3.17

Support

Representation ID: 6514

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.

Support

Representation ID: 6550

Received: 13/09/2021

Respondent: Mrs Susan Trolley

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: 6551

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 3.15 – 3.17 (Spatial Strategy Options) – Object
2.11 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.
2.12 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.”
2.13 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 Rushden Road, Milton Ernest through the expansion of an existing employment use. 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.
2.14 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 – which it must be assumed includes existing provision at Milton Ernest) providing opportunities for the creation of balanced communities.
2.15 In the case of Milton Ernest, 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 employment activity within the site.
2.16 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.

Object

Representation ID: 6566

Received: 13/09/2021

Respondent: Challenger Multi Academy Trust

Agent: Fisher German LLP

Growth Strategy Options
2.11 In respect of the proposed growth strategy options, at this stage we consider the distribution of housing should be displayed as a percentage, that way it can more quickly respond to changes in housing requirement for example, whilst maintaining the spatial distribution of housing.
2.12 In respect of the proposed options, we consider it almost inevitable that the spatially optimal solution is likely to be a hybrid of a number of the referenced options. Our favoured approach would be an approach which seeks to continue delivery in the urban areas, deliver higher growth on key transport corridors, particularly the A421, but retains an apportionment of growth to be disbursed to the rural area. The issue with the other options is that they place too significant an emphasis on delivery on limited areas. Such an approach reduces the ability of the market to function most efficiently, as the variety and competition will be reduced. This reduces the ability for small and medium housebuilders to enter the market and reduces the options for home purchasers. This will become particularly apparent if a higher housing requirement is deemed to be appropriate, placing further emphasis on a more limited pool of settlements. Dispersed growth as well as assisting delivery, encouraging a wider range of housebuilders into the market delivering concurrently, also has the benefit of supporting rural communities remain vibrant and ensuring a healthy demographic composition, preventing issues such as village ageing.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) in our opinion should form part of every spatial option, albeit the level to be delivered could of course differ option to option. We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established at this point the significant harm such an approach has caused in recent years nationally, as reflected in matters such as declining public transport routes, closure of village pubs, closure of shops and the general decline in vitality of village life generally where development has been withheld. Whilst the current plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result in a 10-year period with no proposed growth which would be unacceptable and as such some provision must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing prevalence of home working and the greening of private vehicles through developments in electric vehicles, which by the end of the Plan Period are likely to be highly prevalent, with new petrol and diesel car sales ending in 2030. Post lockdown there is likely to be a continued demand for semi-rural opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a facet of future delivery, we would urge caution be applied if the Council are to rely heavily on delivery arising from new settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery prior to the first dwellings being delivered. Our preferred approach in this scenario is to positively allocate such sites above and beyond the sites needed to meet housing needs. If work is underway and delivery has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which should provide the confidence needed to the market to commit to the works and evidence necessary to obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn’t come forward at all. We would not object if Strategic Sites were used to facilitate an increase in housing requirement, to provide delivery later in the Plan period. This should not be delivered through a stepped trajectory, with sufficient land needing to be allocated to deliver Local Housing Need in full through the Plan period.
2.16 The above approach is potentially beneficial in that it means the Council can retain an element of control, meaning they can ensure the new settlement/s comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery. If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence and appropriate planning consents, then the Council can begin to rely on delivery to meet base Local Housing Need. Given the likely lead in times, it is considered unlikely any development will be forthcoming until the latter end of the Plan period. As such if a higher housing requirement is assessed as being necessary, additional smaller sites will need to be identified in the early years of the Plan. This approach however could provide supply in the long term and an important avenue for future delivery, particularly towards 2050.

Support

Representation ID: 6571

Received: 13/09/2021

Respondent: Mr R Brown

I support 2C and/or 2A.

I say no to 2D and 1A.

