3.17

Option 2a - Development in and around the urban area, plus A421 transport corridor with rail-based growth – south

Huntingdonshire District Council in principle support this option as it would meet the identified housing and employment needs of the Borough in full. It is also noted that the Draft Sustainability Appraisal (June 2021) scores option 2a more positively in sustainability terms than options 2b, 2c and 2d. SA Objective 5 ‘Promote strong, sustained and balanced economic growth, stimulating job creation across a range of sectors’ and SA Objective 15 ‘Reduce the need to travel and promote sustainable modes of transport’ were both scored more highly in option 2a than the other preferred options.

Option 2a would also promote the vitality and viability of Bedford town centre as it concentrates development in close proximity to the town centre along established transport routes. This option utilises existing transport infrastructure, in particular the five railway stations located within and to the south of Bedford which would facilitate public transport use assisting Bedford Borough in contributing to the UK’s targets on carbon emission reductions. It would also coordinate strategic growth with a potential/proposed new Bedford station built to the north to accommodate the East-West rail line. Having development at scale within a contained radius improves opportunities to incorporate and finance new and enhanced public transport routes to serve new and existing communities and maximises the use of existing social and community infrastructure.

Option 2b - Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement from a choice of either Wyboston (also known as Dennybrook) or Little Barford

Option 2b causes Huntingdonshire District Council significant concern regarding the risk of coalescence between St Neots and any growth in its surrounding area (including at Wyboston and Little Barford) and impact of this growth on residents of St Neots in terms of access to and demand for services, retail and social and community infrastructure. If a new settlement were located either at Wyboston (Dennybrook) or Little Barford, landscaping and settlement breaks would be critical to prevent physical coalescence and retain separate settlement identities. Huntingdonshire District Council would wish to work very closely with Bedford Borough Council if a development strategy option including one of these sites is pursued in order to understand potential impacts and if chosen to ensure appropriate mitigation is put in place prior to any detrimental impacts being experienced by St Neots’ residents and businesses.

As detailed assessments are yet to be published on the impacts on infrastructure and services in St Neots and nearby villages arising from either the Wyboston (Dennybrook) or Little Barford new settlements, Huntingdonshire District Council’s initial concerns relating to each of these sites are provided below. Once detailed assessments are undertaken, Huntingdonshire District Council would wish to work with Bedford Borough Council to minimise and mitigate any detrimental impacts on St Neots and nearby villages and to maximise any potential positive outcomes for Huntingdonshire’s residents.

Wyboston (Dennybrook Garden Village)

Huntingdonshire District Council object in principle to the potential new settlement at Wyboston (known as Dennybrook Garden Village). The closest elements of the proposal immediately adjoin the western side of the A1 either side of Bushmead Road and would be situated within 100 metres of the western edge of St Neots which gives rise to significant concerns over the many impacts it would be likely to have for local residents.

Huntingdonshire District Council is extremely concerned about the long term intended scale of the proposed development at Wyboston (Dennybrook). It is noted that the developer, Taylor Wimpey, submitted the site to Bedford Borough Council for 7,500 - 10,150 new homes. It is noted that the site has however been included within three of Bedford’s preferred options for 2,500 new homes. This is significantly less than the developer’s intentions for the site. The consultation material is unclear on the justification for this reduction to 2,500 homes and the implications a reduced quantum of development would have on the infrastructure and services capable of being provided. Huntingdonshire District Council is very concerned about the feasibility of delivering just the reduced scheme as it would be unable to provide sufficient infrastructure to meet all locally generated needs and so would, in all probability, place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. It would be beneficial to gain clarity on Bedford Borough Council’s long term ambitions for Dennybrook and whether the intention for the longer term strategy beyond 2040 would be for continued expansion to a scale more aligned to the developer’s stated intentions.

The Bedford Borough Transport Model: New Settlement West of Wyboston (April 2021) specifies that it considered three development scenarios without and with proposed mitigation measures for Wyboston (ranging for 2,500 to 5,150 new homes at Dennybrook by 2040 and up to the maximum proposed settlement size of 10,150 dwellings by 2050). This reinforces the Council’s apprehension over the long-term intentions for Dennybrook. This assessment leads to several detailed concerns, namely:
• Paragraph 2.4.2, further explanation is required why ‘no employment has been assumed to be associated with the proposed development for this assessment’. A development of this potential scale in any of the scenarios should incorporate a mix of uses in order to support a balanced and sustainable community. To assess the potential journeys and impact that employment development may have on the transport network is essential to understand comprehensively the mitigations required to make a scheme acceptable in highway terms.
• Figure 3.2 shows that without the proposed mitigation measures the traffic generated by the proposed Dennybrook development is forecast to primarily use routes to the south of the development towards Roxton and onto the A1 / A421 Junction, to the west towards the north-east of Bedford town and the A6, and to the north to access St Neots via Bushmead Road or Duloe Road. However, Figure 3.3 shows that the mitigation would increase traffic on the northern roads Bushmead Road and Duloe Road in AM Peak hour (08:00 to 09:00) in the 2050 Dennybrook scenario, with paragraph 3.3.4 stating that the pattern of forecast development traffic is not significantly altered by the proposed mitigation measures. Implementation of Dennybrook will not be acceptable without adequate highway and non-motorised user infrastructure improvements to fully mitigate its impacts.
• Figure 3.5 shows an increase in the forecast flow change from that forecast in the 2030 Local Plan scenario to 2050 even with mitigation in the AM peak hour (08:00 to 09:00) along Bushmead Road will worsen. This is unacceptable.
• Figure 3.11 shows the forecast volume-capacity ratio change from that forecast in the 2030 Local Plan scenario to 2050 including mitigation, AM peak hour (08:00 to 09:00). It shows that there is a larger change on Duloe Road, Bushmead Road, Monarch Road and Nelson Road within St Neots raising concern over the impact on residents along these routes.
• Table 3.6 shows an increase in delays to Bushmead Road / Staploe Road and Bushmead Road / Duloe Road even with mitigation. Table 3.7 again shows significant impacts in terms of increased delays which would be unacceptable, as such further mitigation measures should be explored. If adequate mitigation cannot be incorporated within the scheme then it would indicate the scheme cannot be successfully delivered.

Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Dennybrook further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the potential new settlement and its resultant impacts.

The potential development at Wyboston is not well connected to existing public transport routes nor will it be to the preferred route option for East-West rail where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy. Without thorough consideration and incorporation of sustainable and safe modes of transport connecting the settlement to such transport hubs, it is likely to result in increased trips being made by private cars. The reliance on the A1 for transport and the impact of development on the capacity along the A1 is of concern, particularly regarding the impacts on the Buckden roundabout for which mitigation works are required in response to locally proposed development. In addition, the potential delays in journey times arising from increased vehicle movements along the A428 and consequent delays and congestion within St Neots would detrimentally affect residents and businesses of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change.

The location and quantum of employment floor space within the site are of concern, particularly in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses within the proposed new settlement should the proposal move forward.

The proposed new settlement is an extensive predominantly greenfield site comprising land of highest quality agricultural value. Alternative options which prioritise the use of previously developed land should be fully explored before this site is included in Bedford’s future development strategy. The site may have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

In conclusion, Huntingdonshire District Council have considerable concerns over the long-term potential scale of the scheme and object to the potential allocation of Wyboston (Dennybrook) as a strategic scale location for growth based on the significantly detrimental impact on St Neots in terms of increased demands on infrastructure, proximity of development, substantial landscape impact, traffic generation, air quality, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

Little Barford

Huntingdonshire District Council equally have several points of concern and observations about the potential new settlement at Little Barford. It is located approximately 500m south of St Neots with a proportion of its northern and eastern edges aligning with Huntingdonshire’s district boundary.

Huntingdonshire District Council are concerned about the long term intended scale of the proposed developed at Little Barford. It is noted that the site was submitted to Bedford Borough Council for 3,385 – 3,955 new homes. The site has however been included within three of the preferred options for 3,085 new homes. Based on the consultation material, justification for the reduction in this figure to 3,085 is unclear as a reduced quantum of development would have an impact on the infrastructure and services capable of being provided within the scheme and thus increase pressure on services and infrastructure within St Neots detrimentally impacting existing residents.

It is also noted that two other sites were submitted to Bedford Borough Council around Little Barford on either side of Barford Road for a combined total of 1,385-1,645 new homes, but it appears that only the site at Top Farm (land east and west of Barford Road) for 3,385-3,955 new homes is included within the preferred development strategy options.

Huntingdonshire District Council is concerned about the feasibility of delivering the Little Barford new settlement and whether it will be able to provide sufficient infrastructure to meet all locally generated needs. If adequate infrastructure is not provided on the proposed development this would likely place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. Moreover, the Little Barford new settlement heightens the risk of coalescence which must be avoided through measures such as very substantial landscaping including landscape buffers to retain a physical and perceptual separation from Little Barford to St Neots. To assist in addressing these concerns, it would be beneficial to gain clarity on Bedford Borough Council’s long-term ambitions for the Little Barford new settlement and the adjoining land submitted during the Call for Sites consultation.

Huntingdonshire District Council acknowledge that this site is likely to benefit from being in closer proximity to a new East-West rail route where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy and thus has greater potential to incorporate sustainable modes of transport. However, there is still uncertainty on the location of an East-West railway line station and when it may be delivered. Additionally, there is also the timing and delivery of the proposed realigned A428 route which will impact the eastern edge and southern aspects of the site to consider. These may give rise to delays in effective masterplanning of the site, mix of land uses, incorporation of sustainable and accessible transport and its eventual delivery. This is a concern as this could place additional pressure on the services and infrastructure of St Neots if not planned thoroughly and with enough services and infrastructure in which to sustain itself. These concerns are exacerbated as St Neots town centre is located 2 miles north of the site whereas Bedford town centre is some 9 miles away. Therefore, it is likely that people will look to St Neots for services.

The uncertainty of the location and quantum of employment floor space within the site are of concern, in particular in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses should the proposal move forward.

Development at Little Barford is likely to increase pressure on the road network particularly along Barford Road and the roundabout between it and the A428. The potential delays in journey times arising from increased vehicle movements along the A428 and Barford Road and consequent delays and congestion within St Neots would detrimentally affect residents of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change. There are also concerns about any linkages and impact on local roads Potton Road and Dewells Lane.

Table A.5 of the Bedford Borough Transport Model Local Plan Assessment (May 2021) identifies that additional mitigation is required for this site, this being the incorporation and linkage of the settlement via accessible and sustainable modes to St Neots and an interchange station at Tempsford. In principle Huntingdonshire District Council are supportive of greater integration between areas via safe and sustainable modes of transport. This mitigation measure is required in addition to those identified within Table A.3 of the assessment under the two options ‘pink, yellow & brown’ and ‘red & orange’ where the options indicate growth in the Little Barford area. Improvements in pedestrian and cycle connectivity between St Neots and Little Barford would also be necessary to support active and sustainable modes of transport. Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Little Barford further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the scheme and how these can be delivered. This should incorporate improved pedestrian and cycle connectivity.

It is acknowledged that a new settlement at Little Barford would reduce the loss of higher quality agricultural land when compared to Wyboston. Although the development may have an impact on designated heritage assets. The site may also have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

Land to the west of Barford Road toward Wyboston Leisure Park is at a high risk of flooding, therefore large scale development within its immediate vicinity (even if not located on land classified as vulnerable to fluvial flooding) must consider and mitigate the impact it may have on all forms of flooding events in line with national policy. This should also consider the combined flooding impacts of the development with the improvement works to the A428. Mitigation measures must not increase the likelihood of flooding events elsewhere, for instance within St Neots where the River Great Ouse runs through the centre of the town and is therefore more vulnerable to flooding. This is particularly important to make any development resilient in terms of flooding and climate change.

