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New searchThe recently published White Paper proposes significant changes to the town and country planning system, among them a simplification of the plan-making process. Eclipse Planning Services generally supports this approach. There are many areas of policy, in this particular Local Plan and generally, which do not need to be reviewed. In this case, the Council should concentrate its efforts on the issues of the amount and distribution of development and of infrastructure.
The Vision is far too long and should be reduced ideally to half its length or less. Most of the material thus removed could then be recast as objectives. There is a grammatical error in the second sentence which must be corrected – by the removal of the word “against”.
It is inferred that the Council’s preference is for 2040; comment is sought on any alternative to this rather than to support the Council’s position. Nevertheless, we consider that the plan period should extend no further than 2040. Perhaps the single most important source of data for forward planning is the household projections produced by MHCLG. These project forward for a period of 25 years from a given base date. This might in itself lend support to a plan period extending beyond 2040. However, successive sets of these projections show how unpredictable the future actually is; a set may forecast a higher or lower figure for the end date than its predecessor published only two or three years earlier. In any event, forward planning should be regarded as a continuous rather than intermittent process. The Council’s decision to embark on a review almost as soon as the Local Plan 2030 was adopted is a good example of this, where the examining Inspectors have given firm guidance, as indicated on page 3 of the Consultation Paper. There will inevitably a further review long before 2040, if the Government’s guidance on timescales is maintained. Furthermore, the town and country planning system may need to take stronger measures within its scope to tackle climate change long before 2040. Eclipse Planning Services considers that the case for not setting an end date any further forward than 2040 is reinforced by the summary of the position on housing provision on page 16 of the Consultation Paper. In short, the extent of existing commitments (11,000 dwellings) means that the range of additional provision to 2040 varies by a factor of 3 (5,000 to 15,000 additional dwellings), arising from a factor of only 1.6 in the range of the annual requirement (800 to 1,305 dwellings). Furthermore, it would be very difficult to anticipate the affordability data due in March 2021 or the outcome of the review (“in its entirety”, as the document says) of the standard method.
Eclipse Planning Services has carefully examined the material illustrating the six potential options on pages 18 to 20 of the Consultation Paper and the summary in Table 1. On the whole we think that the advantages and disadvantages of each are quite well summarised, but some important factors appear to have been overlooked. Most important of all, none of the options has been considered in terms of the great range in the potential residual housing requirement, in other words the number of additional dwellings above existing commitments this review must plan for. The Council acknowledges, and we note in our response to Question 3, that this figure ranges from 5,000 to 15,000 dwellings. For example, the Grey option – dispersed growth – would be less unsustainable at the lower end of the range; but the lower end would also significantly if not entirely undermine any strategy based on one or more new settlements, in this case both the Orange and Red options. We note what the Council says about the eventual strategy possibly combining elements of more than one option; indeed, there is some overlap between options already. We consider that, for reasons given below, some options should be eliminated from the start, irrespective of the size of the residual housing requirement. Brown - Urban based Growth This option appears to be closest to the pattern of development which has on the whole taken place up to now. In the last twenty years or so, however, there has been increasing concern that the continued outwards expansion of small and medium sized towns is not necessarily the most sustainable option. The effect of such growth has been (among other things) to place an increasing proportion of the population of these towns outside reasonable walking or cycling distances of the centres which still provide many services and much employment, and to put increasing strain on infrastructure including the road network. Many local authority districts contain a number of such towns. Here, however, Bedford itself dominates and contains more than half of the Borough’s total population. The problem of peripheral expansion is therefore perhaps not quite so acute; there is for example a critical mass available in Bedford to support a reasonable level of bus services. Nevertheless, given the high and increasing cost of infrastructure, it is essential that best use be made of it. The potential locations for growth are illustrated on page 18. Even in this diagrammatic form, some locations, for example on the north side of Bedford and at Rushden, are not well placed to benefit much, if at all, from the investment in major infrastructure