Issues and Options

Yes

1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope notes the need to accommodate growth in line with national requirements no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the desire of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”

1.3. Although referencing East-West Rail and improved connectivity to Oxford and Cambridge, it is considered that the vision should provide more direct and positive comment regarding the Council’s desire to deliver new housing and economic growth levels associated with the arc. 1.4. The review plan should make clear that its aim is not simply to extend the strategy set out in the current 2030 local plan i.e. delivery of basic indigenous growth requirements. Rather the vision should set out the Council’s intent to deliver a step change in both housing and economic growth with higher aspirational levels of growth associated with the arc being attained before the end of the plan period. 1.5. There is also concern that the vision suggests that development in rural areas will be provided solely through neighbourhood plans (NP’s). 1.6. Whilst NP’s are to be encouraged, not all rural communities wish to prepare NP’s and this should not then preclude development in those areas i.e. where plans are not produced. 3 PHILLIPS PLANNING SERVICES LTD 1.7. The vision should include reference to rural growth through NP’s or through the Local Plan itself in areas where Parish’s or other relevant groups have not confirmed that a NP is to be produced before the plan reaches the preferred options stage.

I do not agree with this plan period

1.8. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy cover the period to 2050. 1.9. It is therefore appropriate to plan for a longer period in line with the Arc strategy. We consider the plan should cover the period to 2045 if not 2050.

Brown – Urban based growth , Yellow – A421 based growth , Grey– Dispersed growth

1.10. Whilst it is helpful to seek views on the broad growth options which have been set out in the consultation document we agree with the supporting commentary within the Issues and Option paper that it will be necessary to include a variety of approaches rather than become fixed on one option to the exclusion of all else. 1.11. The NPPF (paragraph 67) makes clear that plan making authorities should have a clear understanding of the land available within their area prior to developing strategic policies. A review of the call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. The NPPF is also clear that a mix of size and types of sites should be included within development plans to provide choice and to avoid circumstances arising where there is over reliance on one particular site or strategy which if it does not perform as expected results in the plan failing to deliver sufficient housing. 1.13. Paragraph 68 of the NPPF states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. 4 PHILLIPS PLANNING SERVICES LTD 1.14. The NPPF also promotes development in rural locations. Paragraph 78 states that in rural areas housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify how new development will enable villages to grow and thrive 1.15. Having regard to the above Peter David Homes considers that there is significant merit in pursuing a mix of the ‘Yellow’ A421 corridor growth, ‘Brown’ expansion of the Bedford urban area, and ‘Grey’ dispersed growth model allowing some expansion of villages. This would ensure that appropriate regard is had to the Oxford to Cambridge growth arc recommendations, the sustainability of growth adjoining or close to Bedford and also the need for some growth in more rural areas to maintain the vitality and viability of those settlements.

1.16. Infrastructure including education, health, transport, community facilities and open space are considered key considerations in the delivery of growth in Bedford Borough. 1.17. Sites which can deliver or provide contributions towards the delivery of new local infrastructure should be favoured when allocations are being considered. 1.18. For example, land controlled by Peter David Homes in Renhold can deliver a new area of local open space in the form of a village green for the use of the existing community as well as residents of new development. 1.19. There are no issues of deliverability or technical constraints to development of the PDH land such that full contributions towards relevant and justified local infrastructure can be delivered.

1.20. There are successful employment areas on the east side of Bedford (Elms Farm & Viking Estates) within a short walking or cycling distance of Renhold. These estates also have good access to the A421 and so links to the M1 (junction 13) and A1 (Black Cat Roundabout). It is considered that further employment development would be best located along the A421 corridor and close to key junctions points to the A421.

1.21. Providing growth along and around the strategic connections between Oxford and Cambridge (e.g. A421 and East-West Rail) are considered key to drawing in investment to the Borough and increasing the value of its economy.

I agree

1.23. Yes, it is considered very important that clear guidance is provided so that developers are aware of the expectations. 1.24. However, it is respectfully submitted that the ‘planning’ system is not the correct vehicle for imposing strict climate change standards for construction. This is a matter which should be controlled through Building Regulations. 1.25. Building Regulations provide a national standard and developers accept and do not seek to avoid Building Regulation requirements. Building Regulations must be adhered to or developments cannot be insured and sold. 1.26. Where the planning system has sought to introduce detailed construction requirements including policies relating to carbon reduction, green energy etc., this has resulted in major differences between local authorities in terms of what is required. Some have little or no detailed policy on such matters others have highly onerous policies which make construction in one area far more costly than may be the case on the other side of an authority boundary line. Developers therefore seek to avoid and minimise requirements placed on them through the planning system because of this inconsistency and so a sense that what is being asked for is unfair or unnecessary. 6 PHILLIPS PLANNING SERVICES LTD 1.27. It is considered that planning should provide guidance on how layouts can assist in combating climate change, sustainable drainage, ecological enhancements, environmental requirements etc. but should not seek to duplicate or go beyond building regulations in terms of construction specification, energy and water use. This creates confusion and inconsistency between local authority areas as outlined above.

1.28. In a similar vein to our answer to question 9, we submit that there is no need to introduce local standards which change or exceed those required nationally.

1.29. The provision of new and enhancement of pedestrian and cycle routes to local facilities and accessibility to public transport are clearly ways in which we can encourage the greater use of sustainable modes of transport through the Local Plan. 1.30. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.31. New developments should also be required to deliver Electric Vehicle charging points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles.