Issues and Options

As a rural parish we note especially the draft vision relating to rural communities: "The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. Rural communities will embrace sensitive development through neighbourhood plans that provide and support much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all." Firstly, we commend that the vision recognises the 'intrinsic character and beauty' of the rural areas. However, as a policy objective, mere 'recognition' carries little meaning. We understand the real underlying sentiment of the Council to be the 'protection' of the intrinsic character and beauty. This should be reflected in the policy wording. Secondly, we note that that the section on the Borough's country side is the only section in the draft vision which implies, and imposes, a value judgement without corroborating evidence. The vision suggests that rural communities 'embrace sensitive development through neighbourhood plans that provide much needed housing' [our emphasis]. As a rural community it can feel as if the Borough's housing needs are imposed on rural communities without adequate regard for the intrinsic character and beauty, transport and infrastructure and, indeed, the actual housing needs of the community itself (as shown, for example, by the Housing Needs Survey conducted as part of the Neighbourhood Plan process). As such we cannot support this particular aspect of the draft vision. Thirdly, the vision specifically identifies 'the Embankment and Victorian parks' as 'jewels in Bedford's crown'. The Borough is equally fortunate to have the River Great Ouse running through its boundaries. The river valley, together with the historic settlements which line the river (such as Harrold) form a beautiful and largely intact rural landscape characterised by open fields, woodlands, ancient churches, villages with their prominent sandstone architecture and conservation areas, single lane bridges and winding country roads. This ecosystem is as much a jewel in Bedford's crown and deserves the same recognition and focus on sympathetic protection and developments as the Embankment and the Victorian parks. Without this recognition there is a very real danger that this historic landscape with its unique character becomes unrecognisable within a generation and irreversibly lost. Each of the villages in the Ouse valley are preparing Neighbourhood Plans and, as part of this process, will draw up Village Design Statements. Given the time and money spent on producing these policies we hope that these could inform a more detailed vision. In conclusion we recommend that the draft vision be amended as follows: "The borough is characterised by both an ancient countryside and an historic market town. The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be protectedrecognised. Rural communities will embrace sensitive development through neighbourhood plans that provide and support much needed housing and employment, and rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all."

Yellow – A421 based growth , Pink – Rail growth

We support options 'Yellow' and 'Pink'. We regard Options 'Orange', 'Grey', 'Red', and 'Brown' as being not just disadvantageous to our current Parishioners, but also to result in a suboptimal outcome for the population of the planned new developments. Options 'Orange', 'Grey' and 'Red' all require either dispersed, or concentrated, but substantial development in the countryside. The current infrastructure, both in terms of the existing road network and public transport (or more accurately, the lack of public transport) already struggle to support the existing rural population. Traffic congestion makes access to employment and schooling in the urban centres a time-consuming and miserable experience. The villages of North Bedfordshire regularly identify 'traffic and speeding' as one of the main problems affecting the population. In our view, traffic and speeding is simply a reflection of the large number of cars per household and the number of journeys which are required to access work and schooling in Bedford (and London via the Bedford train link), Milton Keynes, Northampton, Cambridge or Oxford. The historic fabric of the North Bedfordshire villages and the local geography exacerbate the traffic problem. Each of the historic villages has its unique traffic bottleneck, be that a single lane bridge or a single or narrow lane in the village centre. In addition, the regular and frequent flooding of the River Great Ouse requires lengthy journeys up or down stream to avoid closed bridges. This is the case even before the housing required by the 2030 Local Plan has been built. We believe that each of the options 'Orange', 'Grey' and 'Red' will worsen the current situation. In addition, 'Orange' is entirely predicated on an additional train station North of Bedford along the Oxford/Cambridge train line. Given the lack of certainty of the planned route and the likely opposition to an additional stop just outside of the main Bedford station, this option strikes us to be predicated on unrealistic or undeliverable assumptions. We are concerned that option 'Brown' could add significant pressure on the A6 access route into Bedford. The A6 is the main access for the North Bedfordshire countryside into Bedford, and it is not unusual for 20 minute traffic delays to build up from 7.30am every morning. By contrast, options 'Yellow' and 'Pink' would be based along existing well-developed, or planned, traffic infrastructure capable of supporting the additional growth.

The current infrastructure supporting the rural communities is generally poor. Roads are often in need of repair and the service provided by public transport is unattractive. For example, the bus route from into Bedford is long and the timetable and the early finishing all still make driving into Bedford the preferred option for those who can and thus adding to traffic problems. Unless these severe shortcomings are addressed in a sustainable manner, any new development in the rural areas will make the current situation worse. Our experience leaves us with little hope that a solution will be found. New development, especially in the numbers required, cannot be based on increased car usage. Access routes into Bedford and traffic in the centre is already too congested. New developments either need to connect into a high-frequency existing, or, if not existing, feasible public transport network, or alternatively permit journeys by bike or on foot to access, work, school or leisure.

