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Form ID: 1950

No

Whilst the Local Plan 2030 was recently adopted, it is important to acknowledge that this plan was prepared in the context of the NPPF 2012 and does not reflect more recent national planning policy, as detailed within the subsequent revisions to the NPPF in 2018 and 2019. It cannot therefore be correct to assume that the recently adopted Plan is up to date in the context of national planning guidance. The Council will also be aware that the MHCLG’s consultation paper ‘Changes to the current planning system’ was published in August 2020, with a view to bringing forward further changes to the planning system that are expected to be brought into effect before the end of the year. The Council will therefore need to undertake a more comprehensive review of all current policies within the adopted Local Plan to ensure consistency, whilst also ensuring imminent new guidance is also taken into account.

Form ID: 1951

Whilst reference is made to the benefits of East-West Rail through Bedford, there is no reference within the Vision to the Oxford to Cambridge Arc despite multiple references to this within the document and the significant economic benefits that are likely to accrue in view of the Borough’s strategic location at its centre. Specific reference should be provided within the Vision to this significant long term objective and how the Borough will look to take advantage of it in respect of economic and housing growth and associated infrastructure improvements.

Form ID: 1952

I do not agree with this plan period

Paragraph 22 of the NPPF requires that strategic policies should look ahead over a minimum 15 years period from adoption to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Based on the expected timetable for the adoption of the Local Plan Review, 2040 should be the minimum period that this Plan covers. The Oxford to Cambridge Arc is however a key economic priority for the Government with ambitions for significant economic and housing growth, supported by major improvements in infrastructure that are expected to be delivered during the period to 2050. As a result, the Budget announced in March 2020 that it plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the Ox Cam Arc up to 2050. Indeed, both Oxfordshire and the Cambridgeshire and Peterborough Combined Authority, either side of Bedford Borough, are preparing Strategic Plans to guide future plans and investment up to 2050. On this basis, we would suggest that serious consideration is given to extending the Plan period to 2050.

Form ID: 1953

Nothing chosen

It is appreciated that the implications for the Borough in respect of the Ox Can Arc, particularly in respect of future economic and housing growth and the associated infrastructure delivery, are not clear at this stage. As such, it is difficult to develop a spatial strategy for the Local Plan Review beyond that which addresses development needs solely related to meeting the needs of the Borough itself. This issue will however need to remain flexible as it is likely that progress will be made during this Plan’s preparation and the emerging strategy will need to be adjusted to address this over the coming months. In solely considering the growth requirements of the Borough, it is agreed that it is likely that the chosen strategy will need to be a combination of the growth options identified. It should however be acknowledged that the current Local Plan 2030, as recently adopted, already provides an appropriate sustainable strategy for the distribution of growth within the Borough that was found sound by an independent Inspector. In the first instance therefore, we would support an approach based on the adopted strategy and consider this should be the starting point for the consideration of further growth in future years, generally reflecting a combination of Brown (Urban based growth) and Grey (Dispersed growth). These options remain appropriate in that they would benefit from access to a range of existing services and facilities and ensure the benefits of growth are distributed across the Borough to support and enhance both urban and rural communities. Inevitably however, these sources are unlikely to be sufficient to fully meet the Borough’s own growth needs and other sources to accommodate the additional growth will be required. Of the remaining options, all potentially have a role to play. However, our concern with a number of these options is their reliance on the delivery of major infrastructure. For instance, Orange (East-West rail northern station growth) is reliant on a new rail station north of Bedford which is not part of any emerging proposals in connection with the Ox Cam Arc and unlikely to be acceptable if this increases journey times between Oxford and Cambridge, as highlighted. The other remaining options may well be better placed to respond to the wider Ox Cam Arc growth aspirations once their implications for the Borough are better understood.

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