3.17

Support

Representation ID: 5763

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

I believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.
3.16 We would like your views on which of the alternatives / options should form the strategy of the local plan. We still have more work to do over the coming months to determine the best growth strategy for Bedford Borough and will take into consideration your comments before a decision is made. To help inform that decision, we have carried out an appraisal of the likely social, economic and environmental effects of each alternative and this may be helpful when considering the options. The results of that work are published as the Draft Sustainability Appraisal Report, May 2021 (see Table 1).
3.17 If you think that there are other strategies we should be considering, please let us know. These may be ones set out in the Development Strategy Topic Paper or completely different alternatives.

Option 2b: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes and southern parishes, plus one new settlement (AT LITTLE BARFORD)
• Within the urban area (1,500 dwellings).
• Adjoining the urban area (1,500 dwellings), up to 51 ha employment.
• Transport corridor – rail based growth: land within the parishes of Kempston Hardwick, Stewartby and Wixams (low option) (5,500 dwellings), up to 80 ha employment.
• Transport corridor – south: land within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton (1,500 dwellings).
• New settlement at Little Barford (3,085 dwellings) or Wyboston (2,500 dwellings), up to 20 ha employment.
• Total between 12,500 and 13,085 dwellings and up to 151 ha employment.
Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.

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

Object

Representation ID: 5800

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

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 my parish has always been classified as open countryside in the settlement hierarchy so I am surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future master planning 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, economic 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. I believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land. These sites would also support Bedford Town Centre. Colworth was the site supported in the 2035 plan which was later reviewed. The A6 was not a considered sufficiently problematic to prevent this site being adopted – the site was dropped because it was difficult to mitigate against the noise from Santa Pod. So, I find it hard to understand why the A6 is deemed such an insurmountable problem now.
100-word Summary
I consider that option 2b with a new settlement at Little Barford is the best option. The East West rail station south of St Neots will provide a truly sustainable form of development at Little Barford. It will be better connected to the new station than Dennybrook. The latter does not provide a suitable alternative – too far from the rail station, risk of coalescence, good agricultural land. My 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

Representation ID: 5861

Received: 08/09/2021

Respondent: Mr Norman Hoy

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

Object

Representation ID: 5881

Received: 08/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

Option 2a
We raise no specific objections to Option 2a. We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
Option 2b
We raise no specific objections to specific elements contained in Option 2b, relating to proposals adjoining the urban area and transport corridor.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is marginally less reliant on the rail corridor than Option 2a and as a result on the face of it is a superior option – however the introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2b were it to be advanced with a new settlement as part of the overall strategy.
Option 2c
We raise strong objections to Option 2c.
We would question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is heavily reliant new settlements. Given how poorly new settlements fair in the assessments set out in the evidence base this option cannot, by some margin, be considered to be the most appropriate option when considered against the reasonably alternatives. It is also the case that new settlements will inevitably challenge the ability to deliver the (higher) standard method in the early phases of the plan which – as we have set out elsewhere in our submissions – is vital to the success of the Local Plan Review.
Option 2d
We raise no specific objections to specific elements contained in Option 2d, relating to proposals adjoining the urban area, transport corridor south and transport corridor east.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
The introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2d were it to be advanced with a new settlement as part of the overall strategy.

Object

Representation ID: 5894

Received: 08/09/2021

Respondent: Mrs Susan Randell

OPTION 2C would be my choice if there has to be development on the A421 corridor.

I have lived in the village of Wootton since 1975. My children were born here and attended local schools. In the last ten years Wootton has seen development like no other village. The village has doubled in size with an excess of 1200 houses being built but the infrastructure has not grown in proportion.

Promised doctor’s surgery never materialized and until Covid struck, waiting times for appointments was up to 4 weeks.

Schools are full to capacity with the threat of bussing 4-year-old children across the borough to schools that may have places. The new build lower school was at capacity by the time it was opened and now has to have extensive repair work done to it to make it fit for purpose.

Planning Applications for more houses keep being applied for, objections from residents are ignored and the applications get passed. A recent one for 85 houses by the upper school got rejected on the grounds the road was too narrow to take the extra traffic and it was a danger to school children walking to and from school. The developers refused to accept the rejection and have now taken this to the secretary of state in a bid to get it passed.

Warehouses have been built on the edge of the village running alongside the A421 bypass, these were never in the original plans for development and have brought added problems with LGV’s mis reading signs and driving through the village. New signage has been introduced now but still many drivers miss these and come through the village. You should see a 40 ton lorry trying to turn round on a mini roundabout because they realize they have come the wrong way to access the warehouses. We now have the added delight of a hotel and pub promised alongside these monstrosities while local run pubs in the village are struggling to make a living and a Premier Inn sits about three miles up the road from Wootton.

Our green spaces around Wootton are gradually being concreted over at a time when only weeks ago Mayor Dave was celebrating all the green spaces to be had in Bedford Town. Not so many years ago this area was designated for a new community forest but most probably the trees planted then have been buried under said warehouses. Please leave what few green spaces we have left alone for us to enjoy, there are other areas that may benefit from building but no more in Wootton.

Support

Representation ID: 5934

Received: 08/09/2021

Respondent: Mr Tom Tagg

Option 2a: I support option 2a because urban development is more sustainable than rural. It uses brownfield land at Stewartby, develops homes in and close to the urban area and to railway stations and so will reduce the amount of car use/travel/CO2 compared to other options.
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.

