3.17
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5229
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2a: sustainability measures such as public transport and cycle ways must be in place at the outset to establish positive user habits.
Option 2a: sustainability measures such as public transport and cycle ways must be in place at the outset to establish positive user habits.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5231
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2b: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Option 2b: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5233
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2c: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Option 2c: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5234
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2d: Rail based 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 2d: Rail based 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).
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5235
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2d: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Option 2d: it has not been demonstrated that infrastructure is such that Wyboston/Little Barford resident may be able to easily access the rail station and sustainable transport modes easily. These settlements are away from large centre meaning inevitable journeys to Bedford or Cambridge to meet regular needs. More detail/commitment required before development at Wyboston/Little Barford can be considered.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5237
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Option 2d: Transport corridor village based development: this will be road based development and thus is highly unsustainable. Settlements will not be sufficiently large to sustain themselves and residents will regularly have to travel.
Option 2d: Transport corridor village based development: this will be road based development and thus is highly unsustainable. Settlements will not be sufficiently large to sustain themselves and residents will regularly have to travel.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5248
Received: 03/09/2021
Respondent: Mr Christopher Thompson
Options 2b, 2c & 2d:
New developments close to the Bedford / Cambrideshire border need to be carefully considered as these would cause a drain on facilities in St Neots, while all the council tax from these dwellings would go to BBC.
The new dwellings are also planned for building entirely on green field sites.
Option 2a:
Development is more focussed on brown field. Developing next to existing urban areas also makes sense in terms of existing services etc.
I would be supportive of this option 2a.
However, some additional development around the East-West train station makes sense.
Options 2b, 2c & 2d:
New developments close to the Bedford / Cambrideshire border need to be carefully considered as these would cause a drain on facilities in St Neots, while all the council tax from these dwellings would go to BBC.
The new dwellings are also planned for building entirely on green field sites.
Option 2a:
Development is more focussed on brown field. Developing next to existing urban areas also makes sense in terms of existing services etc.
I would be supportive of this option 2a.
However, some additional development around the East-West train station makes sense.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5259
Received: 03/09/2021
Respondent: Red Eagle Securities
Agent: Woods Hardwick Planning
Please see detailed response.
Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document 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 just to meet the LHN and it does not even take into account the emerging Oxford to Cambridge Arc Spatial Framework (ASF), and the Government’s ambition to deliver substantial growth in the region to capitalise on its economic potential, which could see a higher housing target still in this area, reflective of Bedford’s central location within the arc.
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 ASF, a consequence of the programme imposed by Policy 1. As such, the preparation of the Local Plan 2040 will have to continue ahead of adoption of ASF in place. Nonetheless, it would reasonable and appropriate for the Council to proceed with the preparation of a Plan that fully acknowledges the transformational growth anticipated in the Arc. The consultation 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 document 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 East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Red Eagle Securities strongly objects to this suggestion as the level of housing need indicated by the Standard Method already exists now and is not currently being met given the much lower housing requirement in the Local Plan 2030.
Indeed, the Council purposely took advantage of the transitional arrangements when the 2012 Framework was first updated in 2018, in order to delay having to provide for the increased housing need required under the Standard Method in the Local Plan 2030, which is the primary reason this early review has been required. A stepped trajectory would further delay meeting a need that exists now with real consequences for those struggling to afford a suitable standard of living accommodation in the Borough. We noted in our representations submitted at the Issues and Options stage, that housing prices in Bedford Borough are circa 10 times average salaries, and further delaying seeking to meet housing need until later in the Plan period will do nothing to address the significant affordability issues faced by many in the Borough.
Red Eagle Securities is of the view there already exist both sustainable and deliverable options for growth within the Borough that can appropriately absorb the additional need arising as part of the LPR, thereby avoiding the need for a stepped trajectory. Indeed, paragraph 4.6 of the consultation document confirms that sites put forward through the Call for Sites could deliver far more homes than need to be allocated in the Plan.
Turning to the growth and spatial strategy options in the consultation document, all of the preferred emerging options have a degree of focus on the A421 transport corridor. The Draft Plan Strategy Options presents a bias that A421 transport-related growth should comprise the greatest proportion of growth within the Borough, due to the very limited range of options it presents.
Red Eagle Securities is concerned that the options have been dictated by the Sustainability Appraisal, which suggests that village-related components of growth perform more poorly, primarily due to the need to travel by private from these locations, but this ignores the seismic structural changes currently taking place in both the labour and housing markets as a consequence of the Covid-19 pandemic.
In the labour market many transitional office based sectors are seeing either a permanent shift to home working, or a hybrid approach, whereby personnel work from home for part of the working week, with resulting reduction in traditional journeys to work and reduced traffic. At the same time, the housing market has seen a substantial shift in demand away from towns and cities to properties in more rural locations, with great access to open space and countryside. It would be a significant failure if the LPR fails to respond to this.
