Policy DS2(S) Spatial strategy

Support

Representation ID: 9110

Received: 16/07/2022

Respondent: Ann Mills

I broadly support the overall emphasis of the Spatial Strategy to focus development within the Bedford urban area, strategic locations adjacent to the urban area and the A421 corridor with its potential for growth in rail transport. I also support the strategic plan for the rural areas of the Borough. This is the right approach regardless of the development of the Oxford-Cambridge Arc.

Comment

Representation ID: 9257

Received: 27/07/2022

Respondent: Mrs Alison Myers

I am very concerned about the loss of open spaces within Bedford - areas of brownfield land are required to provide nature spaces and amenity for the community. More houses exacerbate climate issues re run off and urban heating.

The spatial strategy has been greatly influenced by EW Rail - growth areas such as Little Barford and to the south of Bedford must ensure potential rail corridors are not constrained .

Little Barford growth is in a sensitive landscape setting and does not relate well to Bedford.

Comment

Representation ID: 9266

Received: 27/07/2022

Respondent: Mrs Alison Myers

I support options for growth south of Bedford as there is greater potential for these to be sustainable in terms of travel and the location of employment and the existing retail facilities. I have concerns that Little Barford does not relate well to sustainable transport and will lack a sense of connection to Bedford. It is also in an area of open and sensitive landscape.

Comment

Representation ID: 9275

Received: 27/07/2022

Respondent: GB PC

Policy DS2(S) Spatial strategy should be reworded to include infrastructure, as indicated:

Rural area
xii. The completion of strategic Key Service Centre and more limited Rural Service Centre residential development and associated infrastructure identified in Local Plan 2030 on sites which are allocated in neighbourhood plans and the completion of Local Plan 2030 Policy 27 Land north of School Lane, Roxton;

Object

Representation ID: 9280

Received: 27/07/2022

Respondent: Mr Jonathan Pelham

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

I disagree with the plan for Shortstown expansion to the west. This is green belt agricultural land and Shortstown is already struggling to cope with the large amount of houses added to it which have caused various problems traffic through the A600 bottleneck to the A421 with its accident blackspot being only one of many.

Support

Representation ID: 9301

Received: 28/07/2022

Respondent: Mrs Lucy Crawford

Staploe Parish Council support this policy which proposes growth on brownfield sites, sites south of Bedford and at a new settlement in Little Barford. This is in keeping with the NPPF which states that brownfield sites, and sites with sustainable transport links are preferred and that grade 1 and 2 agricultural land should be avoided.

we would like to see more detail about how the Borough Council have cooperated with St. Neots Town Council / Huntingdonshire / Cambs Councils and Central Bedfordshire Council.

Object

Representation ID: 9302

Received: 28/07/2022

Respondent: Mrs Frances Baylis

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

I object to expansion of Shortstown to the west. Shortstown has seen substantial additional housing but no improvement of transport links and the
impact of large sites currently in build has not been reviewed.

Object

Representation ID: 9316

Received: 28/07/2022

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investment LLP

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan is not legally complaint owing to failure to comply with the duty to co-operate and fails to meet the tests of soundness. The Council has not co-operated effectively with neighbouring authorities regarding strategic cross-boundary impacts of the proposed new settlement at Little Barford; the supporting evidence (New Settlements Assessment and Sustainability Appraisal) is inconsistent in its approach and does not represent a suitable, fair and objective assessment of the spatial strategy options; and the transport evidence (BBTM) is inconsistent with national policy, with serious concerns over the application of the BBTM results to the site selection process.

Object

Representation ID: 9332

Received: 28/07/2022

Respondent: Mrs Frances Baylis

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

I object to expansion of Shortstown to the west. Shortstown has seen substantial additional housing but no improvement of transport links and the impact of large sites currently in build has not been reviewed.

Object

Representation ID: 9350

Received: 28/07/2022

Respondent: Mrs Sylvia Lorenzo

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

I object to expansion of Shortstown to the west. Shortstown has seen substantial additional housing but no improvement of transport links and the
impact of large sites currently in build has not been reviewed.

Support

Representation ID: 9359

Received: 28/07/2022

Respondent: Staploe Parish Council

Staploe Parish Council support this policy which proposes growth on brownfield sites, sites south of Bedford and at a new settlement in Little Barford. This is in keeping with the NPPF which states that brownfield sites, and sites with sustainable transport links are preferred and that grade 1 and 2 agricultural land should be avoided.

