1.44

Showing comments and forms 1 to 30 of 77

Object

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

Representation ID: 3912

Received: 28/08/2021

Representation Summary:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available

Full text:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available

Object

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

Representation ID: 3998

Received: 29/08/2021

Representation Summary:

The proposal of new settlements in 2b to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Full text:

The proposal of new settlements in 2b to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Object

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

Representation ID: 4129

Received: 30/08/2021

Representation 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.

Full text:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 4165

Received: 30/08/2021

Representation 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. The criteria / scoring system
is insufficiently sensitive if it produces so little variation between the options. In the favoured
options 2a to 2d, 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.

Full text:

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. The criteria / scoring system
is insufficiently sensitive if it produces so little variation between the options. In the favoured
options 2a to 2d, 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

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

Representation ID: 4193

Received: 30/08/2021

Representation Summary:

The report suggests that out of the 15 criteria, 7 have been given to all the options – is this accurate?
People will not travel to Bedford but will go to St Neots.
Why is it acceptable to build on greenfield land, rather than use available brownfield land?

Full text:

The report suggests that out of the 15 criteria, 7 have been given to all the options – is this accurate?
People will not travel to Bedford but will go to St Neots.
Why is it acceptable to build on greenfield land, rather than use available brownfield land?

Object

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

Representation ID: 4331

Received: 31/08/2021

Representation Summary:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Full text:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Object

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

Representation ID: 4363

Received: 31/08/2021

Representation Summary:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Full text:

The proposal of new settlements in 2a to 2d does not recognise that people will go to St Neots not Bedford, they fail to recognise the impact of new settlement on existing landscape and the option of new development on greenfield land appears to have been accepted by the council even though brownfield sites are available.

Object

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

Representation ID: 4428

Received: 31/08/2021

Representation Summary:

The appraisal is flawed for the reasons given above.

Full text:

This appraisal is flawed. I have taken the comments of Staploe Parish council, which I have read and understand and added some additional comments.
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. 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. [Question for the Planners: Is this reasonable or sufficient?]
3. In the favoured options 2a to 2d, BBC have failed fully to consider the true impact of new settlements (incl. Dennybrook) on:
a. 6. 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. As a resident of Honeydon I can confirm that we rarely visit Bedford, and neither do our neighbours.
b. 8. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. 9. 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 happily 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

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

Representation ID: 4472

Received: 31/08/2021

Representation 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.

Full text:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 4545

Received: 01/09/2021

Representation 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.
The criteria / scoring system is insufficiently sensitive if it produces so little variation between the options.
In options 2a to 2d, it seems that BBC 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.

Full text:

In options 2a to 2d, it seems that BBC have not considered 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. The words fail to fully recognise the devastating impact of new settlements on the existing landscape.
c. Maximum 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

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

Representation ID: 4638

Received: 01/09/2021

Representation 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.

Full text:

I have severe Parkinson’s and cannot type easily. Please duplicate all of Lucy Crawford’s responses for my views. Her email address is Lucy_crawford@hotmail.com and she lives at 33, Staploe PE19 5JA

Object

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

Representation ID: 4696

Received: 01/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 4748

Received: 01/09/2021

Representation Summary:

The appraisal is flawed.
BBC appears to making no attempt to use the stock of brownfield sites e.g. Twinwoods, contrary ti the NPPF

Full text:

This appraisal is flawed. I have taken the comments of Staploe Parish council, which I have read and understand and added some additional comments.
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. 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. [Question for the Planners: Is this reasonable or sufficient?]
3. In the favoured options 2a to 2d, BBC have failed fully to consider the true impact of new settlements (incl. Dennybrook) on:
a. 6. 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. As a resident of Honeydon I can confirm that we rarely visit Bedford, and neither do our neighbours.
b. 8. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. 9. 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 happily 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

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

Representation ID: 4983

Received: 02/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 4994

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: 5004

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: 5017

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: 5492

Received: 06/09/2021

Representation Summary:

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 are highlighted grey in my table and 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. [Question for the Planners: Is this reasonable or sufficient?]
3. In the favoured options 2a to 2d, I believe that BBC have failed to properly consider the true impact of new settlements (incl. Dennybrook) on:
a. 6. 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. 8. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. 9. 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 happily 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

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

Representation ID: 5589

Received: 06/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 5640

Received: 07/09/2021

Representation 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.

Support

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

Representation ID: 5691

Received: 07/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 5747

Received: 07/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 5785

Received: 07/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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.
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. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, I 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

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

Representation ID: 5851

Received: 08/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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.
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

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

Representation ID: 5925

Received: 08/09/2021

Representation Summary:

While I understand the approach adopted to compare the many sustainability aspects of each proposed development option and generally support the 15 sustainability objectives (para 1.4), their application in practice is severely limited for the following reasons:
• Referring to the Summary table at the end of Appendix 5 that compares all development options.
• Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include: 2. Protect, maintain and enhance biodiversity and habitats; 8. Protect and enhance landscape character and townscape character…; 11. Minimise flood risk; .
• 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 consider this to be reasonable or sufficient.
In the emerging preferred development options 2a to 2d, I believe that BBC have failed to properly consider the true impact of new settlements (especially including Dennybrook) on:
• 6. 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.
• 8. Landscape character – all options score the same and the words fail to fully recognise the impact and destruction of new settlements on the existing landscape.
• 9. Maximise development on brownfield/avoid loss of agricultural land – despite the massive loss of high quality 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 BBC happily accept this and have made no effort to maximise use of their stock of brownfield land – contrary to the NPPF.
THE ABOVE LIMITATIONS IN THE PROCESS CAST SERIOUS DOUBT ON THE VALIDITY OF THE EMERGING PREFERRED OPTIONS 2B, 2C AND 2D, especially for the Dennybrook site.