There is now undoubtedly an opportunity to provide sustainable new housing in accessible villages such as Oakley, that is planned specifically to be suitable for home working. Sites such as Red Eagles Securities’ at Lovell Road, Oakley, would be ideally place to provide new homes in an accessible location, with good public transport links to Bedford, helping to meet the demand for housing in the Borough’s rural area. It would alsoy enable homes that are needed now to be delivered quickly avoiding the need for a stepped trajectory in the Plan.
The DSTP does not appear to acknowledge in particular the additional transport corridors outside the A421, such as the A6, to their fullest potential, instead considering these options in the context of “new settlements” only as opposed to further growth in the form of small or medium allocations at existing, sustainable locations, such as Oakley.
Pages 31 – 36 of the DSTP does identify potential highway constraints along the A6 to the north of Bedford, but this remains in 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.
Red Eagle Securities is therefore of the view that any spatial strategy included in the next iteration of the LPR should seek to diversify growth across the Borough by incorporating elements of sub-options 2 and sub-options 3 complementing growth in the A421 corridor and on the edge of the urban area, with small and medium size allocations in sustainable villages such as Oakley. 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
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5271
Received: 03/09/2021
Respondent: Mr Michael Lennox
We feel that the the major developments should be in new settlements and brownfield sites . Your proposals reflect both to a limited extent.
Still think there is scope for another new settlement to the North of Bedford (Twinwoods, Thurleigh). Clearly much thought has gone into your proposals and I would rank them as follows First option 2c Second 2b Third 2a Fourth 2d . In particular option 2d would impact on rural areas along A421/A603 and developement would be split by the bypass
We feel that the the major developments should be in new settlements and brownfield sites . Your proposals reflect both to a limited extent.
Still think there is scope for another new settlement to the North of Bedford (Twinwoods, Thurleigh). Clearly much thought has gone into your proposals and I would rank them as follows First option 2c Second 2b Third 2a Fourth 2d . In particular option 2d would impact on rural areas along A421/A603 and developement would be split by the bypass
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5275
Received: 03/09/2021
Respondent: Mr Joe Lewandowski
N/a
Why is the proposal to build a ‘village’ on the Twinwood airfield site not been considered in this Local Plan? It was in the Local Plan 2030. A site there would make more sense than spreading the large number of houses in the rural areas south of Bedford.
Also, I understand that at one point a larger development was proposed at Wyboston that would have been near the proposed EWR station. Why does this not appear in this Local Plan. That would make more sense than Option 2d. Good infrastructure could be provided in such a new ‘village’. Far better than overloading existing services.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5298
Received: 03/09/2021
Respondent: Catesby Estates plc
Catesby Estates object to the emerging preferred spatial options (2a-d) which all fail to identify any growth in the sustainable rural service centres.
Catesby Estates object to the emerging preferred spatial options (2a-d) which all fail to identify any growth in the sustainable rural service centres.
It is essential that the chosen spatial strategy directs additional growth to the rural service centres to meet the requirements of the NPPF (in particular Paragraph 79) which states that “planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”. It is therefore essential that the spatial strategy established for the Local Plan Review realises the full growth potential of the rural villages. The benefit of such a growth strategy will be that facilities and services (such as local bus services, retail and schools) and the overall sustainability of these settlements will be maintained and enhanced.
New settlement proposals will have infrastructure, delivery and viability challenges meaning they are unlikely to deliver new housing particularly quickly. In contrast, the Borough benefits from existing sustainable rural service centres with services and facilities which can accommodate appropriate levels of new housing much faster.
A proportion of future housing growth should therefore be directed to the rural service centres. The Local Plan 2030 identified a requirement of 25-50 additional homes for each of the rural service centres. Neighbourhood Plans for some of the rural service centres have only accommodated the lowest end of this requirement i.e. 25 homes. The identified growth potential of the rural service centres is therefore still to be fully achieved.
To help support local services the chosen spatial strategy for the Local Plan Review should incorporate the development of a minimum of 50 dwellings in each of the rural service centres. This would provide clear guidance for future reviews of the Neighbourhood Plans currently in place.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5401
Received: 03/09/2021
Respondent: Mrs Gwendalyn Selo Skingley
I object to Southern Bedford development for reasons outlined previously. We are losing the semi-rural status of these communities. There is too much light pollution already (Whistl warehouse for example is hugely light polluting).
Lack of infrastructre, schools, green spaces and homes of adequate size. New homes are very small with small outdoor spaces, and local facilities are small and poor.
Damage to heritage of local area.
Urban growth should be prioritised where there is a higher chance of established transport routes which do not rely on cars.
Investment in surgeries and schools needed and quickly not over years
I object to Southern Bedford development for reasons outlined previously. We are losing the semi-rural status of these communities. There is too much light pollution already (Whistl warehouse for example is hugely light polluting).
