8.35

Object

Representation ID: 3651

Received: 16/08/2021

Respondent: Great Barford Neighbourhood Plan Group

Infrastructure needs to be delivered at the same time and in parallel to development, not delayed to possibly come later

Object

Representation ID: 3696

Received: 19/08/2021

Respondent: GB PC

Infrastructure must be planned at the same time and in parallel to the development that will need it, not as an afterthought to play catch-up

Support

Representation ID: 3820

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC has no comments to make.

Support

Representation ID: 3821

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC has no comments to make.

Support

Representation ID: 4079

Received: 30/08/2021

Respondent: Ann Mills

Essential requirement for overall viability of plan.

Object

Representation ID: 4416

Received: 31/08/2021

Respondent: None

If you want people off the roads: stop building new ones.

Object

Representation ID: 4935

Received: 02/09/2021

Respondent: Kler Group

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.

Object

Representation ID: 5340

Received: 03/09/2021

Respondent: Mr Jetinder Dhaliwal

Will the infrastructure deliery plan be consulted upon before final submission ?

Will is also impact assess ALL planned major infrastructure projects impacting the region/town ? It should be a cumulative impact assessment and not in isolation for each project and requirement. How else are people to know what the quality of life will be like before/during/after the implementation of the plan. Failing to do that in advance would be remiss and not good for the people of Bedford.

Object

Representation ID: 5376

Received: 03/09/2021

Respondent: Mrs Clare Buddle

When do the community get consulted? If details are contained in the submission draft, this will be too late for a reasonable , democratic discussion.

Support

Representation ID: 5729

Received: 07/09/2021

Respondent: National Highways

Highways England welcomes the opportunity to comment on the Bedford Borough Draft Local Plan - Strategy Options and Draft Policies consultation which covers the period from 2020 to 2040.
Highways England has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. In relation to this consultation, our principal interest is safeguarding the operation of the A45 located approximately 2.5km north of the Plan area in Northamptonshire.
We understand that there is a requirement to deliver 1,275 dwellings per year, which equates to a total of 25,500 over the Plan period. There are already 13,000 existing housing commitments leaving 12,500 new dwellings to be allocated. The proposed yearly requirement is higher than currently set out in the adopted Local Plan (970 dwellings).
We have reviewed the interactive Call for Sites map and while we understand that not all of these sites will be allocated in the final Local Plan there are a number which have the potential to impact the operation of the A45 in Northamptonshire:
• Site ID: 896 for 540 dwellings at Land south-west of Rushden
• Site ID: 774 for 70,000sqm B1/B2/B8 employment at Chelveston Renewable Energy Park, Chelveston Airfield, Chelveston cum Caldecott
• Site ID: 939 for 128 dwellings, Land at Poplars Farm, Wymington
• Site ID: 946 for 98 dwellings, Land west of Rushden Road, Wymington
• Site ID: 1002 for 4,500 as a garden village at Land adjacent Colworth Science Park
• Site ID: 918 for 397 dwellings at Land south of Odell Road, Sharnbrook.
Should any of these sites be allocated in the final Local Plan, further assessment work may be required to ascertain the impact on the SRN and to determine the need for mitigation.
There is also a requirement to deliver of 171ha of employment land over the plan period. There is currently available supply for 48ha of employment land, leaving 123ha of land to be allocated in the Local Plan. Furthermore, Policy E1S sets out that a minimum of 8,642 net additional jobs will be provided by the end of the plan period.
We understand that it is expected that some future employment will be brought forward through large scale sites that are well connected to transport networks, including to the SRN. The council are currently considering three business parks of 30ha each with the remaining land allocated to smaller sites for offices and general industry.
Regarding the growth strategy options, we understand that an issues and options consultation took place in 2020 where six options were reviewed. As part of this consultation four options have been presented: 2a, 2b, 2c and 2d. All options seek to focus growth in the Bedford Urban Area and in settlements to the north east of Bedford and parishes south of Bedford. We consider that these strategies may have more of an impact on the A1(T), as opposed to the A45 in Northamptonshire.
We note that further work is required to determine the proposed trajectory for housing and employment in light of infrastructure improvements proposed, including the A428 Black Cat to Caxton Gibbet improvement and East West Rail proposals as well as the wider transport strategy set out in the document.
We wish to continue to liaise with Bedford Borough Council in the development of the Local Plan to understand which sites will be allocated and whether there may impact on the A45. If sites identified in the Call for Sites exercise to the north of the Plan area are allocated, consideration will need to be given to the potential impacts on the A45, specifically at the A45/A6 Chowns Mill roundabout. While improvements are underway at this junction, additional assessment work may be required to understand the impacts in light of the greater housing and employment requirements identified for Bedford,

Object

Representation ID: 5883

Received: 08/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.

Support

Representation ID: 6253

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

We agree that an Infrastructure Delivery Plan will be required to support the chosen development strategy.

Object

Representation ID: 6351

Received: 10/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.