Object

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

Representation ID: 5971

Received: 08/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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.
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

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

Representation ID: 6020

Received: 08/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 6074

Received: 09/09/2021

Representation Summary:

5.1 We raise objection to the contents of the Sustainability Appraisal. The framework for considering sustainability is well established, and we do not raise objection to the general scope of the appraisal. However, it is felt that there is an underlying bias towards urban centric growth, which discounts further growth in the Key Service Centres and smaller sustainable villages.

5.2 The four options in Option 2 are described in the consultation as primarily an urban centric set of options focused on growth in and around the urban area, and rail connection points. We would argue this approach is far too simplistic and omits an opportunity to enhance the sustainability of Key Service Centres through the provision of additional services and employment opportunities. It also ignores the potential to build upon the community-led ambitions of the many Neighbourhood Plans that have been prepared in the Borough

5.3 We would comment that at paragraph 8.10, the Council comment on merits of growth around rail hubs and yet ignore to a large extent the value of the bus network with high frequency bus services being a far more flexible and viable option to providing an alternative to the car. The delivery of housing growth along the high frequency bus network, such as that served by the X5, has the knock on benefit of supporting improvements to services and wider improvements to sustainability across a broader range of settlements.

5.4 An enhanced population along the bus network increases passenger numbers which enables improvements to those existing services to be more viable. By enhancing the network as a whole, you can better serve smaller settlements and improve their sustainability as a consequence. We would highlight again that Countryside has significant experience of procuring additional bus services through their developments in collaboration with local services and ensuring they become viable.

5.5 We would also highlight that sustainable development needs to plan for the longer term. The private motor vehicle/car is considered to have a harmful effect on the environment, contributing to rising CO2 levels and poor air quality. As a consequence, the language of sustainability talks about “reducing the reliance on the private motor vehicle”. However, as we progress forward in carbon neutral/zero emissions vehicles, this notion will be out of date. The Government has brought forward it’s ban on the sale of new petrol and diesel cars to 2030, with all new cars and vans required to deliver zero emissions from the tailpipe from 2035. The car industry has also reacted with many car manufacturers already committed to being fully electric by 2035. As well as the largest manufacturers such as Volkswagen Group committed to their vehicles being carbon neutral at the point of manufacture.

5.6 With the move towards more environmentally friendly forms of private transport which are driven and supported by the ever-growing energy provision coming from renewable sources, the impact of the private motor vehicle will change, and will be part of a range of sustainable transport options.

5.7 We would also raise objection to the very narrow view that somehow sustainability can only be achieved by one model of growth, with a focus on what is new, being located in only a select few locations; and that somehow everything else is not sustainable, nor could ever be altered to being sustainable. In our view it ignores the wider objective of enhancing the sustainability of existing settlements of all sizes, and fails to support the long-term vitality and viability of those existing settlements and the services and facilities they rely upon.

5.8 It also assumes that travel patterns will continue to grow along the same trajectory, but our collective experiences through the Covid19 pandemic have accelerated the trend of home working supported by advancements in technology. As demonstrated by the pandemic, a large portion of the economy can continue to function without the need to travel, and to some extent has opened people up to embracing technology and minimise their need to travel to communicate. All development needs to consider, that going forward, a greater proportion of people will be working from home or in localised hubs without need to travel long distances. That degree of flexibility is already coming in in the form of communal work spaces, and hot desking etc. Therefore, the provision of high-speed broadband to all new developments, as well as supporting enhancements to the existing network, is essential in delivering sustainable growth.

5.9 We would therefore conclude, by arguing that the sustainability credentials of the settlement of Great Barford should be assessed independently, and the opportunities for growth in the settlement fully considered in light of its sustainability credentials. It is self-evident that Great Barford occupies a sustainable location, served by A421 at the junction with the A1, and is supported by high frequency public transport links via the X5 and 27 bus services. The settlement is independently accessible from the major road network, and within short distance of a major employment area on the eastern edge of Bedford, with existing pedestrian and cycle connections into the town. We believe that the allocation of development at Great Barford would meet many of the sustainability objectives the Council are arguing in support of options 2a – 2d, and as such would question why strategic growth here has been discounted.
Countryside takes its responsibilities as a sustainable developer very seriously and have a number of strategies to ensure we meet these objectives and continue to monitor progress (sustainability approach document attached at Appendix A).

Object

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

Representation ID: 6106

Received: 09/09/2021

Representation Summary:

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:
4. 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.
5. 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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

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

Representation ID: 6153

Received: 09/09/2021

Representation Summary:

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 are highlighted grey in my table and 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. [Question for the Planners: Is this reasonable or sufficient?]
3. In the favoured options 2a to 2d, I believe that BBC have failed to properly consider the true impact of new settlements (incl. Dennybrook) on:
a. 6. 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. 8. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. 9. 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 happily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.