1.39

Object

Representation ID: 6595

Received: 14/09/2021

Respondent: Mr Aiden Farmer

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 6717

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6755

Received: 14/09/2021

Respondent: Ms S Kelly

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6807

Received: 15/09/2021

Respondent: Mr Damian Smith

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 6894

Received: 15/09/2021

Respondent: Master Corey T Farmer

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Support

Representation ID: 6986

Received: 16/09/2021

Respondent: Mr Robert Tusting

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 7025

Received: 17/09/2021

Respondent: Mr Robert Tusting

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.




c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 7049

Received: 17/09/2021

Respondent: Glenalmond Developments Ltd

Agent: Cerda Planning Ltd

We raise a number of concerns in relation to the Site Selection methodology Update.
As an overarching observation, we note that the 430 call for sites submissions have already been assessed against a range of criteria – we comment on the specific assessments in our response to the Site Assessment Pro formas.
These assessments go beyond a factual recording of the call for sites submissions, and apply an analysis on specific topics (for example in relation to heritage matters the Site Assessment Pro formas make clear that heritage matters could lead to a site not being allocated). Two important matters arise – firstly, site assessments are already underway when the site selection methodology is in draft form only and has not benefited from this current consultation exercise which should inform and refine the methodology process. Secondly, it is not clear how the assessments in the Site Selection Pro formas feed in/relate to the Site Selection Methodology and whether the assessments already completed are intended to be in addition to the site selection process to be undertaken, or are a substitute for some part(s) of the site selection process set out in the Site Selection Methodology Update.
Turning now to specific comments in relation to the content of the Site Selection Methodology Update.
Paragraph 7 sets out that there are 3 discrete assessments to be applied to each site. It is not clear whether this is intended as a sequenced assessment – such that a site must pass each of the three stages in turn before being taken forward to the next stage assessment – or whether the assessments are undertaken in combination/concurrently. The former would provide for a more transparent approach to site selection – if the latter then it is difficult to discern which elements of the assessment each site scored well against and which elements bear against a site.
Related to our point above, we raise concerns in relation to Paragraph 8 and the overarching approach to site scoring. It does not appear that there is any weighting being applied to each assessment criteria which we consider is unjustified. It could be the case, in a neutral scoring system, that a site fails the assessment because it includes land in FZ2 or 3 which is never intended to be built upon in the same way that a site fails the assessment because it has a substantial harm to heritage assets incapable of being mitigated. In such circumstances otherwise well performing sites are excluded from being considered for allocation. Conversely, by applying a weighting to the assessment enables a more refined and justified assessment reflective of the significance of the site constraints and opportunities.
Furthermore, in relation to Paragraph 10 it is not clear what role mitigation is to play in the assessment methodology. It is often the case that there are constraints weighing against a site that can be mitigated either in full or in part. It would not be appropriate for sites to be excluded from consideration for allocation without consideration being given to the extent of mitigation.
So far as the sustainability objectives – which are set out after Paragraph 10 – it is evident that a number of these cross over (for example 1b, 1c, 1d, 3c, 3d, 3e, 15a, 15b, 15c and 15d all deal with accessibility by foot). In such circumstances a site failing one question would fail all questions, and as a result would be scored more poorly than a site failing a single self-contained objective (such as 11a). This would be to misrepresent the site assessment, and a more uniform approach should be considered so as not to undermine the outcome of the assessment work.
Turning to Paragraph 11, here it is stated that the constraints known to the Council are rolled forward from the Allocations Plan. However, no cross check/re-assessment as to the relevance of the constraints is being undertaken, and as a result these constraints may no longer apply, apply to a lesser magnitude, or indeed be greater than as reported in the Allocations Plan. As such, a wholesale review is required rather than a simple roll forward.
For similar reasons, we raise concerns in relation to the provisions of Paragraph 12. This relates to education and appears to be a roll forward of the work undertaken in relation to the Local Plan 2030 without a review or reconsideration as to accuracy or appropriateness in guiding sites to be selected to deliver housing in the period to 2040. This work should therefore be re-evaluated.
Finally, it is to be noted in respect of Paragraph 13 that the development strategy is yet to be set, whilst in relation to the fourth bullet, it is not clear if accessibility considerations include accounting for rural school transport provision – if not (as it appears) then the assessment should be reconsidered to factor this provision in.