Object

Representation ID: 5935

Received: 08/09/2021

Respondent: Mr Tom Tagg

Option 2b: Option 2b has the advantages of option 2a, but adds a new settlement at either Little Barford or Wyboston.
I could support option 2b if the new settlement was at Little Barford, close to the new EWR station, thus reducing car journeys. The nearby new settlements of Loves Farm and Winteringham to the east of St. Neots, have been successfully built over the recent few years immediately adjacent to St. Neots railway station. These are close enough to allow people to walk or cycle to the station, therefore significantly reducing car use. A similar approach could be taken at Little Barford with new dwellings built close to the station to encourage walking and cycling. 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.
I OBJECT IN THE STRONGEST TERMS TO OPTION 2B IF IT WERE TO INCLUDE A NEW SETTLEMENT AT WYBOSTON (DENNYBROOK) AS IT IS NOT A SUSTAINABLE LOCATION FOR THE FOLLOWING REASONS:
1. Although the option states Wyboston as the location for a new settlement, the actual development is for Dennybrook garden village, being promoted by Taylor Wimpey. The location of this is from Wyboston extending north to the Bushmead road and west to Colmworth. The proposed site at Dennybrook falls mostly within the Parish of Staploe. The parish is entirely rural with no settlement policy area. Within the parish the small hamlet of Honeydon, is encircled and wiped out by the planned development. The hamlet of Begwary will also be engulfed by the development. The NPPF requires the identity of existing settlements to be protected.
2. When looking at the spatial approach to locating new development, the proposed site at Dennybrook would be located within close proximity to St Neots. Coalescence will occur with St. Neots, Honeydon, Colmworth, Colesden, Chawston and Wyboston, all being joined by this development. Spatially, this would be contrary to the Council’s adopted Local Plan which seeks to prevent coalescence of settlements. In addition, policy 37 of the Council’s adopted Local Plan makes clear that developments need to ‘Protect the landscape setting and contribute to maintaining the individual and distinct character, and separate identities of settlements by preventing coalescence…’.This is also against NPPF recommendations.
3. The option is very misleading as it indicates that Wyboston will be a development of 2,500 houses. BBC have subsequently clarified that this will be in the plan period to 2040. This is contrary to the plans submitted by Taylor Wimpey who plan to build-out 5,150 homes by 2040, increasing to 10,800 by 2050.
4. The scale of this proposed development is massive – a new Town the size of Biggleswade or double the size of Cambourne! In the Call for Sites information (977) the area of land is between 725ha (BBC) and 981ha (Taylor Wimpey). (Why is there a difference?)
5. As detailed in the BBC Landscape Character Assessment (LCA) report the area is high quality arable farm land, largely Grade A, growing wheat, barley and other essential crops, which should be maintained and development resisted. The Bedfordshire Natural Capital Assessment report confirms that the borough has 30,139ha of arable land, so Dennybrook would wipe out 2.4 to 3.3% of the Borough’s stock of arable land.
6. Development on high quality agricultural land would be in direct contravention of the NPPF (para 170) which states that: “Planning policies and decisions should contribute to and enhance the natural and local environment…”
7. With a growing population and the fact that only approx. 35% of the area of the UK is farmland for food production, BBC should actively protect and retain this high quality farmland.
8. The site lies in a very rural area with few access roads and minimal infrastructure. The roads are unclassified small local country and farm roads (many of which are designated as unsuitable for HGVs), mostly narrow two vehicle width, often single vehicle width with passing places. They are very poorly maintained by BBC (e.g. the more major Bushmead Road is full of potholes and BBC have refused to properly repair it within the next 10 years) and are totally unsuited to a development of 10,800 houses, which at 2 vehicles/household, will bring an additional 21,600 vehicles to these roads.
9. BBC’s LCA report describes a network of quiet rural lanes connecting the scattered settlements and which provide an important resource for informal recreation. These would be lost in this huge development.
10. The site is all on grade 2 (high quality) agricultural land and it is highly valued for its peace, quiet, open countryside views and rural setting by its residents as evidenced by a Neighbourhood Plan survey conducted in early 2021. Clearly, any significant development within the Parish would make a permanent change to the landscape and the setting of the small hamlets and rural nature in the locality. Such physical changes cannot be reversed, and the Council would need to be satisfied through a thorough review of the supporting documents to the site submissions that they adequately address the impacts, especially in terms of achieving sustainable development – in line with Paragraph 16 of the NPPF and section 39(2) of the Planning and Compulsory Purchase Act 2004. Paragraph 174 (b) of the NPPF makes clear that planning policies should contribute to and enhance the natural and local environment by: ‘recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland…’. Grade 2 agricultural land is considered to be the best and most versatile agricultural land and would be applicable in this instance.
11. There are many roadside nature reserves along these roads, in fact, Honeydon has by far the largest area of roadside nature reserves in the Borough. so it would not be possible to widen them without destroying valuable protected wildlife habitats.
12. The Bedfordshire Natural Capital Assessment highlights areas within the proposed Dennybrook land take, the opportunity to add woodland buffer areas to the existing woods and fields. This opportunity would be lost if the Dennybrook development were to proceed.
13. The LCA also describes the landscape character and the distinctive sense of openness and of wide views. . Within the ‘evaluation’ section at page 55 of the LCA it notes that potential future change could include Small scale development in villages which could lead to loss of their distinctive character; Road upgrades affecting rural road character; Suburbanisation of villages. This would suggest that even relatively small changes would affect the rural setting of the area. Moreover, the proposed landscape strategy for the area as identified within the LCA is to ‘enhance’ elements of the landscape. The introduction of 2,500 to 10,800 new dwellings would significantly and permanently erode the rural character of the Parish with all the beautiful landscapes lost – all contrary to Paragraphs 20, 153, 174, and 175 of the NPPF and policy 37 of the adopted Local Plan.
14. The developers propose site access in the south via Roxton road onto the Bedford Road and in the north onto the Bushmead road. The Bushmead Road is not suitable for the existing level of traffic. In earlier reviews for Local Plan 2035 of a smaller (4,000 dwellings) settlement at Wyboston, BBC had stated that “the existing road widths, visibility and constraints are inappropriate to accommodate the proposed levels of development”. How can an increase of 250% in the size of the development mean that BBC have now changed their view on this key point?
15. Traffic making its way into St Neots via the Bushmead road will enter past a busy primary school in a 20mph zone, with extensive traffic calming measures into a residential zone – all unsuitable for the huge volume of traffic this development will bring. There are already traffic pinch points in St Neots, e.g. the town bridge.
16. The BBC Call for Sites 997 Assessment recognises that the development would cause serious capacity constraints to existing junctions, complex traffic and transport requirements and significant pressure on the surrounding highway network. Significant infrastructure interventions are likely to be required.
17. Flooding. The proposed site has 5 watercourses which are tributaries of, and feed into, the River Great Ouse just upstream of St Neots. These are all known to flood locally and have added to the three serious flooding incidents in St. Neots in the past year. Building on this huge area of land would increase the surface water runoff and increase the flood risk in Honeydon and in St Neots.
18. There will be huge pollution to air, water, soil, light and noise from traffic as well as dust and noise from 30 years of development construction operations. Residents of Staploe and Duloe would be affected by a huge increase in traffic through their hamlets and on the Bushmead Road.