which has already been completed (the A421) or is planned (the East West rail link, the A428 to the east). The location of development shown in the drawing west of St Neots is not what L & P Chess are now promoting; land west of the A1 at Wyboston is located south west of St Neots, rather than west, and although extensive, is not on a scale implied by the diagram. We therefore consider that the elements of the Brown option which do not form part of other options should be rejected; or to put it another way, the Brown option could be discarded altogether because the more promising and appropriate elements of it are also included in other options – Yellow and Pink. Yellow – A421 Based Growth We note from the diagram on page 18 that this option is illustrated by a continuous yellow band from south west of Bedford to a point on the A1 west of St Neots. Even without a detailed site analysis, it is clear from scrutiny of the most recent Ordnance Survey sheets that development in this corridor cannot, or at least should not, be continuous. There is for example no junction on the A421 between Workhouse End and the A1, and we suppose that Highways England would be reluctant to approve any more junctions on the section of the road covered by the yellow band. There may be some limited opportunities off the old A421 running through Great Barford. This option might however better be characterised as nodes on a corridor rather than simply as a corridor; this would avoid giving the impression that this option could “appear as urban sprawl and join-up nearby villages”. In terms of the other stated pros and cons in the Consultation Paper, the land west of the A1 at Wyboston is a first-class opportunity for development even if “western expansion of St Neots or a new settlement at Wyboston” are not needed. Pink – Rail Growth We note that the diagram on page 19 shows significant development to the south west of Bedford and at Tempsford. This raises a question about the scope for development at Tempsford, bearing in mind that the existing settlement is in Central Bedfordshire and that the boundary between Bedford Borough and Central Bedfordshire runs along the River Great Ouse. This imposes constraints on where Bedford Borough Council can legitimately allocate land, and where it can then in practice do so given the extent of areas of flood risk. This option implies the successful completion of the East West rail link sooner rather than later. The Council is right to be cautious about the speed with which this can be achieved. However, the key point is that the Council must also be realistic about the extent to which the new rail link will contribute to sustainable travel, particularly for journeys to work. Only in London does rail make a significant contribution to travel to work; and even in some of England’s eight major provincial cities, such as Bristol and Nottingham, it makes a very limited contribution. None of this should however deter the Council from identifying other suitable opportunities in the area which would be appropriate locations for major development irrespective of the speed of completion of the rail link. We consider that the development of land west of the A1 at Wyboston would be appropriate even of the rail link were not proposed. The rail link should be regarded as a significant incidental benefit to the St Neots area as a whole. The land west of the A1 at Wyboston is the best option in this part of Bedford Borough in terms of its location in relation to existing development and the road network, and the absence of any significant constraints. Orange – East West Rail Northern Station Growth Eclipse Planning Services considers this to be the least convincing of all the options, either on its own or in combination with any other. Even the title is a contradiction in terms. We have examined the material on the East West rail website, which clearly shows the lack of firm proposals for the section from Bedford to Cambridge – in contrast to the Bletchley to Bedford section, which was never closed, or the Oxford to Bletchley route, where a significant section has been reopened. The proposals appear to make greater use of the existing Bedford Midland station, which is surprising given the layout of the existing and former railway lines in the area and what would appear to be the somewhat limited scope for alternative routes, particularly in the built up area. In this context it is difficult to see how a new settlement and station north of Bedford fits in. Such a scheme might provide improved access to London, but this is not in our view a factor of great weight. Grey – Dispersed Growth This is likely to be the least sustainable option, especially if the residual housing requirement is at the higher end of the range. It is likely to result in the greatest increase in the number and length of journeys by private car and the least efficient in its use of infrastructure. Eclipse Planning Services considers that this option should be discarded altogether. Red – New Settlement Based Growth A historical perspective is very important in this context. The Government has for some time lent support to the principle of new settlements in the form of garden villages or towns, and to some schemes in particular. Such support stems in our view to a certain extent from a misunderstanding of the circumstances in which the original New Towns were proposed, which