Issues and Options

Yes

Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 4 2.8 To deliver this number of homes, the Local Plan should also include additional land to provide a 10-20% buffer above the identified housing need figure in order to ensure that there is flexibility in the plan to meet requirements should sites fail to come forward. 2.9 Therefore, the suggestion in the Issues and Options Consultation Document that 800 dwellings would be the lowest number in the housing range needs to be reviewed immediately and the appropriate development strategy considered in view of this higher figure. 2.10 The tone of central government is to plan positively to achieve a significant boost in housing delivery. This has been set out in both the 2017 and the 2020 Housing White Papers, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge arc and the fact that Government confirmed that the 2016-based household projections did not provide an appropriate basis for the standard method. 2.11 The scope of the Local Plan should therefore be to accommodate a minimum of 15,000 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance). If the standard methodology changes and the minimum need figure reduces slightly as a result, having planned for a higher target to start with allows flexibility to remove sites from the draft plan if necessary. This approach would not be possible should the Council take the approach of planning for an inappropriately low housing target from the outset. Oxford to Cambridge Arc 2.12 Another key issue which should be addressed in the scope of the Local Plan Review is Government ambition for the Oxford to Cambridge Arc. 2.13 Central Government have outlined the ambition for the Oxford to Cambridge arc to deliver 1 million new homes and 1.1 million new jobs by 2050. It is a key growth area, with significant infrastructure investment planned with committed funding. In order to accelerate new housing and infrastructure development, the Government is in the process of creating four new Development Corporations in the Oxford to Cambridge Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge. 2.14 The March 2020 Budget identified the Oxford, Milton Keynes, Bedford and Cambridge Arc as a ‘key economic priority’ and noted that a preferred route for East West Rail between Bedford and Cambridge had been announced. The Budget also set out the plan to work with local partners to develop a long-term Spatial Framework with the intention being to assist in strategic planning across the Arc. 2.15 The Government is therefore committed to the delivery of the Oxford to Cambridge Arc, with the expectation being that there will be significant residential development to support the economic potential of the area. 2.16 Local authorities within the Arc, such as Bedford Borough, should plan positively/proactively for predicted growth in line with these key aspirations and commitments. Whilst Bedford Borough have planned for their existing growth projections, these are not considered to go far enough to enable the level of development and growth that is being proposed as part of the Arc initiative. Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 5 2.17 Policy 1 of the adopted Local Plan 2030 requires the Local Plan Review to address Arc related issues. The implications of the Arc, including policy announcements and infrastructure investment decisions, should be assessed against Local Plan proposals. This is particularly important where they relate to the level of growth to be planned for and spatial decisions. 2.18 The position within the Arc is also likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council are able to respond to any announcements avoiding delays in the preparation of the Plan.

1.1 This Issues and Options representation is made on behalf of The Police and Crime Commissioner for Bedfordshire who has a land interest in Kempston. A separate call for sites submission has been made for this site. 1.2 The Police and Crime Commissioner for Bedfordshire is promoting land west of Bedford Police HQ for residential development. 1.3 This site is located within the urban area of Kempston and has access to a wide range of services including education provision and Woburn Industrial Estate (a major employment area). Services and facilities in Bedford and those being provided as part of the recent growth to the south of Kempston are also in close proximity to the site. Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 2 1.4 The site is relatively unconstrained, although it is noted that it is currently identified as an urban open space, despite being inaccessible to the public and lacking amenity/biodiversity value. 1.5 The site will be able to connect to an access onto Woburn Road, which was granted consent (application ref: 20/00278/MAF) in early 2020. 1.6 This representation is structured around the 13 comments which are set out in the Issues and Options Paper. However, only those questions that are relevant to The Police and Crime Commissioner for Bedfordshire’s land interest have been answered.

3.1 The Draft Vision of the Issues and Options document should focus on the key considerations included within the scope of the Local Plan Review. 3.2 Whilst at this moment in time it is recognised that options still need to be assessed and decisions made about the spatial strategy, future iterations of the Vision should be more specific and set out clearly what the area will be like at the end of the plan period. 3.3 There is currently limited reference in the Vision to development in the town centre and no mention of the contribution that the redevelopment and intensification of urban sites inside the town centre, such as that owned by the Commission, could make to the overall development strategy and the sustainability of Bedford. Without being site specific, it is suggested that text is added to the Vision to recognise the contribution of such sites to the overall strategy. 3.4 As with any Local Plan Review, it is considered that the successes and failings of the Plan that came before it should be used to refine and alter strategies taken. In this regard, as is discussed under question 5, the lack of allocated sites with short term delivery potential in the Local Plan 2030 has contributed to a situation where the five year land supply is being challenged. This needs to be avoided in the Local Plan Review which requires the allocation of small to medium sized sites for development alongside larger allocations and possibly new settlements with longer lead in times. It is suggested that this flexibility and differential in the deliverability of sites is reflected in the Vision. 3.5 It is also noted that it is common practice for objectives to be used in a Local Plan vision which set out what the Local Plan should achieve to make the Vision a reality. Incorporating objectives into the Local Plan Vision would show in more detail what Bedford Borough are trying to achieve over the plan period.