19. The area is home to barn owls, tawny owls, little owls and woodpeckers. Skylarks grace the skies along with red kites & buzzards. Kingfishers are seen on the reeds in the brooks and egrets visit too. The hedgerows and fields are a haven to brown hares, badgers, foxes, deer and hedgehogs. Water voles and otters frequent the brooks. Grass snakes and great crested newts are seen around the brooks and adjacent gardens. In the evenings, bats are regularly seen. The grass verges are designated nature reserves where rare protected species such as Bath Asparagus, Small Eggar Moths, Sulphur Clover and Crested Cow Wheat, along with wild bee orchids, are found. This is one of only two places in the UK that Bath Asparagus grows. This wide range of biodiversity will be destroyed by this huge development.
20. The site was proposed (on a smaller scale at around 4,000 homes) for inclusion within BBC’s Local Plan 2035 in 2017 but was rejected, BBC stating at the time “the site lies very close to St Neots and it is likely that pressure would be placed on services and facilities in St Neots.”
21. Despite falling just within Bedford Borough, the site has comparatively poor access to Bedford itself. Residents will favour St. Neots which will add further economic damage to Bedford town centre, which is in serious decline and in desperate need of an economic boost, as stated by BBC themselves within their submissions to the East West Rail project.
22. The transport impacts will be acutely felt for this proposed new settlement. It is clear that the proposed development at Dennybrook would be a car reliant settlement. The location of the site means that, for employment purposes in particular, many residents will be commuting above-average distances and will be almost wholly reliant on private cars. There is no public transport in the area and the distances will not encourage walking or cycling. The proposed new EWR station planned for Tempsford or Little Barford will not be close enough to avoid using the car for access. BBC noted in their earlier site assessment “The site is located in a relatively convenient location for vehicle journeys on the strategic road network, which may be a deterrent to non-motorised travel.“ Increased car use will lead to increased CO2 and pollution levels contrary to BBC’s sustainability objectives and Vision.
23. The site will be under the Luton airport stack that is due to be relocated to the area in February 2022 – blighting the lives of all who live below it.
24. There is no detail of the provision for doctors, dentist, opticians, schools or shops so these facilities nearby will be overwhelmed. There is already huge pressure on services in St. Neots (e.g. doctors, dentists) and at Hinchingbrooke hospital. As the two main doctors surgeries for this area are in Cambridgeshire this is the hospital which will be impacted most.
25. Referring to the information presented by Taylor Wimpey (TW) in response to the call for sites (977) for their proposed Dennybrook development:
a) TW Vision Document. This is a child-like portrayal of some sort of utopia where the destruction of the natural landscape and all its valued features and wildlife are enhanced by building 10,800 houses! Ridiculous statements are made for the huge development to "merge seamlessly into the existing landscape" – these are to be 3-storey town houses in an open landscape! The brooks are to be enhanced to encourage otters – shown on the plans to be next to children’s playgrounds! Access and infrastructure requirements are totally underestimated or absent. There is no mention of green housing - carbon zero - district heating, etc. This document gives no confidence in Taylor Wimpey’s plans being either appropriate or deliverable and they are certainly not sustainable.
b) Call for sites 977. TW state that the land is vacant – it is not – it is high quality agricultural land. TW state that suitable access is achievable via two access points to Bushmead Road to the north and Colesden Road to the south – two access points for 21,600 vehicles + employment traffic is clearly insufficient. TW plan to build-out 5,150 houses by 2040, increasing to 10,150 by 2050 – this does not align with BBC’s 2,500 houses by 2040. TW state that “the proposal could be designed to reflect best practice in mitigation of climate change”. “Could” is not good enough – it must be designed to mitigate climate change.
c) The BBC site assessment for 977 recognises the following issues:
i. X The site is not within or adjoining the urban area or a defined settlement policy area, or within the built form of a small settlement.
ii. x The site is within or adjoining a site of nature conservation importance.
iii. xx Protected species recorded on the site.
iv. ? Uncertain or insufficient information to achieve a net gain in biodiversity.
v. x The proposal has the potential to cause harm to heritage assets.
vi. x The site is separated from a defined settlement policy area or the built form of a small settlement.
vii. x The site is not previously developed land as defined in the NPPF.
viii. x All or a majority of the site is best and most versatile agricultural land as defined in the NPPF.
ix. ? Potential highway access requiring mitigation.
x. x Serious highway or junction capacity constraint.
d) TW include in their Call for Sites 977 submission a Heritage Impact Assessment (by CSA). This includes the following statements. “Development would most likely result in adverse impacts to the significance of Grade II listed buildings as a result of alteration to setting.”; “Development will result in some adverse impact to … non-designated … farms”. Under the NPPF and local plan policy these adverse impacts and harm have to be taken into account in decision making.
e) TW include in their Call for Sites 977 submission a Landscape Briefing Note (by CSA). This includes the following statements. “A scheme of this size will inevitably result in landscape and visual harm...”; “A strategic development of the nature proposed will inevitably have an adverse impact on the Site’s landscape character and its surroundings.”
f) TW include in their Call for Sites 977 submission an Ecology Strategy Note (by CSA). This includes the following:
i. The site was visited twice in October 2020 and January 2021, but “no detailed mapping or survey was done.” CSA confirm that “ 2.5 It should be noted that the survey work to inform this report was undertaken outside of the optimal season for botanical survey work.”. So this report is based on desktop work and reports of flora and fauna. This is insufficient for a development of this scale.
ii. CSA recognise that there are three non-statutory nature conservation designations covering roadside verges. These are variously noted to be small and extensive? CSA recommend in 3.5 that “These roadside verges should be retained and protected in their entirety alongside development, including in relation to construction traffic routing and any road improvement works.” “4.14 … many of the road verges within the Site, in particular those protected verges to the north-west, are known to support some of the highest quality grasslands for biodiversity, and are known to support at least three nationally rare species.” Given the scale of the development and the need to upgrade the country roads to cope with 21,600 vehicles, it is extremely likely that these will not be preserved.
iii. At 4.25 CSA summarise Habitats and Flora with “….the anticipated large-scale loss of even low importance habitats as a result of development of the Site would result in the net loss of biodiversity.”
iv. At 5.9 CSA summarise Fauna with “Development would result in the fundamental of change of habitats within the Site, displacing many of those species associated with arable landscapes…”
v. In the overall summary at 6.1 and 6.2 CSA state: “To ensure that a net gain in biodiversity is achieved given the scale of development, large-scale habitat restoration will be required,….”
g) It is clear from the CSA Ecology note that TW have not yet done full studies at the appropriate time of the year and so underestimate the level of ecological interest that exists across the site. Even with their low opinion of the quality of the site, TW recognise that there will be massive biodiversity loss and that very major large scale habitat restoration will be required – for a development in the Ox-Cam Arc, TW will have to achieve 20% biodiversity net gain.
h) TW have failed to address environmental net gain as they have not taken into account, and not made any proposals for, the loss of natural capital and arable food production needed to feed the UK population.