Lack of infrastructre, schools, green spaces and homes of adequate size. New homes are very small with small outdoor spaces, and local facilities are small and poor.
Damage to heritage of local area.
Urban growth should be prioritised where there is a higher chance of established transport routes which do not rely on cars.
Investment in surgeries and schools needed and quickly not over years
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5406
Received: 03/09/2021
Respondent: Landcrest Developments Ltd
Agent: Woods Hardwick Planning
See detailed representations.
The purpose of this representation, prepared on behalf of Landcrest Developments Ltd (“Landcrest”), is to respond to the Local Plan 2040 strategy options, together with commenting on the initial assessment of the land East of Oakley Road, Bromham in the Site Proforma (Site ID 521).
It demonstrates that in weighing up the emerging strategy options, the optimum approach for meeting housing need within the Borough should involve further growth at existing villages in accordance with the emerging Settlement Hierarchy, and that this is critical if the increased housing requirement derived from the Standard Methodology is to be met. This factors in the current Local Plan 2030 strategy directing the majority of planned growth toward the urban area, therefore supporting a more diversified approach to meeting housing need in the Borough for the period through to 2040 is considered most appropriate and sustainable.
Additional comment is provided in response to the site assessment work being undertaken by the Council and summarised on the Pro forma, although it is acknowledged this remains ongoing. This information directly addresses the potential effects of the Land East of Oakley Road, Bromham, in the context of the sustainability objectives of the Site Selection Methodology 2021.
Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document 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 just 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, which could lead to a further increase in the housing delivery required.
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 1. As such, the preparation of the Local Plan 2040 will have to progress in advance of adoption of the ASF. Nonetheless, it would be 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, arising from its central location within the Arc. 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 East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Landcrest strongly objects to this approach on the basis that this level of housing need exists now and is not currently being met due to the much lower housing requirement in the adopted Local Plan.
Indeed, the Council has consciously used the transitional arrangements when the 2012 Framework was first superseded by the 2018 version, to avoid having to deliver the increased housing need under the Standard Method through the Local Plan 2030, which is the principal reason this early review of the Plan has been required. A stepped trajectory would only delay further meeting a need that exists presently, with real consequences for those struggling to afford a suitable standard of living accommodation in the Borough.
Landcrest is of the view there already exists sustainable and appropriate options for growth within the Borough, that can suitably provide for the additional need arising as part of the LPR, thereby avoiding any requirement for a stepped trajectory. Indeed, paragraph 4.6 of the consultation document confirms that the sites put forward through the Call for Sites total far more homes than need to be allocated in the Plan.
Turning to the preferred emerging growth and spatial strategy options in Section 3 of the consultation, these all have a degree of focus along the A421 transport corridor and 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 alternative options it presented.
Landcrest is concerned that the options have been dictated by the draft Sustainability Appraisal, which suggests that village-related components of growth perform more poorly – primarily due to the need to travel by private car 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 Bromham. Bromham is indeed acknowledged as one of the most sustainable settlements outside of the Bedford urban area, owing in no small part to its connectivity with Bedford.
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 Bromham.
At paragraphs 3.19 – 3.21, the DSTP suggests that the option 2 strategies are the most sustainable, followed by the 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 constitute as 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 is in 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 Landcrest’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 – which in any event do not detract from the sustainability of Bromham, it being better related to the A428, 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 not 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, Landcrest 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 Bromham 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 needed now, avoiding the requirement for a stepped trajectory, which is not justified and would simply delay meeting a need that already exists.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5415
Received: 03/09/2021
Respondent: Mr Peter Norris
Regrettably this form does not identify all 7 categories (comprising 13 0ptions) for individual comment. Brief comment by Option Number are:
1A&B: NOT supported - insufficient building land without intolerable urban spread
2A: Ignores the A1 settlements so NOT supported
2B: IS SUPPORTED
2C: NOT supported - overloads the rail-based (pink) parishes
2D COMPLETELY UNACCEPTABLE - would lead to the loss of Renhold within an enormous urban sprawl up the A421.
3a - 3c: NOT supported - nothing south of Bedford
4: NOT supported - does not include any new settlements
5, 6 & 7: No preference offered
Regrettably this form does not identify all 7 categories (comprising 13 0ptions) for individual comment. Brief comment by Option Number are:
1A&B: NOT supported - insufficient building land without intolerable urban spread
2A: Ignores the A1 settlements so NOT supported
2B: IS SUPPORTED
2C: NOT supported - overloads the rail-based (pink) parishes
2D COMPLETELY UNACCEPTABLE - would lead to the loss of Renhold within an enormous urban sprawl up the A421.
3a - 3c: NOT supported - nothing south of Bedford
4: NOT supported - does not include any new settlements
5, 6 & 7: No preference offered
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5426
Received: 03/09/2021
Respondent: Mr Derek Armitage
Supportive of focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End.
