Issues and Options

In order to achieve more sustainable development, the current principle of developing additional primary road networks to facilitate new development needs to be reviewed and altered in favour of environmentally sustainable alternatives. An emphasis needs to be placed on the provision and availability of easy and affordable public transport, and sustainable transport alternatives – encouraging good quality connections and sustainable transport hubs. An integrated network of segregated cycle routes in both urban and rural areas needs to become the norm encouraging people of all ages and abilities to feel safe and use their bicycles more regularly. Transport hierarchy needs to be adhered to in relation to providing for sustainable modes of travel – this has been even more evident in the 2020 – 2030 plan during the global COVID-19 Pandemic. A shift in urban street layout and practices to prioritise walking, cycling and public transport, needs to be given rather than to the private car. Easy access to electric cars, charging points and car clubs – as a mean to reduce Single Vehicle Occupancy (SOV) trips needs to be adapted around the county. The provision of local infrastructure (e.g. shopping facilities, sporting/recreational facilities, community centres etc) need to be available locally in order to reducing the need for residents to use the car to access them – a culture of the “20-minute neighbourhood” is required. The “20-minute neighbourhood” is all about ‘living locally’ – giving people the ability to meet most of their everyday needs within a 20-minute walk, cycle or local public transport trip of their home. In essence, a requirement to undertake the following is necessary;  Make sustainable modes of transport safe and easily accessible – removing physical barriers (e.g. crossing of the A421, widening access route to and from the town centre e.g. Bromham Bridge);  Substantially increasing the frequency of bus services to communities, in particular rural communities;  Actively reducing the priority given to unsustainable forms of transport.  Reversing past unsustainable transport policies and actions

The represented Parish Councils are particularly concerned that growth which will come forward as part of the 2030 Local Plan is located on high quality agricultural land. Whilst it is acknowledged that The National Policy Framework (paragraph 170) and Local Plan (policy 46S) identifies the need to continue to protect and enhancing agricultural land, they feel that policies should give greater emphasis to both the development of brownfield land and the protection of high quality agricultural land to redress this current imbalance and trend.

No other issues to be addressed.

The key issue for all the rural areas represented is the amount of housing growth to be delivered and where. Central to this is both the ONS data and the formula used. In preparation of the 2030 local plan, ONS data from 2014 and the Standard Method of Calculation (SMC) were used to calculate housing growth giving a housing need of 1300 per annum. As stated in the Issues and Options consultation, using the latest 2018 ONS data gives a much-reduced figure for housing need of circa 800 dwellings per year. It is understood that the Borough Council have recently been working with a third-party demographic company and have come up with a figure of circa 1100 units per annum. With the SMC now under review in the recent consultation ‘Changes to the current planning system - Consultation on changes to planning policy and regulations’ by the Ministry of Housing, Communities and Local Government dated August 2020, it seems that in all likelihood that the formula for calculating housing need will change again. What is clear is that using the ONS 2014 data and the current SMC there gives is a significantly higher housing need compared to the other data figures and other formulae. In all probability, the final housing need figure will be lower than that used for the 2030 local plan if, as it should, the 2018 ONS data is used. As set out in other sections of this response, if the vision genuinely seeks to recognise the intrinsic character and beauty including areas of tranquil retreat in the Borough then it is essential that the most up-to-date ONS data and method is used to identify accurate housing needs thereby protecting the rural areas from unnecessary and harmful development on greenfield sites in the rural area.

Yes

We acknowledge the need for an early review of Local Plan 2030 following the Inspectors recommendation, however, there are a number of matters still awaiting resolution which could have a significant impact on the level of growth required in the Borough, for example, how the growth associated with the Oxford to Cambridge Arc is to be distributed along with the current consultation and review of the standard methodology to resolve the housing requirement via the Planning for the future white paper. There is great concern that these unresolved matters could have a significant impact on the direction of the new Local Plan and, in particular, on the housing figures required for the new period. At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford. Therefore, there is no support for urban growth in North Beds as there is no current or proposed road or rail infrastructure available and this would mean that traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic. Those routes are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. More policies should be developed that relate specifically to the rural area, which forms a very large part of the Borough, as these policies are vague and very much open to interpretation.

We believe that there is a need to specifically refer to and protect the Borough’s main asset, the River Great Ouse and the Great Ouse Valley , in the vision given it traverses the landscape creating beautiful landscape views and is a haven for wildlife, particularly given climate change challenges and solutions are likely to be centred around the river. There is also no mention of improved road infrastructure in the north of the Borough which at the moment is served only by the A6. This is a totally inadequate road for current inhabitants of villages and will not cope with the amount of development currently envisaged in the north of the Borough. There is also current or proposed rail infrastructure available for the area so this would mean that car-based commuter options are the only viable option for the area. The villages in the north of the Borough already suffer from ‘rat-running’ by drivers either travelling into Bedford town for access schools/station or to reach main arterial road networks leading to other areas. The A6 already cannot cope with the amount of traffic travelling into Bedford or on to the Great Ouse Way. We could not support the development of any of the large developments proposed in the document along the A6 corridor particularly as to accommodate further growth in addition to current growth (both in Bedford and East Northants) would either result in further disruption, delays, noise and pollution to existing residents or necessitate new transport infrastructure which would be at odds with the vision to provide sustainable development and transport and the recognition of the intrinsic beauty and character of the Bedfordshire countryside The subsequent suburbanisation of the Ouse Valley would be significantly harmful.