26. In terms of Dennybrook meeting the BBC Vision in item 2.1, for the many reasons above:
i. It will not make the Borough a greener, more sustainable, more attractive and prosperous place to live.
ii. It will not tackle climate change and mitigate its effects.
iii. It will not facilitate sustainable food production.
iv. It will not be supported by appropriate infrastructure.
v. It will not avoid areas of high flood risk.
vi. It will not provide sustainable development and transport.
vii. The developer plans no use of sustainable and renewable energy technology.
viii. It will not contribute to reducing the borough's carbon footprint.
ix. It will not secure a net-gain in both biodiversity and environmental quality.
x. It will not complement the borough's natural environment.
xi. It will not recognise the borough's countryside, its intrinsic character and beauty including areas of tranquil retreat.
xii. It will not reflect the area's unique local character.
xiii. It will not protect locally important green spaces and valued local landscapes for the enjoyment by all.
PROGRESSING THE DENNYBROOK DEVELOPMENT WILL MEAN THAT BBC WILL FAIL TO MEET ITS VISION.

27. From all the above it is entirely clear that the Dennybrook site can in no way be considered to be a truly environmentally sound or sustainable solution to BBC’s housing needs, and would therefore be contrary to policies contained within the NPPF and the Council’s adopted Local Plan. Accordingly, the proposed new settlement should be removed from all Local Plan options, any further consideration by BBC, and discounted when considering sites for allocation going forward to the pre-submission draft Local Plan.
28. In addition there are plans for approx. 7,500 homes in Tempsford (Central Bedfordshire) and further development is already planned for St Neots at Wintringham Park and Loves Farm (Huntingdonshire DC). All of this is excessive development, concentrated in one area. Integrated planning between the three Councils, including the Black Cat/A428 upgrade and East West Rail proposals, is desperately needed to bring some common sense to all these proposals and for the sake of the lives of the residents who are faced with massive disruption, inconvenience, noise and pollution for up to 30 years of construction work.
29. Furthermore, HMG planning policy says that brownfield sites should be selected in preference to greenfield sites and that development must recognise “the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land” and that “Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality”. The land for Dennybrook/Wyboston is all grade 2, which is defined as “Best and most versatile agricultural land” in the NPPF. Dennybrook should not therefore be selected for development as there are other sites available which include significant areas of brownfield land e.g. Stewartby and Twinwoods.

Object

Representation ID: 5936

Received: 08/09/2021

Respondent: Mr Tom Tagg

Option 2C: For the reasons given above, with the inclusion of Dennybrook, I OBJECT TOTALLY TO THIS OPTION.
This exacerbates the issues by putting two new settlements so close together into the plan. Along with the Tempsford and St. Neots proposed developments this will worsen the already excessive development in one area. There would also be the key challenge of delivery of two (or four) new settlements in close proximity to one another and the ability of the housing market to deliver them simultaneously.
Integrated planning between the three Councils (BBC, Beds Central and Hunts DC), including the Black Cat/A428 upgrade and East West Rail proposals, is desperately needed to bring some common sense to all these proposals and for the sake of the lives of the residents who are faced with massive disruption, inconvenience, noise and pollution for up to 30 years of construction work.

Object

Representation ID: 5938

Received: 08/09/2021

Respondent: Mr Tom Tagg

Option 2d: For the reasons given above, I OBJECT TOTALLY TO THIS OPTION with the inclusion of Dennybrook.

Support

Representation ID: 5979

Received: 08/09/2021

Respondent: Mr John Mabberley

Of the emerging preferred strategies Option 2b provides the most satisfactory solution to the continued development and prosperity of the Borough.

It provides for sensible degree of housing and future employment in an area of the Borough which is well-suited to future development being close to the A421 Dual-Carriageway and close by the Thameslink/MML stations planned for Wixams and the upcoming EWR linking across the Oxfoed Cambridge Arc.

It is important that the EWR plans fully match this planned growth area and less emphasisi should be given to Town Centre Development . Routing of the EWR into Bedford Midland should be an option (for some trains) but the major route should be on the south of the town being services by a new Bedford Parkway service offering fast trains in the direction of both Cambridge and Oxford/Milton Keynes.

Development in the ‘Southern Parishes’ and ‘Rail-based growth Parishes’ will be conducted with the minimum impact on carbon budget and similarly the supporting south-of-Bedford EWR option is over comparatively flat terrain allowing low-carbon operation of train services and ease of access during construction. Such an arrangement of housing and employment development and supporting EWR is a sustainable solution supporting biodiversity and minimizing short and long-term impact on the environment.

The option 2b also favours a significant growth on the east of the Borough and the much-preferred option is at Little Barford. This provides easy access long-term and during construction and is conveniently close to transport routes on the A1 and ECML. It could also be readily served by the ‘South-of-Bedford’ option for EWR with a station at Tempsford or even just north of Sandy – either would serve as an EWR / ECML interchange.

A significant development at Little Barford would also link with development close by being planned by Central Bedfordshire Council.

