3.17

I believe 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 Grow"
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. Staploe Parish Council would like to highlight that our parish has always been classified as open countryside in the settlement hierarchy so we are surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook (site 977) would form part of the first phase of a large new town of up to 10,800 homes in an entirely rural, unserviced location.
In terms of the proposed settlement at Dennybrook (site 977) (site land west of Wyboston), this ‘new settlement’ does not provide a suitable alternative. This proposed settlement provides for around 2,500 homes. It is located very close to the existing settlement of St Neots and Wyboston and entirely engulfs the existing hamlets of Honeydon and Begwary. It appears to offer very little separation causing potential coalescence. This new settlement would also be car dependent with limited access to the wider road network due to the existing narrow roads. There is poor connectivity in terms of a choice of sustainable modes of transport, including the train. Further details in respect of the proposed development at Dennybrook are addressed in the site assessment for Dennybrook (site 977).
It is evident that the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.
Another option may be a new settlement of 2,500 homes at Twinwoods or Colworth. I 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.

With reference to Option 2B if a new settlement is required then Little Barford should be the preferred location as it is close to the East West rail station. Dennybrook (977) should be discounted because there is a risk of coalescence with St Neots, local roads are unsuitable, the traffic modelling was inadequate, it would engulf existing hamlets and fundamentally change the rural nature of the parish, it would use high quality agricultural land and it is too far from the proposed E-W rail station to be sustainable.
Browns sites such as Twinwoods or Colworth would be better alternative sites.

Brown field sites first and foremost to help climate change. Large developments on good agricultural land should be avoided at all costs. We need to be more self sufficient in food we can grow ourselves especially after the catastrophe that was Brexit.

Option 2B appear to be the appropriate option as it gives identifies small medium & large sites for development. However, if this option is chosen the large development should be at Little Barford to take advantage of the proximity to the proposed new train station.

I support option 2a. Other options have an adverse effect on the villages, which have already seen considerable development- some natural growth is OK. Development near town will encourage use of new stations and town centre- not the case for development in the villages. There is a case for development near the proposed station at Tempsford/St Neots South, but this won't have been decided when this plan is settled. Development in the villages is not greener and we don't need country parks, just access to our countryside. Development in the villages will just increase traffic and so be less green.

I believe that any new development Gould focus on brownfield sites and void the A421 corridor which a particularly attractive rural area which sustains a range of wildlife and remains a popular green lung for Bedfordians. This option 2d should be rejected and new development should be along the lines of option 2c.

Option 2B appear to be the appropriate option as it gives identifies small medium & large sites for development. However, if this option is chosen the large development should be at Little Barford to take advantage of the proximity to the proposed new train station.

I object in the strongest terms to the proposed development of the A421 Transport corridor specifically 2d. Renhold has been subjected to overwhelming development in recent years and this will inevitably have an overspill in to Renhold's village character. The loss of lovely farmland giving country walks to many will be detrimental to peoples mental health and the inevitable increase in traffic along country roads will be damaging to the environment and peoples quality of life.

If you must have any one of them 2a is the best option because it concentrates development around the transport infrastructure. It also completes the Wixams development and avoids new settlements in the open countryside.

I object to options 2a, 2b and 2d.
There is no further housing needed in or near our small rural community of Cotton End. We wish to remain rural. Massive school barely being used recently built which should have been built at Shortstown.
Only feasible option for our village is option 2c - NO EXTRA HOUSES. Our way of life has been diminished enough. We don't wish to be part of a local service centre or attached to Shortstown. Leave Shocott Spring and surrounding fields alone. Thank you.

Option 6 is by far a preferable strategy. The Council's planning department has a narrow-minded, entirely urban-focussed view of sustainability, one that it has maintained for 30 years. Our rural areas have now become inert enclaves for the retired, stripped of affordable housing for young families and lacking in encouragement for the setting up of anything other than a narrow range of "rural-only" businesses.

While I support the wider distribution of housing in rural key service centres I do so because my preferred option is not even on the table. I believe that the variety and individuality that has traditionally characterised rural development in North Beds is being killed off by the council's current policies.

By insisting all rural housing is concentrated within SPAs in Rural Key Service centres and a few designated small settlements the council is actually sacrificing their inherent character at the altar of sustainability. By doing so it knows that rural dwellers will instead support Options such as 2a, 2b, 2c, and 2d, because the alternatives are wholly unpalatable. It is manifestly a deliberate strategy formulated by the planning department, in order to force and implement its own particular strategic vision on the people of the Borough.

My preference would be to greatly loosen and expand the SPAs around villages, allowing for development that wasn't intensely packed, as current policies encourage. North Beds has many small '"Ends" where there are ample opportunities for sensitive development/redevelopment, as they always have been. The Local Plan 2030's Policies 5S, 6 and 7S have killed off whatever possibility there might be for such development in such settlements, as I warned they would at a meeting of the Executive in September 2018.

Bedford Borough Council essentially wants the rates paid by people in the rural area but doesn't want to allow any significant expansion of development there because it will be expensive for it to service with regards to services. However, the inevitable outcome of this tunnel-vision strategy is that rural areas will continue to wither economically - as they have done over the last 30 years - and simply end up as retirement villages, affordable only to those who have accumulated wealth or who are in the third trimester of their lives.

New settlements at Wyboston and/or Little Barford need to be carefully considered. Wyboston in particular currently has no local facilities - no school, no shop, no children's playground and also no main gas. As a consequence of this, Wyboston relies heavily on the local facilities of St Neots which is in Cambridgeshire, whilst paying their council tax to BBC. This already unfairly drains the Cambridgeshire resources. To increase housing in Wyboston without adequate facilities would result in further draining of limited Cambridgeshire resources. In addition to this, Wyboston is currently a rural area with a high number of local residents keeping horses which is not particularly compatible with high traffic, built up areas. Access to Wyboston is already limited, so detailed plans of where access routes would be needs to be provided prior to incorporating new developments into the Local Plan. The current plans are too vague for local residents or planners to accurately assess the impact.

The size of these proposed new developments also needs to be clarified by BBC. This Local Plan document is saying that Little Barford is proposed at 3085 dwellings and Wyboston at 2500 dwellings. However, Taylor Wimpy are distributing documents suggesting that the size will be 4000 new homes, further increasing to 10,000 and employment space. Homes vs Dwellings needs to be clarified, and whether this will be residential or commercial.

Regarding BBC's plan to develop along the new EWR stations, Wyboston would not be an obvious choice for this. The new station is proposed either for St Neots South or Tempsford, making Tempsford or Little Barford the obvious choices for new large scale developments.

I want to make it clear that although I object to options 2b, 2c and 2d in their current form, I do not fundamentally object to new developments in Wyboston or Little Barford. However, greater clarity on number of homes/dwellings, residential/commercial use, access routes and how this links to the EWR and Black Cat developments is required prior to its approval.

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

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

Option for Twinwoods at Thurleigh, as a significant part of the site is brownfield land and colworth, with guided bus route rail link, A6 sustainable transport options also on the right side of town for access to MK
Little Barford is the next best option. The East West rail station south of St Neots will provide a 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.
Kempston and Wixams could also be developed further.

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

I believe one of options 2a, 2b, 2c or 2d would be best

object to proposal of DenyBrook and Wyboston

Preferred Option.

Preferred option 2a.

Development should be closer to Bedford and EWR stations in Bedford and St Johns etc., to ensure reduced carbon footprint.

Would prefer no large scale development in open countryside to protect its intrinsic nature of open countryside.

If a new settlement must take place it should be at Little Barford near proposed EWR station - 2500 house only.

There should not be two settlements near St Neots as it is not an urban area of Bedford and it does not plan services for Bedford residents.

I have severe Parkinson’s and cannot type easily. Please duplicate all of Lucy Crawford’s responses for my views. Her email address is Lucy_crawford@hotmail.com and she lives at 33, Staploe PE19 5JA

These representations are made on behalf of St Modwen Logistics. St Modwen Logistics own and manage Thurleigh Airfield, an established business park and existing allocation, classified as Protect and Enhance and subject to Policy 70 of the Local Plan 2030 (adopted January 2020).

St Modwen Logistics support Thurleigh Airfield’s continued allocation for employment use, classified as Protect and Enhance. Under the Local Plan 2030 sites classified as Protect and Enhance play the primary role in supporting economic development and growth by offering attractive and available opportunities for development to retain and support existing businesses and to secure new inward investment.

The Bedford Employment Land Study (June 2021) (ELS) identifies Thurleigh Airfield as having potential for intensification and recommends that the site remains in the Protect and Enhance category, which St Modwen Logistics support.

St Modwen Logistics consider that sites identified as Protect and Enhance, and in particular brownfield sites such as Thurleigh Airfield, should be identified and prioritised as a location for employment growth in the Local Plan 2040. Taking account of the ELS (please see separate comments), Thurleigh Airfield has significant potential for growth and St Modwen Logistics respectfully request that this is taken into account in the Local Plan 2040.

