Issues and Options

Yes

1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope notes the need to accommodate growth in line with national requirements no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the desire of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”

1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery of basic indigenous growth requirements. Rather the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of growth associated with the arc being attained before the end of the plan period. 1.5. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 1.6. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 3 PHILLIPS PLANNING SERVICES LTD 1.7. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.

I do not agree with this plan period

1.8. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy cover the period to 2050. 1.9. It is therefore appropriate to plan for a longer period in line with the Arc strategy. We consider the plan should cover the period to 2045 if not 2050.

Brown – Urban based growth , Yellow – A421 based growth

1.10. Whilst it is helpful to seek views on the broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one single option. 1.11. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. The NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which if it does not perform as expected results in the plan failing to deliver sufficient housing. 1.13. Paragraph 68 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. 4 PHILLIPS PLANNING SERVICES LTD 1.14. Alongside this, Paragraph 72 states that the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities. 1.15. The NPPF promotes development in rural locations. Paragraph 78 states that in rural areas housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify how new development will enable villages to grow and thrive 1.16. Having regard to the above the Howbury Hall Estate considers that there is significant merit in pursuing a mix of the ‘Yellow’ A421 corridor growth and ‘Brown’ expansion of the Bedford urban area options. This is particularly the case given the recommendations of the National Infrastructure Committee in respect of the Oxford to Cambridge Arc which is a key reason for the local plan review taking place. 1.17. Development along and close to the A421, in locations which good, close access to junctions onto the expressway, particularly if well related to Bedford and existing housing should clearly be favoured.

1.18. Infrastructure including education, health, transport, community facilities and open space are considered key considerations in the delivery of growth in Bedford Borough. 1.19. Sites which can deliver or provide important contributions towards the delivery of new infrastructure should be favoured when allocations are being considered. 1.20. Land owned by the Estate adjacent to the eastern edge of Bedford just off the A421 would deliver a new school as part of new housing development (if required) and associated open space and new footpath and cycle links to the surrounding network. 1.21. There are no issues of deliverability or technical constraints to development of the estate land such that full contributions towards relevant and justified local infrastructure can be delivered.

1.22. In addition to new residential growth achieving sustainable development includes building: “…..a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;” (NPPF paragraph 8(a)) 1.23. The NPPF (paragraph 80) requires that new planning policies help create the conditions in which businesses can invest, expand and adapt. The Government places significant weight on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. 1.24. In terms of the preferred strategy for economic growth the Estate hold similar views to that set out above regarding housing growth (Question 4) i.e. that this should follow a mixed approach but with a focus on the ‘Yellow’ A421 corridor and ‘Brown’ urban expansion options. 1.25. This would reflect the NIC’s locational growth strategy for this area over the next 30 years. In ‘Partnering for Prosperity’ (November 2017), when discussing the employment needs in the corridor the NIC report advises: “…..the area could support around 335,000 new jobs to 2050, increasing economic output by around £85bn per annum (2011 prices). However, by meeting future needs and removing the constraints to growth arising from the area’s housing shortage the area could sustain a transformational level of growth, supporting around 1.1m new jobs and increasing economic output by £163bn per annum.” (Page 25) 1.26. Most specifically when discussing locational requirements for the new employment growth the report states “……..major urban extensions – for example, between Oxford and Milton Keynes, and between Bedford and Cambridge………….. unlocking growth in and around Bedford,…….“ 6 PHILLIPS PLANNING SERVICES LTD 1.27. On page 36 the report comments that the key opportunities for growth over the next 30 years could include: “…major development around Bedford, supported through the introduction of East West Rail services and the wider connections that exist via the Midland Mainline;” 1.28. This guidance is clear i.e. that growth should be favoured in locations close to the A421 and as extensions of Bedford. The Estate land around the A421 / Renhold / Great Barford junctions on the east side of the town is perfectly situated in this regard.

1.29. Providing growth along and around the strategic connections between Oxford and Cambridge (e.g. A421 and East-West Rail) are considered key to drawing in investment to the Borough and increasing the value of its economy.

I agree

1.31. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.32. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.33. Building Regulations provide a national standard and developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 7 PHILLIPS PLANNING SERVICES LTD 1.34. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters others have highly onerous policies which make construction in one area far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of this inconsistency and so a sense that what is being asked for is unfair or unnecessary. 1.35. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas as outlined above.

1.36. In a similar vein to our answer to question 9, we submit that there is no need to introduce local standards which change or exceed those required nationally.

1.37. The provision of new and enhancement of pedestrian and cycle routes to local facilities and accessibility to public transport are clearly ways in which we can encourage the greater use of sustainable modes of transport through the Local Plan. 1.38. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.39. New development on larger sites can and should be required to deliver new public routes which link with existing footpath and bridleway networks. 1.40. New developments should also be required to deliver Electric Vehicle Charging points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles. 8 PHILLIPS PLANNING SERVICES LTD 1.41. The provision of dedicated charging stations for EV ‘s along the A421 would also encourage a change in people’s behaviour by providing greater convenience and enable movement along the corridor in more sustainable vehicles. A lack of dedicated charging stations on main routes continues to be a bar to use of EV’s for longer journeys. 1.42. The Estate have made submissions as part of the Call for Sites process highlighting the availability of land for allocation as an EV charging facility.