An alternative new settlement at Wyboston would seem much less favourable both in terms of long term economic and social benefit to the Borough and with the significant difficulties of access during building and in the longer term for residents. The infrastructure in rural north Bedfordshire does not support the Wyboston development and to develop a fully supportive infrastructure would significantly damage the Borough’s aspiration to be carbon Nuetral and would negatively impact on Climate considerations.

A development Plan based on Option 2b would provide a solution serving residents in the Borough with the minimum disruption and the very best long term potential.

As an important footnote It is sensible that previous development centred on North Bedfordshire (in the A6 Corridor and around Option E of the EWR have been dropped, largely owning to lack of supporting infrastructure and the overwhelming congestion such development would cause. Option E for EWR should now be abandoned with both Bedford Town Centre and the high growth areas south of Bedford being served by excellent transport services including the BFARE route proposals for EWR.

As these decisions are being considered and developed more emphasis should be given to the implications on Carbon budget and impact on climate.

Object

Representation ID: 5983

Received: 08/09/2021

Respondent: Staploe Parish Council

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

Object

Representation ID: 6030

Received: 08/09/2021

Respondent: Mrs Christina Farmer

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.

Support

Representation ID: 6035

Received: 08/09/2021

Respondent: Tomas Bozek

The proposed options 2b to 2d in the draft 2040 Plan have my full support. I have long believed that development in the Borough should be along the main arterial road networks and should take full advantage of the A421 transport corridor with its connection to the M1, A428 and to the A1 with its easy to other main arterial road networks such as the A14.
With the East West Rail Oxford to Cambridge rail route these development options make perfect sense and will give easy access to the new stations proposed south of Bedford and to the Tempsford/St Neots options. The A6 and Great Ouse Way simply cannot cope with any further development in this part of north Bedfordshire since the congestion morning and evenings has made travelling into Bedford town a nightmare to be avoided.
For this reason I object strongly to any inclusion in the 2040 Plan of the potential sites at Twinwoods and Colworth. In my opinion these are both unsustainable because of the amount of traffic already trying to access Bedford at peak times morning and evening when one can sit for up to 45 minutes queuing to get into Bedford along the Paula Radcliffe Way (A6) and Great Ouse Way.
I am concerned at the proposal to build up to 500 new homes in Sharnbrook which will only exacerbate the congestion issues along the A6 and result in our north Bedford villages becoming rat runs for drivers seeking to avoid the queues into Bedford along the A6 and hope there is scope to revise this planned development.
I would encourage the Borough to proceed with one of the development options 2b to 2d and support large scale development one or both of the sites at Wyboston and Little Barford both of which are clearly capable of taking further development in future plan years after 2040.

Support

Representation ID: 6073

Received: 09/09/2021

Respondent: Mrs Judith Coley

We would like to support the plans to develop sites in the options 2a,2b 2c,2d , along the A421 corridor in the county. However we wanted to add our positive support to the developments along the A421 plans.

Support

Representation ID: 6120

Received: 09/09/2021

Respondent: Jen Giles

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.

Object

Representation ID: 6174

Received: 09/09/2021

Respondent: Mrs Sandie Tusting

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.

Support

Representation ID: 6183

Received: 09/09/2021

Respondent: Mr Keith Randell

As a resident of parish of Wootton I think we had more than our shear of development in the last 10 year's, with good farm land being taken. South side of the A421 look's the best option for our village. With the infrastructure at braking point 2c is the best option.

Object

Representation ID: 6186

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.22 The emerging preferred options put forward by the Council have an urban focus and the four variations all focus development on the urban area, A421 corridor, and existing and planned rail stations. This approach relies heavily on rail investment and also focuses growth to the south of the town, with very little growth planned to the north of the borough.
2.23 In terms of meeting the needs for economic development the Council’s Preferred Options cannot be considered justified, effective, or positively prepared. This is principally due to an overreliance on the allocation and delivery of large-scale business parks (as summarised at paragraph 6.8 of the Consultation Document. Even allowing for up to three large business parks the Council acknowledges: “the remaining 63 ha should be allocated in smaller sites which are more likely to be attractive for office and general industry purposes.”
2.24 The Council’s Preferred Options are not sufficiently flexible to provide for the range and type of sites required, part of which could be met by our client’s land at Highfield Road. Specifically, the Council is reliant on the delivery of New Settlements and rail-based growth where the availability of land for economic development is uncertain and would have long lead-in timeframes. Particularly for proposed components of growth at Stewartby and Kempston Hardwick the Council is reliant upon land currently being promoted for employment use being brought forward for housing instead. This level of uncertainty is not the basis for sound Plan-making or providing support for the Plan’s priorities regarding economic development.
2.25 The Council’s draft Sustainability Appraisal findings recognise this, where Option 3c (including village-related growth) achieves the same assessment of Positive effects for SA Objective 5 (economic development) as the Council’s Preferred Options. This is a function of the diverse range of local employment opportunities in existing Rural Service Centres (14ha – including our client’s land at Oakley) providing opportunities for the creation of balanced communities. In the case of Oakley, concerns with the assessment findings relating to strategic road access and the potential for clustering are overcome due to proximity to the A6 and existing commercial development at Highfield Park.
2.26 Support for additional opportunities for economic development at sustainable locations in the hierarchy is thus consistent with the Plan’s overall objectives and essential to achieve a sound strategy. The Council should thus adopt a ‘hybrid’ approach to strategy options for both economic and residential development to overcome the soundness concerns identified.

Support

Representation ID: 6220

Received: 09/09/2021

Respondent: Peter Coles

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.

Object

Representation ID: 6277

Received: 10/09/2021

Respondent: Mr Richard Hutton

feel that any additional development in and/or around Elstow would have a negative impact on both the village i.e. the rural feel of the village Elstow as well as a negative impact on the environment.

As seen in and around the new builds house estate within Kempston MK42 7FQ area you can see that inadequate transport links have caused a significant build up of traffic affecting residents and travellers alike.
The same will happen to Elstow if any further expansion is approved.

The current support structures in terms of education will also be affected, where we already have an inadequate workforce of teachers nationwide will then be focused in and around Elstow where state education will be stretched even further than already publicly voiced.

Promised Transport links within Wixams which have not come to fruition will also mean more travellers going into Bedford causing further delays due to increased traffic.