I have read, understood and wholly endorse the opinion given in their submission by Staploe Parish Council, I am in favour of Option 2b, with the provision that there is a new settlement at Little Barford and not Wyboston.
The proposed settlement at Dennybrook (site 977) (site land west of Wyboston) 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.
A further option may be a new settlement of 2,500 homes at Twinwoods or Colworth. 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. The 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.

Option 2 (d) proposes development along the A421 corridor. This will create a string of development to the new residential centres of Wyboston/Little Barford. The villages enroute will lose their individual characteristics and access to facilities will require even more journeys negatively impacting on the BBCs green ambitions. Further housing, in addition to the 2030 plan, around Great Barford in particular, with its 3 conservation areas calls into question what the purpose of designating conservation areas is if the Council's own planners ignore them. This village has ever more cars, poor public transport/other amenities to support the existing population.

The Council is concerned that the impact on all options (2a/b/c/d) on transport infrastructure serving Great Denham will be significant and adverse without sufficient steps being taken to introduce better transport options for public transport and to alleviate congestion.
Great Denham has been marketed by developers to appeal to commuters, whether by car or rail, and so the provision of congestion free, affordable transport options are necessary if any of the proposed options is to be adopted.

Option 2a would appear to be most supportive of Bedford while the others with development around St Neots would favour increased commercial opportunities in that area & Cambridgeshire, losing out on a potential (very good) opportunity. 2a also makes maximum use of existing brownfield areas.

Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document and confirms that the starting point for the housing requirement in the Local Plan 2040 is a minimum of 1,275 dwelling completions a year, that being the Local Housing Need (LHN) calculated using the Standard Method.

Accordingly, the Council will need to allocate land to enable a minimum of 25,500 dwellings to be delivered in the period up to 2040. That is to meet the LHN and does not even take into account the emerging strategy for the Oxford to Cambridge Arc, and the government’s ambition to deliver substantial growth in the region to capitalise on its economic potential.

It is acknowledged that the timetable set out in Policy 1 of the Local Plan 2030 does not align with the timetable for the publication of the Arc Spatial Framework (ASF), a consequence of the programme imposed by Policy of the Local Plan 2030. As such, the preparation of the Local Plan 2040 will have to progress without the benefit of an ASF in place. Nonetheless, it would reasonable and expected for the Council to proceed with the preparation of a Plan that fully acknowledges the need for transformational levels of growth due to the need arising in the period up to 2040 together with the levels of growth to be met as part of any future ASF. The document also acknowledges there will potentially be a need for a further early review of the Local Plan to response to the ASF where necessary.

Paragraph 3.5 of the consultation advises that the Council is considering the possibility of a stepped trajectory as part of the Local Plan 2040 with the justification being that a number of infrastructure projects, such as improvements to the Black Cat junction and the delivery of the East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Blakeney strongly objects to this approach on the basis that this level of housing need exists now and is not being met. The Council has already used the transitional arrangements when the 2012 Framework was first replaced, to delay delivering the increased housing need required under the Standard Method through the Local Plan 2030, which is the reason this early review has been required. A stepped trajectory would delay further meeting a need that existing presently with real consequences for those struggling to afford a suitable standard of living accommodation in the Borough.

Blakeney is of the view there already exist reasonably sustainable options for growth within the Borough that can appropriately absorb the additional need arising as part of the LPR, thereby circumventing the need for a stepped trajectory. Indeed, paragraph 4.6 of the document confirms that the site put forward through the Call for Sites total far more homes than need to be allocated in the Plan.

Certainly, the preferred emerging options have a degree of focus along the A421 transport corridor, capitalizing on the accessibility to the Bedford and Kempston an urban area via such a link. The Draft Plan Strategy Options presents a bias that A421 transport-related growth should comprise the greatest proportions of growth within the Borough, due to the very limited range of options it presents, as compared to directing development within and adjoining the urban area which the draft Sustainability Appraisal sets out performs the most strongly against sustainability objectives. The Appraisal further notes that village-related components of growth perform more poorly – primarily due to the need to travel by private from these locations but has not addressed the opportunity that future development in such locations would provide a dual opportunity for meeting housing need in addition to enhancing the public transport infrastructure to capitalize on transport corridors such as the A428 or A6 thereby reducing the need for private transport and enhancing the dependability and quality of public transport services.