In conclusion, Huntingdonshire District Council have concerns over the new settlement at Little Barford based on the significant impact on St Neots in terms of substantial landscape impact, risk of coalescence due to the proximity of the site, increased demands on infrastructure, traffic generation, air quality, flooding, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

Option 2c - Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements which would comprise both Wyboston (Dennybrook) and Little Barford

Development option 2c is not supported by Huntingdonshire District Council as this is too reliant on new settlements at Wyboston and Little Barford providing a significant amount of the additional housing and employment growth in close proximity to one another (45% of the 12,500 new homes). Furthermore, the concern of relying on strategic development to deliver a significant proportion of housing are exacerbated when viewed in combination with the existing new settlement allocated in the Bedford Local Plan to 2030 at Wixam for 4,500 new homes south of Bedford.

Moreover, the deliverability of this option is uncertain when considering the lead in times required to invest and put in place necessary infrastructure. Market absorption is another concern as new developments in close proximity to one another could slow delivery not just within Bedford but also in St Neots which may result in fewer new homes being built to keep up with need. Indeed, the Development Strategy Topic Paper (June 2021) highlights on page 32 the challenge of delivering two new settlements in such proximity to one another. Huntingdonshire District Council reiterate these concerns. Additionally, planning for new development alongside the timelines of major transport infrastructure projects like the A428 and East-West rail are complex with factors that are out of the control of the Local Authority and developers to consider.

The closest points of both new settlements (Wyboston and Little Barford) are within 1km of St Neots, a key urban centre within Huntingdonshire so it is likely that they will look to St Neots for services. No assessment has yet been published on the impacts on infrastructure and services in St Neots, but it is likely that this scale of growth will lead to pressures on the residents, infrastructure, town centre, established employment areas of St Neots as well as the townscape and landscape character of St Neots and nearby villages. It is important to note that the construction of a new settlement will take many years and potentially decades. It can take time for such a development to provide enough services, shops, facilities etc in the initial phases to support its growing population meaning there will likely be increased pressure for St Neots to accommodate these additional needs during that time. This is a considerable concern if both new settlements are pursued but is also a concern if one or the other site is brought forward.

Additionally, within the Draft Sustainability Appraisal (June 2021), option 2c scores less positively than options 2a, 2b and 2d as it does not maximise development on previously developed land and would lead to the loss of high quality agricultural land at Wyboston (Dennybrook).

Huntingdonshire District Council’s detailed concerns and observations on both potential new settlements are included below.

Wyboston (Dennybrook Garden Village)

Huntingdonshire District Council object in principle to the potential new settlement at Wyboston (known as Dennybrook Garden Village). The closest elements of the proposal immediately adjoin the western side of the A1 either side of Bushmead Road and would be situated within 100 metres of the western edge of St Neots which gives rise to significant concerns over the many impacts it would be likely to have for local residents.

Huntingdonshire District Council is extremely concerned about the long term intended scale of the proposed development at Wyboston (Dennybrook). It is noted that the developer, Taylor Wimpey, submitted the site to Bedford Borough Council for 7,500 - 10,150 new homes. It is noted that the site has however been included within three of Bedford’s preferred options for 2,500 new homes. This is significantly less than the developer’s intentions for the site. The consultation material is unclear on the justification for this reduction to 2,500 homes and the implications a reduced quantum of development would have on the infrastructure and services capable of being provided. Huntingdonshire District Council is very concerned about the feasibility of delivering just the reduced scheme as it would be unable to provide sufficient infrastructure to meet all locally generated needs and so would, in all probability, place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. It would be beneficial to gain clarity on Bedford Borough Council’s long term ambitions for Dennybrook and whether the intention for the longer term strategy beyond 2040 would be for continued expansion to a scale more aligned to the developer’s stated intentions.

The Bedford Borough Transport Model: New Settlement West of Wyboston (April 2021) specifies that it considered three development scenarios without and with proposed mitigation measures for Wyboston (ranging for 2,500 to 5,150 new homes at Dennybrook by 2040 and up to the maximum proposed settlement size of 10,150 dwellings by 2050). This reinforces the Council’s apprehension over the long-term intentions for Dennybrook. This assessment leads to several detailed concerns, namely:
• Paragraph 2.4.2, further explanation is required why ‘no employment has been assumed to be associated with the proposed development for this assessment’. A development of this potential scale in any of the scenarios should incorporate a mix of uses in order to support a balanced and sustainable community. To assess the potential journeys and impact that employment development may have on the transport network is essential to understand comprehensively the mitigations required to make a scheme acceptable in highway terms.
• Figure 3.2 shows that without the proposed mitigation measures the traffic generated by the proposed Dennybrook development is forecast to primarily use routes to the south of the development towards Roxton and onto the A1 / A421 Junction, to the west towards the north-east of Bedford town and the A6, and to the north to access St Neots via Bushmead Road or Duloe Road. However, Figure 3.3 shows that the mitigation would increase traffic on the northern roads Bushmead Road and Duloe Road in AM Peak hour (08:00 to 09:00) in the 2050 Dennybrook scenario, with paragraph 3.3.4 stating that the pattern of forecast development traffic is not significantly altered by the proposed mitigation measures. Implementation of Dennybrook will not be acceptable without adequate highway and non-motorised user infrastructure improvements to fully mitigate its impacts.
• Figure 3.5 shows an increase in the forecast flow change from that forecast in the 2030 Local Plan scenario to 2050 even with mitigation in the AM peak hour (08:00 to 09:00) along Bushmead Road will worsen. This is unacceptable.
• Figure 3.11 shows the forecast volume-capacity ratio change from that forecast in the 2030 Local Plan scenario to 2050 including mitigation, AM peak hour (08:00 to 09:00). It shows that there is a larger change on Duloe Road, Bushmead Road, Monarch Road and Nelson Road within St Neots raising concern over the impact on residents along these routes.
• Table 3.6 shows an increase in delays to Bushmead Road / Staploe Road and Bushmead Road / Duloe Road even with mitigation. Table 3.7 again shows significant impacts in terms of increased delays which would be unacceptable, as such further mitigation measures should be explored. If adequate mitigation cannot be incorporated within the scheme then it would indicate the scheme cannot be successfully delivered.

Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Dennybrook further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the potential new settlement and its resultant impacts.

The potential development at Wyboston is not well connected to existing public transport routes nor will it be to the preferred route option for East-West rail where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy. Without thorough consideration and incorporation of sustainable and safe modes of transport connecting the settlement to such transport hubs, it is likely to result in increased trips being made by private cars. The reliance on the A1 for transport and the impact of development on the capacity along the A1 is of concern, particularly regarding the impacts on the Buckden roundabout for which mitigation works are required in response to locally proposed development. In addition, the potential delays in journey times arising from increased vehicle movements along the A428 and consequent delays and congestion within St Neots would detrimentally affect residents and businesses of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change.

The location and quantum of employment floor space within the site are of concern, particularly in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses within the proposed new settlement should the proposal move forward.

The proposed new settlement is an extensive predominantly greenfield site comprising land of highest quality agricultural value. Alternative options which prioritise the use of previously developed land should be fully explored before this site is included in Bedford’s future development strategy. The site may have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

In conclusion, Huntingdonshire District Council have considerable concerns over the long-term potential scale of the scheme and object to the potential allocation of Wyboston (Dennybrook) as a strategic scale location for growth based on the significantly detrimental impact on St Neots in terms of increased demands on infrastructure, proximity of development, substantial landscape impact, traffic generation, air quality, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

Little Barford

Huntingdonshire District Council equally have several points of concern and observations about the potential new settlement at Little Barford. It is located approximately 500m south of St Neots with a proportion of its northern and eastern edges aligning with Huntingdonshire’s district boundary.

Huntingdonshire District Council are concerned about the long term intended scale of the proposed developed at Little Barford. It is noted that the site was submitted to Bedford Borough Council for 3,385 – 3,955 new homes. The site has however been included within three of the preferred options for 3,085 new homes. Based on the consultation material, justification for the reduction in this figure to 3,085 is unclear as a reduced quantum of development would have an impact on the infrastructure and services capable of being provided within the scheme and thus increase pressure on services and infrastructure within St Neots detrimentally impacting existing residents.

It is also noted that two other sites were submitted to Bedford Borough Council around Little Barford on either side of Barford Road for a combined total of 1,385-1,645 new homes, but it appears that only the site at Top Farm (land east and west of Barford Road) for 3,385-3,955 new homes is included within the preferred development strategy options.

Huntingdonshire District Council is concerned about the feasibility of delivering the Little Barford new settlement and whether it will be able to provide sufficient infrastructure to meet all locally generated needs. If adequate infrastructure is not provided on the proposed development this would likely place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. Moreover, the Little Barford new settlement heightens the risk of coalescence which must be avoided through measures such as very substantial landscaping including landscape buffers to retain a physical and perceptual separation from Little Barford to St Neots. To assist in addressing these concerns, it would be beneficial to gain clarity on Bedford Borough Council’s long-term ambitions for the Little Barford new settlement and the adjoining land submitted during the Call for Sites consultation.

Huntingdonshire District Council acknowledge that this site is likely to benefit from being in closer proximity to a new East-West rail route where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy and thus has greater potential to incorporate sustainable modes of transport. However, there is still uncertainty on the location of an East-West railway line station and when it may be delivered. Additionally, there is also the timing and delivery of the proposed realigned A428 route which will impact the eastern edge and southern aspects of the site to consider. These may give rise to delays in effective masterplanning of the site, mix of land uses, incorporation of sustainable and accessible transport and its eventual delivery. This is a concern as this could place additional pressure on the services and infrastructure of St Neots if not planned thoroughly and with enough services and infrastructure in which to sustain itself. These concerns are exacerbated as St Neots town centre is located 2 miles north of the site whereas Bedford town centre is some 9 miles away. Therefore, it is likely that people will look to St Neots for services.

The uncertainty of the location and quantum of employment floor space within the site are of concern, in particular in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses should the proposal move forward.

Development at Little Barford is likely to increase pressure on the road network particularly along Barford Road and the roundabout between it and the A428. The potential delays in journey times arising from increased vehicle movements along the A428 and Barford Road and consequent delays and congestion within St Neots would detrimentally affect residents of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change. There are also concerns about any linkages and impact on local roads Potton Road and Dewells Lane.

Table A.5 of the Bedford Borough Transport Model Local Plan Assessment (May 2021) identifies that additional mitigation is required for this site, this being the incorporation and linkage of the settlement via accessible and sustainable modes to St Neots and an interchange station at Tempsford. In principle Huntingdonshire District Council are supportive of greater integration between areas via safe and sustainable modes of transport. This mitigation measure is required in addition to those identified within Table A.3 of the assessment under the two options ‘pink, yellow & brown’ and ‘red & orange’ where the options indicate growth in the Little Barford area. Improvements in pedestrian and cycle connectivity between St Neots and Little Barford would also be necessary to support active and sustainable modes of transport. Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Little Barford further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the scheme and how these can be delivered. This should incorporate improved pedestrian and cycle connectivity.

It is acknowledged that a new settlement at Little Barford would reduce the loss of higher quality agricultural land when compared to Wyboston. Although the development may have an impact on designated heritage assets. The site may also have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

Land to the west of Barford Road toward Wyboston Leisure Park is at a high risk of flooding, therefore large scale development within its immediate vicinity (even if not located on land classified as vulnerable to fluvial flooding) must consider and mitigate the impact it may have on all forms of flooding events in line with national policy. This should also consider the combined flooding impacts of the development with the improvement works to the A428. Mitigation measures must not increase the likelihood of flooding events elsewhere, for instance within St Neots where the River Great Ouse runs through the centre of the town and is therefore more vulnerable to flooding. This is particularly important to make any development resilient in terms of flooding and climate change.