Supportive of focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5431
Received: 03/09/2021
Respondent: Mr Derek Armitage
Supportive of Option 2a and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End.
Supportive of Option 2b and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.
Supportive of Option 2a and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End.
Supportive of Option 2b and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5435
Received: 03/09/2021
Respondent: L&Q Estates Limited
Agent: Pegasus Group
L&Q Estates is promoting land to the East of Wixams which would support the delivery of Growth Strategy Option 2a. Please find enclosed our vision document for Wixams East (Site ID 3233) which provides more detail on how this site fits within the growth strategy.
Wixams East, whilst located within the Parish of Wilshamstead, is more spatially related to Wixams in terms of access to services and facilities. This site is therefore put forward as an extension to Wixams and would sit within the transport corridor - rail base growth villages in the growth strategy options.
The Draft Plan Strategy and Options and Draft Policies Consultation identifies 4 emerging preferred options for where development will be focused over the plan period. Wixams East would support the delivery of all 4 of these options. The sustainability appraisal shows that 2a performs better than the others because it concentrates most growth at rail-based locations at Stewartby/Kempston Hardwick. We are supportive of this conclusion. Options 2a is also not reliant on the creation of a new settlement which takes longer to deliver over the plan period due to the amount of infrastructure required from the outset.
L&Q Estates is promoting land to the East of Wixams which would support the delivery of Growth Strategy Option 2a. Please find enclosed our vision document for Wixams East (Site ID 3233) which provides more detail on how this site fits within the growth strategy.
Wixams East, whilst located within the Parish of Wilshamstead, is more spatially related to Wixams in terms of access to services and facilities. This site is therefore put forward as an extension to Wixams and would sit within the transport corridor - rail base growth villages in the growth strategy options.
Wixams East is proposed to accommodate 2,000 dwellings, a local centre and a new primary school. Access is proposed via two existing roundabouts along the A6. The proposed access strategy will also promote access to and from Wixams and the scheduled Wixams Station for all modes of transport with particular emphasis on walking and cycle. It is proposed that Wixams East will be an extension to Wixams and one community will be formed in the longer terms.
Wixams East will create new parks and spaces that will provide links to the surrounding countryside and provide extensive public open space. The most significant green infrastructure provision will be the creation of a new linear park. We will maximise the connection with the existing and new community to ensure that this regional park will be accessible via all modes of transport for the enjoyment for all. The linear park creates the opportunity to ensure long term biodiversity net gains through habitat enhancement and creation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5437
Received: 03/09/2021
Respondent: Mr Daniel Kownacki
All development options shown indicate large developments outside of the existing urban area. Bedford Town Centre has a vast amount of undeveloped 'brownfield' space (particularly south of the river) and with naturally better public transport provision, I feel this area should be the focus for a very high density development before any out-of-town sites are considered.
All development options shown indicate large developments outside of the existing urban area. Bedford Town Centre has a vast amount of undeveloped 'brownfield' space (particularly south of the river) and with naturally better public transport provision, I feel this area should be the focus for a very high density development before any out-of-town sites are considered.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5438
Received: 03/09/2021
Respondent: Mr Derek Armitage
Strongly object to Option 2d as the proposed transport corridor (east) is unsustainable and will place irreparable strain and harm upon the A603 corridor. Furthermore, there is no clear requirement for the additional 28ha of employment land delivered by Option 2d due to the increase in home working and the already significant proposed employment provision with Option 2a - 2c.
Focus should remain with urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End and on new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.
Strongly object to Option 2d as the proposed transport corridor (east) is unsustainable and will place irreparable strain and harm upon the A603 corridor. Furthermore, there is no clear requirement for the additional 28ha of employment land delivered by Option 2d due to the increase in home working and the already significant proposed employment provision with Option 2a - 2c.
Focus should remain with urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End and on new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5440
Received: 03/09/2021
Respondent: Mr Derek Armitage
Supportive of Option 2c and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision and align with existing A421 transport corridor.
Supportive of Option 2c and focus on urban growth and continued expansion around southern parishes of Stewartby, Wixams, Shortstown and Cotton End. Also supportive of new settlements at Little Barford and Wyboston as they align with the E-W Rail strategy and railway station provision and align with existing A421 transport corridor.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5449
Received: 03/09/2021
Respondent: BRVP Landowners
Agent: Woods Hardwick Planning
Whichever strategy is taken forward by the Council, it should include a new settlement in the form of the Enabling Development for the water sports lake at the Bedford River Valley Park. This would deliver much needed homes and hugely beneficial leisure facility for the Borough.
The purpose of this statement, prepared on behalf of the Bedford River Valley Park (BRVP) Landowners comprised of, Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (“The BRVP Landowners”), is to respond to the Local Plan 2040 strategy options. Separate comments on the initial assessment proforma for the BRVP (Site ID 3245) have also been submitted.