Object

Representation ID: 9404

Received: 29/07/2022

Respondent: O&H Land

Agent: Varsity Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

O&H support the South of Bedford Policy Area but there is currently no firm proposal for a Stewartby Hardwick station. The development strategy should continue to focus on this area but recognise the potential that already exists along the Marston Vale Line.

Object

Representation ID: 9432

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Please see attached report

Comment

Representation ID: 9449

Received: 29/07/2022

Respondent: Luton & Bedfordshire Green Party

We would ask that "and work towards making Bedford" , be reworded as "and make Bedford"

Support

Representation ID: 9452

Received: 29/07/2022

Respondent: Anne Dorber

The allocation of the majority of new development to areas easily accessible from the new stations, is welcome, as is making use of available brownfield sites.

Object

Representation ID: 9462

Received: 29/07/2022

Respondent: Landcrest Developments Ltd

Agent: Woods Hardwick Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The comments by Landcrest set out that the strategy is flawed and sub-optimal in its approach to achieving sustainable growth in the right places at the right time.

Object

Representation ID: 9519

Received: 27/07/2022

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy DS2(S) Spatial Strategy
2.3 The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives.
6
Fisher German LLP is a limited liability partnership.
Registered in England and Wales. Registered
Number: OC317554. Registered Office: The Head
Office Ivanhoe Office Park, Ivanhoe Park Way,
Ashby-De-La-Zouch, Leicestershire, England, LE65
2AB. A list of members’ is available for inspection at
Head Office.
2.4 Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement: this included potential growth at Willington.
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need. Option 2D was identified as a reasonable alternative.
2.7 Willington was included in growth option 2D, outlined above, whereby growth at villages including Willington in the transport corridor-east would have been combined with other growth options such as development in and around the urban area and one new settlement.
2.8 The Council considered that the benefits of Option 2D are that housing development in the wider Parishes would enable housing delivery to be achieved earlier in the plan period (this is a very strong benefit consistent with the aims of Government).
7
Fisher German LLP is a limited liability partnership.
Registered in England and Wales. Registered
Number: OC317554. Registered Office: The Head
Office Ivanhoe Office Park, Ivanhoe Park Way,
Ashby-De-La-Zouch, Leicestershire, England, LE65
2AB. A list of members’ is available for inspection at
Head Office.
2.9 The negatives identified with Option 2D were that development would be considered to be more dispersed which could reduce the amount of development where railway stations could be accessed by active travel. There was also a perceived impact upon the landscape and settlement characters (not necessarily specific to Willington). Option 2D is noted in the topic paper to be the least popular option with the public.
2.10 Overall, village related growth was considered by the Council to be the worst performing option compared to the other growth options. However, no further comment is made in detail on option 2D despite its similarity with option 2B being noted within the Topic Paper (and option 2B was ultimately assessed as the most appropriate growth option).
2.11 As detailed in response to Policy DS3 and DS5, there seems an absolute reluctance by Bedford Borough to allocate any further additional growth at the Rural Services Centres despite the benefit being that some proportionate growth would be delivered earlier in the Plan period rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and withe current cost of living crisis, failure to deliver housing in settlements such as Willington will result in more and more young people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth to ensure they do not age and stagnate.
2.12 Land at Barford Road Willington has shown that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars.
2.13 The Plan and Strategy also has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.

Support

Representation ID: 9535

Received: 11/07/2022

Respondent: Clapham Parish Council

Please consider this the formal response to the public consultation on the draft Local Plan 2040.
Clapham Parish Council fully supports the approach to future development in the areas denoted in the draft Plan.
We recognise that Clapham has already had allocated significant development in the current plan and is glad the future Plan does not include further large development in its boundary.
We ask that Bedford Borough Council considers the planning and community needs of the villages outside the town, not only of rural villages, but also of those less rural villages such as Clapham which border the town, in considering the current and future pressure on transport infrastructure.
We remain concerned about the impact of the East West Rail proposals on Clapham, regardless of which route is ultimately chosen. We ask that future Local Plans consider the impact of EWR’s construction on Clapham, its residents and its environment and would like to develop partnerships with Bedford Borough Council to develop mitigation for the proposals.
We continue to support the need for active travel.