In conclusion, Huntingdonshire District Council have concerns over the new settlement at Little Barford based on the significant impact on St Neots in terms of substantial landscape impact, risk of coalescence due to the proximity of the site, increased demands on infrastructure, traffic generation, air quality, flooding, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

Option 2d - Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement from a choice of either Wyboston (also known as Dennybrook) or Little Barford

Huntingdonshire District Council do not support development option 2d as there are concerns regarding the cumulative impact of a new settlement and development within the eastern parishes along the A421 and their proximity to St Neots and nearby villages in the south of Huntingdonshire District. It is not clear on the size, quantity and potential locations of development sites along this corridor but the option states that it would total 750 homes and 28ha of employment land. This makes assessing their landscape impacts, transport impacts and impacts existing communities along the A428 more difficult.

The scale of development is also unlikely to provide significant new services and infrastructure resulting in future residents needing to travel to urban centres at Bedford and St Neots for service provision. Furthermore, in the Draft Sustainability Appraisal (June 2021) option 2d scored less positively on SA Objective 5 ‘Promote strong, sustained and balanced economic growth, stimulating job creation across a range of sectors’ and SA Objective 15 ‘Reduce the need to travel and promote sustainable modes of transport’. This option is likely to encourage private car use over more sustainable modes of transport due to limited opportunities to utilise service provision via public transport options.

Therefore, this option is likely to place extra demands on service provision within St Neots to the detriment of their accessibility by local residents, particularly in combination with a new settlement at either Wyboston or Little Barford. It is also likely to have a detrimental impact on the local and strategic road network in order to access services within Bedford and St Neots. This may result in additional vehicles on the transport network resulting in delays and congestion and implications on air quality with a greater impact on climate change.

Huntingdonshire District Council’s detailed concerns and observations on both potential new settlements are included below.

Wyboston (Dennybrook Garden Village)

Huntingdonshire District Council object in principle to the potential new settlement at Wyboston (known as Dennybrook Garden Village). The closest elements of the proposal immediately adjoin the western side of the A1 either side of Bushmead Road and would be situated within 100 metres of the western edge of St Neots which gives rise to significant concerns over the many impacts it would be likely to have for local residents.

Huntingdonshire District Council is extremely concerned about the long term intended scale of the proposed development at Wyboston (Dennybrook). It is noted that the developer, Taylor Wimpey, submitted the site to Bedford Borough Council for 7,500 - 10,150 new homes. It is noted that the site has however been included within three of Bedford’s preferred options for 2,500 new homes. This is significantly less than the developer’s intentions for the site. The consultation material is unclear on the justification for this reduction to 2,500 homes and the implications a reduced quantum of development would have on the infrastructure and services capable of being provided. Huntingdonshire District Council is very concerned about the feasibility of delivering just the reduced scheme as it would be unable to provide sufficient infrastructure to meet all locally generated needs and so would, in all probability, place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. It would be beneficial to gain clarity on Bedford Borough Council’s long term ambitions for Dennybrook and whether the intention for the longer term strategy beyond 2040 would be for continued expansion to a scale more aligned to the developer’s stated intentions.

The Bedford Borough Transport Model: New Settlement West of Wyboston (April 2021) specifies that it considered three development scenarios without and with proposed mitigation measures for Wyboston (ranging for 2,500 to 5,150 new homes at Dennybrook by 2040 and up to the maximum proposed settlement size of 10,150 dwellings by 2050). This reinforces the Council’s apprehension over the long-term intentions for Dennybrook. This assessment leads to several detailed concerns, namely:
• Paragraph 2.4.2, further explanation is required why ‘no employment has been assumed to be associated with the proposed development for this assessment’. A development of this potential scale in any of the scenarios should incorporate a mix of uses in order to support a balanced and sustainable community. To assess the potential journeys and impact that employment development may have on the transport network is essential to understand comprehensively the mitigations required to make a scheme acceptable in highway terms.
• Figure 3.2 shows that without the proposed mitigation measures the traffic generated by the proposed Dennybrook development is forecast to primarily use routes to the south of the development towards Roxton and onto the A1 / A421 Junction, to the west towards the north-east of Bedford town and the A6, and to the north to access St Neots via Bushmead Road or Duloe Road. However, Figure 3.3 shows that the mitigation would increase traffic on the northern roads Bushmead Road and Duloe Road in AM Peak hour (08:00 to 09:00) in the 2050 Dennybrook scenario, with paragraph 3.3.4 stating that the pattern of forecast development traffic is not significantly altered by the proposed mitigation measures. Implementation of Dennybrook will not be acceptable without adequate highway and non-motorised user infrastructure improvements to fully mitigate its impacts.
• Figure 3.5 shows an increase in the forecast flow change from that forecast in the 2030 Local Plan scenario to 2050 even with mitigation in the AM peak hour (08:00 to 09:00) along Bushmead Road will worsen. This is unacceptable.
• Figure 3.11 shows the forecast volume-capacity ratio change from that forecast in the 2030 Local Plan scenario to 2050 including mitigation, AM peak hour (08:00 to 09:00). It shows that there is a larger change on Duloe Road, Bushmead Road, Monarch Road and Nelson Road within St Neots raising concern over the impact on residents along these routes.
• Table 3.6 shows an increase in delays to Bushmead Road / Staploe Road and Bushmead Road / Duloe Road even with mitigation. Table 3.7 again shows significant impacts in terms of increased delays which would be unacceptable, as such further mitigation measures should be explored. If adequate mitigation cannot be incorporated within the scheme then it would indicate the scheme cannot be successfully delivered.

Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Dennybrook further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the potential new settlement and its resultant impacts.

