1.28

Showing comments and forms 1 to 20 of 20

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3810

Received: 26/08/2021

Representation Summary:

I note that the Strategy Paper defines Option 2a – 2d as the preferred options. These options suggest that a significant number of dwellings should be built in the “Southern Parishes” (Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton).

I am a long-time resident of Wilstead and strongly object to the proposed new houses in Wilstead.

I provide, below, further details to support my objection to further building in Wilstead.

All these parishes have been subject to developments in recent years so should not have to bear further developments.

Wilstead has been designated a Key Service Centre, but the village should never have designated as such. The scoring methodology originally used to determine this needs to be updated. The village no longer has a weekly doctor’s surgery. The village is quoted as being on a bus route to and from Bedford. A large proportion of the village is located more than 800 metres from the nearest bus stop and there are no longer any services down Cotton End Road (except once, on one day a week). There are two bus companies and the services are hourly but within 10 minutes of each other. There is no bus service on a Sunday and during the week the services are predominately in the mornings and early afternoon. The last service from Bedford to Wilstead is at 7pm.

The local Primary School is full to capacity and cannot accept any additional pupils. It was hoped that Secondary education would be available at Wixams Academy but this is already at capacity without additional houses being built in either Wixams or Wilstead.

It is noticeable that the villages in the north of the Borough are, in the main, excluded from the Plan. A 10% increase in housing for each village would be much more equitable without increasing the strain on those villages. The Borough Council could also allocate more houses to larger villages that have existing better facilities and infrastructure (e.g. GP Surgeries, shops and schools) already in place.

There have been significant developments in Wilstead recently and whilst these developments appeared to be acceptable at the time, the incremental addition of houses with no associated increase in facilities (school places, GP service, public transport etc) has meant that the village cannot accept any further houses. Just recently, there has been a large development (off Whitworth Way) which has caused traffic chaos around the local school.

Wilstead should not have to contribute any more houses to the Borough Plan.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4298

Received: 31/08/2021

Representation Summary:

Very complex information.

However, I have understood that an element of the information is flawed.

Brown - urban growth, as you have described as "within the urban area (sites within the urban area boundary) or (all or part of the site is within 0.5 miles of the urban area boundary") does not describe the land for the proposed new settlement on land west of Wyboston - referred to as Brown - urban growth (St Neots).

St Neots is adjacent to the A1 motorway and the land west of Wyboston is well beyond the A1, it is open countryside.

Full text:

Very complex information.

However, I have understood that an element of the information is flawed.

Brown - urban growth, as you have described as "within the urban area (sites within the urban area boundary) or (all or part of the site is within 0.5 miles of the urban area boundary") does not describe the land for the proposed new settlement on land west of Wyboston - referred to as Brown - urban growth (St Neots).

St Neots is adjacent to the A1 motorway and the land west of Wyboston is well beyond the A1, it is open countryside.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4803

Received: 01/09/2021

Representation Summary:

I AGREE with the following options:
Option 3a
Option 3a
Option 3b
Option 3c
Option 4
Option 5
Option 6
Option 7


I OBJECT to the following options:
Option 1a
Option 1b
Option 2a
Option 2b
Option 2c
Option 2d

Full text:

I AGREE with the following options:
Option 3a
Option 3a
Option 3b
Option 3c
Option 4
Option 5
Option 6
Option 7


I OBJECT to the following options:
Option 1a
Option 1b
Option 2a
Option 2b
Option 2c
Option 2d

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4922

Received: 02/09/2021

Representation Summary:

I support Option 2c. It seems to me to provide the necessary increase in housing stock yet gives modest protection to the
rural areas of east Bedfordshire. I am pretty sure there will be an adverse effect somewhere within the area however
when East-West Rail finally decides the O-C route, the effect being to alter the emphasis on site allocation.

Full text:

I support Option 2c. It seems to me to provide the necessary increase in housing stock yet gives modest protection to the
rural areas of east Bedfordshire. I am pretty sure there will be an adverse effect somewhere within the area however
when East-West Rail finally decides the O-C route, the effect being to alter the emphasis on site allocation.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4924

Received: 02/09/2021

Representation Summary:

We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date. The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4993

Received: 02/09/2021

Representation Summary:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.