Comment

Representation ID: 9539

Received: 13/07/2022

Respondent: Ravensden Parish Council

Ravensden Parish Council in principle welcomes the development strategy in the 2040 submission version plan, as it builds on our preferred option from the 2021 consultation (Option 2b), but subject to the reservations set out below. We also support the deletion of the proposed new settlement at Dennybrook which would have had significant traffic implications for the road network in the Parish, notably the B660.
At para 4.23 of the Submission Plan, it says that East West Rail is a “critical catalyst and pivotal to achieving the Plan’s vision”. The Local Plan 2040 should acknowledge that Government has yet to finally decide whether the section between Bedford and Cambridge should be constructed at all, or in a given timescale, or on a particular route. Therefore much of the strategy of the Plan could be undone if Government does not confirm the premature assumptions which the Borough Council has made with regard to this section of the proposed railway. The absence of a fall-back strategy in the Submission version of the Local Plan 2040 could be considered unsound.
For these reasons, EWR corridor E should be deleted from the Key Diagram. The scheme is not a commitment and it is outside the control of the Borough Council to deliver it through the Local Plan 2040.
The Parish Council notes that the greater part of the dwelling requirement for the Borough is to be met through the creation of new settlements in the A421 corridor, based on new stations at Kempston Hardwick and Wixams (as part of the wider South Bedford policy area), and at Little Barford. That strategy would be consistent with the creation of a sustainable and environmentally acceptable multi-modal corridor along the A421, and undermines the case for the railway to cross the undulating and environmentally sensitive landscape north of Bedford. If EWR is not built, then the south Bedford development strategy including a new settlement at Kempston Hardwick could still be achieved, as it would continue to be served by the Marston Vale line, plus the new committed station at Wixams on the Midland Mainline.
However, we are concerned that a new settlement at Little Barford would have no public transport rationale if EWR did not go ahead or if a more southerly route through Tempsford was chosen. Although it would lie within the A421 corridor following the completion of the Black Cat/Caxton Gibbett dual carriageway, much of the sustainability rationale for the Little Barford proposed new settlement would fall away if EWR was not constructed through the proposed allocation (see related comment below about the Key Diagram).

Object

Representation ID: 9548

Received: 19/10/2022

Respondent: Michelle Mednick

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I am a resident in wixams and want to share that I oppose to the proposals due to the pressure it will put on roads, traffic, school places, areas overcrowded and less green spaces which will put a strain on the environment.

Object

Representation ID: 9558

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy DS2(S) Spatial strategy and Para.4 Making Bedford a net-zero carbon emissions borough at the heart of the Oxford – Cambridge Arc, development should be focussed within the urban area, at specified strategic locations adjacent to the urban area and at growth locations within the A421 / East-West Rail corridor and with the potential for rail-based growth.
The sites allocated in Local Plan 2030 including land at Ford End Road should be used for railway purposes including second booking hall for Bedford Midland Station with extra parking, buses, walking/cycling and disabled to Platform 4 at Bedford Midland. Lands are needed to straighten tracks between Danfoss site and Bedford Midland for East-West rail services including freight and ease pressure on Platform 1 at Bedford Midland. Better buses needed for linking Bedford Midland with the Bus Station, including all Grant Palmer services. land south of the river

Strategic locations adjacent to the urban area which contribute to delivering the Bedford – Milton Keynes Waterway Park and the Bedford River Valley Park;

The completion of Wixams new settlement, incorporating eastern and southern extensions, and the development of a strategic village expansion utilising brownfield land at Kempston Hardwick identified in Local Plan 2030;
An expansion of Shortstown(near Cardington) should have active travel links to the rail network.
A new settlement and related employment provision at Little Barford well connected to the new East-West Rail station at its intersection with the East Coast Main Line, together with a dedicated shuttle bus service (See Policy HOU19).
However, there should be a station at Kempston Retail Park,which could be the same as Broadmead and will replace both the proposed Kempston Hardwick and Stewartby stations. Please see https://ertarail.co.uk/publicity/.