It demonstrates that in weighing up the emerging strategy options, the optimum approach for meeting housing need within the Borough should involve a balanced approach, including growth along the A421 corridor and in the form of a new settlement at the BRVP, as enabling development for the consented water sports lake, as was outlined in detail in the BRVP Landowners Call for Sites submission and response to the previous consultation on Issues & Options (Summer 2020).
Such an approach is critical if the increased housing requirement derived from the Standard Method is to be achieved.
Additional information is provided in response to the site assessment work being undertaken by the Council, which remains ongoing, particularly the Site Assessment Proforma. This information directly addresses the potential effects with regards to the submitted site in the context of the sustainability objectives of the Site Selection Methodology 2021.
Section 3 of the Draft Plan Strategy Options and Draft Policies Consultation document 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 just to meet the LHN and does not take into account the emerging Oxford to Cambridge Arc Spatial Framework (ASF), and the Government’s ambition to deliver substantial growth in the region to capitalise on its economic potential, which could lead to a further increase in the housing delivery required.
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 ASF, a consequence of the programme imposed by Policy 1. As such, the preparation of the Local Plan 2040 will have to progress in advance of the final ASF being in place. Nonetheless, it would reasonable and expected for the Council to proceed with the preparation of a Local Plan that fully acknowledges the emerging need for transformational levels of growth in the Borough in the period up to 2040, arising from its central location within the Arc. The document also recognises there will potentially be a need for a further early review of the Local Plan to respond 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 East-West Rail, in the earlier years of the plan period would enable greater levels of growth in the later years. Given that LHN exists now, the BRVP Landowners are of the view that a stepped approach in the delivery of the housing requirement should be avoided if at all possible, particularly when there already exist sustainable options for growth within the Borough, such as the BRVP Enabling Development, that can help meet the additional need arising as part of the LPR early in the plan period, thereby avoiding the need for a stepped trajectory.
Turning to the growth and spatial strategy options set out in Section 3 of the consultation document, whilst all of the preferred emerging options have a degree of focus along the A421 transport corridor, capitalising on the accessibility to the Bedford and Kempston urban area via such a link, only option 2d proposes new housing in the “eastern parishes” where BRVP is located, and even then only 750 dwellings are indicated within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston and a further 28 ha of employment land.
It is suggested that the capacity for new housing is currently underestimated, and more specifically, a new settlement comprising residential-led mixed-use development to provide the enabling development for the water sports lake at the BRVP, should be identified in the same way as the potential new settlements at Wyboston and Little Barford.
Whilst smaller in scale, nevertheless, the enabling development would still be substantive enough to warrant such identification as part of this growth option, and such transparency would be beneficial in providing certainty to assist the delivery of what would be a major leisure asset for the Borough, as was outlined in detail in the Call for Sites submission and Vision Document submitted on the Landowners’ behalf.
Equally, however, were the Council to take forward one of options 2a – c, or another option, there is also no reason why a new settlement comprising the residential-led mixed-use enabling development could not be included given its inherent merit as a standalone proposal.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5454
Received: 03/09/2021
Respondent: Mrs Lynn Tippett-Wilson
I am strongly against option 2D and for developing on anything other than brown field sites. Urban development is more sustainable than developing in rural sites. Option 2D would destroy the intrinsic character and beauty of Renholds' green spaces and its high quality agricultural land (which is against government policy). The infrastructure in Renhold is not adequate to support the some 1000+ new homes proposed and there would be pollution and excessive noise imposed through increased traffic as well as risk of death through speeding. There would be untold environmental damage done that no amount of offsetting could repair.
I am strongly against option 2D and for developing on anything other than brown field sites. Urban development is more sustainable than developing in rural sites. Option 2D would destroy the intrinsic character and beauty of Renholds' green spaces and its high quality agricultural land (which is against government policy). The infrastructure in Renhold is not adequate to support the some 1000+ new homes proposed and there would be pollution and excessive noise imposed through increased traffic as well as risk of death through speeding. There would be untold environmental damage done that no amount of offsetting could repair.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5502
Received: 06/09/2021
Respondent: Mr Stuart Ledwich
Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along the A421 transport corridor. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe.
Staploe Parish Council consider that the dispersed growth strategy is still applicable which would include housing growth to existing serviced settlements, plus A421 transport corridor and rail growth, as well as the proposed new settlement of Little Barford (option 2b, in part). Such a strategy would provide 13,085 dwellings, including at least an additional 10% allowance for growth to small and medium scale housing sites associated with the existing key and rural serviced settlements. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor.