Full text:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy, and to specifically take into account the sustainability of Bromham as a location that has and can continue to contribute to a sustainable pattern of development within Bedford Borough. Although it does not currently form part of the preferred strategy, there are sound planning reasons why the strategy should include growth in Bromham as explained below and in the representations to paragraph 3.17.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that rural population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
However, the key point here is that some villages are better related to Bedford town centre, the wider urban area, and have more sustainable travel options than other villages. To categorise all growth in the villages as having a major negative effect in relation to these SA objectives is inaccurate as some settlements are very close to the urban area with high levels of sustainable travel links to Bedford town centre, such as Bromham.
To put that point in context, Bromham is the largest settlement outside the urban area, and is the highest scoring settlement from the Council’s 2018 Settlement Hierarchy analysis (noting that a review is underway of this evidence). It is on the edge of the urban area, and is physically closer to Bedford Train Station and town centre (circa 5km) than other parts of the urban area. In fact, its proximity to the town centre and urban area means it arguably should be considered in the same development strategy option as areas that adjoin the urban area.
Not surprisingly given its status, services, and location, the current adopted strategy allocated a minimum of 500 new homes to the settlement during the Plan period to 2030. This strategy was informed by an evidence base that scored positively in relation to the SA, and therefore was found sound by the Inspector. Hence, Bromham is inherently a very sustainable location to accommodate growth.
However, the sustainability credentials of Bromham as a location for growth are not reflected in the generation of strategy options at 3.12. It only appears in two options which are realistic (namely 3b and 3c which include development in and around the urban areas). Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options.
Again, the appraisal of these two options (3b and 3c) in the Draft SA is skewed by the assumption that all growth in the villages is in locations where there is a greater need to travel and which is more likely to be by car. The specific merits of Bromham as a location where the need to travel is reduced and where there are sustainable travel options are therefore not captured in the current draft of the SA, and this is a significant omission.
The Topic Paper concludes on these two options that they do not perform as strongly compared to others with reference to highway constraints on the A6 north of Bedford, the need to allow villages to assimilate already planned growth, and the loss of focus on EWR.
In response, Bromham as a location would not impact the A6 north of Bedford as traffic routes to Bedford and the M1 via the A4280, A428 and A422. This would therefore not be a constraint to growth at Bromham.
Planned growth at Bromham within the Neighbourhood Plan is likely to be delivered early in the Plan period, and thus there will be a lengthy period of time during the Plan period within which development could come forward. There is no evidence to suggest Bromham needs such a lengthy period of time to assimilate planned growth, nor that the benefit of any period would outweigh the need for Bromham to contribute to a sustainable pattern of development and meet needs arising from the urban area.
More fundamentally, however, this is a new Local Plan, covering a longer Plan period to 2040, and having to address a minimum of a circa 33% increase in its housing requirement per annum and an almost four fold increase in the number of dwellings to allocate. Whilst it is legitimate to have regard to the distribution of existing commitments when considering its strategy, the Plan cannot ignore settlements that should continue to contribute to a sustainable pattern of development in line with the policies of the Framework around sustainable transport and climate change (particularly in the context of a higher housing requirement).
Additional growth at Bromham of up to 345 dwellings (reflecting the capacity of Site ID 757 as discussed below) need not detract from a focus on EWR given the scale of housing need to be met across the Borough.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs.
Furthermore, and more fundamentally, it is requested that the Council reconsider the role of Bromham given its location on the edge of the urban area, its proximity to the town centre and Bedford train station, and its sustainability credentials. The scale of growth that could be accommodated at Bromham need not challenge or threaten a strategy focussed on the urban area and rail based growth, but complement it in identifying deliverable sites in a sustainable location that can boost supply to meet the higher housing requirement.
For the avoidance of doubt, these representations are not suggesting all Key Service Centres should accommodate further growth of 500 dwellings as assessed in the Options. Our representations are that deliverable sites in sustainable locations around villages near the urban area, should contribute to boosting supply in the early part of the Plan period to meet the new housing requirement. Bromham is unique given its close relationship to the urban area of Bedford and the town centre and train station, and there is a strong case for this settlement to form part of the final preferred strategy (either recognised on its own, or recognised as part of the wider urban area).
Rainier Developments would draw your specific attention to land south of Northampton Road, Bromham (ID 757) as a suitable site that would complement the strategy.
The site adjoins the settlement boundary, and is enclosed by built development (existing and committed) on two sides to the east and south, and by the road network (Northampton Road and A428) to the north and west. Built development also exists at Chestnut Avenue to the north of Northampton Road.
Its development would therefore be restricted by physical features, and would represent a logical rounding off of the settlement within the confines of the built form and complimenting the committed site to the south at Beauchamp Park. The site was previously identified as a ‘preferred site’ and considered as a reserve site by the Parish Council in its preparation of its Neighbourhood Plan. It is fair to say that the site is recognised as the next logical allocation for residential development in the settlement.
There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning. Taking these into account, the site has capacity for approximately 345 dwellings.
The development of the site would clearly make an important contribution to housing supply, including affordable housing at 30% (circa 100 dwellings). This is significant given it has been resolved that the undetermined outline planning application (19/01904/MAO) at Beauchamp Park will only provide 15% affordable housing, resulting in a shortfall of supply (circa 60 affordable dwellings) against the level expected to be delivered to meet the significant affordable need within the area during the Plan period. There are other environmental benefits, including biodiversity net gain and an extension to the Bromham Heritage Trail through new areas of open space. There will also be economic benefits in terms of jobs generated from the construction phase, and an increased population supporting the viability of services and facilities within Bromham, and nearby Bedford.
The site benefits from good access by sustainable modes of travel to facilities within the village as demonstrated previously within the Vision Document, as well as nearby Bedford. There is capacity within those facilities, particularly the local school which at present is 3 Form Entry but has the capacity to expand to 4 forms of entry as explained in the Neighbourhood Plan and agreed with the Local Education Authority. There is therefore capacity to accommodate additional spaces to meet demand arising from the development of Site ID 757 within the local school which is the preference of the Parish Council.
Separate representations have been made in response to the Site Assessment Consultation on Site ID 757.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5003

Received: 02/09/2021

Representation Summary:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy.

Full text:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
The suitability of Roxton to accommodate modest growth is recognised within the Options identified within the Topic Paper, forming part of Option 2d, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options). Although Option 2d is not considered the best performing option in the Sustainability Appraisal, dispersing housing growth over a wider area than Option 2a has the advantage of enabling the housing requirement to be met earlier in the Plan period. That will have significant economic and social benefits.
Whichever option or mix of options is carried forward as the preferred strategy, villages like Roxton need to accommodate modest growth (i.e. an additional circa 50-75 dwellings) over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs, particularly as it will help to ‘top-up’ the housing requirement during the early part of the Plan period.
Rainier Developments would draw your specific attention to land off Bedford Road, Roxton (ID 776) as a suitable site that would support the delivery of the strategy in contributing circa 70 dwellings towards meeting the housing requirement and affordable housing need. The site adjoins the settlement boundary, is closely inter-related with the physical form of development, and is enclosed by the Bedford Road to the north. There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning.
Separate representations have been made in response to the Site Assessment Consultation on ID 776.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5016

Received: 02/09/2021

Representation Summary:

The suitability of Wootton to accommodate growth is recognised within the Options identified within the Topic Paper, forming part of Option 2a, 2b, 2d, 3b, 3c, 4, 6, and 7. Whichever option or mix of options is carried forward as the preferred strategy, villages like Wootton need to accommodate growth over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.

Full text:

The Council are requested to reconsider its development strategy options to take into account the requirement for growth within villages in accordance with national policy.
Village related growth (all Key Service Centres and Rural Service Centres) has been defined as one component of growth (paragraph 3.4), and assessed in the Draft SA as one option on that basis (page 66). The Draft SA scores major negatives for village related growth in relation to reducing emissions of carbon dioxide/improving energy efficiency, promoting town centres, and reducing the need to travel/promoting sustainable travel (summarised at paragraph 3.7).
Before considering these specific matters further below, the point needs to be made that national policy requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services and maintain the vitality of rural communities (paragraph 79 of the NPPF). It has to be acknowledged that a third of the population of the Borough live in the rural area, and that population will have housing and economic needs over the Plan period that need to be met locally.
A no growth option for the villages is not consistent with national policy, or ‘sound’. Nor is it consistent with the emerging Vision for the Borough which sees the villages accommodating development in order to provide and support much needed housing, and rural facilities and services.
In response to the Draft SA, the assumption that future growth in villages will have a negative effect on reducing emissions is seriously questioned in the context of the transition to electric vehicles during the lifetime of the Plan. Further, the role and nature of town centres is already changing, and will continue to evolve through the lifetime of the Plan as residential uses are introduced. Their vitality and viability are being, and will continue to be impacted by much wider considerations than the location of new homes.
The suitability of Wootton to accommodate growth is recognised within the Options identified within the Topic Paper, forming part of Option 2a, 2b, 2d, 3b, 3c, 4, 6, and 7 (although Options 4, 6 and 7 do not include any growth in and around the urban areas, and therefore appear unrealistic as options).
Whichever option or mix of options is carried forward as the preferred strategy, villages like Wootton need to accommodate growth over the remainder of the Plan period to continue to grow and thrive to 2040. Such a strategy would not detract from the urban and rail-based growth focus.
It is acknowledged that the Council intend to do further technical work to inform its final preferred strategy for the Plan. In moving forward, it is recommended the Council recognise that all villages have a role to play in meeting future housing needs where it supports local services and meets local needs.
Rainier Developments would draw your specific attention to land south of Keeley Lane, Wootton (ID 760/771) as a suitable site that would support the delivery of the strategy in contributing circa 50 dwellings towards meeting the housing requirement and affordable housing need. The site adjoins the settlement boundary, is closely inter-related with the physical form of development, and is proposed in part to be allocated within the emerging Wootton Neighbourhood Plan. There are no physical constraints that render the site unsuitable for development, and all environmental features of interest can be accommodated through careful masterplanning.
Separate representations have been made in response to the Site Assessment Consultation on ID 760/771.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5445