Support

Representation ID: 9573

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policies DS2(S) and DS5(S) sets out the proposed distribution of growth in the Borough.
L&Q broadly support the growth strategy, which seeks to focus new residential development within the main Bedford urban areas, and at strategic urban extension locations where new development can contribute to the objectives of the Oxford – Cambridge Arc, and be delivered alongside appropriate infrastructure.
However, we would highlight the viability challenges associated with brownfield, urban town centre development, for example addressing ground contamination and utilities. For residential development, the need to optimise housing delivery in these locations is essential to making schemes viable and deliverable and flexibility around key, competing policy requirements is required. Due to the national and borough housing need, we would encourage the Council to support proposals for housing delivery outside of the identified areas for strategic growth, on a site by site basis, nothing the contribution that smaller, infill site developments can make.
As indicated previously, L&Q is already investing in the South of Bedford area at Wixams. In that context, it supports the intention to deliver sustainable future urban extensions within the South of Bedford area for 7,050 new homes (alongside appropriate infrastructure), and
specifically the identification of broad areas of growth at Draft Policies HOU15 (Land South of Wixams) and Policy HOU16 (Land at East Wixams). We note that a more detailed strategic place making framework for the South of Bedford policy area will be adopted as a Supplementary Planning Document, but that the Stepped Trajectory Topic Paper (April 2022) indicates capacity of 300 dwellings at Land South of Wixams and 1,800 dwellings at Land East of Wixams.
In our view Wixam is a sustainable location for housing growth; that is, it benefits from good access to employment centres, it located in the Oxford – Cambridge Arc growth area, it benefits from existing infrastructure, and has the potential to deliver additional new infrastructure where required.

Object

Representation ID: 9587

Received: 29/07/2022

Respondent: Arrow Planning Limited

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

3.1 The spatial strategy of focusing growth in the south of Bedford area (Policy HOU12) is supported by our client. However, our client contends that the approach taken to
allocating sites and, in particular, the quantum of development allocated on certain sites is not justified nor consistent with national policy, for the following reasons.
3.2 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13, HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear understanding and expectation as to the quantum of development that the Plan is proposing in these locations.
3.3 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
3.4 What is not evident from the evidence base or the Local Plan, is the approximate developable areas and thus whether these are realistic densities. Upon examination of the Policies for each site, and the Figures in the Local Plan which accompany each, the only way to achieve all the Policy requirements, in particular the amount of open space and green infrastructure, would necessitate very high densities on the majority of these
sites (c. 50/60+ dph).
3.5 There is no evidence accompanying the Local Plan which justifies this approach; the HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which a high density would lead to, nor is there market evidence supporting housing demand for such a high quantum of small units in these locations.
3.6 This is likely to lead to future applications which either decrease the number of homes, resulting in unmet need (in terms of overall quantum and/or mix) and possibly nondelivery of key infrastructure. Alternatively, it may lead to non-delivery of green infrastructure due to pressures to deliver housing numbers.
3.7 The quantum for each allocation is not based on a proportionate or robust evidence base and are therefore not sound.

Object

Representation ID: 9592

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

U&C recognise that in the Central Area (as defined in the Emerging Plan), no existing or potential location for strategic growth can be considered in isolation. All options relate to, or are dependent upon, the same elements of strategic infrastructure investment to a greater or lesser degree. Furthermore, the advantages arising from investment have potential to be supercharged, to the benefit of existing and new communities, if planned comprehensively. This applies especially to energy, green infrastructure, biodiversity, water conservation and sustainable modes of transport.
Our representations in September 2020 (Issues and Options) recognised the challenge of moving ahead with the Bedford Borough Local Plan, given a lack of strategic context. We were nevertheless firm in calling for: ‘more than just effective cross boundary relationships. It is now time for effective joint planning to establish a framework to meet short term needs and deliver long term potential.’ U&C were hopeful that Policy 1 of the Adopted Local Plan, which refers to strengthening cross boundary relationships but also hints at a possible joint plan, was not a hollow prospect. U&C has been and is supportive of and has lobbied for strategic growth to be locally led through effective collaboration.
The Submission Plan does not address this challenge and opportunity.
While the Borough Council’s commitment to respond positively to strong economic, social and environmental drivers within the Central Area is evident in the opening pages of the emerging Plan, the translation of that ambition into policy does not address cross-boundary issues and does not adequately address significant delivery issues, which are clearly identified within the evidence base, published in support of the Plan. These shortcomings are not confined to the proposals for two new settlements, assumed to come later in the plan period (although they are not subject to any policy controls on timing), but it is in respect of these proposals that U&C now focuses its objection. These allocations present greatest risk to coordinated development within the Central Area, threaten to frustrate or delay development in adjoining areas and do not adequately address wider cumulative impacts.