However, the focus on transport-related growth primarily has revolved around the future East-West Rail and A421 and overlooked other noteworthy transport corridors such as the A6 and A428 which provides good access to well-established Key Services Centres, such as Clapham. Clapham is indeed acknowledged as one of the most sustainable settlements outside of the Bedford urban area, owing in no small to its connectivity with Bedford proper.

The DSTP does not appear to acknowledge in particular these additional transport corridors to their fullest potential, instead considering these options in the context of “new settlements” as opposed to further growth to existing, sustainable locations such as Clapham.

At paragraphs 3.19 – 3.21, the DSTP suggests that option 2 strategies are the most sustainable, followed by options 3 strategies. Both include an element of urban focus, with the former placing an additional emphasis on transport corridors and the latter upon key/rural service centres and new settlements.

As aforementioned, there are options for growth along transport corridors other than the A421 that would still comprise sustainable solutions and would be considered more sustainable options than that falling under option 3. Specifically, north-based transport growth as an option has been entirely overlooked and instead growth in such locations is strictly considered in the context of village growth.

Given that village growth itself would indicate a growth across a range of key and rural service centres, the “average” sustainability” impact of such a strategy overshadows the true cost of distributing development to the most sustainable settlements in the northern parts of the Borough well-connected to Bedford.

Pages 31 – 36 of the DSTP does identify potential highway constraints along the A6 to the north of Bedford, but this remains the context of new settlements at Twinwoods and Colworth and it appears an assessment of the impact solely in the context of expanding existing settlements was not undertaken which could potentially mitigate the capacity concerns. The Bedford Borough Transport Model makes clear that the impact from new settlements is based on an increase of c. 5,895 whereas village related growth in locations already well served by existing corridors would experience far lower, more appropriate, levels of growth if included as part of a spatial strategy – in line with the levels of growth distributed under Local Plan 2030.

It should also be noted that options 3b and / or 3c, which include an element of Blakeney’s preferred strategies for growth, already contain elements of the existing strategy from the Local Plan 2030. As such, and in light of potential concerns surrounding capacity of the A6 and indeed the A421 also, a reasonable approach would be to diversify growth across the Borough by incorporating elements of sub-options 2 and sub-options 3. The diversification of a strategy in this manner would reduce the reliance on any one area of the Borough having to absorb and facilitate growth in the context of both the updated LHN and the incoming ASF.

It is unavoidable that this Council will need to examine more closely all options for sustainable growth as opposed to merely the best options for growth. Doing so would future-proof the Plan insomuch as is possible against the emerging requirements of the ASF at this current point in time to meet not only the minimum targets for housing growth until 2040 as per the LHN, but also the ASF in addition to boosting the supply of homes where possible in line with key objectives of national planning policy.

Other concerns raised within the DSTP in relation to the pros and cons of sub-option 3 growth (in terms of KSCs and RSCs) at paragraph 3.36 is that they would “support the creation of new businesses but with the proviso that this could lead in locational terms to a poorer relationship between where people live and work”.

In practical terms, this is a less of an issue than it ever has been in light of the Covid-19 pandemic. There is a strong desire from many to relocate to less intensified locations such as villages in the countryside given the massive increase in prominence in working from home in 2021. It is already apparent that consumer demand is leading to this being planned for in new developments, through the inclusion of home offices in dwellings and through the specification of technology such as broadband to facilitate it. Certainly, sub-options 3 do no detract from appropriate growth in the urban area and accordingly we should expect people to choose to settle where they consider is best for them in terms of where they live and where they work. This can only be achieved, however, if there is an appropriately diversified development strategy which provides plentiful options for growth across the Borough in differing locations.

Taking the above together, therefore, Blakeney consider that the best approach for a development strategy for the period up to 2040 is one that genuinely champions the distribution of growth in locations that can appropriately support them in a sustainable fashion. This would require a diversified approach that incorporates true transport-based growth in and around the Bedford urban area together with growth at KSCs such as Clapham which remains the most sustainable settlement outside of Bedford proper. Indeed, it would provide a wider choice for future residents to live in rural locations given the rise of the working population that works from home, as well as unique opportunities for the continued revitalization of local economies at such locations. It would also ensure delivery of new housing that is need now, avoiding the requirement for a stepped trajectory, which is not justified and would simply delay meeting a need that already exists.

I am against Option 2d as this includes further development in Great Barford. Under the Local Plan 2030 the village has already been allocated 500 new dwelling which is over a 50% increase in dwellings. Although classed as a Key Centre Great Barford does not have the infrastructure to support further development and introducing the necessary infrastructure will significantly impact on the character and environment of the village.