Issues and Options

No

We note the review is intended to focus mostly on growth and infrastructure. Given the Borough Council's enthusiastic support for East-West Rail, the Parish Council is surprised there is no reference to the railway in the proposed scope, the most significant infrastructure project the Borough will have seen. Although this is a National Infrastructure Project, the Borough Council through this Review has a wider responsibility to consider the effect of the railway on issues such as community cohesion, landscape character, countryside access, visual amenity and tranquillity, the need for supporting infrastructure, and measures to mitigate the wider effects. This policy area should be added to the list. The ongoing debate about the merits of East-West Rail exemplifies a shortcoming in the forward planning process which the Local Plan Review should seek to rectify. Claims of benefit to the Borough often do not adequately distinguish between urban and rural areas, with benefit accruing more often to the urban area at the expense of rural communities. The scope should ensure all policy areas are tested against this principle to ensure equitable outcomes for all.

The Vision states that the Borough's countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. Ravensden Parish Council considers this statement is too vague and does not go far enough. There should be a balance between the need for development and the protection and enhancement of the countryside because of its intrinsic character and beauty. The rural assets surrounding Bedford add real value to the whole Borough and should be protected and enhanced as much as the regeneration of the town centre is promoted. The long-term tangible benefit to the whole Borough will be realised in terms of health, well-being, environment and sustainability. Whilst the Vision claims some benefits could arise if East West Rail comes through Bedford, it does not - but should - mention the dis-benefits to the rural communities through which it will pass and that these impacts should be mitigated. The Vision states that local communities will embrace sensitive development through Neighbourhood Plans. This principle is acceptable so long as the level of development is appropriate to the parish and community in which it is to take place, and is endorsed by local communities through NP referenda. Since the Vision accepts the role of Neighbourhood Plans in the forward planning process, they should not be overridden by the Local Plan Review, or there is a serious risk of undermining confidence in the whole neighbourhood planning process. Although this Plan Review will not take into account longer term development needs arising from the Oxford-Cambridge Arc (as they have yet to be defined), the Vision for the Review could consider providing a spatial framework post plan period in which such development might be accommodated. The Parish Council provides its thoughts on this matter in its response to Questions 3 and 4 below.

I agree with this plan period

The Plan period should not extend beyond 2040 given the uncertainties of longer term forecasting. Even up to 2040, the range of potential housing requirements (5000 to 15000 additional dwellings) is too wide to form a sensible basis for development and infrastructure planning, and ignores any additional requirement relating to the Oxford-Cambridge Arc. The dwelling requirement for the plan period should be clarified more precisely as soon as possible. Beyond 2040 the Review could consider outlining a spatial framework to accommodate Oxford-Cambridge Arc development requirements that are appropriate to the Borough.

Yellow – A421 based growth , Pink – Rail growth , Orange – East-West rail northern station growth

