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Form ID: 2347
Agent: Arrow Planning Limited

No

2.1 The scope of the Local Plan Review should include specific reference to the Ox-Cam Arc (‘the Arc’) as a key national issue that will have significant impacts and relevance to Bedford Borough. 2.2 There should, therefore, be a specific aim included within the scope of the Local Plan Review that addresses issues and proposals relating to the Arc. 2.3 It is acknowledged that the Government’s White Paper on proposed reforms to the Planning System was published partway through this consultation. Clearly, the scope of the Local Plan Review may have to be adjusted to consider any changes to National Policy which result from changes following the consultation, albeit the timetable for any such changes is currently unclear.

Form ID: 2348
Agent: Arrow Planning Limited

3.1 Firstly, the draft Vision starts with the wording “by the end of the Plan Period”. Whilst the Plan Period sets out the timetable for the Plan’s Policies to achieve their aims, a Local Plan will ultimately have far reaching consequences well beyond the period. 3.2 This is an unambitious and negative approach, and instead, the Vision for the Plan should be one that provides a pathway for life beyond the Plan Period. 3.3 Secondly, the Vision’s focus appears to be on Bedford and greater consideration within the Vision should be given to other areas, particularly sustainable settlements such as Wootton, and the opportunities for a comprehensive holistic approach to development in those locations which would deliver much needed housing and wider community benefits.

Form ID: 2349
Agent: Arrow Planning Limited

I do not agree with this plan period

4.0 Question 3 In line with Government policy, the shortest plan period would be 2020 to 2040. Do you agree with this plan period? If you think the plan period should be longer, what plan end-date would you suggest and why? 4.1 The Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change. Arrow Planning on behalf of Denison Investments LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 4 4.2 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for. 4.3 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas.

Form ID: 2350
Agent: Arrow Planning Limited

Brown – Urban based growth , Yellow – A421 based growth , Pink – Rail growth , Orange – East-West rail northern station growth

5.1 We propose that an approach including a combination of elements is the most appropriate one to take in this instance. As the consultation sets out, each proposed approach will have advantages and disadvantages. 5.2 For example, taking an urban based growth approach is unlikely to meet the housing and job needs for the Borough, and will also miss opportunities to support and strengthen local communities outside of the urban areas. Meanwhile, a reliance upon new settlements will not meet needs in the shorter term given the long lead in time for new settlements. 5.3 A dispersed approach is inefficient as it discourages sustainable transport given the rural nature of much of the Borough. 5.4 A logical and sustainable approach would be a combination of urban, with a focus on the transport corridors of the A421 and rail corridors, so a combination of “Brown”, “Yellow”, “Pink” and “Orange”. 5.5 Settlements such as Wootton have historically taken growth and this evidences the suitability of Wootton as a sustainable location to meet housing needs. It is ideally located close to transport corridors and existing and future employment opportunities, whilst benefitting from facilities such as a Secondary School. 5.6 It is also vital that the Council does not concentrate development in specific areas, and instead ensures a variety of sites and locations. Focusing on areas that did not have allocations in the Local Plan 2030, such as Wootton, would enable a wider range and choice of housing to come forward and avoid potential supply issues caused by a reliance on strategic sites or in areas still delivering Local Plan 2030 (or older) sites.

Form ID: 2353
Agent: Arrow Planning Limited

6.1 A key element of infrastructure that is often overlooked at the outset is power. The ability to power developments, and, either alongside this or independently, for new renewable energy developments to connect to the grid, is a significant cost consideration. 6.2 Therefore, BBC should be giving careful consideration to energy infrastructure and the ability for development needs to be met at the outset, without large investment sums required that in some instances can prevent sites from coming forward.

Form ID: 2354
Agent: Arrow Planning Limited

I agree

7.1 Guidance in respect of responding to climate change should be included within the Local Plan, rather than as an additional document. In order to achieve BBC’s Vision and aims, and to respond to climate change, the approach to responding to climate change should be at the heart of the Plan. It should not be left to additional guidance, and instead should be set out in the appropriate level of detail within the Plan. 7.2 In addition, the approach to climate change should include support for innovative and changing technology. It should not be prescriptive, and it should recognise that technology will change rapidly over the lifetime of the Plan. In particular, it should support and actively encourage those applicants who are proposing innovative and ground-breaking solutions which respond to climate change.

Form ID: 2355
Agent: Arrow Planning Limited

8.1 We are not aware of any local evidence or need to go beyond national standards. Instead, the Local Plan should require development to be in accordance with the latest national standards at the time that a planning application comes forward.

Form ID: 2356
Agent: Arrow Planning Limited

9.1 The consultation document sets out sensible suggestions such as safe and green cycleways, dedicated busways or more innovative transport systems and modes. However, what it does not recognise is the importance of locating development in the correct locations which will in turn encourage people to make greater use of sustainable modes of transport. 9.2 Placing development near to sustainable transport nodes, or developing new transport nodes and interchanges, will make it more attractive for residents to use those methods of travel. Proximity to existing services and facilities, particularly those such as schools, is effective at discouraging car use and encouraging walking and cycling. 9.3 Similarly, improving connectivity between these various locations for non-vehicular means of travel will encourage the use of transport methods other than the private car.

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