Object

Representation ID: 7075

Received: 09/09/2021

Respondent: June Coles

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 7122

Received: 09/09/2021

Respondent: Stephen Coles

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 7202

Received: 17/09/2021

Respondent: Mr Peter Knight

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 7289

Received: 01/09/2021

Respondent: Miss Laura Jones

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7470

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

6.55 It is understood that as part of the Bedford Local Plan 2040, the Council will identify site’s to be allocated for employment land and these will be identified at the Regulation 19 Consultation Stage.
6.56 The methodology for this site selection process is set out in the Site Selection Methodology (2021). This sets out that each site is to be assessed against 15 sustainability objectives to test the social, economic and environmental impacts of development in response to key issues in the local area.
6.57 Sites are rated based upon how well they perform against each of the questions contained within the 15 objectives, from ‘major positive effect’ to ‘major negative effect’.
6.58 The initial assessment for all sites submitted as part of the 2020 Call for Sites process has also been published as part of the Reg 18 Local Plan. The Bedford Business Park is included within this as site reference 809.
6.59 Whilst we consider the Site Selection Methodology is a useful tool for considering sites suitable for residential development, we do not consider that all of the criteria are relevant when assessing sites for employment land allocations. For example, a number of the assessment criteria concern a site’s proximity to primary schools, food stores and sports facilities. We consider this is more important when considering the location of new housing developments and that there are different priorities when considering locations appropriate for employment uses, such as proximity to the strategic road network. In addition a number of these criteria are repeated under a number of the sustainability objectives which risks applying an inappropriate weighting to those criteria in the site assessment process.
6.60 Furthermore, the Site Selection Methodology is weighted towards housing development in terms of assessing flood risk. Sites which are located within flood zones 2 or 3a are automatically rated as having a negative or major negative effect on this basis. However, this does not take into account that the NPPF guidance sets out that less vulnerable uses (such as employment uses) may be suitable within flood zones 2 and 3. This therefore leads to such sites being scored negatively against this criterion despite policy not precluding such uses.
6.61 We also consider that the Methodology is unable to capture that large scale developments may be able to provide additional facilities as part of future development which would support the uses to be created. For example, the Bedford Business Park proposals include an element of retail uses, green infrastructure and other amenities in order to support future employees and complement the business offer. This therefore seeks to create a sustainable employment community in its own right and should therefore score highly against sustainability criteria.
6.62 The Methodology also fails to take into account the fact that some potential constraints can be mitigated against as part of future development to ensure there is no unacceptable impact. For example, whilst the Bedford Business Park site is located in an area where protected species are likely to exist, the proposals put forward an extensive series of mitigation measures to such species are protected along with enhancement measures to deliver net gains for biodiversity. We consider any assessment of the site should take the proposed mitigation measures into account and rated accordingly.
6.63 We therefore consider that it may be more appropriate to consider sites against the NPPF criteria concerning deliverability when considering allocations for employment land. As set out above, the site fully accords with the criteria and is demonstrated to be suitable, available and achievable for development.
6.64 Notwithstanding this, a full appraisal of the site has been undertaken in line with the site selection methodology criteria and is included in Appendix 2 This demonstrates that the proposals meet all the relevant criteria and should therefore be taken forward as a site 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

Representation ID: 7499

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

Please note the Brownfield site register is incomplete and needs to be revised to include all of the sites to allow the selection process to fully keep abreast of the Brownfield options which should be exhausted first to protect natural rural landscapes being chosen to make the developments easier/cheaper than manage the more challenging and costly options of redevelopment of brownfield sites. If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7608

Received: 01/09/2021

Respondent: Miss Nicola Tagg

If numbers (2,1,0,0,-1,-2) are used to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7655

Received: 01/09/2021

Respondent: Mr Simon Goodship

If numbers (2,1,0,0,-1,-2) are used to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7751

Received: 22/09/2021

Respondent: Mr Michael Thompson

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.




c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7810

Received: 03/09/2021

Respondent: Mr Emilio Meola

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 7849

Received: 03/09/2021

Respondent: Mr Mark Ibbett

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. I do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, I believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

Object

Representation ID: 7953

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

Please note the Brownfield site register is incomplete and needs to be revised to include all of the sites to allow the selection process to fully keep abreast of the Brownfield options which should be exhausted first to protect natural rural landscapes being chosen to make the developments easier/cheaper than manage the more challenging and costly options of redevelopment of brownfield sites.

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8011

Received: 24/09/2021

Respondent: Mr Larry Gooch

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8117

Received: 03/09/2021

Respondent: Dr Emma Thompson

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8156

Received: 03/09/2021

Respondent: Mr Ross Thomson

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8195

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8254

Received: 03/09/2021

Respondent: Mr Daniel Francis

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 8298

Received: 03/09/2021

Respondent: Miss Erin Francis

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.




Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8340

Received: 03/09/2021

Respondent: Mrs K Francis

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 8444

Received: 03/09/2021

Respondent: Mr Theodore Cassell

Please note the Brownfield site register is incomplete and needs to be revised to include all of the sites to allow the selection process to fully keep abreast of the Brownfield options which should be exhausted first to protect natural rural landscapes being chosen to make the developments easier/cheaper than manage the more challenging and costly options of redevelopment of brownfield sites.

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.

1.39 100 word summary
The scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. We believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.

Object

Representation ID: 8541

Received: 03/09/2021

Respondent: Mrs Claire francis

See comments under 1.44 Sustainability Appraisal

Object

Representation ID: 8704

Received: 13/09/2021

Respondent: Mr J Francis

See comments under 1.44 Sustainability Appraisal