I agree with this plan period

Agree with plan period 2020- 2040. The longer the plan period is, the more challenging it can be for communities to respond to social, economic and environmental changes. The fact that local plans need to be reviewed at least five years in accordance with the National Planning Policy, reinforces that the shortest plan period is preferable.

Brown – Urban based growth , Yellow – A421 based growth , Pink – Rail growth

The Parish Councils consider that a combination of Brown (Urban- Bedford Town and St Neots/Wyboston/Wixams only), Yellow (A421 based growth) and Pink (rail) focused growth would provide the optimal solution for both protecting the character and landscape of the open countryside particularly the Great Ouse Valley and utilizing existing sustainable transport networks to places of work and leisure. As part of the recently adopted Local Plan for Bedford there will be potentially 1750 new homes in the key service centres and villages northern half of the Borough including 500 which are planned in the adjacent village of Sharnbrook. This will add further traffic and pressure on an already busy A6 road. The East Northamptonshire Joint Core Strategy (2011-2031) identifies three towns – Rushden, Higham Ferrers and Irthingborough - immediately north of the boundary with Bedford Borough as 'Growth Towns'. A total of 5195 houses are planned for these towns with the core growth (3285) proposed in Rushden. The Sustainable Urban Extension at Rushden East is located off the A6 and nearest to the shared boundary with Bedford Borough. It will include 2,700 of these new homes, employment opportunities, including offices and industrial premises as well as other infrastructure. East Northants Council identify local transport issues and impacts that must be resolved as part of the 'master plan' for the area. However, no reference is made to the impacts that this planned growth will have on the wider road network including the A6 south. It is well known that lower house prices in Rushden compared to Bedford has encouraged people working in Bedford to live in Rushden (see average house prices in respective towns on Rightmove and Zoopla). This significant planned growth immediately north of Bedford Borough will, in all likelihood, continue to encourage commuting into Bedford creating additional traffic and associated noise and pollution on the villages such as Bletsoe located off the A6. Any significant house builds in Bedfordshire cannot be considered in isolation to this planned growth in East Northants which is already an adopted policy and of course the new dwellings proposed as part of the Bedford Borough Local Plan 2030. Any proposed expansion on either side of the county borders and the expansion to Rushden will substantially impact on traffic on the A6, without any further urban development at Wymington. Bletsoe Parish Council do not support further urban growth in the northern part of the Borough adjacent the A6 as there is no current or proposed road or rail infrastructure available. This would mean that all associated new growth traffic to Bedford, Kettering, Northampton and Milton Keynes would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic and are already used as a rat run for both domestic and large commercial vehicles, damaging the rural road surfaces and in some cases undermining the foundations of the stone cottages close to the road. We consider the combination of Brown (Urban- Town Centre and St Neots/Wyboston/Wixams), Yellow (A421 based growth) and Pink (rail) would offer a number of advantages most of which are set out in the option appraisal - support for services, facilities and businesses in urban areas, particularly Bedford town centre; greatest potential for residents to make sustainable travel choices (walking, cycling and public transport); increasing development density improves public transport viability; best use of brownfield and under-used land; reduces need for development in open countryside; more employment uses within centre will improve viability and create direct benefits of other associated business uses such as retail and leisure; ease of access to employment areas with good connectivity is important; high-tech employment development in balanced communities with the option to live and work locally; Increased employment opportunities in the urban area and sustainable methods of transport for those residents in most deprived areas. There appears to be a lack of sites proposed in the south of Bedford with only new growth proposed at Wixams which sits within two Local Authority boundaries. It is particularly surprising not to see an option for more development at the former Stewartby Brickworks site (which is brownfield land) as it is capable of delivering a significant number of homes and potentially a new settlement. Orange (East-West rail northern station growth) At the time of this consultation, the preferred route for East - West Rail will be from Bedford Midland station travelling eastwards through Ravensden towards Tempsford and onto St Neots. This proposal does not include a new station in the Borough of Bedford with any new growth along this corridor having to travel either into Bedford to the existing station or to the proposed new station in the St Neots/Tempsford area. There is no support for urban growth in North Beds as there is no current or proposed road infrastructure available, in the absence of a rail station and connection, so this would mean that all traffic to Bedford, Kettering, Northampton, Milton Keynes and Cambridge would be along the A6 or along rural roads which are narrow and inadequate to accommodate any increase in traffic, which are already used as a rat run for both domestic and commercial vehicles. For this reason, this growth option does not provide any real benefits and will cause significant harmful visual and landscape impacts on the surrounding rural area and use valuable agricultural land.  □ Grey (Dispersed growth) During the current Local Plan period (2020-2030), many of the villages are either required or choosing through neighbourhood plans to deliver significant housing growth. For example, the Key Service Centres of Sharnbrook and Great Barford will see a 50% increase in the number of households where as Clapham and Bromham will see the number of households increase by 25%. In general terms, the growth in all rural areas over the next 10 years will be considerable. Much of the housing growth in the rural area is generally located on greenfield land which not only results in the loss of important agricultural land but also results in harmful visual and landscape impacts in the open countryside and its associated settlements. Also, a dispersed growth option is unlikely to create sustainable economic growth perpetuating car reliant modes of travel. □ Red (New settlement-based growth) The New Settlement based growth is opposed (apart from at Wyboston which offers the best sustainable transport solution for growth) for the following reasons - The long lead times meaning that homes and associated development take a number of years to complete often beyond the plan period; Significant investment is needed early on to prepare and plan the location and to create the necessary infrastructure for a new settlement. The need for this ‘upfront’ investment takes time. Excellent public transport is essential to the success of a new settlement and this proves often difficult to deliver due to investment requirements and the multiple public transport providers involved; New settlements sometimes involve complicated land assembly which is critical to providing appropriate supporting infrastructure in a timely manner; Recent Inspector’s letters relating to proposed new settlement allocations in local plans Tendring, Colchester, Braintree (15th May 2020), Uttlesford (10th January 2020) and the Inspector’s report for Hart (10th February 2020) identified a number of issues that needed careful consideration – The high-level delivery assumptions are often biased and play down risks; There is greater potential for stalled or undeliverable housing; Housing development is more likely to be watered down in terms of quality and principles post allocation due to under estimated infrastructure and other costs. The Borough should not allow developers to return to previously agreed permissions to allow them to reduce commitments made in their initial s.106 agreements through viability studies (which are generally confidential and not made available to the public) to provide fewer benefits for the community than agreed when the initial permission was granted.; The potential need for greater public sector investment post site allocation to compensate for biased assumptions which would be poor value for money compared with other growth options put forward in the pre-allocation process. The Borough Council should not therefore under-estimate the requirement to carefully and sensibly demonstrate that there is reasonable prospect that a new settlement proposal can be delivered. Without robust but proportionate evidence on delivery, infrastructure and viability that objectively tests the positive and negative impacts and takes account of any consequences new settlements should not be supported. In any event, if, as it is anticipated, the number of additional dwellings needed is low (see ‘Other comments’ at the end of this response in relation to the calculation of housing growth), then a new settlement would not be the optimal way to deliver additional housing growth.