Object

Representation ID: 6572

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Growth Strategy Options
2.11 In respect of the proposed growth strategy options, at this stage we consider the distribution of housing
should be displayed as a percentage, that way it can more quickly respond to changes in housing
requirement for example, whilst maintaining the spatial distribution of housing.
2.12 In respect of the proposed options, we consider it almost inevitable that the spatially optimal solution is
likely to be a hybrid of a number of the referenced options. Our favoured approach would be an approach
which seeks to continue delivery in the urban areas, deliver higher growth on key transport corridors,
particularly the A421, but retains an apportionment of growth to be disbursed to the rural area. The issue
with the other options is that they place too significant an emphasis on delivery on limited areas. Such
an approach reduces the ability of the market to function most efficiently, as the variety and competition
will be reduced. This reduces the ability for small and medium housebuilders to enter the market and
reduces the options for home purchasers. This will become particularly apparent if a higher housing
requirement is deemed to be appropriate, placing further emphasis on a more limited pool of
settlements. Dispersed growth as well as assisting delivery, encouraging a wider range of housebuilders
into the market delivering concurrently, also has the benefit of supporting rural communities remain vibrant and ensuring a healthy demographic composition, preventing issues such as village ageing.
2.13 Dispersed growth (or Village related as it is referred in the consultation material) in our opinion should
form part of every spatial option, albeit the level to be delivered could of course differ option to option.
We would wholeheartedly reject any attempt to constrain any dispersed growth, as it is well established
at this point the significant harm such an approach has caused in recent years nationally, as reflected in
matters such as declining public transport routes, closure of village pubs, closure of shops and the
general decline in vitality of village life generally where development has been withheld. Whilst the current
plan makes some provision going forward, clearly this is to be delivered up to 2030, and thus would result
in a 10-year period with no proposed growth which would be unacceptable and as such some provision
must be provided to ensure sufficient provision is made over the extended Plan period.
2.14 A dispersed pattern of growth is better enabled through the availability of modern technology including
recent modal shifts in online shopping, improvements to high-speed broadband provision, the increasing
prevalence of home working and the greening of private vehicles through developments in electric
vehicles, which by the end of the Plan Period are likely to be highly prevalent, with new petrol and diesel
car sales ending in 2030. Post lockdown there is likely to be a continued demand for semi-rural
opportunities, with the COVID-19 pandemic placing a greater emphasis on space and outdoor living.
2.15 Whilst we do not object to the principal of identification of a new settlement as a facet of future delivery,
we would urge caution be applied if the Council are to rely heavily on delivery arising from new
settlement/s to meet the overall quantum of housing growth necessary over the Plan period. Such sites
are notoriously difficult to deliver and require significant amounts of planning and infrastructure delivery
prior to the first dwellings being delivered. Our preferred approach in this scenario is to positively allocate
such sites above and beyond the sites needed to meet housing needs. If work is underway and delivery
has started, this can be reflected in later plan reviews. This ensures that the site is allocated, which
should provide the confidence needed to the market to commit to the works and evidence necessary to
obtain the appropriate planning consents but means that housing delivery will continue if work is delayed or doesn't come forward at all. We would not object if Strategic Sites were used to facilitate an increase
in housing requirement, to provide delivery later in the Plan period. This should not be delivered through
a stepped trajectory, with sufficient land needing to be allocated to deliver Local Housing Need in full
through the Plan period.
2.16 The above approach is potentially beneficial in that it means the Council can retain an element of control,
meaning they can ensure the new settlement/s comes forward in an acceptable manner, and are not forced to compromise on key elements to ensure the site is delivered due to an over reliance on delivery.
If it becomes apparent at a future Local Plan Review that the site is going to deliver, through evidence
and appropriate planning consents, then the Council can begin to rely on delivery to meet base Local
Housing Need. Given the likely lead in times, it is considered unlikely any development will be forthcoming
until the latter end of the Plan period. As such if a higher housing requirement is assessed as being
necessary, additional smaller sites will need to be identified in the early years of the Plan. This approach
however could provide supply in the long term and an important avenue for future delivery, particularly
towards 2050.

Object

Representation ID: 6607

Received: 14/09/2021

Respondent: Mr Aiden 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.

3.17 100 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.

Support

Representation ID: 6672

Received: 14/09/2021

Respondent: Wilden Parish Council

Re: Local Plan 2040 Consultation

Having considered the above consultation, Wilden Parish Council resolved to support Option 2A.

