Issues and Options

Thank you for consulting Central Bedfordshire Council (CBC) on the Bedford Borough Local Plan Review. Central Bedfordshire Council welcomes the opportunity to comment on the review of the local plan from the outset to help shape the next plan for Bedford Borough and we look forward to continuing the good working relations that have already been forged between the two Councils. To this end, I hope you find the comments below useful. CBC welcomes the early review of the Bedford Local Plan in the context of the Oxford-Cambridge Arc and the need to provide additional growth to contribute to meeting the aspirations set out by Government. Given the potential levels of growth that are envisaged, CBC considers it paramount to consider the needs and delivery of infrastructure from the outset of the plan – not just in relation to connectivity, but also key areas such as green infrastructure, education and health. This is relevant to both the delivery of infrastructure within Bedford Borough as well as implications for existing and potential new infrastructure within neighbouring areas. CBC supports the approach for this current consultation in that it focuses on developing a strategy to guide housing and employment growth and identify the infrastructure needed to support it. CBC considers that an appropriate and robust strategy from the outset is paramount to the success of the plan. CBC further supports the approach proposed in terms of identifying policies that seek to deliver quality development at the same time as tackling climate change, protecting the natural environment, providing open spaces, and providing opportunities for self and custom build homes. Whilst it would be helpful to have an understanding of the levels of growth envisaged for the Borough, to be delivered through this plan review, CBC appreciates that this is not possible at the current time. The consultation material suggests that the published Standard methodology would be used to identify the future growth requirements but that the Plan period, which is currently part of this consultation, would be a contributing factor for the identified housing targets. It is currently identified that if the plan period is to 2040, the plan would need to deliver between 5,000 and 15,000 new homes, but if the plan period runs to 2045, this would increase to between 9,000 and 21,625. However, a review of the standard methodology is currently underway and therefore CBC considers that the Borough Council will need to bear this in mind and consider a potential adjustment of plan targets in the future. Having said that, CBC recognises the need to make progress with the plan review and therefore the Council’s early identification and consideration of potential options for the distribution and delivery of growth. It is our view that in the first instance, brownfield and previously development land should be utilised to its maximum capacity before looking to greenfield land to deliver growth. The urban based location options would offer huge benefits in terms of sustainability and growth could be successfully delivered without the need for new large-scale road infrastructure. Intensification of sites within Bedford should be fully considered in line with the estate regeneration objectives of the NPPF and the decisions around East West Rail that have now been taken, which provide confidence in terms of infrastructure in this area. CBC consider some of the ‘cons’ outline in the consultation paper could be successfully overcome through high quality design and exemplar sustainability objectives. Opportunities should be taken to provide exemplar and sustainable development, with the necessary infrastructure available from the outset. The consultation document makes numerous references to new infrastructure, but there is also a need to consider the potential impacts of growth on existing infrastructure, particularly around A421 and the A1 corridor. Planned growth within CBC Local Plan must be taken into account when considering the growth options and their potential impacts. CBC note some of the options suggest development in close proximity to the A1 corridor. If growth in this location is being proposed, a comprehensive understanding of the capacity of the A1 corridor would be required. Further work would be needed to explore a solution for additional traffic impacts. Bearing in mind the known constraints here, this would likely involve the need for large-scale intervention, such as realignment. CBC would welcome the opportunity to be involved in such work. CBC would question whether growth could be considered in these locations without a commitment to such interventions, which would undoubtedly require government funding. CBC would also be interested to understand the rationale behind the potential growth option at St Neots. In relation to employment, CBC appreciates that the evidence work to identify future requirements for employment land is still ongoing and we look forward to future discussions when this is available. The recognition within the consultation material of the need to attract businesses back to the urban areas and the Town Centre is supported. In relation to any future employment requirements and opportunities that are more strategic in nature, it is considered that any expansion of existing sites as well as the provision of new employment sites, should be well located and where it can be supported by both the local and strategic road network. Whilst CBC understand the Planning for the Future White Paper and Changes to the current planning system consultations (Aug 2020) have only recently been released, and this was after the publication of the Bedfordshire Borough Local Plan consultation, there will be a need to consider the implications of these proposals when progressing with further iterations of the plan. I hope you find the above comments helpful. Please do not hesitate to contact me if you wish to discuss these comments further. I look forward to future and ongoing discussions in relation to cross-border working and the provision of a sound Local Plan for Bedford Borough.

