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.

No

Given the overwhelming evidence highlighting the significant improvements to wellbeing that having access to local green spaces provides, it would seem sensible to have a specific Policy section that deals with this matter directly. This should include specific protection for current and new local green space but also include tracked targets for increasing and improving overall biodiversity across the Borough, including all new development both residential and industrial. There are several good examples of well landscaped business development in the Borough, such as Priory Park, which manages to mix good quality green space within well designed and set-out business units. The successful balance of this type of development should become the template for the future of Bedford; rather than the current apparent drive to cover most of Borough with characterless warehousing units and lacklustre green ‘screening’.

Whilst acknowledging that “The borough's countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised” there is no mention at all of one of the Borough’s most significant environmental assets i.e. the River Great Ouse and River Valley Area. It seems odd to reference the embankment as part of the ‘jewel in the crown’ of the Borough and yet not the acknowledge the contribution the remainder of the valley makes North and South of the town centre. “Sustainable development and transport, the use of renewable energy technology, green infrastructure and new high quality green spaces in both urban and rural areas, will all contribute to reducing the Borough’s carbon footprint and securing a net-gain in biodiversity” will require strong policies to implement, especially around the impact of transport by ensuring that traffic capacity management and green transport infrastructure is in place ahead of any development starting. This seems to be an inherent problem with development in Bedford Borough, where the impacts seem to be only considered as remediation rather than being pro-active at time of development.

I agree with this plan period

A shorter Plan date would seem to provide more flexibility than a longer one, even a twenty year plan seems to be excessive when you factor in the huge uncertainty that major events such as Brexit and COVID-19 will and have brought to the country, especially in areas such as working patterns, location and net immigration. It would also make sense to set targets on a shorter term and to be based on more recent data (2014 seems very old in terms of statistical data). The plan also seems to be outlining an approach where it is encouraging large movements of population from elsewhere in the country to Bedford Borough rather than focusing on the housing need for those already residing here, this seems to be at odds with planning for local need.

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

Supported: Yellow - Growth along the A421 road corridor which already has good road links and opportunities to improve road-based public transport would seem to be an obvious choice, especially given this could connect well with the outskirts of Bedford Town, allowing for improved green transport connectivity to the town centre as an area for employment opportunity and commerce. Pink - Developing housing growth which is closely aligned to existing and planned road and rail infrastructure would make most sense. Potentially Supported: Brown – from a local perspective this option is somewhat welcome as it has potentially minimal impact on the key and rural service centres, however, it should also be noted that any development along the A6 is very likely to increase peak time congestion to and from Bedford on a road that commuters already experience significant delay on. This will potentially increase traffic on rural roads as residents look to alternative routes around the Borough ‘blackspots’. Not Supported: Orange – would have a significant impact on an area of open countryside and rural villages in North Bedford due to the loss of green space and increased traffic on predominately rural roads. The proposal is also very dependent on several factors that are outside of the control of the Borough, such as the opening of a new station north of Bedford, train re-scheduling etc. To include this option would seem to add significant and unneeded risk to the Local Plan delivery target. Grey – this option seems to be completely at odds with the draft vision statement “Sustainable development and transport, the use of renewable energy technology, green infrastructure and new high quality green spaces”, there are little to no employment opportunities within rural locations, any new development will encourage commuting. Very few rural settlements have any significant level of services, so again, travel to and from service centres will be required, increasing traffic flows making development unsustainable from the outset. As there are insufficient green transport links between rural areas the majority of these journeys are likely to be via public or private transportation, the bulk of which are not yet underpinned by renewable energy resources. The advantages listed for this option are also very weak. Red - this option would result in unacceptable intrusions into areas of open countryside and unmanageable pressures on existing road infrastructure. There is no evidence as to how this development approach is going to be able to deliver on the benefit to ‘provide opportunities for sustainable and active transport links, both between new settlements and to the urban areas’. Almost all traffic generated from these sites would need to access the A6 north of Bedford, a road already considered a notorious ‘blackspot’ for local residents at peak times.

Maintenance of the existing road network infrastructure, especially in the rural areas, should be a major priority for the Borough, also adding localised infrastructure e.g. doctors surgeries, schools, shopping facilities, sporting/recreational facilities, community centres etc. would help meet the needs of local residents and help reduce the requirement to use the car to access them. Defining what is meant by ‘growth’ would have been useful i.e. sustainable growth that looks to improve the quality of life for existing residents as a priority, by access to green space, improved air quality, new recreational facilities and services etc. would all be supportable growth aims. Poorly located and/or growth for growth’s sake initiatives would not be supported.

Where possible employment sites need to be located close to centres of existing or new population and have good access to sustainable transport networks, ideally located on brownfield sites. Warehousing should not be located in rural communities accessed by the rural road network which is unsuitable for large or heavy vehicles.