Received: 03/09/2021

Representation Summary:

If the propsed development for an additional 2500 to 10000 homes must proceed the most sustainable and suitable options are;
Option 2a
or
Option 2b provided that the site a Little Bardford is used with NO development at the Wyboston site

The Wyboston site has mistakenly been badged as rural when it most clearly is a RURAL location of high quality agricultural land.

Little Barford is an urban location close to the station with superior transport links.

Bushmead road is too narrow for current traffic. There is a 20mph speed limit for the school so increasing traffic must be avoided.

Full text:

If the propsed development for an additional 2500 to 10000 homes must proceed the most sustainable and suitable options are;
Option 2a
or
Option 2b provided that the site a Little Bardford is used with NO development at the Wyboston site

The Wyboston site has mistakenly been badged as rural when it most clearly is a RURAL location of high quality agricultural land.

Little Barford is an urban location close to the station with superior transport links.

Bushmead road is too narrow for current traffic. There is a 20mph speed limit for the school so increasing traffic must be avoided.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5878

Received: 08/09/2021

Representation Summary:

aragraph 1.28 Development Strategy Topic Paper
We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date.
The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.
Paragraph 1.33 Issues and Options Consultation Summary and Responses
We have no specific comments to make in relation to the Issues and Options Consultation Summary and Responses. However, we would note – in support of our comments in relation to the Development Strategy Topic Paper – that a number of respondents at Issues and Options stage made reference to the need for more and/or different combinations of strategy options to be considered.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5919

Received: 08/09/2021

Representation Summary:

The comments for Options 2b, 2c and 2d FAIL TO IDENTIFY the negative issues arising from the inclusion of new settlements, i.e.:
• Greener: The loss of high quality agricultural land for Wyboston/Dennybrook is not identified. The negative impact on air quality because of the greater need to travel by private car is not identified (but is for the same settlements in options 3a, 3b, 3c, 5 and 6).
• More accessible: The fact that Wyboston/Dennybrook is not a development near to a rail station is not identified. It is not recognised that the dispersal of growth to new settlements is likely to increase the need to travel and trip lengths significantly. This is unlikely to be by walking, cycling or public transport meaning that there is likely to be a significant increase in private car use. But this is identified for the same settlements in options 3a, 3b, 3c, 5 and 6?
• More Prosperous: The fact that Wyboston/Dennybrook is 12 miles from Bedford and its residents will use St. Neots to the detriment of Bedford fails to be recorded. A bland statement of “The effect on town centres is uncertain.” is insufficient. Yet for the same settlements options 5 and 6 note that “Town centres will not benefit as the benefits of growth are dispersed away from the urban area.”
I can only conclude that the summary comments in this table are MISLEADING in respect of options 2b, 2c and 2d. If these have informed the strategy for these options to become BBC’s emerging preferred options, then BBC need to URGENTLY RECONSIDER their emerging preferred options.
3.28 and 3.29 High level transport conclusions:
As noted in items 1.23-1.27 (AECOM transport models) above the conclusions in these two paragraphs are seriously FLAWED, notably, inter alia, as follows:
• The model significantly underestimates the numbers of vehicles leaving the Wyboston/Dennybrook development in the AM peak hour. The conclusion in 3.28 that “…the forecast impacts of the proposed development at Dennybrook are not significant in terms of generating additional delays and congestion on the highway network.” is INCORRECT and cannot be relied upon.
• The note in 3.28 that “Twinwoods and Colworth – the assessment highlighted significant forecast delays and congestion at the Clapham Road / Manton Lane roundabout to the north of the Bedford urban area, particularly in the PM Peak hour (17:00 to 18:00), both with and without the proposed mitigations which is an issue for both developments as the modelling shows up to six minute delays at this junction.” is an INCORRECT SUMMARY. THIS ISSUE ARISES IN THE 2030 REFERENCE CASE with the developments allocated in the current Local Plan and planned highways mitigations, before any new developments (e.g. Twinwoods and Colworth) are considered. When they are considered they add little to the congestion at this junction. A solution to this junction congestion issue needs to be found by BBC by 2030, irrespective of any local plan 2040 proposals by developers north of Bedford on the A6.
• The resulting conclusions at 3.29: “The main area where additional mitigation is not identifiable is on the A6 approach to Bedford from the north. In the absence of currently deliverable railway stations at either location which might make an impact, the capacity issues here are too great to allow further development on the A6 (north) corridor such as the new settlements proposed at Twinwoods and / or Colworth.” ARE INCORRECT. This is a 2030 issue that BBC have to solve, irrespective of any local plan 2040 proposals by developers north of Bedford on the A6.
I can only conclude that these conclusions are MISLEADING and if these have informed the strategy for the dismissal of developments north of Bedford and the selection of BBC’s emerging preferred options, then BBC need to URGENTLY RECONSIDER their emerging preferred options.
THE ABOVE ISSUES HAVE BEEN CARRIED FORWARD INTO THE CONCLUSIONS AND RECOMMENDATIONS IN PARAS 3.32 TO 3.41, AND THEREFORE THESE ARE INVALID AND NEED TO BE REASSESSED.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6072

Received: 09/09/2021

Representation Summary:

4.1 The settlement of Great Barford was included in many of the options (2d, 3b, 3c, 4, 6, and 7) in the Issues And Options Consultation June 2020, with many of the options allocating 500 dwellings to the settlement in the next plan period; with option 2d identifying some growth to the area but no specifics.

4.2 As Great Barford is only now included in one of the four options being consulted upon – Option 2d, we must raise objection and highlight that the exclusion of strategic growth of Great Barford is a missed opportunity; and that the reasoning given in the sustainability appraisal for discounting this level of growth are considered superficial and indicate an underlying bias towards urban centric growth.