Thank you for consulting Central Bedfordshire Council (CBC) on the Bedford Borough Local Plan Review. Central Bedfordshire Council welcomes the opportunity to comment on the review of the local plan from the outset to help shape the next plan for Bedford Borough and we look forward to continuing the good working relations that have already been forged between the two Councils. To this end, I hope you find the comments below useful. CBC welcomes the early review of the Bedford Local Plan in the context of the Oxford-Cambridge Arc and the need to provide additional growth to contribute to meeting the aspirations set out by Government. Given the potential levels of growth that are envisaged, CBC considers it paramount to consider the needs and delivery of infrastructure from the outset of the plan – not just in relation to connectivity, but also key areas such as green infrastructure, education and health. This is relevant to both the delivery of infrastructure within Bedford Borough as well as implications for existing and potential new infrastructure within neighbouring areas. CBC supports the approach for this current consultation in that it focuses on developing a strategy to guide housing and employment growth and identify the infrastructure needed to support it. CBC considers that an appropriate and robust strategy from the outset is paramount to the success of the plan. CBC further supports the approach proposed in terms of identifying policies that seek to deliver quality development at the same time as tackling climate change, protecting the natural environment, providing open spaces, and providing opportunities for self and custom build homes. Whilst it would be helpful to have an understanding of the levels of growth envisaged for the Borough, to be delivered through this plan review, CBC appreciates that this is not possible at the current time. The consultation material suggests that the published Standard methodology would be used to identify the future growth requirements but that the Plan period, which is currently part of this consultation, would be a contributing factor for the identified housing targets. It is currently identified that if the plan period is to 2040, the plan would need to deliver between 5,000 and 15,000 new homes, but if the plan period runs to 2045, this would increase to between 9,000 and 21,625. However, a review of the standard methodology is currently underway and therefore CBC considers that the Borough Council will need to bear this in mind and consider a potential adjustment of plan targets in the future. Having said that, CBC recognises the need to make progress with the plan review and therefore the Council’s early identification and consideration of potential options for the distribution and delivery of growth. It is our view that in the first instance, brownfield and previously development land should be utilised to its maximum capacity before looking to greenfield land to deliver growth. The urban based location options would offer huge benefits in terms of sustainability and growth could be successfully delivered without the need for new large-scale road infrastructure. Intensification of sites within Bedford should be fully considered in line with the estate regeneration objectives of the NPPF and the decisions around East West Rail that have now been taken, which provide confidence in terms of infrastructure in this area. CBC consider some of the ‘cons’ outline in the consultation paper could be successfully overcome through high quality design and exemplar sustainability objectives. Opportunities should be taken to provide exemplar and sustainable development, with the necessary infrastructure available from the outset. The consultation document makes numerous references to new infrastructure, but there is also a need to consider the potential impacts of growth on existing infrastructure, particularly around A421 and the A1 corridor. Planned growth within CBC Local Plan must be taken into account when considering the growth options and their potential impacts. CBC note some of the options suggest development in close proximity to the A1 corridor. If growth in this location is being proposed, a comprehensive understanding of the capacity of the A1 corridor would be required. Further work would be needed to explore a solution for additional traffic impacts. Bearing in mind the known constraints here, this would likely involve the need for large-scale intervention, such as realignment. CBC would welcome the opportunity to be involved in such work. CBC would question whether growth could be considered in these locations without a commitment to such interventions, which would undoubtedly require government funding. CBC would also be interested to understand the rationale behind the potential growth option at St Neots. In relation to employment, CBC appreciates that the evidence work to identify future requirements for employment land is still ongoing and we look forward to future discussions when this is available. The recognition within the consultation material of the need to attract businesses back to the urban areas and the Town Centre is supported. In relation to any future employment requirements and opportunities that are more strategic in nature, it is considered that any expansion of existing sites as well as the provision of new employment sites, should be well located and where it can be supported by both the local and strategic road network. Whilst CBC understand the Planning for the Future White Paper and Changes to the current planning system consultations (Aug 2020) have only recently been released, and this was after the publication of the Bedfordshire Borough Local Plan consultation, there will be a need to consider the implications of these proposals when progressing with further iterations of the plan. I hope you find the above comments helpful. Please do not hesitate to contact me if you wish to discuss these comments further. I look forward to future and ongoing discussions in relation to cross-border working and the provision of a sound Local Plan for Bedford Borough.