In support of a dispersed growth strategy, it makes clear at Paragraph 68 of the NPPF that the Council’s Local Plan should identify a supply of housing covering ‘years one to five, specific developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15 of the plan’. Paragraph 69 goes on further to state that ‘Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.’ The development around existing served settlements would provide for these small and medium sites, which could deliver early in the plan period negating the reliance of large urban extensions and new settlements which inevitably are built out towards the end of the plan period, and potentially beyond. It is noted within the Settlement Hierarchy (September 2018) that the main urban settlement of Bedford/Kempston provides the most services, employment, public transport and facilities, and it is therefore where additional urban development should be focused. In addition to this, further sites can be allocated to key and rural serviced settlements as identified in sections 3 and 4 of the Settlement Hierarchy report, which identifies six key service centres and 10 rural service centres. Further development in and around these settlements would support existing services and facilities. It is also noted that the report is currently being reviewed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook. This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook 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 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.
It is evident that the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.
We do also recognise that the Little Barford site may be affected by the East West rail line, it might put pressure on services in St Neots (although it is a much smaller site than Dennybrook and only 2,500 of the potential 3, 085 are required) and it would not benefit Bedford town centre. Therefore, another option may be a new settlement of 2,500 at Twinwoods or Colworth. The Parish Council believe that the problems on the A6 north of Bedford are going to need to be resolved anyway in order to support the housing development proposed in the 2030 plan and for residents to access the east west rail station in the centre of the town. We believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5555
Received: 06/09/2021
Respondent: Mr Peter Turner
We are objecting to Option 2d as we feel that future housing growth should be concentrated within the urban setting of Bedford in order to achieve the benefits outlined in your Sustainability Appraisal. The rural area around Bedford comprises many attractive villages which should be allowed to remain separate and not be compromised by housing developments stretching outside the village envelopes.
As residents of Great Barford, we are very concerned about the possibility of more housing development within the village, especially as we already await the construction of 500 new homes and have yet to see the impact that these dwellings will have upon village life. Furthermore, we have the potential threat of the proposed East-West Rail line and the devastating impact that could have on the village and so we urge you to exclude Great Barford from your 2040 Growth Plan.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5599
Received: 06/09/2021
Respondent: Mrs Julie Kilby
Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.
I consider that the dispersed growth strategy is still applicable which would include housing growth to existing serviced settlements, plus A421 transport corridor and rail growth, as well as the proposed new settlement of Little Barford (option 2b, in part). Such a strategy would provide 13,085 dwellings, including at least an additional 10% allowance for growth to small and medium scale housing sites associated with the existing key and rural serviced settlements. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor.
In support of a dispersed growth strategy, it makes clear at Paragraph 68 of the NPPF that the Council’s Local Plan should identify a supply of housing covering ‘years one to five, specific developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15 of the plan’. Paragraph 69 goes on further to state that ‘Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.’ The development around existing served settlements would provide for these small and medium sites, which could deliver early in the plan period negating the reliance of large urban extensions and new settlements which inevitably are built out towards the end of the plan period, and potentially beyond. It is noted within the Settlement Hierarchy (September 2018) that the main urban settlement of Bedford/Kempston provides the most services, employment, public transport and facilities, and it is therefore where additional urban development should be focused. In addition to this, further sites can be allocated to key and rural serviced settlements as identified in sections 3 and 4 of the Settlement Hierarchy report, which identifies six key service centres and 10 rural service centres. Further development in and around these settlements would support existing services and facilities. It is also noted that the report is currently being reviewed. I would like to highlight that our parish has always been classified as open countryside in the settlement hierarchy so we are surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook (site 977) would form part of the first phase of a large new town of up to 10,800 homes in an entirely rural, unserviced location.
In terms of the proposed settlement at Dennybrook (site 977) (site land west of Wyboston), this ‘new settlement’ does not provide a suitable alternative. This proposed settlement provides for around 2,500 homes. It is located very close to the existing settlement of St Neots and Wyboston and entirely engulfs the existing hamlets of Honeydon and Begwary. It appears to offer very little separation causing potential coalescence. This new settlement would also be car dependent with limited access to the wider road network due to the existing narrow roads. There is poor connectivity in terms of a choice of sustainable modes of transport, including the train. Further details in respect of the proposed development at Dennybrook are addressed in the site assessment for Dennybrook (site 977).
It is evident that the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.
Another option may be a new settlement of 2,500 homes at Twinwoods or Colworth. The Parish Council believe that the problems on the A6 north of Bedford are going to need to be resolved anyway in order to support the housing development proposed in the 2030 plan and for residents to access the east west rail station in the centre of the town. We believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre. Colworth was the site supported in the 2035 plan which was later reviewed. The A6 was not a considered sufficiently problematic to prevent this site being adopted – the site was dropped because it was difficult to mitigate against the noise from Santa Pod. So we find it hard to understand why the A6 is deemed such an insurmountable problem now.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5608
Received: 06/09/2021
Respondent: Mrs Denise Hill
I am NOT in favour of proceeding with option 2d or 1a as they are particularly concerning to me. I fear they would seriously have a detrimental affect on our village.