The potential development at Wyboston is not well connected to existing public transport routes nor will it be to the preferred route option for East-West rail where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy. Without thorough consideration and incorporation of sustainable and safe modes of transport connecting the settlement to such transport hubs, it is likely to result in increased trips being made by private cars. The reliance on the A1 for transport and the impact of development on the capacity along the A1 is of concern, particularly regarding the impacts on the Buckden roundabout for which mitigation works are required in response to locally proposed development. In addition, the potential delays in journey times arising from increased vehicle movements along the A428 and consequent delays and congestion within St Neots would detrimentally affect residents and businesses of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change.

The location and quantum of employment floor space within the site are of concern, particularly in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses within the proposed new settlement should the proposal move forward.

The proposed new settlement is an extensive predominantly greenfield site comprising land of highest quality agricultural value. Alternative options which prioritise the use of previously developed land should be fully explored before this site is included in Bedford’s future development strategy. The site may have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

In conclusion, Huntingdonshire District Council have considerable concerns over the long-term potential scale of the scheme and object to the potential allocation of Wyboston (Dennybrook) as a strategic scale location for growth based on the significantly detrimental impact on St Neots in terms of increased demands on infrastructure, proximity of development, substantial landscape impact, traffic generation, air quality, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

Little Barford

Huntingdonshire District Council equally have several points of concern and observations about the potential new settlement at Little Barford. It is located approximately 500m south of St Neots with a proportion of its northern and eastern edges aligning with Huntingdonshire’s district boundary.

Huntingdonshire District Council are concerned about the long term intended scale of the proposed developed at Little Barford. It is noted that the site was submitted to Bedford Borough Council for 3,385 – 3,955 new homes. The site has however been included within three of the preferred options for 3,085 new homes. Based on the consultation material, justification for the reduction in this figure to 3,085 is unclear as a reduced quantum of development would have an impact on the infrastructure and services capable of being provided within the scheme and thus increase pressure on services and infrastructure within St Neots detrimentally impacting existing residents.

It is also noted that two other sites were submitted to Bedford Borough Council around Little Barford on either side of Barford Road for a combined total of 1,385-1,645 new homes, but it appears that only the site at Top Farm (land east and west of Barford Road) for 3,385-3,955 new homes is included within the preferred development strategy options.

Huntingdonshire District Council is concerned about the feasibility of delivering the Little Barford new settlement and whether it will be able to provide sufficient infrastructure to meet all locally generated needs. If adequate infrastructure is not provided on the proposed development this would likely place extra demands on service provision within St Neots to the detriment of their accessibility by local residents. Moreover, the Little Barford new settlement heightens the risk of coalescence which must be avoided through measures such as very substantial landscaping including landscape buffers to retain a physical and perceptual separation from Little Barford to St Neots. To assist in addressing these concerns, it would be beneficial to gain clarity on Bedford Borough Council’s long-term ambitions for the Little Barford new settlement and the adjoining land submitted during the Call for Sites consultation.

Huntingdonshire District Council acknowledge that this site is likely to benefit from being in closer proximity to a new East-West rail route where a new station is expected along the East Coast Mainline Railway between St Neots and Sandy and thus has greater potential to incorporate sustainable modes of transport. However, there is still uncertainty on the location of an East-West railway line station and when it may be delivered. Additionally, there is also the timing and delivery of the proposed realigned A428 route which will impact the eastern edge and southern aspects of the site to consider. These may give rise to delays in effective masterplanning of the site, mix of land uses, incorporation of sustainable and accessible transport and its eventual delivery. This is a concern as this could place additional pressure on the services and infrastructure of St Neots if not planned thoroughly and with enough services and infrastructure in which to sustain itself. These concerns are exacerbated as St Neots town centre is located 2 miles north of the site whereas Bedford town centre is some 9 miles away. Therefore, it is likely that people will look to St Neots for services.

The uncertainty of the location and quantum of employment floor space within the site are of concern, in particular in relation to the impact on the vitality and viability of the Established Employment Areas within St Neots, especially those to the south (Howard Road Industrial Estate, Little End Road/ Alpha Drive Business Park and Colmworth Business Park). The proposal is highly likely to impact upon the vitality and viability of existing employment areas within St Neots and careful consideration must be given to promoting a sustainable and complementary mix of uses should the proposal move forward.

Development at Little Barford is likely to increase pressure on the road network particularly along Barford Road and the roundabout between it and the A428. The potential delays in journey times arising from increased vehicle movements along the A428 and Barford Road and consequent delays and congestion within St Neots would detrimentally affect residents of St Neots. The impact this would have on air pollution and air quality is particularly important as central St Neots contains an Air Quality Management Area. Huntingdonshire District Council is concerned that this could exceed acceptable thresholds of air pollutants and harm the health of Huntingdonshire residents, this would also be contrary to national policy on air quality and climate change. There are also concerns about any linkages and impact on local roads Potton Road and Dewells Lane.

Table A.5 of the Bedford Borough Transport Model Local Plan Assessment (May 2021) identifies that additional mitigation is required for this site, this being the incorporation and linkage of the settlement via accessible and sustainable modes to St Neots and an interchange station at Tempsford. In principle Huntingdonshire District Council are supportive of greater integration between areas via safe and sustainable modes of transport. This mitigation measure is required in addition to those identified within Table A.3 of the assessment under the two options ‘pink, yellow & brown’ and ‘red & orange’ where the options indicate growth in the Little Barford area. Improvements in pedestrian and cycle connectivity between St Neots and Little Barford would also be necessary to support active and sustainable modes of transport. Should the development strategy at the next stage of the Local Plan preparation include the proposed development at Little Barford further assessment will need to include substantially more detailed consideration of the mitigation measures required to accommodate travel demands arising from the scheme and how these can be delivered. This should incorporate improved pedestrian and cycle connectivity.

It is acknowledged that a new settlement at Little Barford would reduce the loss of higher quality agricultural land when compared to Wyboston. Although the development may have an impact on designated heritage assets. The site may also have detrimental impacts on the designated Lower Great Ouse River Valley green infrastructure network opportunity zone (policy AD24 of the Bedford Local Plan to 2030). All possible avenues to avoid this should be explored before any mitigation options are considered. All opportunities to deliver biodiversity net gain within the scheme should also be investigated and secured.