Object

Representation ID: 6729

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

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: 6767

Received: 14/09/2021

Respondent: Ms S Kelly

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: 6783

Received: 14/09/2021

Respondent: Mr Nicholas Flynn

I wish to respond to the Consultation on the Local Plan 2040 principally by expressing concern that the whole emphasis to the Plan seems to be founded on the premise that as many areas as possible should be earmarked for Housing and Employment rather than trying to limit the extent to which the countryside should be increasingly and irrevocably consumed by seemingly endless developments.
I understand that the Council needs to achieve, at least in principle, certain targets in order to fulfil Government requirements but it would appear that Bedford has been overenthusiastic and is setting targets considerably higher that all contiguous Councils in the same East Midlands area. This creates the impression that Bedford Borough actually has a policy, or at least an aim, to create as many development opportunities as possible rather than trying to keep countryside destruction to a minimum.
I appreciate that allocation of areas for some form of development does not automatically mean that all of those areas will see development come to fruition and there needs to be some form of “reserve”. However, over a period of some 18 years to the end of this Plan period there will undoubtably be some Blue Sky opportunities which would, at least in part, make up some shortfall.
It is pleasing, although only correct, that the first priority for any new housing should be existing brownfield sites, of which there are several in Bedford and surrounding areas. However, developers are very wary of such sites and shy away from them if at all possible. There should be some mechanism for making these brownfield areas a first priority although clearly the Council is unable to force the current landowners to accept sale considerations well below their aspirations even if the result is that these sites remain undeveloped for tears to come. Perhaps the Council should consider some forms of inducement in an effort to see such sites come to fruition.

We have all been invited to submit our preferences for the 4 Options 2a, 2b, 2c and 2d set out in your recent flyer.
My preferences are, in order ;-

2a (least bad of the 4)
2c
2b
2d (worst of the 4)

Support

Representation ID: 6787

Received: 14/09/2021

Respondent: Mrs Judith Wootton

As a long-term resident of Renhold (over 60 years), I should like to ensure the essential character of Bedford and its rural hinterland are preserved into the future. The above plan with its high focus on national strategies and targets threatens this unless a strong local voice is heard in this process.

Looking at the 4 options being considered by the council, it seems to me that option 2c offers the best compromise between necessary development and preservation of the local landscape and amenity. This is achieved by focussing development around brown field sites, semi urban areas close to Bedford town and new compact settlements at Little Barford and Wyboston. Crucially it avoids urban sprawl and the coalescence of village ends which are a long-held feature of the area.

Of the alternatives, 2d is the least preferred since it offends on virtually all the critical factors identified above and maximises the opportunity for future speculative building on adjacent agricultural land.

Object

Representation ID: 6819

Received: 15/09/2021

Respondent: Mr Damian Smith

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: 6906

Received: 15/09/2021

Respondent: Master Corey T 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.

Object

Representation ID: 6914

Received: 15/09/2021

Respondent: Mr Mark Tippett-Wilson

• I’m strongly opposed to options 1a and 2d, as having recently moved to Renhold to retire and sample the village I feel that these options would:-

o Impact my wifes and my quality of life including mental well being
o Massive increase in air and light pollution in this and surrounding areas
o Increase noise levels increase through additional traffic during and after the builds
o Require significant more infrastructure, e.g. road, pavement and utility infrastructure, (gas, electric, water and broadband) potentially impacting all of the area during and on completion of the work
o Increase road traffic accidents in this area due to the increase volume of traffic
o Devastate the farming, wildlife and countryside in the local area forever.

Support

Representation ID: 6915

Received: 15/09/2021

Respondent: Mr John Cleary

I support 2C and/or 2A.

I say no to 2D and 1A.

Object

Representation ID: 6998

Received: 16/09/2021

Respondent: Mr Robert 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.

Object

Representation ID: 7038

Received: 17/09/2021

Respondent: Mr Robert Tusting

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: 7046

Received: 17/09/2021

Respondent: Mr Philip Mann

2d & 1a are of particular concern for those that live in Renhold. Renhold is a small group of 3 settlements with very little facilities. Urban development is more sustainable than rural. It is important to guard against coalescence and Renhold is at risk from urban sprawl.
It is better to develop brownfield sites than build on open countryside. 2d & 1a must not be allowed to destroy the intrinsic character & beauty of Renhold’s green spaces and its high [quality] agricultural land. Development on good quality agricultural land is Against government policy.
Renhold’s ancient woodlands at Great and Early Grove are vulnerable if routes 8 or 9 are chosen for East West Rail and further housing development with all the pollution it would bring would jeopardise the wildlife which lives here. Widening roads & development in open countryside would destroy wildlife corridors & valuable wildlife habitats.
Renhold village comprises ‘6 ends’ each separated by small tongues of farmland. In the recent green infrastructure survey in preparation for the Neighbourhood plan, residents placed key importance on protecting this unique character and identity and the importance of the green buffer zone.
Many of the roads in Renhold village are in a poor state of repair. They are quite unsuitable for large volumes of traffic or HGV’s and there is a Traffic Restriction Order and a weight restriction in place.
Speeding continues to be an issue and the PC are looking to purchase more speed restrictions which already include traffic lights, average speed cameras and vehicle activated signs, as motorists use Renhold as a rat run to and from the A421 and the A6. More housing would exacerbate the problem.

Object

Representation ID: 7053

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise significant concerns in relation to the potential for a stepped trajectory to be taken forward in the Local Plan 2040.
The effect of a stepped trajectory, deferring the delivery of the standard methodology until 2030, is to significantly undershoot on the delivery of annual housing need. In itself this is a significant failure, but in this instance the significant adverse impacts are compounded by a Local Plan adopted based on a low locally derived housing need future and therefore already under delivering against actual housing need.
This means that real people in real need now cannot access the housing market because of the lack of housing, affordability ratios will significantly increase and those people on the housing waiting list will also be unable to access affordable housing given that the primary source of affordable housing is from open market housing sites.
A stepped trajectory runs counter to the provisions of Policy 1S of the Local Plan 2030, a policy put in place to ensure an immediate plan review so as to meet the requirements of the standard methodology. If put in to effect, a stepped trajectory would mean that for Bedford the standard methodology will not take effect until approximately 12 years after the standard methodology was first brought in, which by any measure is wholly inappropriate and unjustified.
It cannot be said that the Council do not have the range of smaller and medium sized sites to enable a smooth rather than stepped trajectory – a significant number of the 430 call for sites submissions are capable of being brought forward without significant on or off site infrastructure. This basket of sites can be delivered without delay and do not justify a stepped trajectory.
Paragraph 3.3 of the Local Plan 2040 refers to the considerable challenges in meeting the requirements of the standard methodology. Those challenges will only increase if a stepped trajectory is put in place, since the second half of the plan period will require on an annual basis housing delivery far higher than even the standard methodology.
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: 7087

Received: 09/09/2021

Respondent: June 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.

Support

Representation ID: 7134

Received: 09/09/2021

Respondent: Stephen 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.

Support

Representation ID: 7155

Received: 17/09/2021

Respondent: Mr Richard Hull

Agent: Phillips Planning Services

3.0 Emerging Preferred Options – 2a, 2b, 2c and 2d

There is an underlying bias towards urban centric growth in the preferred strategy options, which discounts further growth in the Key Service Centres and smaller sustainable villages. None of the four emerging preferred growth options include any growth in the north of the Borough.

The north of the Borough includes several highly sustainable settlements including the Key Service Centres of Bromham, Clapham, and Sharnbrook, and the Rural Service Centres of Carlton, Harrold, Milton Ernest, Oakley, and Turvey. There are also many other sustainable smaller villages.

The decision not to allocate further growth to the northern villages appears to be based upon the findings of the Bedford Borough Transport Model prepared by Aecom. The assessment considers a range of predetermined scenarios for growth and identifies that where a range of development is considered in the north (and across the Borough) up to 2040, there will be adverse impacts on the A6 corridor and there is no adequate mitigation available. Therefore, a broad conclusion is reached that development along the A6 corridor is constrained.