My reasoning is as follows -
Renhold is a small village and is already at risk of urban sprawl.
These options would destroy the intrinsic beauty of out village, all the things we hold dear to us, the peacefulness, the village tranquility of life. Its rural identity is the whole reason why my husband and I moved here in the first place. We desperately wanted to live some where peaceful. It would seriously affect my health if that was taken away from me.
Renhold has been fighting (for certainly as long as the 12 years I've lived here, to calm the traffic through the village the roads are country roads, they are in very poor condition already, not meant for heavy traffic. Our utility and sewage systems are creaking at the seams, the roads flood and drains overflow immediately.
Urban development is more sustainable than rural. I beg you not to destroy the ancient woodlands we have, to not build on any agricultural land around our village as that goes against government policy. Brownfield sites must be sought and developed and not go for quick fixes and allow the destruction of what we hold so dear to us. My life would be utterly ruined and my health so badly affected I'm scared to even think about it right now.
I only have this avenue to be able to have OUR voices heard.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5650
Received: 07/09/2021
Respondent: Mr Phillip Yockney
Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.
I consider that option 2b with a new settlement at Little Barford is the best option. The East West rail station south of St Neots will provide a truly sustainable form of development at Little Barford. It will be better connected to the new station than Dennybrook. The latter does not provide a suitable alternative – too far from the rail station, risk of coalescence, good agricultural land. Our second preference if Little Barford were deemed unsuitable would be Twinwoods at Thurleigh as a significant part of the site is brownfield land. See above and site assessments for reasons.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5658
Received: 07/09/2021
Respondent: Living Space Housing
The current timetable for the Local Plan 2040 anticipates adoption by Winter 2023. The Council is currently
consulting on a Strategic Options version of the Plan, which suggests the Plan requirement will be 25,500 houses over the Plan period (2020 – 2040). Living Space support the Council in using this figure as their starting point, but believe that this should be seen as a minimum figure. The Council have an opportunity to allocate land to ensure a robust supply of housing over the Plan period, setting this figure as a minimum will help achieve this.
The draft Plan proposes a series of Options for the Local Plan Strategy. Each Option provides the district with
different opportunities, and Living Space believe that the final strategy should be a mix of each option.
Both Options 2b and 2c propose New Settlements. Whilst Living Space believe that new settlements can help boost land supply and create new opportunities for a district, the delivery of new settlements can be lengthy and often encounter delays. Furthermore, recent changes to the National Planning Policy Framework (NPPF) states that, where new settlements are proposed, Planning Policies should be looking further ahead (at least 30 years) to take into account the likely timescale for delivery. Therefore, the Council will need to amend their Local Plan period if they propose a new settlement.
Please see attached representations letter on behalf of Living Space Housing.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5662
Received: 07/09/2021
Respondent: Hallam Land Management
Agent: David Lock Associates
Paragraphs 3.17, 3.10-3.16
Hallam Land Management objects to the preferred growth strategy options which are narrowly focussed on those variants of Option 2, and therefore also the decision to reject the alternatives or elements thereof presented in Option 1 and 3-7 and its variants. Hallam considers that a preferred strategy needs to be more reflective of a balanced and appropriately weighted approach in planning for sustainable development across the Borough and in this regard considers that a single preferred strategy must include an appropriate combination of the wider options presented with due weight given to those that can create a balanced and sustainable spatial strategy.
The variants of Option 2, although positive in focus towards Bedford and being aligned, broadly in the context of the anticipated Oxford Cambridge Arc Spatial Framework, notwithstanding the constraints of the A6 corridor, exclude opportunities for development at an appropriate scale to support existing communities. There are also doubts as to whether the most restrained variant – Option 2a would be able to provide sufficient capacity, in isolation, for growth, certainly around rail station locations provide opportunities for maximising sustainable accessibility to Bedford and along the East West Rail corridor.
No change is observed in the evidence base or the outcome of the existing plan – that existing well connected and well served settlements represent highly sustainable options for development. Specifically, the preferred strategy should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in East West Rail and connectivity to Bedford station – rail related potential is not limited to the south of the town and Bedford Station is as, or more, accessible from the north – more so with enhanced sustainable transport links, potentially including the A6 corridor as a focus for infrastructure investment (i.e. more frequent bus services and physical cycle links). The preferred strategy should not therefore rule out opportunities for continued development at Key Service Centres, particularly to the north of Bedford which is otherwise avoided by variants of Option 2 and is likely to rely on windfall development without any additional allocations. Such an approach will fail to realise sustainable investment in those existing communities and their infrastructure. Indeed, the opportunities that do exist to invest in sustainable transport, both for new and existing communities, to the north of Bedford, should be identified and supported through the transport and growth strategies of the plan. That the Council considers mitigation opportunities in the A6 corridor to be insufficient to support major scale development at Twinwoods or Sharnbrook, does not mean that there are not opportunities to be realised through lesser scale sites (than Twinwoods or Sharnbrook) in sustainable existing communities.