Urban based growth - Ravensden Parish Council does not support further large scale growth on the edge of Bedford in the parish but urges that maximum use is made of urban opportunities such a brownfield land, office and retail conversions and sensitive redevelopment. The Review should be mindful of minimising the need to travel, thereby reducing emissions and promoting a low carbon economy. Taking into account the Graze Hill commitment (which will add 50% to the housing stock in the parish), there are no suitable sites for significant housing development anywhere in the parish, without seriously compromising landscape character, existing or proposed open space, or the setting and role of our settlements; or adding unacceptably to the already high volume of traffic which crosses the parish, or overloading other existing infrastructure (e.g. drainage). Existing landscape features, amenity spaces, strategic gaps and recreation areas should continue to be protected. A421 based growth - Ravensden Parish Council supports this scenario as it would sustainably integrate new housing with the strategic road network and with major existing and potential new employment sites. This scenario could also form the basis of a longer term strategy for accommodating appropriate levels of growth resulting from the Oxford-Cambridge Arc and couple into a Bedford south parkway station serving Thameslink, MML and EWR services. Rail growth - Ravensden Parish Council supports this scenario for the same reasons as A421 growth, i.e. south west of Bedford. EWR Northern Station - Ravensden Parish Council do not consider there is "significant potential for growth north of Bedford". We are emphatically and unanimously opposed to this scenario which we consider to be wholly unrealistic, for the following reasons. 1. The principle, route, financing and timescale for the implementation of the central section of EWR have yet to be confirmed and EWR can therefore form no basis at the present time for any development strategy in this Review; 2. EWR advised Parish Councils as recently as 18th August 2020 that an intermediate station north of Bedford is not being considered by them. This would slow journey times and reduce the so-called benefits of the scheme. If intermediate stations were to be planned, the cost-benefit assessment for all route options should be re-appraised; 3. There is no suitable large scale developable land within the Route E corridor for a new station and associated development. Any proposal to divert the line outside the current Route E corridor to allow for an additional station on developable land would open up the need for EWR to recommence their whole consultation process on route options, thereby delaying the whole project significantly; 4. Road infrastructure to serve major new development north of Bedford is wholly inadequate and other services (e.g. electricity and water supply, which occasionally cannot cope even with present demand) would require significant reinforcement; 5. Major residential development would further increase undesirable levels of commuting by road to employment sites within Bedford and beyond, seriously impacting road conditions, highway safety, and the environment of the Parish; 6. There would be unacceptable impacts on local landscape character, recreational and visual amenity, and the nature conservation value of this acknowledged tranquil area; 7. There are no large brownfield sites anywhere in the Route E corridor north of Bedford and therefore major development would mean the loss of the most versatile Grade 2 and 3a agricultural land, contrary to the Review's stated objective of maximising the use of brownfield land for development; 8. By suggesting a parkway station is required, this proposal tacitly accepts that Bedford town centre and the road network serving Bedford Midland Station are unable to absorb any additional travel demand that might arise from EWR, especially at peak periods. If parkway stations are needed to relieve congestion at Bedford Midland, then they would be better placed on the Midland Main line north-west of Bedford where travel demand and railway capacity already exists, and south of Bedford where EWR and Thameslink/MML services could be integrated. Dispersed growth - The current local plan 2030 defines a settlement hierarchy and a policy approach to development at settlements which Council officers confirmed in the Issues and Options presentation to Parish Councils, are to be retained in this Review. However, allocating development proportionately to settlement size would take limited account of the existing settlement hierarchy or policies. In line with the adopted policies in the 2030 Local Plan, any dispersed development proposed for lower order settlements such as Ravensden Church End and Ravensden Crossroads should, if it is needed, be appropriate in scale and well related to the built form of the settlements. Development adjacent to the settlements would also need to be supported by local communities through Neighbourhood Plans or meet a particular local need. Development in the open countryside should be allowed only for specific and appropriate types of development. To reiterate the Parish Council's comments under the Urban Growth scenario, any further large scale development on the northern edge of Bedford should not be considered. New settlement based growth - Ravensden Parish Council is not opposed to the principle of new settlement(s) along the A6 corridor as proposed by landowners in the call for sites for the 2030 Local Plan. Some of these proposals provide opportunities to make significant use of large brownfield sites, (which the Review intends to prioritise) and all of them would meet a large proportion of the projected housing need requirement, thereby relieving pressure for large scale development on the fringe of Bedford or on an unacceptable scale elsewhere. However, there could be significant traffic effects in this parish which would need to be planned for, infrastructure should be provided before development takes place and the environment of existing communities protected, through effective traffic management including enforcement.

There is an overriding need for major improvements to highways infrastructure, public transport, footways and cycleways for current, let alone future needs. Improvements should take place in advance of any major development proposal. Improvements to health, education and recreation facilities, telecoms, water/sewerage/land drainage should also be planned for strategically and not piecemeal as and when planning applications are considered. The Review needs to reflect and act on changes in travel and work practices post-Covid 19 e.g. working from home, a reduced demand for office and retail space, reduced commuting and the need for very high­speed data links to residential properties.

New employment sites should be allocated close to the strategic road network south of Bedford where there is abundant flat land, a concentration of existing businesses, most new residential development (thereby minimising commuting distances) and connectivity via Midland mainline and EWR stations. The potential dualling of the Bedford western by-pass would reinforce the strategic importance of the highway network to the west, south and east of the town and accessibility to major employment sites. New large scale employment sites should not be located in the relatively isolated countryside and sensitive landscape north of Bedford. Any such sites should only meet local needs and be supported through the Neighbourhood Planning process.

The Review needs to facilitate much better road/cycle/pedestrian/public transport links from the rural areas. Unfortunately, creating quicker and easier access to stronger centres tends to diminish not improve the economic prospects of other towns in their catchment. With easier access to and more attractive employment opportunities in Cambridge/Milton Keynes/Oxford, Bedford could easily become less, rather than more self-contained and sustainable, and out-commuting could increase. It is therefore important that, compared with the rest of the Arc, the Review recognises the economic pre-eminence of larger towns and cities and does not simply try to replicate them. Instead it should promote the Borough as a sustainable location in which to live, with outstanding recreational, cultural and educational facilities set in attractive countryside.

Ravensden Parish Council has nothing to add.

I disagree

Ravensden Parish Council does not have a view on the need for further guidance but, if it is not part of the Local Plan Review, any revised guidance should be the subject of full public consultation before it is adopted.

I Ravensden Parish Council has no comment to make.