While it is acknowledged that general scenarios have to be considered in order to assess the impacts of strategic growth on the highway network, it is a very blunt tool and so its conclusions should be considered in that context. The transport modelling is clearly quite broad, particularly when considering development opportunities in the larger settlements in the north of the Borough which are primarily assessed in the “Grey scenario” (dispersed growth). In this scenario development in the north is considered as a proportion of overall growth across the Borough and the highways impact is felt more widely. This is clearly a blanket approach which lacks the fine grain of assessment necessary to properly understand the impact of growth opportunities in key locations, and therefore too easily discounts development in the Key and Rural Service Centres in the north which are sustainable settlements with capacity for growth. We would contend that the transport modelling does not provide a conclusive position that a more targeted approach to growth in the north cannot be accommodated on the highway network. The report identifies that mitigation measures are available, and therefore a more focused assessment should be considered.

Growth in the north including in the Key Service Centres, and Rural Service Centres has been too easily discounted and this is a lost opportunity as there are several highly sustainable settlements in this location. Additional growth in the northern settlements can make a positive and meaningful contribution to the wider strategy going forward to 2040, improving the long term vitality, and the viability of existing services and facilities. We would argue that allocations should therefore be made proportionally across the Borough in the interests of long-term sustainability.

The preferred strategies that are being consulted upon are also missing an opportunity to build upon the platform being created through the current Neighbourhood Plan process.

Our client therefore raises objection to Growth Options 2a, 2b, 2c, and 2d as they fail to provide any growth in the north of the Borough which undermines the long-term sustainability of the villages in this area.

Support

Representation ID: 7163

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

We support the proposed growth along the A421 corridor. This accords with the Government’s strategy of delivering a growth corridor between Oxford and Cambridge which includes the building of one million high quality new homes, and over one million new jobs across the corridor by 2050, in order to maximise the areas economic potential.

However, although the four growth options being consulted upon all include the A421 corridor, only Option 2d includes the eastern parishes and fully explores the potential of this corridor and its settlements to accommodate growth. We contend that the eastern parishes should be included in the selected growth strategy otherwise an important part of the Oxford To Cambridge arc, namely the villages around the Black Cat interchange, will be left out. The eastern area of the corridor includes several sustainable settlements including Key Service Centres, all with good links onto the A421 and the A1. Allocations should be made across the entire corridor to ensure its economic potential is maximised.

We therefore raise objection to Growth Options 2a, 2b, and 2c as they have omitted a crucial part of the A421 corridor, and wish to elevate option 2d as the preferred option for growth.

Of the selected growth options, our client’s support growth Option 2d which seeks to distribute growth along the entire A421 corridor. This option will contribute towards the Governments strategy of delivering a growth corridor between Oxford and Cambridge.

Great Barford is the largest settlement in the eastern parishes, and a Key Service Centre and it would therefore be logical that it be proportionally allocated the larger share of the identified growth.

We would also state that the quantum of development identified in option 2d is too low and would not fully utilise sustainable sites available within the eastern parishes, particularly in Great Barford, where our client’s control land suitable for a further 92 dwellings, within easy access of a major junction onto the A421, and close to the high frequency bus route provided by the X5 linking between Milton Keynes, Bedford and Cambridge.

Object

Representation ID: 7166

Received: 17/09/2021

Respondent: C Jackson & Sons (Bedford) LTD

Agent: Phillips Planning Services

None of the preferred strategy options allocate any growth in the north, including for employment purposes. Our client raises an objection on the basis that the plan is not giving proper consideration to supporting existing employment areas in the north of the Borough, not considering opportunities to support the expansion of those existing businesses. Our client’s site at Thurleigh could expand onto land (Site 715) adjacent to his existing employment site at Keysoe Road. As a large business and local employer, it was hope dthat the sites identification might come through either an allocation, or an altered policy framework setting out support for the growth of existing businesses.

Support

Representation ID: 7169

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

None of the preferred growth option include any particular focus on leisure and tourism, and the Plan does not contain much commentary about the potential tourism development can offer for supporting a diverse local economy, bringing employment and benefits to the wider town. Our clients land known as Great Barford Lakes (Site 744) provides an opportunity for a leisure use driven by tourism which comprises of a hotel and lodges based around water-based recreation on the lake, and the River Great Ouse. The site is located close to the A21 junction outside Great Barford.
Pre-application discussions were held many years ago on the potential of a speculative application. The reason this did not move forward was the perceived risks involved in progressing a planning application with no clear policy support for tourism application. Hotel provision is defined as a “town centre use”, and yet it is evident that hotel provision must address locational needs and desires to attract customers.