4.3 It is important to note that many of the options were not discounted due to issues with allocating growth to Great Barford itself, but because there are considered to be issues with the overall strategy in those particular options. For example, Option 7 was discounted because the required level of growth cannot be achieved. It is therefore crucial that Great Barford is not discounted as a suitable settlement for growth simply because it happened to be one element of an overall strategy in options which are considered to be less desirable. We would strongly contend that the sustainability credentials of Great Barford should be considered on its own individual merits.

4.4 Great Barford is a Key Service Centre and a sustainable settlement in a major strategic location on the Oxford To Cambridge Arc. It is an ideal location for delivering further strategic growth in this Local Plan Review. Countryside are delivering other strategic sites within the Oxford to Cambridge arc such as at Bourn airfield (3500 new homes) and have experience of working with a range of stakeholders to address cross boundary matters.

4.5 Option 2d in the consultation is the only option which includes all of the A421 corridor on the Oxford To Cambridge Arc. Given the Government’s objectives for the arc and the strategic importance of this location, and the fact that Great Barford is the most sustainable settlement in the eastern parishes, it is considered crucial that it be included in the final strategy taken forward

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6341

Received: 10/09/2021

Representation Summary:

We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date.
The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
.
Please use a separate form (this page) for each consultation document paragraph, policy or evidence base document you are commenting on.
Which paragraph number, policy number or evidence base document are you commenting on?
Please add your comments in the box below, and continue on an additional sheet if necessary.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.
Paragraph 1.33 Issues and Options Consultation Summary and Responses
We have no specific comments to make in relation to the Issues and Options Consultation Summary and Responses. However, we would note – in support of our comments in relation to the Development Strategy Topic Paper – that a number of respondents at Issues and Options stage made reference to the need for more and/or different combinations of strategy options to be considered.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7048

Received: 17/09/2021

Representation Summary:

We raise a number of concerns in relation to the Development Strategy Topic Paper.
As an overarching observation, this Topic paper is one of the key evidence base documents underpinning the Local Plan 2040. It is vital for the success of the plan, both in terms of being found sound and also delivering sustainable development, that the chosen development strategy is the most appropriate when considered against the reasonable alternatives, based upon a proportionate evidence base.
In this respect it is firstly highly material to identify that development strategy options are being developed at a time when the evidence base has not been prepared. In particular, a review of the settlement hierarchy is underway but no draft findings have been prepared to inform development strategy. In addition, and perhaps more concerning, there is no Infrastructure Delivery Plan as yet. As a result, there is nothing in the evidence base to identify what constraints or opportunities exist in relation to infrastructure, and flowing from this, development strategy options cannot have regard to whether option(s) being considered are justified and effective (deliverable). Furthermore, the absence of an Infrastructure Delivery Plan is such that development strategy options cannot be prepared to assist in addressing current infrastructure deficiencies, which might include reasonable options which have been ‘closed out’ prematurely absent of any knowledge of infrastructure opportunities.
This is an important sequencing point and we strongly recommend that no further work be undertaken on development strategy options until such time as an Infrastructure Delivery Plan is drafted and available for review and comment.
We would also raise significant concerns in relation to the ‘optioneering’ process that has been undertaken to date.
The Development Strategy Topic Paper attempts to explain how the various elements have come together to create a series of options, and how those options have then been assessed. However, the methodology and the way it has been explained is confusing, there is overlap between different elements of the assessment, and the options considered are not sufficiently wide to allow for a meaningful consideration of the positive and negative outputs of each option.
.
Please use a separate form (this page) for each consultation document paragraph, policy or evidence base document you are commenting on.
Which paragraph number, policy number or evidence base document are you commenting on?
Please add your comments in the box below, and continue on an additional sheet if necessary.
By way of example, the common themes we take from the Development Strategy Topic Paper are that urban growth tends to perform well, and that new settlements perform poorly against a range of assessment criteria. It is not clear, in this context, why options in relation to village growth have been linked to new settlements assessed as a combination rather than discretely. Inevitably when village growth options are tied to new settlements the assessment will be less positive when it is acknowledged that new settlements generally perform poorly. The result is the unjustified down scoring of villages as a development strategy option.
We strongly suggest that the villages be assessed on their own, and if a further option assessing the villages with new settlements is to be taken forward then further options assessing the villages with the urban area should be assessed.
Paragraph 1.33 Issues and Options Consultation Summary and Responses
We have no specific comments to make in relation to the Issues and Options Consultation Summary and Responses. However, we would note – in support of our comments in relation to the Development Strategy Topic Paper – that a number of respondents at Issues and Options stage made reference to the need for more and/or different combinations of strategy options to be considered.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7469

Received: 21/09/2021

Representation Summary:

5.5 It is clear that the Bedford Business Park proposals have the potential to deliver substantial social, economic and environmental benefits for both Bedford and the wider region.
5.6 Due to the nature of the proposals and the opportunity presented, there has been a significant amount of market interest in the site for employment uses. It is envisaged that the provision of much needed high quality employment space in this location will be attractive to both new businesses relocating to the area and existing local businesses looking to grow. This includes large scale industrial and logistics occupiers, advanced manufacturing and research and development companies which are increasingly seeking high-spec new build premises, rather than second-hand stock. SEMLEP has confirmed that Cloud Wing’s proposals fit well with the strategic economic vision for the area (Appendix 1).
5.7 Furthermore, due to the unique scale and locational characteristics of the site, there is potential to capture regional and national opportunities that would not be possible on a smaller site. Indeed Cloud Wing has been approached by SEMLEP and the DIT to explore the potential for the site to accommodate an EV Gigafactory to support the Country’s transition to electric vehicles which would deliver significant high-quality employment opportunities for Bedford and secure major international investment in high-tech manufacturing.
5.8 It is also being explored whether the site might be well-placed due to its size and location to contribute to the wider modal shift of logistics from road to rail through rail freight opportunities being promoted by the NIC. This modal shift is being driven by wider challenges facing the UK’s freight system including decarbonisation, congestion and how technological advancements can assist in meeting increasing societal demands. The role of rail freight in addressing these challenges has recently been endorsed by the Government in its response to the NIC’s Report ‘Better Delivery: A Challenge for Freight’ which confirms that the ‘Future of Freight’ Strategy is due to be published by the DfT later this year.
5.9 This therefore demonstrates the substantial benefits and opportunities afforded by the Bedford Business Park, which will not only boost local job creation and economic growth, but provide the ability for Bedford to contribute to, and benefit from, national growth objectives and opportunities, shaping Bedford’s identity as a new hub of prosperity at the heart of the Arc.
6.45 The PPG states that a site is: “considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.46 Cloud Wing control the site and therefore there are no legal ownership or other technical impediments to delivering development on the site.
6.47 Furthermore, the site is being actively promoted for economic development and is the subject of an outline planning application currently pending determination.
6.48 Accordingly, the site is available now in NPPF terms.
Availability
“considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.49 As per the NPPG, a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in term, including an assessment of the economic viability of a site.
6.50 Given the scale of development proposed for the site, the development will be delivered over several phases. This will include ground remediation works and the delivery of transport infrastructure in the first phases, as set out below:
Achievable
Phase 1 – ground remediation works in the location of the former Kempston Hardwick brickworks
Phase 2 – construction of bridge proposed over the railway line and main road infrastructure
Phase 3 – construction of employment uses in areas where no ground remediation works are required
Phase 4 – construction of employment uses on the former Kempston Hardwick brickworks location
Phase 5 – construction of employment uses in the south of the site.
6.51 Whilst the timings for delivery are dependent on achieving a planning permission and identification of a Development Partner, both of which are currently ongoing, it is anticipated that it would be possible to start on site with site clearance, remediation and enabling works within 6 months of receiving an outline planning permission, following the discharge of any relevant planning conditions. It is anticipated that works to deliver the primary infrastructure for the first phase would then commence approximately 6 months later, following the grant of reserved matters, with the aim of the first phase being complete and ready for occupation within 18 months. 6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
6.52 As set out above, there are no significant site constraints that might prevent development or make the development unviable.
6.53 Therefore, it is considered that the site is achievable for development as there is a realistic timeframe for development and there are no economic viability constraints that would hinder delivery.
Deliverability Summary
6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
Changes requested:
– That the Council recognise the substantial benefits and opportunities presented by the Bedford Business Park by identifying it as a proposed allocation in the emerging Local Plan.
– We request that the site is formally allocated for economic development within the emerging Local Plan and that the Site Selection Methodology be amended to better reflect the range of factors and key characteristics that are relevant for assessing the merits of employment land.
See 59 page attachment relating to Bedford Business Park.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7476

Received: 21/09/2021

Representation Summary:

Wilstead is a village of just over 1,000 houses and any further substantial development will completely alter the character of the village. We have recently completed a Neighbourhood Plan where villagers were consulted and the overwhelming response to further development was that it was not appropriate for Wilstead (especially as we have the Wixams development less than a mile away). There needs to be a distinct gap between the village and Wixams to prevent the two communities becoming merged; this is also necessary to preserve the two separate identities. Wilstead’s development in the past has been of a stretched ‘ribbon development’ form and traffic is an ongoing problem. Much further development would increase these traffic problems with both Cotton End road and Bedford road already experiencing speeding and congestion at busy times, such as the school closing time.

The facilities in the village are not suited to much further expansion, for example the primary school is oversubscribed, and the bus service only covers part of the village. The village has already agreed to accept development of 105 houses as its contribution to the current local plan; this is an increase of over 10% and this will already threaten or overwhelm local facilities such as village primary school and the secondary school at Wixams, both of which are already oversubscribed. Also, there is only one small shop and a pharmacy that is not open all the time, with no easy public transport to access GP or medical facilities. All of these reasons mean the village is not appropriate for more large scale ‘estate style’ developments that do not bring any benefit to the community (as they predominantly house commuters who do not have the time to engage with village activities.

A key question to be asked of the Borough’s Local Plan is why is there not more sharing of the development in both north and south Bedfordshire? Wilstead appears to be chosen because of its proximity to an existing large-scale development in the form of Wixams. Further large scale development would put too much pressure on a village that already requires considerable volunteer effort to transport villagers to and from hospitals and GPs (the Wilstead Good Neighbours Scheme)!

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7574

Received: 21/09/2021

Representation Summary:

I object to the proposed building of additional houses in Wilstead on the grounds that wilstead has already been spoilt by too many recent developments. Other parts of Bedford (in particular North) seem to be excluded from the plan to build more houses.
It is very important that wilstead remains a rural village any major increase in the number of houses over a relatively short period of time, would completely alter the character of the community.
Wilstead should not have been designed as a Key Service Centre. The scoring methodology originally used to determine this must be re-assessed. The village no longer has a weekly doctor’s surgery. The one Post Office and General Stores represented 20% of the overall score and the Chemist no longer has a convenience store. Similarly the village is quoted as being on a bus route to and from Bedford. A large proportion of the village is located more than 800 meters from the nearest bus stop and there is no longer any service down Cotton End Road (except once on one day a week)
In addition, the local Primary School is full to capacity and cannot take further pupils. It was hoped that secondary education would be available at Wixams Academy, but this is already at capacity without additional houses being built in either Wixams or Wilstead.
There are villages in the Borough that are not being proposed for any development. A 10% increase in housing for each village would be much more equitable. The Borough Council could also allocate more houses to larger villages who have expected capacity in terms of school places and so could take more development. There are also villages which have greater facilities such as GP surgery and more local shops.
Some of the development put forward after the Call for Sites would be in direct flow of water draining form the Southern escarpment and some would be partly on a floor plan – existing ditches cannot cope already.
The increase in traffic from any development would result in even more congestion outside the school and in Whitworth Way – areas which are already dangerous at school opening and closing times. It would also put undue strain on other existing narrow roads.
Wilstead should not have to contribute to the Borough Plan.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8832

Received: 29/09/2021

Representation Summary:

RESPONSE TO DEVELOPMENT STRATEGY TOPIC PAPER
4.1 The settlement of Sharnbrook was included in many of the options in the Issues And Options Consultation June 2020 – options 3b, 3c, 4, 6, and 7. All of these options allocated 500 dwellings to the settlement in the next plan period.

4.2 We must raise objection and highlight that the exclusion of strategic growth in this part of the Borough is a missed opportunity; and that the reasoning given in the sustainability appraisal for discounting this level of growth are considered superficial and indicate an underlying bias towards urban centric growth.

4.3 It is important to note that many of the options were not discounted due to issues with allocating growth to Sharnbrook itself, but because there are considered to be issues with the overall strategy in those particular options. For example, Options 4 and 6 were discounted primarily because they do not include any development in the urban area which the Sustainability Appraisal identifies to be the most sustainable location. Most of these options also include the delivery of two new settlements, two of which are proposed off the A6. However, the transport modelling has found that the A6 does not have sufficient capacity to accommodate this scale of development, and yet does not address whether smaller scale growth, such as 250 dwellings at Sharnbrook, could be accommodated.