Land to the west of Barford Road toward Wyboston Leisure Park is at a high risk of flooding, therefore large scale development within its immediate vicinity (even if not located on land classified as vulnerable to fluvial flooding) must consider and mitigate the impact it may have on all forms of flooding events in line with national policy. This should also consider the combined flooding impacts of the development with the improvement works to the A428. Mitigation measures must not increase the likelihood of flooding events elsewhere, for instance within St Neots where the River Great Ouse runs through the centre of the town and is therefore more vulnerable to flooding. This is particularly important to make any development resilient in terms of flooding and climate change.

In conclusion, Huntingdonshire District Council have concerns over the new settlement at Little Barford based on the significant impact on St Neots in terms of substantial landscape impact, risk of coalescence due to the proximity of the site, increased demands on infrastructure, traffic generation, air quality, flooding, climate change and detrimental outcomes for Huntingdonshire residents and businesses.

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

Option 2a, 2b, & 2d - Object
Option 2c - Support

To be sustainable, future development needs to be located within the existing urban centres or within walking distance of rail links. Even if new development in the villages is supported by enhanced bus services these remain inconvenient and unpopular, and will not provide a realistic alternative to car ownership. Options 2 a,b, & d are a continuation of the existing policy of unsympathetic urban sprawl. This is destroying the character of our villages and surrounding environment, adding to congestion/pollution, and exacerbating the decline of the town centre.

The first point we wish to make applies to the plans depicting the growth strategy options. It is not clear that Stewartby Parish features as one of the rail based growth parishes (shown with a pink notation). It is described in the text as being part of the growth area but if the location of Stewartby station is correctly shown, the parish boundary is not included. Please could this be checked and rectified.

It may also be helpful to illustrate the potentially re-located railways stations along East West Rail and not just the one near to St Neots. This applies to Stewartby and Kempston Hardwick. As the Local Plan evolves, the East West Rail strategy is likely to clarify.

O&H are supportive of high levels of growth in this sustainable location. They are also supportive of a new settlement strategy where sustainability can be demonstrated through excellent public transport links. They would caution against over-reliance on a new settlement strategy in the medium term and consider that this should be balanced by bringing forward smaller sites in the shorter term on sites that are readily deliverable. With this in mind, O&H would favour growth options 2a or 2d over 2b or 2c.

These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
Finally, none of the emerging preferred options allocate any growth to Bromham. Bromham is largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy therefore allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and thus was found sound by the Inspector. Bromham is inherently a very sustainable location to accommodate further growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in any of the preferred options. The northern boundary as currently drawn for the southern parishes within 2a, 2b, and 2d is the A428, and yet Bromham to the immediate north of the A428 is as well related to the urban area and would contribute in the same way to a sustainable pattern of development.
As with the point made above, it is acknowledged that Bromham has existing commitments which will deliver housing within the early part of the Plan period. However, Bromham is a sustainable location for growth given its relationship to the urban area and should therefore play a role in meeting the higher housing needs of the Borough (boosting supply in the early part of the Plan period to meet the higher requirement and avoid stepping the trajectory).
This is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase per annum in its housing requirement and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change.
Bromham has capacity to accommodate more development. As noted under representations made at paragraph 1.28, land south of Northampton Road, Bromham (Site ID 757) is a suitable and deliverable site, and could complement existing commitments to the south at Beauchamp Park. That site is already well advanced in the planning process and likely to come forward early in the Plan period.
In determining the best growth strategy, we encourage the Council to reconsider its approach to Bromham and include it as a discreet addition to its preferred strategy, and allow for further growth over the Plan period. Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy in this context.

We support options 2a,b,c,and d as they have better road, rail links and easy access to Bedford.

These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
The suitability of Roxton to accommodate modest growth is recognised within the Options identified within the Topic Paper, forming part of Option 2d, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options). Although Option 2d is not considered the best performing option in the Sustainability Appraisal, dispersing housing growth over a wider area than Option 2a has the advantage of enabling the housing requirement to be met earlier in the Plan period. That will have significant economic and social benefits.
Whichever option or mix of options is carried forward as the preferred strategy, villages like Roxton need to accommodate modest growth (i.e. an additional circa 50-75 dwellings) over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
Rainier Developments would draw your specific attention to land off Bedford Road, Roxton (ID 776) as a suitable site that would complement the strategy in this context.

These representations should be read alongside representations made to paragraph 1.28 and the Development Strategy Topic Paper and Sustainability Appraisal.
As a preliminary point, the emerging preferred options only amount to approximately 12,500 homes. The allocation of 12,500 homes would only just ensure the minimum number of homes required are provided, and would not provide any flexibility to address any delays in delivery that might be encountered during the plan period. It is common for Plans to over provide by some 10% to 15% to give certainty that the housing need will be met, and we note the adopted Local Plan contained an 11% buffer endorsed by the Inspector. The Council should include similar over provision when preparing their Plan.
Secondly, none of the emerging preferred options allocate any growth to all villages, and only certain villages may receive growth depending on which option is chosen (i.e. the southern, rail based, or eastern parishes). To allocate no growth to villages is contrary to national policy which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
A third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that should be met locally. Whilst there are existing commitments within the villages which should contribute housing during the early part of the Plan period, those commitments do not meet the higher housing requirement and it is unrealistic to then assume those villages and communities needs will be satisfied for the remainder of the Plan period to 2040. Moreover, there is no evidence to suggest villages are not capable of accommodating further modest growth over the Plan period. The final preferred strategy therefore needs to include an allocation for some growth within the villages over the entire Plan period to ensure rural communities remain sustainable.
The suitability of Wootton to accommodate growth is recognised within the Options identified within the Topic Paper, forming part of Option 2a, 2b, 2d, 3b, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options).
Whichever option or mix of options is carried forward as the preferred strategy, villages like Wootton need to accommodate growth over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
Rainier Developments would draw your specific attention to land south of Keeley Lane, Wootton (ID 760/771) as a suitable site that would complement the strategy in this context.