In this context, Hallam considers that a preferred strategy should combine elements of the wider discounted options (1 & 3-7) to best achieve the scale of growth that is likely to be required. Hallam considers that elements of discounted options have a part to play if the housing numbers are to be met in capacity terms and in securing an appropriate geography of opportunities and in helping meet the deliverability gap that is implied by stepped housing requirements and any allocations of large scale new communities or settlements. Hallam also considers that the preferred combination of options must be identified to enable a robust trajectory of delivery to come forward. In practice, Hallam have suggested that this will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. Of those locations identified for more strategic scale development along the A421 and East West Rail corridor, account should also be taken of cumulative delivery rates in the context of the scale of delivery being planned in Bedford Borough but also in Central Beds and other adjoining locations as part of the Oxford Cambridge Arc agenda. Some flexibility or tolerance may be required with anticipated delivery timescales. Such uncertainties and a requirement for contingencies translates into a more balanced focus that looks also towards the north of Bedford.
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Whilst considering that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford and therefore, emphasises for clarity, that this must extend beyond the 0.5 miles of the urban area boundary to include the most immediate neighbouring settlements that have significant potential to benefit from enhanced sustainable connections. An example in this context is Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). It becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. There are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the village.
The potential for Clapham to accommodate future growth and being well connected to Bedford, whilst being distinct as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham present the opportunity for the Borough Council to encapsulate a Greater Bedford option or element in its plan preparation and in due course in the plan strategy. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions but needs a comprehensive approach. A Greater Bedford element to the plan, including the urban areas and immediate settlements would reflect that ambition and provide a positive framework for investment and early delivery. .
The Development Options Topic Paper, in referring to the sustainability appraisal of the broad components of growth, considers the urban area component of the preferred options (including the rejected variants of Option 1, which would play a key role in a wider strategy) to perform best and then considers the adjoining urban area component to perform almost as well. In this context it follows, in Hallam’s view, that growth in immediate neighbouring settlements to the Bedford Urban Area such as Clapham are also capable of performing just as well as what is currently considered to be the adjoining urban areas with enhanced sustainable connections in the form of frequent public transport services and active travel routes. In this context a limit to identifying opportunities for growth to within 0.5 miles of the urban area boundary is considered arbitrary and not necessarily reflecting functional relationships. In practice existing settlements such as Clapham are arguably better located than sites in the immediate adjoining area, where patterns of existing development are likely to constrain opportunities for development that can fully exploit and enhance sustainable transport corridors. In Hallam’s view the definition of the adjoining area should be broadened to include the most immediate settlements that are able to be well connected though relatively modest infrastructure investment. In essence, this approach begins to reflect elements of Options 3b and 3c, 4, 6 and 7, insofar that the focus is extended to those smaller settlements that are immediately adjacent to Bedford and have the potential to benefit from enhanced sustainable connectivity.
An added benefit of securing an appropriate level of growth in those smaller settlements, particularly those adjacent to Bedford, would also be to support local services. Key Service Villages such as Clapham with additional development has the potential to support and enhance the offer of local services, including community facilities and local retail. These benefits are particularly important for people who do not have access to a car. A greater reliance of access to local services and facilities have been underpinned recently by the changes to working and living patterns arising through the Covid-19 pandemic.
Furthermore, a rationale in the current adopted development strategy is apportioning growth to Key Service Villages to support the provision of new Primary Schools with a scale of growth sufficient to support the delivery of 1 form of entry accommodation, is at odds with the Borough’s Council’s position (as set out in its paper for Education Provision for the Local Plan 2030) that new primary schools should by preference be for 2-3 forms of entry. It follows in this context that allocating further development to Key Service Villages would enable for the delivery of primary schools that are of an operationally efficient and preferable size (i.e. 2-3 forms of entry).
In identifying a Preferred Spatial Strategy Option, Hallam’s View is that this should be based on:
1. Embrace and include urban based growth and areas adjoining the Bedford urban area boundary including immediate neighbouring settlements (i.e. such as Clapham) that are or have the potential to be well connected to Bedford (therefore, partially reflecting Options 3b, 3c and Options 4 and 6) recognising also the contribution such elements can make before larger scale elements of the strategy
2. Medium to longer term infrastructure focused transport-oriented growth around existing and proposed East-West Rail Stations and key public transport routes or larger scale options (partially reflecting the variants of Options 2 and Options 4,5 & 6).
3. And, to a lesser extent, continue to focus more modest levels of growth at other Key Service Villages outside the Bedford catchment where development will further support local services and facilities to reduce the need to travel for day to day requirements and fully support the delivery of operationally efficient primary schools (as reflected in Options 3b and 3c and Options 4, 6 & 7).
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5701
Received: 07/09/2021
Respondent: Miss amber scally
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.