4.4 It is therefore crucial that Sharnbrook is not discounted as a suitable settlement for growth simply because it happened to be one element of an overall strategy in options which are considered to be less desirable. We would strongly contend that the sustainability credentials of Sharnbrook should be considered on its own individual merits.

4.5 Sharnbrook is a Key Service Centre and a sustainable settlement in the North of Bedford Borough and is an ideal location for delivering further growth in this Local Plan Review. We would therefore contend that deliverable sites in Sharnbrook be considered on their own merits, and that a more targeted analysis of impact is undertaken.

4.6 The site at Hill Farm, Mill Road has been independently assessed as part of the Neighbourhood Plan process, and the site has been considered as sustainable and suitable to accommodate the expansion of the village. Its development avoids the constraints found within or to the west of the village, and within the Strategic Environmental Assessment, performed strongly in respect of the potential effects on ‘Biodiversity’, the ‘Historic Environment’, ‘Landscape’ and ‘Transport’.

4.7 The Examination into the Sharnbrook Neighbourhood Plan has now been completed with the Examiner concluding at paragraph 4.12 of her report:

“I have considered the results of that [Regulation 16] consultation together with the evidence on the site assessment process and the SEA. I find that the decision of the SPC to allocate Site 901, land at Hill Farm, Mill Road is soundly based.”

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 9002

Received: 01/10/2021

Representation Summary:

Growth Strategy Options
2.1 The 2040 Local Plan consultation document sets out the level of housing growth required in
Bedford Borough and the emerging preferred growth strategy options to meet growth needs
within the Plan period. It states that 25,500 homes are required over the 20-year Plan period
from 2020 to 2040, and that as a result of existing commitments totalling 13,000 homes, the
new Local Plan will need to allocate land for a minimum of 12,500 new homes.
2.2 There are four emerging preferred options forming the spatial strategy to meet this growth.
These are:
• Option 2a: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth.
• Option 2b: Development in and around the urban area, plus A421 transport corridor with
rail-based growth and southern parishes growth, plus one new settlement.
• Option 2c: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, plus two new settlements.
• Option 2d: Development in and around the urban area, plus A421 transport corridor with
rail-based growth, southern and eastern parishes growth, plus one new settlement.
(emphasis added)
2.3 Of the four growth options currently being consulted on, three include the provision of at least
one new settlement. The new settlement options that have been selected at this stage are:
• Little Barford – 3,085 dwellings; and
• Wyboston – 2,500 dwellings.
2.4 The inclusion of one new settlement as part of the growth strategy (options 2b and 2d) would
provide c.20-25% of the housing allocations required over the Plan period. If two new
settlements were included (option 2c), these would provide c.45% of the growth required. This
represents a significant proportion of proposed development across the Borough over the 20-
year plan period.
Growth in Huntingdonshire
2.5 The 2040 Local Plan consultation document shows that both new settlements are located on the
eastern edge of the Borough, in close proximity to the administrative boundary of BBC’s
neighbouring authority Huntingdonshire District Council (HDC). Where new development is
proposed adjacent or near to the boundary with other local authorities, it is important that the
combined effects are taken into account. The location of the new settlements therefore raises
questions around the impact on Huntingdonshire and whether the evidence base has adequately
considered the infrastructure requirements and transport mitigation that may be required to
support these growth strategies, as per the NPPF paragraph 24 and the duty to cooperate.
2.6 At this point, it is important to look at the strategy for development within Huntingdonshire.
The District’s new Local Plan adopted in May 2019 (the HDC Plan) sets out that around 75% of
housing will need to be focused in the spatial planning areas, which are defined as Huntingdon,
St Neots, St Ives and Ramsey. A central part of the Plan strategy is development in ‘Strategic

