sustainably located within the A421 corridor. Growth at Key Service Centres is an approach that the Council has accepted as sustainable in the spatial strategy of the adopted LP2030, and the evidence base for the Local Plan 2040 indicates no in-principle constraint to capacity for further development at Great Barford that could not be adequately mitigated.

5.5 Endorsement of growth at Great Barford under Option 2d in the context of a ‘hybrid’ strategy recognises that there is no arbitrary distinction between ‘village-related’ growth and support for development in the ‘east’ and ‘south’ corridor parishes in terms of their capacity to contribute towards sustainable development. The benefits of ‘village-related’ development do not suddenly materialise only where Key Service Centre and Rural Service Centres are located in the A421 corridor and do not evaporate altogether outside of it.

5.6 To achieve the objectives of the emerging Local Plan 2040 it is necessary to support further village extensions to the settlement of Great Barford, incorporating our client’s Willoughby

Park proposals, to secure contributions to sustainable development that are assessed favourably in the draft Sustainability Appraisal (including new green infrastructure, community facilities and opportunities for recreation). The potential to secure these benefits should be reflected within the Council’s conclusions on site selection and evidence base for the submission draft version of the Plan, once finalised, including the Infrastructure Delivery Plan and Settlement Hierarchy Review, which both remain awaited.

DraftSustainabilityAppraisal–SuggestedAppropriateStrategyAlternative
5.7 A ‘hybrid’ option would assign the ‘village-related’ growth component only to those settlements outside of the ‘east’ and ‘south’ corridors. Levels of development, for the purposes of an indicative distribution, have been retained at 500 units in Key Service Centres and 35 units in Rural Service Centres albeit these are arbitrary figures and should be determined on a case-by-case basis. Wixams has been excluded from the total for Key Service Centres (reflecting its inclusion in the locations for rail-based growth). The only exception, taking account of this, is an increase of 215 units in the distribution to Oakley (based on its suggested reclassification as a Key Service Centre set out in representations on behalf of other clients submitted to this consultation).

5.8 For the A421-based components of the strategy the total distribution to the ‘east’ corridor parishes are retained at the figure of 750 dwellings in the Council’s Preferred Option 2d. This marginally exceeds the Council’s arbitrary figures applied for the purpose of testing Great Barford, Roxton and Willington as ‘village-related’ growth but would in our view represent a more realistic starting point taking account of the capacity for growth at Great Barford and in-particular our client’s Willoughby Park site. There is no site-specific justification or settlement-specific justification as to why this figure should be limited to 750 dwellings.

5.9 In terms of the ‘hybrid’ strategy this could accommodate greater flexibility in terms of large- scale strategic growth included in the strategy options. We have included the Council’s minimum figures for inclusion of rail-based growth at Kempston Hardwick/Stewartby and New Settlements in either the A6 or A421 corridor, which is more likely to reflect realistic timescales for development.

5.10 Including both components, if required (New Settlements and rail-based growth) would comfortably exceed the minimum 12,500 units required from additional allocations, with an

appropriate buffer for flexibility and contingency (particularly in terms of the prospects for meeting increased needs before 2030). There is no reason higher quanta could not be included as part of an extended plan period. Equally, this could allow some settlements outside of the transport corridors to be excluded from further village-related growth. We would, however, not recommend this where Neighbourhood Plans being prepared have failed to address important strategic priorities (as at Oakley and Sharnbrook, for example).

5.11 The ‘hybrid’ strategy based on these components are summarised in Table 1 below:

SEE ATTACHMENT FOR TABLE

5.12 We have utilised the ‘hybrid’ strategy to consider an assessment of effects in-line with the Council’s Sustainability Appraisal framework. When the ‘hybrid’ strategy is compared with the standalone findings for growth components and the Council’s Options 2d and 3c, as well as the ‘do nothing’ scenario, it is apparent that the potential benefits towards sustainable

development are enhanced.

5.13 This is as a result of recognising that the potential negative effects the Council assigns to village-related growth are incorrect and, in any event, inaccurate because it ignores the location of some Key Service Centres and Rural Service Centres within the A421 corridor. It also recognises that some the benefits of what is in reality ‘village-related’ growth in the ‘east’ and ‘south’ transport corridors will be shared across settlements elsewhere in the hierarchy. Likewise, the assessment of positive effects for strategy options including the ‘east’ transport should be increased due to the ability to provide for sustainable village extensions at Great Barford. The results are summarised in Table 2 below:

SEE ATTACHMENT FOR TABLE

Attachments:

Draft Plan representation (11.18 MB)

Manton Lane - BBC I and O Rep - September 2021 Final (272.27 KB)