Infrastructure shapes our lives – it is the foundation upon which our economy is built. It vital that we are determined to deliver better infrastructure to grow the economy and improve opportunities for people across the country. Transport links get us where we need to be, energy systems power our homes and businesses, digital networks allow us to communicate and infrastructure supplies us with clean water / takes away our waste. It is vital to improving our quality of life and integral to the creation of vibrant new places to live and work. Suitable and appropriate infrastructure provisions have taken on an ever-increasing importance in the light of recent global COVID-19 Pandemic Depending on the growth location (see Question 4 and answer), appropriate transport and service infrastructure will be needed including new roads, dedicated and safer pedestrian and cycle routes, providing assistance for vulnerable road users, EV charging facilities, sustainable drainage systems, schools, doctors and dentist premises, convenience shopping facilities, sports and recreation facilities and community facilities. Suitable and appropriate employment uses commensurate with the scale of the growth option would be desirable. Care needs to be given when considering strategic transport solutions for growth as it has potential to irreversibly damage the intrinsic beauty and character of the Bedfordshire countryside particularly along the Ouse Valley. It is difficult to see how any significant growth can be accommodated north of Bedford town as without improved transport infrastructure it would either result in further disruption, delays, noise and pollution to existing residents in villages such as Bletsoe adjacent the A6 or necessitate new transport infrastructure which would be at odds with the vision set out in the Issues and Options consultation.

In line with the current policy approach, new employment sites should be located primarily on brownfield land in or next to the main urban area as these are closest to existing Borough population and as they are better linked to the existing primary transport network and hubs. In all cases, consideration should be given to the strategic location of site in relation to accessibility for sustainable modes of travel in order to reduce peak periods traffic congestion and pollution. By minimising delays on the Strategic Road Network, through effective demand management and transport planning measures, economic growth will prosper along with delivery of better environmental outcomes. Industrial employment sites should be considered in close proximity to the strategic road network (e.g. A421, A428 A1, M1 etc) and should not be located in rural communities accessed by the rural road network which could encourage further ‘rat-running’ of larger vehicles along country roads and through villages.