Expansion Locations’ which offer opportunities that are unprecedented in the District for
sustainable development. One of these locations is the growth of St Neots East.
2.7 Policy SEL 2 details the expansion of St Neots East, which allocates 226ha of land for mixed-use
development including, but not limited to, 3,820 homes (3,265 in the plan period) and 22ha of
employment. Combined with additional allocations for 220 homes within St Neots, this growth
equates to over 17% of the District’s allocated housing requirement. The plan below shows the
cumulation of the two new settlement locations in Bedford and the allocation of St Neots East in
HDC.
Figure 2.1 Location plan of St Neots East, Little Barford and Wyboston new settlements relative to St Neots
Source: Lichfields
2.8 With significant development already proposed in this location, it is particularly important that
the cross-boundary implications of the new settlements at Little Barford and Wyboston are
taken into account. A review of the documents submitted for the HDC Plan shows that the
Council liaised with BBC during the preparation of the Plan, and that BBC stated they were
happy with the relationship between St Neots, development south of the A428 in Bedford
Borough (where Little Barford is located) and green infrastructure corridors traversing the
boundary1. It is also noted that HDC specifically clarified with Central Bedfordshire Council
(CDC) that they had no outstanding concerns regarding the expansion of St Neots East2.
2.9 In this context, the following section discusses the evidence base supporting BBC’s consultation document to see if the cross-boundary implications have been adequately considered, as they were by HDC.
The Evidence Base
Bedford Borough Transport Model Local Plan Assessment Summary Report
2.10 This document has been used to inform the Plan making process and provides a summary of the likely effects of four potential development/spatial scenarios on traffic flows in Bedford Borough. More detail on our review of this report and associated model runs can be found in Section 3.0 of this consultation response. It provides a high-level comparison of the scenarios looking at several key transport metrics and identifies the mitigation measures required for each scenario.
2.11 ‘New settlement-focused growth’ was one of the four spatial scenarios tested in the transport model, which focused on providing growth through the creation of one or more new settlements in the Borough. Figure B.3 of the summary report shows that this scenario is based on the four new settlement proposals put forward as part of the 2020 call for sites. This includes Colworth (2,400 homes), Twinwoods (3,495 homes), Wyboston (2,500 homes) and Little Barford (3,085 homes).
2.12 Notably, the four scenarios tested within the assessment are all discrete, and are not considered in combination with one another. For instance, the transport assessment considers ‘urban-focused growth’, ‘infrastructure-focused growth’ and ‘new settlement-focused growth’ as three separate scenarios, whereas the emerging preferred options are a combination of these. The highway impact of the emerging preferred options is therefore unclear in this regard.
2.13 In terms of the effect on traffic beyond the Borough, one of the key transport metrics analysed is ‘cross-boundary impacts’. This is the forecast of vehicle volume to road capacity, measured at junctions outside of Bedford Borough. While this metric could provide a valuable insight into the impact of the proposed new settlements on traffic outside of the Borough, the outcome is limited for two reasons.
• Firstly, the results for the ‘new settlement-focused growth’ scenario reflect the combination of all four new settlements listed above, and not just the two (Wyboston and Little Barford) that have now emerged as the preferred locations. This extends to the assessment of transport mitigation; the ‘cross-boundary impact’ is forecast to neither improve or worsen with the inclusion of mitigation measures, but this includes the mitigation required to support all four new settlements.
• Secondly, the results are intended to present the forecast scale of change between the four development scenarios, highlighting the relative performance of the scenarios and not the absolute performance. For the ‘cross-boundary impact’ metric, the data analysed the number of nodes (junctions) where the volume-capacity ratio exceeded 85% (the threshold for which congestion becomes apparent) and varied significantly (over 5%) across the four growth scenarios.
2.14 As a result of this two-factor approach, the results do not truly reflect the impact on congestion outside of the Borough.
2.15 We acknowledge that more in-depth transport assessments have been carried out which analyse the Little Barford and Wyboston new settlements both alone and in combination. However, while these do appear to analyse the impact on the highway network outside of the Borough,
they are not explicit in terms of the impact on neighbouring authorities or the cross-boundary mitigation required to support the proposals.
(Draft) Sustainability Appraisal Report
2.16 An essential part of the evidence base, this document sets out the sustainability appraisal framework and sustainability objectives for the emerging 2040 Local Plan. The draft report provides an appraisal of the likely social, economic, and environmental effects of each growth strategy option put forward in the process of Plan preparation and concludes that the four emerging preferred growth options (2a to 2d) are the best performing overall.
2.17 Throughout the appraisal of each spatial option, there is not a clear consideration of the sustainability impacts on neighbouring authorities. The only point that categorically discusses the wider social, economic and environmental impact outside of Bedford relates to the objective to ‘promote vital and viable town centres’; the comments for spatial options including a new settlement state that residents might visit competing town centres outside of the Borough if these are nearer or easier to visit with improved transport links.
2.18 Further, the assessment states that locating growth in new settlements is still likely to increase the need to travel and length of trips to ‘the urban area’, which is where most services, facilities and employment opportunities will remain located. Here, the urban area refers to Bedford only and not nearby settlements beyond the Borough boundary which are geographically closer to the two new settlement proposals.
2.19 The lack of consideration around the potential cross-boundary impacts on Huntingdonshire (or any other neighbouring local authority) within the report may be due to the fact that there is no specific reference to this within the fifteen sustainability appraisal objectives. It appears that this matter has been somewhat neglected, and that the sole focus of the appraisal is on the effects within Bedford. It is therefore questionable whether the sustainability appraisal is sufficiently robust in justifying the preferred growth options; strategic discussions between neighbouring authorities is essential to the delivery of sustainable development (e.g. sustainable transport links).
Development Strategy Topic Paper
2.20 It is a requirement of the Plan-making process that Plans are tested to ensure their deliverability. This document provides a deliverability assessment of the development strategy options that have been considered so far in the preparation of the new Local Plan, in particular why options 2a, 2b, 2c and 2d have emerged as the preferred options for inclusion in the consultation document.
2.21 The deliverability analysis of each option is high level only. This is due to the absence of more detailed work, including a full infrastructure delivery appraisal, Plan wide or site-specific viability appraisals and detailed transport modelling. For each option, the key strengths and weakness are identified as a basis for determining whether, in delivery terms, there is a case for them to be selected as preferred options.
2.22 Throughout the analysis, there are only two parts that touch on wider cross-boundary implications. First, in assessing option 2a, one of the delivery challenges identified is that “substantial development has already taken place on the edge of Bedford. Further outward spread runs the risk of coalescence with nearby settlements”. However, given that option 2a focuses growth around the urban area and southern parishes, this only relates to settlements south of Bedford, such as Wootton, Stewartby and Marston Moretaine. It is of concern that this is thought to be a strategic delivery issue for this growth option, but not for others proposing a
new settlement on the eastern edge of the Borough, given that these pose a greater risk of coalescence with St Neots.
2.23 For options 2a to 2d (the emerging preferred options), a strength is identified as the ‘opportunity to establish a new planned community at Wyboston or Little Barford in proximity to the proposed EWR station at St Neots / Tempsford’. It therefore acknowledges the proximity of the proposed new settlement options to existing areas within Huntingdonshire; however, it does not then consider the cumulative impact of this on the neighbouring local authority as a weakness. This appears to be one-sided, disregarding the cross-boundary impact as a delivery challenge.
2.24 Taking the two points above together, the deliverability analysis is therefore inconsistent in its approach and does not represent an objective assessment of each option.
Issues & Options Consultation – Summary and responses
2.25 This document summarises responses to the 2020 Issues and Options consultation. In the comments received (not specifically attributed to any party), concern was expressed about the impact of growth on communities and infrastructure beyond the Borough boundary (particularly around St Neots), and that cross-boundary discussions should continue through the Duty to Co-operate. Other respondents also felt that the cumulative impact on infrastructure is important and therefore cross-boundary master-planning may be an option. The Council’s response does not provide a clear and reasonable answer to these concerns.
Cooperation with Huntingdonshire
2.26 As set out above, a review of the evidence base supporting the consultation document indicates that the location of the proposed new settlements adjacent to Huntingdonshire has not been adequately assessed. Overall, it does not provide a clear justification demonstrating that there will be no significant adverse impacts on the neighbouring Authority in terms of deliverability, highway mitigation and infrastructure, and further evidence is needed to show that the proposed new settlements are achievable; significant investment in infrastructure may be necessary in order to deliver development in this area at scale.
2.27 National policy states that:
“Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary.” (NPPF Paragraph 26).
2.28 To demonstrate effective and on-going joint working, national policy requires strategic policy-making authorities to prepare and maintain statements of common ground documenting the cross-boundary matters being addressed and progress in cooperating to address these. The statements should be made publicly available throughout the Plan-making process to provide transparency (NPPF, Paragraph 27). They also form part of the evidence required to show that local planning authorities have complied with the Duty to Cooperate; this is a legal duty to engage constructively and actively with neighbouring authorities and other prescribed bodies in planning for strategic matters that cross administrative boundaries.
2.29 A Duty to Cooperate statement forms part of the evidence base for the adopted Bedford Local Plan 2030. While the adopted Plan does not include any proposals for new settlements, those put forward in the 2020 call for sites were consulted on throughout the Plan-making process. In the record of cooperation, one of the issues identified was that a new garden village at Wyboston would be adjacent to Huntingdonshire. The record goes on to state that should the Wyboston
proposal proceed, there will be a need for cross-boundary implications to be assessed by HDC and BBC and that ”the two Councils will continue to cooperate in respect of future new settlement proposals”.
2.30 Following this, we cannot find any evidence that further discussions are taking place with neighbouring authorities now that new settlement proposals in this area are being consulted on. For Plan-making, national planning practice guidance (NPPG) makes clear that councils are expected to document the activities undertaken during the process of addressing strategic cross-boundary matters, including working together at the outset of Plan-making and producing joint research. This is particularly important for new settlements, which typically constitute a significant proportion of growth over the Plan period, and even more so now in the context of the NPPF 2021 paragraph 22 and the need to develop a vision within which to set policies for larger scale development such as new settlements for a minimum of 30 years, ten years more than the emerging Plan period. The proposition for a new settlement at Wyboston is in excess of 10,000 new homes3, quadruple the emerging allocation figure of 2,500 and with a potential impact on Huntingdonshire which is significantly greater than that associated with just 2,500 homes. Little Barford has an emerging allocation for 3,085 homes, with its maximum potential set out as 3,385 to 3,955 in the site pro-forma4, which is more in line with the 2040 Local Plan.
2.31 It is therefore not clear that BBC is currently cooperating with HDC in assessing the cross-boundary impacts of the proposed new settlements at Little Barford and Wyboston. Such an approach is not in compliance with national policy. The Council needs to show that it is engaging with HDC to determine that the new settlements are deliverable over the Plan period and that they are based on effective joint working across the local authority boundaries. This evidence is also needed to provide communities and other stakeholders with a transparent picture of how they have collaborated.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 9063