are quite different from those of today, and the scale on which they were built. Notwithstanding Government support, new settlements have in recent years often not found favour as a means of meeting housing and other requirements. The recent experience in Essex alone should give the Council serious cause to think about any option involving new settlements. The combined Local Plan for north Essex (Braintree, Colchester and Tendring districts) ran into difficulties over its reliance on new settlements; Examination of the Section 1 Plan began in October 2017 but strategic issues were still being discussed in January 2020. Shortly afterwards in nearby Uttlesford, the Local Plan proposed three new settlements, where there appeared to be a reasonable case for only one of them owing to its proximity to Stansted Airport. In a letter to the Council dated 10 January 2020, the Inspectors stated that the Local Plan was unsound for reasons summarised in no fewer than thirteen bullet points. Some of these were clearly specific to this particular Plan; but some were potentially applicable to any new settlement. The Inspectors also concluded that the Plan was incapable of being made sound by means of Main Modifications and thee Council resolved on 30th April to start a new Plan. One of the disadvantages of new settlements is the relatively high cost of physical infrastructure (roads, utilities, and other engineering work) in the early years of development. Another is the speed at which social infrastructure (schools, shops, other facilities and services) is provided, which tends to lag behind housing provision. This was a common criticism of the New Towns.
It is difficult to respond in any detail to this question in the absence of the kind of document – an infrastructure delivery plan – to which the Consultation Paper refers on page 24. Broadly speaking, however, infrastructure could be divided into that which helps determine the amount and distribution of development, and that which follows once the amount and distribution has been decided. The first category includes the recent improvements to the A421, and the proposed East West rail link and the improvements to the A428. We think that the Council should make maximum use of the opportunities arising from the A421 corridor. This is consistent with what we say in response to question 4.
The location of new employment sites should be consistent with the best overall strategy for growth – in our opinion, a suitable combination of the Pink and Yellow options as indicated above in response to Question 4. Since the introduction of mandatory district-wide local plans about thirty years ago one of the greatest difficulties in most areas has been in securing enough employment and achieving a suitable balance between housing and employment growth in sectors which require the allocation of significant amounts of land. Accessibility is the key. It follows that employment sites should be at a large scale and well related to the major road network. Land west of (and indeed adjacent to) the A1 at Wyboston meets both of these criteria: a site capable of accommodating over 50,000 square metres of employment floorspace can certainly be regarded as large scale in this context. The Yellow option generally provides the best opportunity to meet requirements for new jobs.
Once again, we consider that the Council should be realistic about not only the timescale for the completion of the East West rail link but also the benefits it would bring to Bedford Borough as opposed to the corridor as a whole. It would be unrealistic to expect the kind of science-based and university-related economic activity to spread throughout the corridor, at least in terms of an end date for this review of 2040.
Climate change is a national if not a global issue. We consider that the existing policies are sufficient and that there is no need for any supplementary planning document. Question 10 The Government is developing new house-building standards to be implemented through building regulations. Is there any local evidence or need to go beyond national standards? The Borough Council itself does not appear to have produced any convincing evidence of the need to go beyond national standards. Eclipse Planning Services view is that there is in any event no need to do so.
The town and country planning system has no control and little influence on the provision of public transport services, and relatively little direct influence on its use. Encouragement in the form of (for example) shelters, seats at bus stops and real time information is the responsibility of the providers. Nevertheless there is much that the planning system can do. First, it should provide for a distribution of development which will either encourage the greater use of existing public transport services or be on a scale which supports the provision of new services. However, we think the scope for the latter in these circumstances is limited, especially if the residual housing requirement is at the lower end of the range discussed in the Consultation Paper. Secondly, the Borough Council should in its engagement with applicants at both outline and reserved matters stages pay particular attention to layouts and other factors which encourage travel on foot and by bicycle. The land west of the A1 at Wyboston is ideally located to promote travel to St Neots on foot and by bicycle.
