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 covers 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 2050 in recognition of the major infrastructure investment running itno billions of pounds that is planned to improve both road and rail connections from Oxford to Cambridge during the plan period.

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 others. 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 recent call for sites information will therefore clearly be relevant to the strategy adopted. 1.12. In addition, 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. 4 PHILLIPS PLANNING SERVICES LTD 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. 1.14. The NPPF also promotes some development in more 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. In the context of changing attitudes to and patterns of working from home new development in villages should incorporate appropriate working spaces within new homes to facilitate this and so provide flexibility and contribute towards overall sustainable objectives. 1.15. Having regard to the above the Laing Family considers that there is 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. 1.16. This allows the Council to respond to the recommendations of the National Infrastructure Commission (NIC) in terms of focusing major growth along the A421 corridor but also recognises the sustainability of new development close to or adjoining the Bedford Urban Area and ensuring that there is some growth around villages to ensure the ongoing vitality and viability of such settlements.

1.17. Infrastructure including education, health, transport, community facilities and open space are considered key considerations in the delivery of growth in Bedford Borough. 1.18. There are no viability concerns associated with the deleivery of the Laing Family land at Biddenham which would prevent appropriate CIL and affordable housing requiremenst being met.

1.19. There are a number of successful employment areas in and around the Bedford Urban area. There are also significant opportunities to the south of the town along the A421 corridor utilising Brownfield land. 5 PHILLIPS PLANNING SERVICES LTD 1.20. A mix of new sites is required including larger strategic sites linked to the wider growth aims of the arc and also some smaller more locally focussed development which assists in maintaining the sustainability and so viability of smaller settlements.

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

I agree

1.23. Yes, it is considered 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. 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 while others have highly onerous policies that make construction in those areas 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 these 6 PHILLIPS PLANNING SERVICES LTD specific inconsistencies and a more general sense that what is being asked for is unfair or unnecessary. 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 that 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 and frequency of high quality public transport are clearly ways in which the Borough can encourage the greater use of sustainable modes of transport through the Local Plan. 1.30. In particular, enhancing pedestrian and cycle connectivity into a network across the Borough of consistent high quality, and delivering improvements in safety are 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.