Bedford will be in a unique position within the Oxford/Cambridge Arc. It will be right in the centre: approximately equidistance from Oxford and Cambridge, and with the additional benefit or relatively quick access to central London and Cross-Rail (at least when compared with Oxford and Cambridge), as well as access to the North via the M1 and the national train network. Oxford and Cambridge attract people from across the country and the world because of their respective rich mix of work opportunities, culture, and living environment. Increased opportunities for agile working will give people greater freedom to choose where to live, but this will not diminish the need for excellent transport connectivity. People will set up homes in places which are affordable, and offer an attractive mix of culture, leisure and transport links. These places will no longer just be places from which to commute to work, but become places in which people will spend significant time and money. Given Bedford's central location within the Oxford/Cambridge Arc, it offers the ideal environment for start-ups spinning out of the academic centres of Oxford and Cambridge. At its core, the Borough offers a mix of attractive countryside and a historic town centre which in parts already is, and in others has the potential for being, visually attractive, while being relatively affordable in comparison to Oxford, Cambridge and London. Good schools for both boys and girls make it an attractive place for families.

Dear Sirs Bedford Borough Council Local Plan Review: Response by Harrold Parish Council to the Issues and Options Consultation This document is the response by Harrold Parish Council to the Issues and Options Consultations forming part of the Local Plan Review by Bedford Borough Council. We hope you will find our comments to be helpful. The impact of the final Local Plan clearly has the potential significantly to impact our Parish and the lives of our Parishioners. We welcome the opportunity to take an active and constructive role in the Local Plan process, and will be available to discuss our response to the Issues and Options Consultations at your convenience. Yours faithfully David Brough – Clerk to Harrold Parish Council

Yes

We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford. Therefore, there is no support for urban growth in North Beds as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic. Those routes are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.

We believe that there is a need to specifically refer to and protect the Borough’s main asset, the River Great Ouse and the Great Ouse Valley , in the vision given it traverses the landscape creating beautiful landscape views and is a haven for wildlife, particularly given climate change challenges and solutions are likely to be centred around the river. There is also no mention of improved road infrastructure in the north of the Borough which at the moment is served only by the A6. This is a totally inadequate road and cannot cope with the amount of development currently envisaged in the north of the Borough. In addition, little consideration has been given to the safety and environmental impacts on the communities that live astride the A6. This is particularly important for Milton Ernest. It is essential that traffic generation is not thought of solely in terms of road capacity and convenience for road users - the needs of residents must be given at least an equal priority There is also current or proposed rail infrastructure available for the area so this would mean that car-based commuter options are the only viable option for the area. The villages in the north of the Borough already suffer from ‘rat-running’ by drivers either travelling into Bedford town for access schools/station or to reach main arterial road networks leading to other areas. The A6 already cannot cope with the amount of traffic travelling into Bedford or on to the Great Ouse Way. We could not support the development of any of the large developments proposed in the document along the A6 corridor.

I agree with this plan period

Agree with plan period 2020- 2040. The longer the plan period is, the more challenging it can be for communities to respond to social, economic and environmental changes. The fact that local plans need to be reviewed at least five years in accordance with the National Planning Policy, reinforces that the shortest plan period is preferable.

Orange – East-West rail northern station growth

The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. There is no support for urban growth in North Beds near Rushden as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. East Northants is also planning a minimum of 2,700 homes as part of the Rushden sustainable urban extension in the east of the Town, alongside the A6/John Clarke Way over the next 15 years as well as further housing at Rushden Lakes as part of that development. Due to its proximity to Northants, any considerable development proposed in Northants that’s will “border” any significant house builds in Bedfordshire cannot be examines in isolation. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land.   Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel.   Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner. Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.

Infrastructure shapes our lives – it is the foundation upon which our economy is built. It vital that we are determined to deliver better infrastructure to grow the economy and improve opportunities for people across the country. Transport links get us where we need to be, energy systems power our homes and businesses, digital networks allow us to communicate and infrastructure supplies us with clean water / takes away our waste. It is vital to improving our quality of life and integral to the creation of vibrant new places to live and work. Suitable and appropriate infrastructure provisions have taken on an ever-increasing importance in the light of recent global COVID-19 Pandemic Depending on the growth location (see Question 4 and answer), appropriate transport and service infrastructure will be needed including new roads, dedicated and safer pedestrian and cycle routes, providing assistance for vulnerable road users, EV charging facilities, sustainable drainage systems, schools, doctors and dentist premises, convenience shopping facilities, sports and recreation facilities and community facilities. Suitable and appropriate employment uses commensurate with the scale of the growth option would be desirable.