Issues and Options

I agree with this plan period

It will be important to consider opportunities/issues relating to growth at Rushden through both plans. The timetable for the Bedford Local Plan is set out on page 10 of the document and includes Draft Plan consultation Summer 2021, Plan for submission consultation in Summer 2022 and adoption by Winter 2023. The potential timetable for the NN Strategic Plan agreed by the JPC at its 25th July 2019 meeting runs behind the Bedford Local Plan but includes Proposed Submission consultation in Winter 2022 and adoption in Winter 2023. It is considered that the timetables are sufficiently aligned to ensure cross-boundary issues can be fully considered through respective plan-making. To this end, it is noted that the proposed plan end date is 2040, and consideration should be given as to whether an end date of 2050 to align with the Arc would be beneficial.

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

The JPDU engaged positively with Bedford Borough Council (BBC) through the preparation of the JCS and the Bedford Borough Local Plan. A number of Duty to Cooperate meetings were held with the JPDU, BBC, East Northamptonshire Council, Borough Council of Wellingborough and Northamptonshire County Council (NCC) Highways to discuss cross-boundary issues. This positive engagement is ongoing. Of most relevance to North Northamptonshire are the potential locations for growth, particularly the options described in the paper as: • Brown- Urban based growth: Growth in and around the Bedford / Kempston urban area, together with extensions to Rushden and St.Neots. Building at higher densities in and around urban areas could deliver a significant number of homes. • Red- New settlement based growth: In addition to expansion of Wixams (new settlement) a number of new settlements could be developed. During the course of the preparation of the Local Plan 2030 four potential new settlement options were discussed but were not taken forward at that time. These and other new settlement options that have yet to be put forward could be considered as part of this plan. Brown- Urban based growth This option would include extensions within Bedford borough that would functionally act as an extension to Rushden. The scale and location of growth at Rushden is a matter for the update of the JCS through the North Northamptonshire Strategic Plan, although cross-boundary considerations will need to be progressed with BBC as the plans are developed. It is important to note that the consultation paper makes no reference to a need for North Northamptonshire or other adjoining authorities to take Bedford’s growth. This has also not been raised in discussion to date with BBC. It is noted that Table 1 in the Issues paper provides a high-level summary of potential advantages and disadvantages of the options. It is noted that this identifies as a disadvantage for Urban based growth that “Growth may overstretch existing services, facilities and infrastructure in towns”. Infrastructure and service provision will be a key consideration in assessing options. The issues identified in this response should be included in this assessment process. The potential option identified in the Issues paper relates to zone RUS1 Rushden South, Between Wymington and south of Bedford Road (A6) that was previously assessed and discounted in considering options for expansion to Rushden. This work is summarised in the Rushden Sustainable Urban Extension Background Paper January 2015. The key positive attribute(s) were summarised as “Good connectivity to Rushden town centre via Wymington Road (emerging USS) and the key negative attribute(s) as “Development would lead to coalescence with Wymington. Contrary to adopted Bedford Borough Core Strategy). The summary/overview of the assessment recognised the need for issues to be considered through concurrent plan-making: “Expansion to south would entail full/ fundamental review of Bedford Borough Core Strategy. This would need to run concurrently with the NNCS Review and would be likely to lead to major delays in the process”. As previously identified, coalescence and the impact of growth on settlements such as Wymington will be an important consideration in assessing potential growth options in this locality. Whilst the comments regarding conformity with the Bedford Borough Core Strategy and the impact on the NNCS Review have been superseded, it will be important to consider opportunities/issues relating to growth at Rushden through both plans (see response to Q.3). In considering future levels and locations of growth at Rushden, alongside the issues identified in the summary table, and the issue of coalescence, the impact of future growth on the Upper Nene Valley Gravel Pits Special Protection Area (SPA) will also be a key consideration in developing the respective plans. In North Northamptonshire, the current SPA mitigation strategy focuses on the impact of recreational disturbance to the wintering waterbirds. Natural England (NE) are becoming increasingly concerned regarding functionally linked land to the SPA. There is a need to understand the interaction with the SPA and surrounding land as well as the impact from visitors. The JPDU have initiated discussions with NE regarding the scope of this work and it is noted that officers from BBC have stated they would wish to be involved in discussions. BBC has undertaken preliminary investigations into the potential for a new station on the Wymington Loop. This work is still in the exploratory stages and they will be keeping neighbouring authorities informed as work progresses. This is not identified in the consultation document so at this stage there is no detail on specific location and whether this may be deliverable. Provision of a deliverable station in this locality could provide future opportunities that may benefit North Northamptonshire. Opportunities provided by a deliverable railway station could provide significant benefits for North Northamptonshire and would be a key consideration in assessing the sustainability of potential growth options to the south/south west of Rushden. Policy 17 of the JCS North Northamptonshire’s Strategic Connections identifies investigating the longer-term potential for a railway station at Irchester (to serve Irchester, Higham Ferrers and Rushden) as a priority for further work and investment at criterion a) iv. Substantive progress has not been made on investigating this potential. Should a railway station at Wymington be proven to be deliverable, the impact on service provision from Wellingborough station, and the relationship with potential for a station at Irchester will be important considerations. It may be the case, that such a station could provide the same benefits sought by the JCS. Red- New settlement based growth The North Northamptonshire JPC previously made representations objecting to the Bedford Borough Local Plan 2035: Plan for Submission. These representations related to the proposed Colworth Garden Village (Policy 27 of the Local Plan 2035) and raised concerns as to whether the necessary supporting evidence base (specifically transport modelling) had been undertaken to justify the Garden Village proposal; such that the scheme as envisaged by policies 26 and 27 was not (considered to be) justified. They also set out that given the scale of Colworth Garden Village, that to be effective Policy 27 should give further consideration to the wider spatial implications of CGV beyond its immediate locality (Sharnbrook/Santa Pod). To be justified (in accordance with the soundness test) policy criteria should give consideration to broader connectivity; with particular reference to green infrastructure, walking, cycling and public transport. Following substantive changes to the Local Plan, including the removal of the Colworth Garden Village from the Plan, the JPC’s substantive objections were withdrawn. It is considered that the issues raised in the representation remain relevant to any consideration of the Colworth Garden Village site through the Local Plan Review. The recognition in the disadvantages section of the summary table that “Issues with new settlement proposals previously put forward would need to be resolved before they could be allocated” is welcomed. It is noted that the Issues Paper states that: “New settlements remain an option for this plan but only where there is a clear case that they would be developable in the plan period”.

In respect of transport modelling, the consultants who are undertaking the model for BBC have contacted the JPDU regarding growth assumptions to be incorporated in the development of the transport model. The JPDU have worked with the partner LPAs to provide this information and advised the consultants on the importance of NCC being satisfied with the model.

Future retail strategy and hierarchy and employment are likely to be cross-boundary issues that require consideration through the development of the respective plans.

Notwithstanding the potential for a new railway station, it will be important to consider sustainable transport links between North Northamptonshire and Bedford Borough, notably on the A6.

It is noted that the Environment section of the document references ‘Biodiversity Net Gain’. It is considered that, in accordance with the government’s ‘25 year Plan to Improve the Environment’ and the stated aims for the Oxford to Cambridge Arc, the plan should be seeking to achieve an overall net environmental gain. As referenced above, the impact of future growth on the Upper Nene Valley Gravel Pits SPA will also be a key consideration.