Issues and Options

12.1 On behalf our clients we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 12.3 Specifically, in relation to the Council’s spatial options, greater weight should be given to site options providing for A421-based growth. As acknowledged in the Council’s list of advantages for this strategic option the A421 corridor provides sustainable links to a wide range of employment opportunities. In terms of modal shift the corridor already benefits from intercity public transport links connecting major settlements within the Oxford-Cambridge Arc with other sustainable settlements such as Great Barford. Specifically, the route of the X5 provides direct connections east towards Cambridge. Journeys on the same route can be continued west beyond Bedford, including access to the major employment hub in Central Milton Keynes. Services are accessed from the close to the heart of the village via stops at the Golden Cross on the Bedford Road/Roxton Road crossroads and thus in very close proximity to our client’s site. 12.4 This means that modal shift objectives are particularly relevant in the case of site options such as our client’s Land at Willoughby Park, which also relate well to existing services and facilities in Great Barford and would contribute to the provision of new, accessible, social and community infrastructure. Greater weight should also be given to sites within a single ownership, supported by comprehensive Masterplan proposals, that illustrate the absence of constraints to delivery of the benefits identified. 12.5 The cumulative benefits of growth in this location in terms of contributing to meeting local requirements for sustainable development and delivery of the Plan’s strategic priorities should be reflected in the Council’s site assessment and site selection process.

13.1 The Council’s stated intention to update its evidence base in relation to environmental sustainability, open space and Green Infrastructure is supported. It was noted during the Examination of the Local Plan 2030 that neither the Council’s evidence base nor the strategy to defer site allocations to Neighbourhood Plans would ensure that these objectives would be met in full. There are various examples of sites previously assessed as part of the plan-making process that were identified as preferred allocation options and would contribute towards the Plan’s objectives for the natural environment but have not since been supported as allocations through the development plan (i.e. through the Local Plan 2030 or subsequent Neighbourhood Plans. 13.2 In updating its evidence base the Council should seek to ensure that the development plan brings forward allocations that satisfy future requirements for growth e.g. additional opportunities for sport and recreation. This is not achieved through the Local Plan 2030 where requirements are identified but meeting these is deferred to Neighbourhood Plans. There is a strong prospect that some Neighbourhood Plans will not deliver the type and location of sites that would secure optimum Green Infrastructure enhancements. 13.3 Where any requirements remain unmet, solutions should be clearly set out via the policies and allocations of the Local Plan Review. Specific allocations should be supported, particularly where this align with the Council’s spatial strategy and objectives for sustainable development and would provide for the additional requirement for housing growth in the period to 2030 and beyond. In this context, allocations to meet housing needs in full and deliver other priorities (such as Green Infrastructure) should not be deferred to the review of Neighbourhood Plans. 13.4 It is essential that the Council’s Infrastructure Delivery Plan (most recent version dated December 2018) is updated to reflect the requirements of further evidence, once available. This would address issues with the evidence for the Local Plan 2030 where the range of projects identified are typically non-specific with uncertainty over future funding to be provided by CIL/S106, given that allocations are not yet provided through the development plan. The lack of specific projects in rural areas does not reflect the overall priorities for development in the spatial strategy and demonstrates that aspects of the evidence base in relation to Green Infrastructure do not fully reflect the contents of the submission Local Plan. i) Land at Willoughby Park, Great Barford 13.5 One such example is our client’s interests at Great Barford, which comprise land in single ownership supported by a comprehensive Masterplan, where allocation as part of the Local Plan Review would ensure delivery of opportunities towards the Plan’s objectives. The Masterplan proposals reflect a landscape-led approach to accommodating development within the site. The context for assessment has evolved since the Council’s previous 2017 Assessment of Site Options. 13.6 The Masterplan proposals for the Willoughby Park site and by extension the reduced 100-unit option are both supported by a landscape assessment that reflects key features within the site. Specifically, the proposed 24ha Countryside Park would address the Council’s previous site assessment conclusions regarding how a defensible northern boundary might be established for the site, with this area incorporating substantial opportunities for landscaping, open space and recreation and ecological enhancement. This extends to the layout of the site’s frontage with Roxton Road, incorporating areas for a community orchard and green infrastructure enhancement together with areas for attenuation as informed by a drainage assessment prepare to inform the Masterplan. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 32 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 13.7 The Council’s identified A421 Corridor spatial option recognises opportunities to enhance Green Infrastructure in this location (specifically referencing the Marston Vale Community Forest). We believe this should be emphasised by a review of the Council’s 2009 Green Infrastructure Study. 13.8 Of particular relevance in terms of the 2009 Study are opportunities to extend the ‘Green Wheel’ north and east of Bedford to connect Great Barford and Roxton. Green infrastructure improvements in this area would also enable an extension of the Bedford River Valley Park and might be associated with delivery of community greenspace in the village. The Council’s Sustainability Appraisal Scoping Report also notes the Lower Great Ouse Valley Green Infrastructure Opportunity Zone as relevant to the Plan’s objectives. 13.9 Comprehensive development of our client’s land north of Roxton Road 500 dwellings and open space would ensure that the objectives of the submission Local Plan are achieved. This comprehensive development would deliver areas of open space, play space and amenity areas; and support delivery of areas for habitat and landscape improvements/creation alongside the delivery of 500 dwellings in the plan period. 13.10 Material prepared as part of undertaking community consultation with local residents in April 2019 reiterates the ability to make provision for a Countryside Park (approximately 24ha) and other wildlife and green space enhancements funded by the development. Evidence for the concept scheme illustrates that this will be provided on the northern edge of the village. This will incorporate the public bridleway and existing footpaths within the site, providing connections to the countryside beyond the A421. 13.11 The Countryside Park itself would follow the existing public bridleway (BW24) and provide an attractive area for recreation; exercising, dog walking etc. It would also provide an extensive area for biodiversity habitat creation and woodland planting. North of the proposed Countryside Park, existing Rights of Way also link to countryside beyond the A421 and represent opportunities for wider landscape connections and links to further green infrastructure corridors east of Renhold. 13.12 Connectivity to the new development and wider Great Barford village could be provided by footpath 20 which follows the route of the brook. Additional green infrastructure and footpath links are shown through the proposed developed area itself, adding important connections to the countryside and a green lung for the development.