We are proud of our rural feel of the village, where the government is trying to provide a better environment, I feel that this will have a negative impact not only on the local environment, but also mean a deteriorating affect on Air Quality and to the surrounding residents health

Object

Representation ID: 6278

Received: 10/09/2021

Respondent: Kelly

I am a resident of Wilstead who have lived in the village for over 40 years, at the time I lived and worked in Wilstead, but over the last decade the village is starting to take on the semblance of a small town, which is not what I moved here for, I see buy your proposed plan that some of the area of Wilstead will be looked at to expand, can I remind you that the village has already expanded over the last few years and I feel it has reached its nominal size and any increase will only be of detriment to the area , meaning the roads and local services will not cope with further expansion, particularly when there are other areas which you have still not fully developed which was part of the Wixam plan and the southern bypass, there are many areas along the bypass which could be developed as new villages which would not effect the original villages around the southern part of Bedford, Wixam still has development land to fill along with several areas from the start of the bypass up to the Marstom Mortain area, I would also like an answer to the question who are these houses for certainly not local people as the expansion of Wilstead did not increase with local people only from outside the area, also the natural beauty of the village will be lost along with the habitats of rare birds such as kite and the dear tracks that circle the village along with foxes and other small mammals.

Please reconsider your plans and fill in the areas that are vacant around the bypass if you have to before condemning the village to becoming a small town like Kempston.

Object

Representation ID: 6279

Received: 10/09/2021

Respondent: Mr Anthony Fowler

Objections to Local Plan 2040 Wilstead Development

My wife and I have been residents of this village for 52 years and were both previously raised as children in a rural village environment. Our choice was to embrace all the positive opportunities presented by village life rather than that found in Urban or Suburban large scale settlements. We therefore regard proposals in this plan as a major threat to this idyll.

Previous village plans allowed for controlled development which could be accommodated within the natural infrastructure, amenities and capability of the village, absorbing sustained growth without significant negative impact on the environment and the rural way of life. With 1200 houses a 10% growth level could conceivably be managed and achieved in small developments whilst retaining the basic characteristics of village life. Plans to increase by 50%- 100% would redefine Wilstead as an Urban settlement with large development sites consuming most available rural gaps and spaces, overwhelming the infrastructure and irretrievably destroying the village dynamics.
• There are currently important rural gaps which provide some differentiation
o eg. the burgeoning development of Wixams.
• With the scale of the Wixam development it is hard to appreciate why there is a need to overrun Wilstead with a similar vision of the future unless the objective is to allow complete Urban sprawl from Bedford into some vast Suburban landscape .
• Our village is a time capsule of progressive housing development, old and new woven into traditional and recognisable landscapes. Vast developments of 100’s of houses would destroy the features we value and remove the ready access to the countryside for the residents.
• The village infrastructure is already approaching the limits of its capability with traffic,utilities and drainage systems often struggling to contend with peak demand.
o With a substrate of blue clay the drainage capability relies on existing open areas to gradually absorb rainfall to avoid inundation in many areas.
o Traffic around the village school presents a regular danger and access to Bedford is becoming increasingly difficult most times without the prospect of 1000 more vehicles.

With government pressures to increase house building the provision of new villages such as Wixams is a clear alternative in sites around the county providing appropriate infrastructure as a preconsidered concomitant. Although Bedfordshire seems to be providing a disproportion solution to these government targets.

Object

Representation ID: 6321

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

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.
pg. 21 of 25

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.

Object

Representation ID: 6349

Received: 10/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

Option 2a
We raise no specific objections to Option 2a. We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
Option 2b
We raise no specific objections to specific elements contained in Option 2b, relating to proposals adjoining the urban area and transport corridor.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is marginally less reliant on the rail corridor than Option 2a and as a result on the face of it is a superior option – however the introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2b were it to be advanced with a new settlement as part of the overall strategy.
Option 2c
We raise strong objections to Option 2c.
We would question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
This option is heavily reliant new settlements. Given how poorly new settlements fair in the assessments set out in the evidence base this option cannot, by some margin, be considered to be the most appropriate option when considered against the reasonably alternatives. It is also the case that new settlements will inevitably challenge the ability to deliver the (higher) standard method in the early phases of the plan which – as we have set out elsewhere in our submissions – is vital to the success of the Local Plan Review.
Option 2d
We raise no specific objections to specific elements contained in Option 2d, relating to proposals adjoining the urban area, transport corridor south and transport corridor east.
We would however question the extent to which the urban area can deliver 1,500 houses in the early phases of the plan period, whilst also delivering necessary infrastructure alongside new housing (and please see our separate comments with regard to the absence of an IDP at this stage, which we see as a significant issue).
Rail based growth is in principle a sustainable approach to delivering development, provided that sites are located within a reasonable distance of rail facilities whilst also benefiting from local services such as primary schooling, local shop/Post Office and other amenities. Site selection in relation to the rail corridor is therefore key to the success of this option.
The introduction of a new settlement as part of this option is the subject of strong objection given how poorly new settlements fair in the assessments set out in the evidence base. For this reason, we object strongly to Option 2d were it to be advanced with a new settlement as part of the overall strategy.

Support

Representation ID: 6400

Received: 13/09/2021

Respondent: Brown & Co Barfords

Agent: Brown & Co Barfords

Bedford holds a significant position within the OxCambs Arc. Given the planned population growth to 2040, together with the proposed East West Rail and upgrade to the A428 from the Black Cat Roundabout, both Wyboston and Little Barford (Option 2c) appear to rational locations for the location of a sustainable new settlement and employment allocation. Such locations are supported as they will provide suitable access to the key transport nodes centered around the convergence of the A1/ A428 and also East West Rail and the existing East Coast Mainline.

Support

Representation ID: 6401

Received: 13/09/2021

Respondent: Mrs J Clements

Agent: Brown & Co Barfords

Taking into account Bedford’s key location within the OxCambs Arc and the planned population growth to 2040, together with the proposed East West Rail and upgrade to the A428 from the Black Cat Roundabout, both Wyboston and Little Barford (Option 2c) appear to reasonable locations for the location of a sustainable new settlement. Such locations would provide suitable access to the key transport nodes centered around the convergence of the A1/ A428 and also East West Rail and the existing East Coast Mainline.