I do not agree with this plan period

4.1 As per the wording of paragraph 22 of the NPPF, the strategic policies for an area: ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.2 If it is assumed that the preparation and adoption of the Local Plan happens in line with the expected timetable, with the revised Local Plan adopted in the winter of 2023 at the earliest, the plan period would run until the end of 2038. By specifying a plan end date of 2040, an allowance of 24 months would be established which would provide some flexibility in the plan production process to ensure the plan looks ahead 15 years from adoption. 4.3 However, recent experience has demonstrated how difficult it can be to deliver a Local Plan in line with the stated timetable; with delays emerging as part of both the plan preparation process and at the examination stage. Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would more appropriate and would provide flexibility in the timetable. 4.4 A plan period which starts at 2020 is appropriate given that that this will be the base date for the evidence gathered to support the Plan.

Brown – Urban based growth , Yellow – A421 based growth , Red – New settlement based growth

4.1 As per the wording of paragraph 22 of the NPPF, the strategic policies for an area: ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.2 If it is assumed that the preparation and adoption of the Local Plan happens in line with the expected timetable, with the revised Local Plan adopted in the winter of 2023 at the earliest, the plan period would run until the end of 2038. By specifying a plan end date of 2040, an allowance of 24 months would be established which would provide some flexibility in the plan production process to ensure the plan looks ahead 15 years from adoption. 4.3 However, recent experience has demonstrated how difficult it can be to deliver a Local Plan in line with the stated timetable; with delays emerging as part of both the plan preparation process and at the examination stage. Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would more appropriate and would provide flexibility in the timetable. 4.4 A plan period which starts at 2020 is appropriate given that that this will be the base date for the evidence gathered to support the Plan.

6.1 Committed infrastructure projects in Bedford Borough, such as East West Rail and upgrades to A421, will be delivered within the next plan period and will enable growth to be sustainably focused in these locations. 6.2 However, neighbouring authorities and key stakeholders should be consulted about potential enhancements to the A1, M1 junction 13, and railway stations north and east of Bedford. This will ensure that a cross-boundary approach is taken, and that available funding is targeted on those areas and projects which deliver maximum benefit for the wider area. Enhancements at the locations could enable growth in both Bedford Borough and the wider area. 6.3 However, it will also be important that the availability of services and facilities in individual settlements is properly assessed as part of developing the spatial strategy. Bedford and Kempston are highly sustainable locations in their own right due to the level of existing infrastructure, e.g. shops, employment and leisure provision. As a result, consideration should be given as to how existing infrastructure can be utilised when identifying sites for development as part of the growth strategy thereby ensuring that growth is focused on sustainable locations.

7.1 The A421 corridor is the logical location for additional employment growth in Bedford Borough, as well as close to new rail stations, should these form part of the future development strategy. 7.2 The Local Plan Review should though recognise that many residents of Bedford Borough travel outside of the Borough for work, especially given the proximity to major employment centres such as Cambridge and Milton Keynes and the ability to reach London via train. It is therefore important that the overall development strategy recognises that many residents will travel for work and that the allocation of residential development land needs to reflect this. 7.3 Therefore, sites such as that at Bedford Police HQ, with good access to the A421 and also good public transport into Bedford rail station, are ideal for allocation with regards to access to employment opportunities not only locally but outside Bedford.

8.1 As noted in response to question 6, it will be important that new residential development is located close to the key pieces of infrastructure, such as East West Rail and the A421, which will provide access to the key economic centres like Milton Keynes, Oxford and Cambridge. 8.2 Rather than identifying sites in less well-located areas of the Borough, the allocation of development sites within the urban areas of Bedford and Kempston will ensure that the benefits of improved connectivity to key economic centres such as Oxford and Cambridge are captured. Growth within the urban area will allow new residents to take advantage of transport connections afforded by East West Rail and the A421 and will do so in a way which minimises the impact on the wider road network. 8.3 It is though acknowledged that new residential development should also be planned within the rural area to ensure the ongoing sustainability of villages.

9.1 Paragraph 20 of the NPPF recognises that planning measures to address climate change are a strategic matter and should therefore be at the heart of decisions made in relation to the development strategy. 9.2 It is further added in paragraph 149 of the NPPF that a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity, should be taken in Local Plans. 9.3 In line with the above, development should avoid areas which are more vulnerable to the impacts of climate change such as flood plain. Adaption measures should also be built into plans i.e. new blue and green infrastructure. New development should be located in close proximity to public transport infrastructure, whilst ensuring that there are opportunities for existing rural settlements to remain functioning with a range of services and facilities for residents. 9.4 Policy standards which are too specific, stating what is to be achieved by new development, should be avoided, unless they relate to the application of the Government’s technical standards as required by paragraph 150 of the NPPF. This because climate change policy and good practice is constantly changing. Climate change scenarios predict extensive changes by the end of the earliest plan period of 2040, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. As a result, Bedford Borough need to be able to adapt to innovation and changing legislation and have the flexibility to accommodate these changes within the lifetime of any planning documentation. 9.5 Also, allowing for changing technologies and approaches has the potential to help with viability as these areas develop and improve and are more widely adopted reducing costs.