Object

Representation ID: 9599

Received: 27/07/2022

Respondent: Andrew and Robert Tusting

Agent: Fisher German LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is our view, for the reasons set out below, that the Local Plan is not sufficiently justified, is not effective and is not consistent with National Policy. It therefore fails to meet the legal tests of soundness.
Policy DS2(S) Spatial Strategy
2.3 The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives or is likely to be deliverable.
Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Oxford to Cambridge Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement:
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need.
2.7 As detailed in response to Policy DS3 and DS5, there seems a reluctance by the Council to allocate further growth to the Rural Services Centres despite the acknowledged available capacity and the benefit being that proportionate growth would be delivered earlier in the Plan period, rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and withe current cost of living crisis, failure to deliver housing in settlements such as Harrold will result in more and more people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth throughout the Plan period also, to ensure they do not age and stagnate.
Land west of Odell Road, Harrold has demonstrated that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars, public transport and cycling. Moreover, due to an increased prevalence in home working and online deliveries, people are able to live more sustainably in what was traditionally considered to be a less sustainable location.
2.9 The Plan and Strategy also has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.

Comment

Representation ID: 9605

Received: 29/07/2022

Respondent: Wilshamstead Ward

Whilst recognising the housing targets that have been set for Bedford Borough and the urgent need for new housing throughout the UK, I believe that in the Local Plan 2040, Bedford Borough is proposing the wrong type of housing in totally the wrong area.

In my opinion, the most pressing housing issue to address today, is the need to build more homes for young people. For many young people a house of their own is only a dream, as they remain either trapped at home with parents or in expensive rented accommodation.

There tends to be a general movement of young people towards urban areas, due to better job opportunities and better social and recreational facilities. Therefore, what the Borough Council is failing to address, is the need for starter homes and apartments in urban areas, where younger people can get a foot on the housing ladder.

The bulk of the Local Plan 2040 in the south of the Borough will lead to the destruction of open green space and result in 4 and 5 bedroom houses which are only affordable to those who are already home owners and looking to scale up. The Local Plan 2040 is light on sustainability and environmental concerns and looks to be a rushed process to meet national housing targets without much thought to the consequences.

Comment

Representation ID: 9615

Received: 26/07/2022

Respondent: Land Allocation Ltd

Agent: AAH Planning Consultants

We note that the growth locations are to be within the urban area, next followed by strategic locations adjacent to the urban area and which contribute to the delivery of key green infrastructure projects and at new growth locations which are focussed along the EWR/A421 transport corridor with potential for rail-based growth, especially in the south of Bedford area and a new settlement at Little Barford.

A number of allocations have come forward within the current Local Plan 2040; however, it is not currently clear how many dwellings these allocations would be able to accommodate, either in total or individually. We maintain that it is essential the Council over-allocates housing land to ensure flexibility, choice and competition in the housing market, reflecting government guidance. We maintain that a mix of smaller and medium-scale sites can be delivered at a faster rate than the larger, allocated sites. These sites, such as our clients, which were submitted in the Call for Sites exercise but not taken forward, form an important contribution to the Council’s five-year housing land supply and should be considered in order to allow Councils to continuously maintain a healthy and constant supply of deliverable sites, especially where there has been such an increase in the housing need figure.

Our previous representations on prior consultations for the Local Plan 2040 has suggested that whilst a larger proportion of housing and employment growth should be focused on the urban area, growth should also be located within the rural areas. We note that Policy DS2(S) Spatial Strategy point xi considers that “The completion of strategic Key Service Centre and more limited Rural Service Centre residential development identified in Local Plan 2030 on sites which are allocated in neighbourhood plans and the completion of Local Plan 2030 Policy 27 Land north of School Lane, Roxton.” We maintain that development in rural areas would ensure that there was a level of housing growth across the areas where those houses are needed. Alongside promoting housing, this would ensure that rural areas received an appropriate level of growth to maintain and enhance economic vitality, and the services and facilities required would be maintained. As previously highlighted, this approach would take into account Paragraph 79 of the NPPF to promote housing growth in the rural settlements of the Borough. More housing in rural areas would maintain their vitality, including the retention of services and facilities that depend on economic growth, promoting greater and more sustainable development.

The draft plan maintains its reliance on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, as highlighted in previous representations, we maintain that any delays to emerging neighbourhood plans could stall the delivery of housing within the Borough. We maintain that those which have been ‘made’ are based on the Local Plan 2030 housing need of 970 dwellings per annum; considering the significant increase in housing need, these ‘made’ neighbourhood plans are likely to require reviewing. In addition, we reiterate that Neighbourhood Plans are not subject to the same stringent examination as Local Plans, and therefore, the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.