14.1 Policy provision to encourage new sports and leisure facilities and community facilities is welcomed in principle and is central to the Plan’s objectives for healthy and safe communities. We urge the Council to address these objectives as part of the Review of the Local Plan 2030 through provision for development opportunities not supported within the existing development plan. 14.2 National Planning Practice Guidance states that to ensure health and well-being necessitates taking account of the current and projected health status and needs of the local population, including the quality and quantity of, and accessibility to, healthcare and the effect any planned growth may have on this (ID: 61-046-20190315). Responses in terms of policy may including making provision to improve the quality and quantity of existing services and addressing barriers to health and well-being, as well as supporting the use of Health Impact Assessments to consider application proposals. 14.3 It is fundamentally unsound for the Council to state that its existing policies including those dealing the provision of Green Infrastructure are up-to-date. This conclusion is undermined by the Council’s acknowledgement of needing to plan for significant increases in the housing requirement as well as reviewing spatial strategy options. Further, currently there is no certainty that sites will be identified through Neighbourhood Plans to provide relevant facilities. 14.4 As illustrated below, specific additional allocations should be specifically supported on the basis of their deliverability – for example land such as our client’s interests at Great Barford that comprise land within a single ownership with a firm commitment to provide for components identified within a comprehensive Masterplan. i) Land at Willoughby Park, Great Barford 14.5 The Council’s current evidence base for the Local Plan 2030 is inconsistent in how it anticipates certain needs will be met. For example, with respect of Great Barford, the Infrastructure Delivery Plan 2030 (December 2018) identifies the essential need for a GP surgery in Great Barford. In the first instance the Council must update its Infrastructure Delivery Plan to demonstrate that these priorities remain essential and outstanding. 14.6 The need for a new medical facility is recognised by our clients (Old Road Securities (ORS)) who are committed to funding the building of the new surgery as part of a first phase of development of Willoughby Park (500 Houses) and are in the process of discussing this with the commissioning bodies. 14.7 The current Infrastructure Delivery Plan notes that a site was previously secured as part of S106 planning obligations for a site delivered at Bedford Road adjacent the Alban CofE Academy. It must be noted that notwithstanding this background there is no prospect of the land in question being taken up and obtaining the additional investment required to deliver GP services. Critically, the IDP also notes: “Further housing development allocated in this village may provide alternative locations.” 14.8 Great Barford is correctly identified as a Key Service Centre and delivering improved GP facilities is a key aspect of its role in the settlement hierarchy. The Council’s IDP suggests an awareness of suitable land capable of meeting this need. To ensure that relevant policies in the plan are effective (e.g. Policy 2S Healthy Communities) it is inappropriate to defer the allocation of sites to Neighbourhood Plans that will not necessarily provide for these objectives. 14.9 Critically, in terms of this issue, as part of the Willoughby Park proposal for 500 houses, the BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 34 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission promoters have committed to either the provision of funding for the delivery of a medical centre earmarked for development on land at Bedford Road in Great Barford, under planning permission 16/00873/MAF, or at Willoughby Park as a central part of the proposed community development area, and in the first phase of development. 14.10 Land for a medical centre has been reserved under a S106 Agreement, ancillary to the ongoing development at Bedford Road, undertaken by Linden Homes (16/00873/MAF). The National Health Service (NHS) has the right to acquire the reserved land within four years of the land being serviced. If the NHS does not take up the reserved land within four years their right to acquire the land ceases. If the NHS does not acquire the reserved land within the four year period or the medical centre is not built and opened within three years of the acquisition, the land must be offered back to the original owners and may be used for residential development. There is therefore a significant risk that the identified need of additional medical facilities in Great Barford will not be met. 14.11 The NHS Clinical Commissioning Group have stated that funding has not yet been allocated by the NHS for building the medical centre. Whilst the land has been made available, physical development cannot commence until funding is committed. 14.12 The Linden Homes site is comparably smaller than that offered on the Willoughby Park site, and the parcel of land allocated for the medical centre would not offer the possibility of expansion if needed in the future. 14.13 We therefore submit that in order to ensure an effective approach to supporting Healthy Communities in terms of implementation and delivery, as sought through Policy 2S, it is essential that the Review of the Local Plan is informed by and supports delivery of the most appropriate locations. This should be based on a full understanding of the capacity for growth and knowledge of available sites and enabled through the allocation of sites in the Local Plan. The ability to secure these requirements on our client’s land at Willoughby Park emphasises the opportunity to deliver the requirements for sustainable development as part of spatial options within the A421 corridor. This supports a review of the housing requirement for Great Barford as set out in Policy 4S of the Local Plan 2030 both in the period to 2030 and beyond along with setting out strategic policies and allocations to achieve the Plan’s objectives.