Object

Representation ID: 6468

Received: 13/09/2021

Respondent: Mr Steven Kent

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.

Support

Representation ID: 6477

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

General approach 1. 2. 3. 4. 5. 6. The general strategy running through all four development options is supported in terms of the need to distribute growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Each of the options do however present varying concentrations of growth within these categories with resulting positive and negative outcomes. We have provided a detailed commentary on each below. Urban Centre and Edge A total of 3,000 homes are proposed within and adjoining Bedford Town Centre with 1,500 homes specifically targeted in the urban area alone. This seems an overly ambitious level of growth for the urban area given the limited land available, the presence of several heritage and environmental constraints and pressures to safeguard land for critical infrastructure such as Bedford Hospital. We would question how the delivery of this number of homes would protect the character of the town given the likely density required to reach this target and the high levels of traffic and congestion already experienced in the town. There will be viability and land assembly challenges for urban land and substantial development has already taken place on the edge of Bedford. Whilst residential development has a place in town centres, there also needs to be an appropriate balance between residential growth and employment/retail/leisure offerings. This is to ensure the vitality of the town centre and its recovery post pandemic. A detailed analysis of the town’s context and capacity for further density/storey heights needs to be carried out before such an option is considered sustainable and achievable. New settlements Paragraph 73 of the NPPF requires LPAs to identify suitable locations for large scale development where this can help to meet identified needs in a sustainable way. This should include: • considering the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains; • ensuring that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access; • set clear expectations for the quality of the places to be created and how this can be maintained (such as by following Garden City principles); and ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed and beautiful homes to meet the needs of different groups in the community; • make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development corporations); and • consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size. Taking into account the above points, it is clear that the advantage of the proposed new settlement at Little Barford is that it would benefit from direct access to the new East West Rail station that is proposed southwards of St Neots. Several of the proposed routing options for the railway line will however 5 constrain the site to an extent. In contrast, a new settlement at Wyboston, given its remoteness from existing urban areas, would have greater reliance on the use of private cars and fewer opportunities to promote active travel and create viable public transport services. This concern is supported by the transport evidence prepared by Aecom on behalf of the Borough Council. 7. 8. 9. 10. 11. 12. 13. Paragraph 73 of the NPPF states that large scale development should be supported by the necessary infrastructure and facilities to include a genuine choice of transport modes. Given the sustainable transport interventions needed to ensure climate change actions are met, delivering a new settlement the equivalent size of a new town in this location cannot be the preference. Furthermore, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another giving rise to concerns around delivery rates as well as significant pressure on existing road infrastructure. Rail based growth parishes The development strategy options include rail based growth at land within the parishes of Kempston Hardwick, Stewartby and Wixams ranging between 3,915 - 7,500 dwellings and 80ha of employment. Currently, the Stewartby and Kempston Hardwick large site promotions include mainly employment development with current applications submitted by Cloud Wing for a 780,379sqm business park and 1,000 new homes at Stewartby. The draft Local Plan development options run contrary to these current land promotions and lack accompanying evidence of deliverability, viability and capacity testing. Delivery of a new railway station and the closure of the exiting Kempston Hardwick and Stewartby stations also affects the masterplanning of the area and could give rise to potentially long lead in times in combination with the extensive remediation works required and off-site highway junction improvements. The principle of development in this location is understood but we would question how much reliance can be placed on the medium-high growth level scenarios delivering within the proposed plan period and how accurately this level of growth can be set out in the Council’s housing trajectory in the absence of evidence concerning lead-in times, infrastructure requirements, remediation works and costs, financial viability testing, masterplaning/capacity testing etc. We would suggest that growth at Stewartby is only capable of delivering post 2035 given the considerable challenges faced with making the site acceptable for development. The principle of further growth at Wixams is also understood although this should be re-categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario and included in the rail based growth parishes to acknowledge the strategic presence of Wixams and focus sustainable growth, investment and infrastructure towards it in a holistic manner rather than invite piecemeal delivery on the edges of Wilstead. Southern parishes Development in the Borough’s southern parishes that surround the A421 has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. This follows paragraphs 68 and 79 of the NPPF and the requirement to promote sustainable development in rural areas where it will enhance or maintain the vitality of rural communities and, more generally, the need to identify a sufficient supply and mix of housing sites. Options 2a, 2b and 2d include potential for 750-2000 dwellings to be delivered within the parishes of Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton. Option 2a includes the higher range (up to 2000) and if distributed equally between these villages would amount to approximately 333 homes each. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability, providing more day-to-day services and facilities and higher levels of self-containment. 6 For this reason, these settlements have potential to accommodate higher levels of growth especially where sites are located within reasonable travel distances of Bedford’s Town Centre and major employment areas, and benefit from existing sustainable travel infrastructure such as cycle/walking routes and bus services. 14. Certain land promotions within the southern parishes present obvious coalescence issues with surrounding villages, which is particularly notable between Gibraltar Corner (see site 636 – land at Gibraltar Corner) and Cotton End (see site 1332 – land at Manor Farm). The Council will need to consider such issues within its site assessments but also be alive to the opportunities presented by other land promotions that present appropriate land for villages to grow especially where this can be comprehensively masterplanned with sufficient land to deliver open space, biodiversity net gain (including Forest of Marston Vale targets), space for recreation, new/enhanced green connections and additional facilities and services. 15. Shortstown is already defined in the current Local Plan 2030 as a ‘Key Service Centre’ comprising a good range of services and facilities and being well connected to the town centre by public transport and cycling. It is approximately a 20 minute cycle and 20 minute bus ride from Bedford Town Centre and railway station and also benefits from close access to the A421 for wider transport connections. As a Key Service Centre, it has the capacity to support further sustainable development. The land promotion at College Farm (Site 1513) includes provision of a new primary school to support housing growth and increase local education capacity in the area. College Farm is also strategically well placed to create important walking and cycling connections to Shocott Spring to the south, Bumpy Lane to the north and the John Bunyan Trail to the west. This would have significant health and wellbeing benefits for the local and wider area. 16. Development at Cardington Sheds (Site 1338) would provide another sustainable location for housing growth in Shortstown, linking into recent development to the east of the settlement. It also creates a unique opportunity to deliver a ‘Heritage Park’ that celebrates the history of RAF Cardington. This would feature public art, educational features, high quality landscaping and play/informal open areas. Further health and wellbeing benefits would be delivered by the introduction of new recreation routes through the site, linking to the A600 (with onward connection to a new primary school at College Farm) and surrounding countryside. 17. Both land promotions would complement rather than compete with the larger potential growth sites, providing Bedford Borough Council with a mix of housing sites and a continuous housing supply throughout the plan period. They can deliver early on in the plan period and deliver growth in a sustainable way that benefits existing and new residents via the provision of new education, recreation and sports facilities, new footpath and cycle connections and a net gain in biodiversity and woodland/tree planting. Eastern parishes 18. 19. Option 2d includes potential growth for 750 dwellings and up to 28ha of employment land within the parishes of Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston. The scale and nature of development at either Little Barford or Wyboston will depend on which is chosen as a strategic location for large scale growth. As such, the remaining villages will need to be assessed in terms of their capacity for further growth, their levels of sustainability and local character. The offer of land promotions in this area ranges significantly and does not necessarily present obvious sustainable choices for growth such as Site 878 (Land west of Great Barford south of the A421). At 2,350 houses, this site will be disproportionately large in relation to the size of Great Barford with significant transport implications and the potential to cause very high harm to both heritage and local character. Site 1355 (Trinity College Farm - North and West Off Roxton Road) for 200 dwellings is, for instance, very poorly related to any existing settlement and unlikely to foster sustainable travel movements and integration with the existing community. The level of growth in the eastern parishes will therefore be partly tempered by the offer of land promotions put forward and their levels of sustainability. Their distance further away from key urban areas like Bedford and St Neots compared to the southern parishes means that in allocation terms, overall growth numbers should be lower. 7 Summary 20. We are in broad agreement with the overarching strategy that directs growth towards sustainable locations such as urban centres, railway stations, the A421 transport corridor and sustainable settlements. Delivering 3,000 homes towards the urban area and adjoining urban area could be overly ambitious for the reasons we have set out above and requires further analysis of the town’s context and capacity to accommodate density/storey heights before such an option is considered sustainable and achievable. 21. In terms of new settlements, Little Barford scores more highly than Wyboston as a sustainable location as it will benefit from the new East West Rail station and a genuine choice of travel modes. However, delivering two new settlements in such close proximity to one another (as in Option 2d) presents too greater competition with one another and concerns around delivery rates and infrastructure capacity, and therefore Option 2c is less favourable and more risky from a strategic point of view. 22. Rail based growth is set at high levels within Options 2a, 2b and 2d with up to 5,500 or 7,500 homes being targeted at Kempton Hardiwck, Stewartby and Wixams. The principle of development at Stewartby and Kempston Hardwick is understood but too much reliance appears to be placed on high growth scenarios in these locations with the likelihood that both deliver too late on in the plan period. Further evidence will be required to demonstrate deliverability and viability in this location particularly given the extent of land remediation required and the likely S106 contributions sought in relation to highway mitigation, education and community infrastructure. 23. The principle of further growth at Wixams is understood as well but would be better categorised as a ‘new settlement’ option within the development scenarios to better reflect its status as a strategic new settlement with potential to be expanded. Inclusion of Wilstead within the ‘southern parishes’ development option should therefore be removed from the southern parishes development scenario. 24. Growth within the eastern parishes is presented in Option 2d but we would suggest growth is better directed towards the southern parishes (as in Options 2a) in order to meet sustainability objectives. Development in the Borough’s southern parishes has potential to provide much needed small and medium sites that contribute to maintaining the Council’s five year housing land supply and ensure the ongoing vitality of existing villages. Key services centres such as Shortstown and Wootton score more highly in terms of sustainability and, for this reason, these settlements have potential to accommodate higher levels of growth. 25. Not all land promotions within the southern parishes present sustainable choices and further assessment will be required to rule out sites that lead to coalescence between villages or relate poorly to existing settlements in terms of size or location. At the same time, the assessments will need to take into account land promotions that provide opportunities to expand existing settlements, giving sufficient weighting to those sites that can deliver early on in the plan period and align with the draft Local Plan objectives to be greener, more sustainable and create strong, safe and resilient local communities.