Received: 12/11/2021

Representation Summary:

6.1. At the heart of the NPPF is a presumption in favour of sustainable development. Plans and decision should apply a presumption in favour of sustainable development. The NPPF explains what this means for plan-making with making effective use of land in urban areas at the heart of mitigating climate change stating that (our emphasis added):
"all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects”
6.2. Section 11 of the NPPF is called ‘Making effective use of land’. There are a number of important requirements set out in this section of the NPPF for plan-makers including the following:
• “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land”20
• “give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land”21
• “promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure)”22
• “Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.”
6.3. Given that the NPPF places such great weight and emphasis on the need to make the most effective use of previously developed land and land within settlements it is surprising how little the Draft Local Plan and its evidence have to say about how the Council intends to comply with the NPPF as part of its plan-making.
6.4. We note that the key point of the Issues and Options consultation was that urban based developed (along with A421 and rail-based growth) was the most strongly supported by consultees:
“The results are reported in full in the Issues & Options Consultation - summary and responses document and the key point was that the (brown) urban, (yellow) A421 and (pink) rail-based growth development locations were the most strongly supported and were twice as likely to be selected as suitable locations for growth as dispersed and new settlement based growth.”
“The most common combination put forward by respondents was urban (brown) with A421 (yellow).”
6.5. BBC’s Development Strategy Topic Paper explains that one of the five ‘components of growth’ it has tested is ‘within the urban area (sites within the urban area boundary)’. BBC explains that the Sustainability Appraisal (SA)concluded that the ‘within the urban area’ component performed the best of all of the potential components:
“In relation to the broad components of growth, the sustainability appraisal found that the within the urban area component performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth. The adjoining the urban area component performed almost as well as the within the urban area component and was better in relation to economic growth.”
6.6. BBC explains that following the SA work more detailed work was undertaken to generate specific strategy options based on different combinations of the broad components using the remaining housing target of 12,500 dwellings and employment land target of 123 hectares. BBC states that the assumptions had to be made about the capacity of each ‘broad location for housing and employment growth’ however this phrase ‘broad location’ is not explained elsewhere which is confusing. BBC explains that the capacity assumptions are informed not by the Council’s own work but simply through the quantum of development put forward through the call for sites process and that further testing will take place following this current consultation. This is a very important point that the Council has not undertaken any assessment of its own as to the potential development capacity of sites and locations in the borough. It is neglectful of BBC to even consider it possible to assess development strategy options let alone select a number of preferred options without having properly assessed site constraints, the realistic capacity of the sites or broad areas being promoted by developers and landowners.
6.7. Regarding the ‘urban component of growth’ BBC explains that given that it performs most strongly “the assumption for the urban and adjoining areas is deliberately ambitious” explaining that: “Development at scale in some parts of the urban area will be challenging and will require comprehensively master planned proposals and may require land assembly powers and significant investment in the infrastructure necessary in order to deliver the development”
6.8. In the following section of the Development Strategy Topic Paper it summarises the development assumptions for options generation with ‘sites within urban area’ showing 1,500 dwellings. BBC has confirmed to us that this assumption is not based on actual sites in the ‘urban area’ and only based on sites submitted to the Council so this figure is entirely unreliable and seems extremely low. BBC’s options that it tests include this 1,500 dwelling figure for the ‘within urban area’ component of growth for Options 1a, 2a, 2b, 2c, 2d, 3a, 3b, 3c and then show 12,500 for Option 1b. BBC rejects Option 1b as it states that it is “Theoretically possible to meet residential growth needs but the densities required would have unacceptable significant impacts”
6.9. How can BBC possibly come to this conclusion when it has not undertaken its own assessment of previously developed land and settlement capacity for Bedford and the other settlements? In terms of the other options it holds the ‘within urban area’ and ‘adjoining urban area’ at a constant of 1,500 dwellings for each component respectively. There is clearly no logic to the housing numbers and shows a serious lack of sensitivity testing of a range of potential urban and settlement capacity assumptions for the options generated by the Council. Clearly if the ‘urban’ and ‘adjoining urban’ components had higher capacity yields then they would form a greater percentage of the overall housing targets and result in less need for housing elsewhere in the borough including the new settlement options. The performance of any option with an increased urban capacity would increase in terms of its performance in the Sustainability Appraisal given that this is the most sustainable location for BBC to plan its future growth.

INCLUDES TABLE OF OPTIONS FROM P23 OF DEVELOPMENT STRATEGY TOPIC PAPER

6.10. We have so many questions that are left unanswered regarding BBC’s approach to assessing its urban and settlement capacity (and previously developed land) which we set out below:
• What does BBC consider to be the ‘urban area’?
• Does BBC only consider the urban area of Bedford town for its previously developed land capacity?
• Does BBC not consider previously development land in the other settlements in the borough apart from Bedford for its development capacity?
• The NPPF expressly requires that authorities need to make as much use as possible of previously developed and brownfield land in the borough – how can BBC demonstrate that it has made any material steps towards fulfilling this requirement?
• How has BBC taken into consideration the potential release of some of its employment sites for potential housing development? We note that there are at least 16 existing employment sites assessed as ‘monitor and manage’ in the Council’s Employment Land Review. Have these been assumed as part of the potential supply of land that could be identified and released for housing?

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