Comment

Representation ID: 9623

Received: 26/07/2022

Respondent: Clapham Parish Council

CPC has no objection to the Vision and Objectives of the proposed local plan noting that it aims for the requisite infrastructure is in place when the proposed growth is brought forward for delivery. To that end, of the total allocation of 27,100 dwellings 1700 dwellings are to be delivered post 2030. This is sensible.

The required supporting infrastructure is set out in the Infrastructure Delivery Plan. This includes the completion of East-West Rail (EWR) by 2030. This is important to note as it provides for the required modal shift to give resilience to the highway network. However, CPC has some concerns that given the complexity of the project EWR, it will not be completed by 2030.
EWR is at an early stage of development and has not commenced its statutory process and which through examination may significantly change its form, location and deliverability. Given this uncertainty, CPC has significant concerns in allocating housing and employment to sites which may ultimately not be facilitated by EWR in a timely manner.

CPC therefore considers the plan is not legally sound, credible or flexible. To make the plan sound, CPC considers the policy should have a fallback position, so if EWR does not come forward, is delayed, or there is a change in routeing, then either the allocated sites are not implemented until it is in place, or sufficient alternative infrastructure or other sustainable measures are identified to support the development sites.

CPC consider not taking this action, will potentially result in intolerable levels of highway congestion and delay to movements around Bedford, including to the residents of Clapham wishing to access Bedford or the A421 corridor.

Comment

Representation ID: 9626

Received: 26/07/2022

Respondent: Clapham Parish Council

Policy Omission: Strategic Gaps
The proposed plan allocates significant growth along the A421 corridor, notably at Kempston Hardwick New Settlement (HOU14), Land South of Wixams (HOU15), Land at East Wixams (HOU16) and Gibraltar Corner (HOU13). These sites effectively provide infill sites to the communities of Wootton, Stewartby and Wixams, creating a continous suburban extension.

These allocations continue the long term trend of coalescence of communities throughout Bedford and Kempston, and provides a dangerous precedence. CPC therefore request consideration is given to the inclusion of a specific policy for Strategic Gaps designed to protect the integrity and character of communities such as Clapham which are located close to, bit outside the urban area of Bedford. The purpose of the policy would be to provide a planning tool which:

Identifies areas of open land/countryside between existing settlements, with the aim to protect the setting and separate identity of settlements, and to avoid coalescence by retaining the existing settlement pattern through maintaining the openness of the land.

CPC would wish this to apply to the open land between Clapham and Bedford. There may be other communities to which this policy could be applicable. CPC suggest the following criteria for consideration

The land to be included within the gap is open and provides a sense of separation between settlements.
· The land to be included within the gap performs an important role in defining the settlement character of the area and separating settlements at risk of coalescence (in particular from land allocations in the Local Plan).
· In defining the extent of a gap, no more land than is necessary to prevent the coalescence of settlements should be included, having regard to maintaining their physical and visual separation.
Taking into account;
landscape character, landscape features (woodland, river valleys and landform), topography, distance, existing vegetation and land uses, the nature of settlement edges and how they integrate with the adjacent countryside, key views, the sense of leaving a place

Inclusion of this policy would align with:
Policy DS2(S) Spatial strategy
xiii. Safeguarding the intrinsic character of the countryside and the environment and biodiversity within it through the careful management of development to meet local needs whilst supporting the rural economy

Object

Representation ID: 9632

Received: 26/07/2022

Respondent: Miss Tara Malciw

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The Eastern Region was deemed the highest rising population in the 2021 Census, in all of the UK and within that, Bedford was the highest rising population with an increase of 17.7% against the national average of 6.6%. I feel that the Local Plan should recognise that growth has already occurred at an alarming rate in Bedford, and further development is not required. I understand, as a Police employee, the need of the public and the housing complications, however I feel the demand could be spread more equally into other areas such as Luton which rose only by 10.9% in comparison or better still, outside of Bedfordshire and the Eastern Region.

The plan may be sound legally, but morally and ethically it poses many concerns, ruining villages where elderly people now feel vulnerable, creating roads where children cannot play and increasing crime rates in rural areas at an alarming rate. The crimes have not only increase to a rate 5 times higher, but the crime type has worsened too from petty crimes and theft of a drink from a shop to stealing Audi’s from peoples homes, removing their means of getting to work, and stealing laptops from the elderly in their own homes, removing their only means of communication.