Support

Representation ID: 6502

Received: 13/09/2021

Respondent: Linda Barber

I want to choose 2c because all the others have a too great an impact on my village of Cotton End. We are already at the brink of being overwhelmed by Shortstown and it’s tentacles and will lose our small village status.

Support

Representation ID: 6513

Received: 13/09/2021

Respondent: Dr Hugh Laing

Agent: Phillips Planning Services

The preferred spatial strategy options (2a-2d) propose that sites are allocated to deliver development of 1,500 dwellings within the urban area and 1,500 dwellings ‘Adjoining the Urban Area’. Further growth is proposed to be focused on the A421 corridor.

There is clearly merit in seeking to utilise sites within and adjoining the urban area in sustainability terms.

Of all of the Spatial Options the sustainability appraisal considers Option 2a the most sustainable. Broad support is provided for this option.

It is submitted that when considering the allocation of sites which fit with and respond to this overall spatial strategy a reasonable mix of sites is required i.e. larger scale strategic sites and smaller and medium scale sites which would provide a different housing type and cater to a different market demand to that of the larger volume housebuilders.

It is also important that the scale of sites reflect the existing settlement character. For example, whilst Bedford has expanded to the north and east with larger scale housing estate style development clearly related to it which has worked well, new development for example in and adjoining Biddenham should be of a smaller scale to reflect its retained village character even though it is now technically considered to be part of the urban area.

A mix of site sizes is required to provide flexibility and deliverability over the plan period with smaller sites 10 – 20 units generally easier to develop and provide a boost in the early years of the plan whilst large more strategic sites take longer to ‘get going’ due to up front infrastructure requirements.

There is also a need to respond to market demand. Whilst some people specifically seek to live within a larger community and enjoy an estate style living others prefer a more village feel and a lower density environment.

In taking forward the Local Plan preparation we again highlight the availability of our clients land at Biddenham (Site 808) which is available, has received a positive assessment as part of the Call for Sites process and could deliver 12 good quality new homes squarely in accordance with the preferred emerging strategy.