Support

Representation ID: 6694

Received: 14/09/2021

Respondent: The British Horse Society

I note that the Infrastructure delivery plan will be prepared at a later date. I assume that “infrastructure of all kinds” includes green infrastructure and multiuser routes.

The Society would be happy to assist in the development of that plan and would suggest that the Hampshire document referred to above may be relevant … to repeat my previous comment:

Although produced for another county, ‘Equestrians in Hampshire – a reference guide for Transport, Planners, Developers and other decision makers’ published by Hampshire Countryside Access Forum with support from Hampshire County Council and the BHS has been widely circulated beyond Hampshire, sparking interest from other authorities outside the county. We would like to work with you to create a similar document for Bedford Borough so that any proposed new bridleways, when implemented, will restore connectivity within the wider rights of way network in a way that will benefit all users, including equestrians.

Object

Representation ID: 7055

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

As set out elsewhere in our submissions, we raise significant concerns that the Local Plan 2040 is being advanced with key evidence base which ought properly to underpin emerging strategy and policy not prepared. This relates to the IDP. Paragraph 8.35 makes clear that once the development strategy is chosen infrastructure requirements can be identified and set out in an IDP.
However, adopting this approach/sequence significantly risks the emerging plan being taken forward in a manner which cannot be delivered, either because the infrastructure burden is so great as to render the strategy undeliverable, or by developing a strategy where infrastructure is not capable of being mitigated.
The correct approach is for the IDP to be prepared now, to inform decisions on development strategy going forward. Evidence base documents should be used to enhance the plan making process, not to be prepared after the event and written to support the chosen strategy and policies.

Object

Representation ID: 7552

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

As drafted, these representations consider that the Council’s Preferred Strategy Options published for consultation will continue the failure to specifically address the role and requirements of Lincroft Academy. This jeopardises CMAT’s ability to effectively delivery the expansion in the Pupil Allocation Number (PAN) required immediately as well as precluding delivery of any future strategy for enhancement and further expansion of the facilities including relocation of the Lovell Road Playing Fields.
This issue principally arises from the failure of the Council to produce any settlement-specific Infrastructure Delivery Plan (IDP) to support consultation on its Preferred Options. Paragraph 8.35 of the consultation document states that this will only be produced once the development strategy has been chosen and infrastructure requirements can be identified. There are three principal issues with this dealt with in the remainder of these representations:
1) The requirement to increase the Pupil Allocation Number (PAN) to approximately 240 pupils at Lincroft Academy is a known and immediate requirement and requires support through the Plan’s strategic policies in all scenarios. This, however, is an increase upon ‘limitations’ imposed in planning conditions attached to past planning permissions.
2) None of the Council’s Preferred Strategy Options identify further village-related growth at settlements outside of narrowly defined parishes within the A421 corridor. In the case of Lincroft Academy specifically this fails to reflect continued pressure on school places arising from recent and committed development. For the settlement of Oakley, fails to reflect that support for further residential development to optimise the potential for enhancement of community facilities will maximise the potential to contribute towards sustainable development and deliver substantial net gains across the wider strategy.
3) The evidence base provided by the Infrastructure Delivery Plan should be completed in-tandem with the review of the settlement hierarchy, whereby these representations endorse Oakley’s reclassification as a Key Service Centre to better reflect the important role of Lincroft Academy and to support further expansion of enhancement of the facilities as required in the future.

Object

Representation ID: 8517

Received: 02/09/2021

Respondent: Bedfordshire Police

BP request that the forthcoming Infrastructure Delivery Plan incorporates in full the findings presented
and evidenced in the enclosed BPIP. This is because the delivery of policing services needs to be planned
and funded in advance of a new development scheme, in the same way as utilities, education, health,
transport and other public services. If this does not take place, BP’s resources used for existing
communities in the Borough will have to be ‘stretched’ to serve the new ones being created. This will
lead to the risk of unacceptable dilution of policing service provision across the Borough.
The above negative outcome would contrast starkly with the basic expectation that when people move
into a new housing estate or other type of development, they expect to be protected by policing services
that can operate effectively and efficiently across the area concerned. This applies to all levels of
services, whether they ring 999 should the worst happen, or are simply benefitting from the reassurance
of day-to-day neighbourhood policing for example.
Underlying the above is the fact that the potential impact on the police and other emergency services
from a new development is not simply due to an increase in population, but also the location of where
that new population is arising and the impact it will have on the present disposition of resources.
Delivery of policing in this respect is not just about responding to a crime or incidents, but also providing
other services such as community assurance, protecting the safety of children or vulnerable people and
preventing crimes from happening in the first place amongst many others.
We also want to make it clear that mitigating the impact of a given scheme on BP and other emergency
services is not a false choice between design or infrastructure measures. These in fact go together to
ensure a development is safe and secure. Neither one alone can achieve this. As evidenced at length in
the enclosed BPIP, new infrastructure for the police will be required in many cases across the Borough
alongside design measures therefore.