As the Town Centre policy framework is rather narrow in scope, we would encourage the Council to consider a broader economic vision, within the context of the Oxford-Cambridge Arc. With economic and population growth will come the commensurate increase in leisure and recreation; as well as drawing in consumers and visitors from outside the Arc. We believe the emerging growth options should therefore include for tourism related development, or preferably consider allocating leisure and tourism opportunity sites.

Support

Representation ID: 7180

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Our client supports the strategies identified in Options 2a, 2b and 2d of the consultation, in which land in the southern Parishes, which includes Wootton could be identified for between 750 dwellings and 2000 dwellings. It is evident from the Call for Sites Proformas that there are several sites available across these Parishes that could make a meaningful contribution towards the delivery of these strategies.

It is further noted that the Sustainability Appraisal identifies Option 2a as the most sustainable option, and this proposes 2000 dwellings be identified in the Transport Corridor – South. If this Option, or indeed 2b or 2d, is eventually selected, our client wishes to put forward his site at the Chequers Public House, Wootton (Site 1503) as suitable site for allocation to meet this delivery.

Object

Representation ID: 7214

Received: 17/09/2021

Respondent: Mr Peter Knight

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: 7242

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

In section 3, ‘Growth and Spatial Strategy Options’ the four growth options the council seeks representation on. These are summarised as:
Option 2a: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes and southern parishes
• 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.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with rail based growth parishes, southern parishes and east parishes, plus one new settlement.
These four options are a result of the issues and options consultation. Of initial concern is that there is no acknowledgement of the route of the new east-west rail line. Despite the fact the recent publications of the route are informal consultations there is a clear intention of the railway to travel north through land between Bedford and Clapham Green. The route to the west is already significantly advanced and therefore there can be a great deal of certainty that the rail route will be delivered.
It is therefore surprising that the Plan does not reference the route in changing the landscape for development and in turn, the opportunities for settlement expansion. For example, the landscape will significantly change if the rail route is pursued to the west of Bedford and East of Clapham Green. Clapham has excellent transport connections and a number of services, but its expansion or growth is not covered by the options above.
It is therefore suggested that BBC consider a fifth option for growth in light of recent publications of the East-West rail, which includes (in part) elevation plans which may release further land for development, particularly in Clapham. The fifth option should look to re-consider Settlement Boundaries and landscape policies, constraining development, in the vicinity of the proposed route.
The recent publication of the NPPF (2021) will also require BBC to reconsider their spatial strategy. New Paragraph 22 requires Local Planning Authorities to provide policies set within a vision of at least 30 years to allow large scale developments, such as new settlements to be delivered.
Conclusions on Housing Provision Options:
The following key conclusions are reached in relation to the Housing Provision Options presented by the Council in the draft Plan:
1. It is considered that the Council needs to reconsider the growth options starting with 1,275 dpa as a minimum and working up from there.
2. The above exercise cannot be undertaken until the Council has made progress with its neighbouring authorities under the DtC to confirm the true extent of unmet need. In any event it is clear that the scale of unmet need is significant and the Council therefore must consider higher growth options. 3. In turn the SA needs to consider high growth options to determine the sustainability merits of meeting a higher proportion of the significant unmet need arising.
4. The next iteration of the draft Plan must include evidence on housing supply and trajectory to enable scrutiny of the Plan’s ability to maintain a rolling 5-year supply of deliverable housing sites.
5. The Policies of the Local Plan will require review in light of the NPPF, particularly in relation to a 30-year vision to see new settlements delivered.
2.13 In order for the Council to address the above points in a transparent manner it is considered that further Regulation 18 consultations will be required that deals with the range of high growth options and the consequent revisions to the spatial strategy, along with filling the gaps in the current evidence base in relation to DtC and also updating the SA.

Support

Representation ID: 7299

Received: 01/09/2021

Respondent: Miss Laura Jones

At Little Barford.
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.

3.17 100 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.