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 includes an acknowledgement that there is a 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 aim 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 to meet minimum 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 development associated with the Arc being attained before the end of the plan period. 1.5. The Vision could also include more ambitious commentary regarding Bedford unique character and locational position within the arc which could see it grow beyond its traditional role as a small town to be of regional significance. 1.6. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 3 PHILLIPS PLANNING SERVICES LTD 1.7. 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. 1.8. 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

1.9. 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. 1.10. It is therefore appropriate to plan for a longer period in line with the Arc strategy.

Nothing chosen

1.11. Whilst it is helpful to seek views on the specific, 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 option. 1.12. 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. 1.13. 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, then results in the plan failing to deliver sufficient housing. 4 PHILLIPS PLANNING SERVICES LTD 1.14. 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. More generally the NPPF includes a focus for using brownfield land where this is well located and can deliver growth in appropriate locations. 1.16. Having regard to the above Cloud Wing UK Limited consider that there is significant merit in pursuing the ‘Yellow’ A421 based growth option in combination with other strategies such as the ‘Pink’ rail route related growth option to the southwest of Bedford. 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. The chosen strategy must be capable of delivering the step change in housing and economic growth required with future site selection based upon the potential for future catalytic growth beyond site boundaries.

1.18. Infrastructure including education, health, transport, community facilities and open space are considered key matters 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 / controlled by Cloud Wing UK Limited can deliver significant new infrastructure including new roads, school, bridge crossings of the railway line enabling the closure of level crossings and associated open space and new footpath and cycle links across large parts of the vale and Marston Forest area. 1.21. Sites which can come forward with minimal impact upon existing communities i.e. sites which can deliver infrastructure to serve new residents as well as those which can deliver enhancements for existing communities should be favoured. 5 PHILLIPS PLANNING SERVICES LTD Question 6 - More employment sites will need to be allocated alongside housing growth. Where do you think new employment sites can be located in Bedford Borough? 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 Cloud Wing UK Limited 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 the ‘Pink’ rail related growth south west of Bedford. 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 6 PHILLIPS PLANNING SERVICES LTD and around Bedford, and focusing development on a small number of key nodes in the Marston Vale.“ 1.27. On page 36 the report comments that the key opportunities for growth over the next 30 years could include: “concentrated growth in the Marston Vale between Milton Keynes and Bedford, focused around a few key rail nodes in the area, and providing the critical mass to expand local services; …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 also south / south west of Bedford. Cloud Wing UK Limited has submitted an outline planning application in late 2018 for a 550-acre B1/B2/B8 mixed employment development (‘’Bedford Business Park’’), where nearly half of the site is brownfield land with excellent connectivity, fully in alignment with the guidance.

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. Identifying the unique selling point and establishing the competitiveness of Bedford will be extremely important to attract the best talent and employment opportunities to Bedford. The biggest constraints for the arc to unleash its potential are, 1) undersupply of homes to support jobs and growth, particularly a lack of large scale residential homes close to employment opportunities; and, 2) lack of large scale employment that can satisfy the needs of modern occupiers (to scale up and offer scope for hybrid development). 1.30. Bedford could benefit significantly over the coming plan period if it engages with the Arc vision. The area to the south of Bedford with its stock of brownfield sites and connectivity is a ready choice to be promoted and invested in. 1.31. There is already a 1,000 homes allocation at Stewartby Brickworks located adjacent to a proposed 550 acre Business Park. Such proposals present an opportunity for Bedford to attract investment, create jobs and generate economic growth.

1.32. No comments are provided on this matter.

I agree

1.33. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.34. 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. 1.35. 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. 1.36. 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. 1.37. 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.

1.38. 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.

1.39. 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. 1.40. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.41. New development on larger sites can and should be required to deliver new public routes which link with existing footpath and bridleway networks. 1.42. New developments should also be required to deliver Electric Vehicle Charing points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles. 1.43. More generally considerations should be given by the Council to ensuring that residential and employment uses are comprehensively plan and located adjacent to each other so as to maximise internal trips. 1.44. Large scale developments in particular can play an important role in influencing people’s behaviour given its scale of infrastructure.