I support plan 2b only with one new site at Wyboston this makes use of the established road links and new East/West Rail link.

I object to development options 2a 2b 2d in the areas that include the Southern parishes and East parishes. (East of the A6 and south of the A421 below the greensand ridge and south eastern river valley)
Although they are located near to transport links they deserve to be viewed and valued as unique and valuable in their rural setting between river valley and greensand ridge. This ancient rural landscape includes many important historical and natural features such as remains of medieval field systems, villages, water courses and listed buildings and provides a beautiful contrast to and view from the Greensand ridge. Development, particularly large scale development in these two areas would irreversibly alter the rural character and unique landscape setting of the Eastern Clay Vale villages (5E in the Landscape Character assessment)
Development here would surely contradict the Landscape management guidelines 5E.1.31 to 5E.1.40 and Development Guidelines 5E.1.41-51 , which include conserving the open large scale setting of Cardington Airship sheds, conserving the clear views and visual relationship with the Mid Greensand Ridge, conserving the dispersed pattern of settlements , preventing the merger of villages, and creating further green infrastructure.
The area should continue to provide an open, agricultural setting to Bedford and contrast to the Greensand Ridge as stated in the landscape strategy for this area.
The only option of 2 I would not object to is 2c – settlements near to new train stations would make sense, and the unique character and ruralness of the Southern and Eastern parishes could be preserved and enhanced.
I also was not able to see in sufficient detail the Natural Capital assessment as I don’t have access to GIS . I really hope that those management and development guidelines in the Landscape Character assessment are considered within the natural capital network as the maps of opportunities seem rather sparse in this 5E Eastern Clay Vale area. The fields below the ridge are plentiful in small springs / ponds / watercourses that may not have shown in general habitat assessments but are oases of biodiversity which could be valuably enhanced. The area is also home to a variety of farmland birds which may not fit with development plans, even for net gain opportunities as they require farmland and hedgerow habitats. This may not be reflected properly in the assessment of development in the Southern and Eastern parishes against Objective 2 of the sustainability appraisal which is rather broad brush when assessing biodiversity impact.

Make do with what we have got, stop destroying ourselves with mega housing estates. Make the community as it stands today sustainable.

I consider that option 2b with a new settlement at LITTLE BARFORD NOT WEST OF WYBOSTON is the best option. The East
West rail station south of St Neots will provide a truly sustainable form of development at Little Barford. Dennybrook (west of Wyboston) does not provide a suitable alternative – too far from the rail station, risk of coalescence, good agricultural land.
Alternatively in in addition to Little Barford development, Twinwoods at Thurleigh would be next choice as a significant part of the site is brownfield land.

I notice from the preferred options that there is a lot of focus on development to the south if Bedford, why has development North of Bedford/ in new areas and in existing villages (where there is significant space and plans for East to West railway line) being considered?

In general I would be supportive of small growth distributed along urban and rural areas of the borough, rather than heavy development in one pocket.

Option 2a: The transport corridor communities must be significantly large to sustain themselves on a daily basis and then access Bedford sustainably for less frequent trips (i.e. the garden city model). The transport corridor settlements must be based on secured, exceptional pubic transport networks.

Option 2b: The transport corridor communities must be significantly large to sustain themselves on a daily basis and then access Bedford sustainably for less frequent trips (i.e. the garden city model): those proposed will not be. The transport corridor settlements must be based on secured, exceptional pubic transport networks: this is unclear.

Option 2d: The transport corridor communities must be significantly large to sustain themselves on a daily basis and then access Bedford sustainably for less frequent trips (i.e. the garden city model): those proposed will not be. The transport corridor settlements must be based on secured, exceptional pubic transport networks: this is unclear.

Option 2a: The communities the borough builds must be strongly and sustainably connected to Bedford town or large enough to operate in isolation (i.e. a New Town). Previous developments in Bedford, such as Abbeyfields and Great Denham, have proved that peripheral development with no strong connection to the town become car reliant and not loyal to the town overall (for example Wixams residents have to drive to access wider services and Great Denham residents can access Milton Keynes as easily as Bedford).

Option 2b: The communities the borough builds must be strongly and sustainably connected to Bedford town or large enough to operate in isolation (i.e. a New Town). Previous developments in Bedford, such as Abbeyfields and Great Denham, have proved that peripheral development with no strong connection to the town become car reliant and not loyal to the town overall (for example Wixams residents have to drive to access wider services and Great Denham residents can access Milton Keynes as easily as Bedford).

Option 2c: The communities the borough builds must be strongly and sustainably connected to Bedford town or large enough to operate in isolation (i.e. a New Town). Previous developments in Bedford, such as Abbeyfields and Great Denham, have proved that peripheral development with no strong connection to the town become car reliant and not loyal to the town overall (for example Wixams residents have to drive to access wider services and Great Denham residents can access Milton Keynes as easily as Bedford).

Option 2a: The communities the borough builds must be strongly and sustainably connected to Bedford town or large enough to operate in isolation (i.e. a New Town). Previous developments in Bedford, such as Abbeyfields and Great Denham, have proved that peripheral development with no strong connection to the town become car reliant and not loyal to the town overall (for example Wixams residents have to drive to access wider services and Great Denham residents can access Milton Keynes as easily as Bedford).

Of the available options, 2a has the potential to be the most sustainable.

Option 2b: rail line dispersal assumes that all residents will be using the train: this will not be true and such dispersal would be highly unsustainable and an inefficient use of resources. It also has the potential to dilute potential sustainability gains (for example the viability of bus services). Rail based development should only commence once the stations and lines are in place and working. Wixams was a rail based development and would have been far more sustainable (although by no means entirely) had the railway station been constructed (it is now car reliant).

Option 2a: sustainability measures such as public transport and cycle ways must be in place at the outset to establish positive user habits.