Issues and Options

Yes

On behalf of the Executors of the late Nigel Alington, CODE Development Planners support the proposed general themes set out in the eight bullet points on page 11 of the Issues and Options – Consultation Paper, Summer 2020. However, we have the following specific comments and contend that the scope under some of the eight themes should be expanded to ensure that sections of the current Local Plan 2030 are reviewed in full. We support the primary focus of the local plan review being growth and infrastructure. However, the challenges and opportunities of the Oxford-Cambridge Arc will create changes in the travel behaviour of those living and working in the borough. The spatial distribution of growth across the borough will need to change to ensure that opportunities for sustainable development (tapping into the opportunities presented by the A428 Black Cat roundabout to Caxton Gibbet improvements (expressway), the additional capacity of the existing A428 for local journeys once the expressway is open, and the location of the new station on the new East West Rail route, all to the east of the borough) are fully explored. Existing policies and supporting text covering spatial strategy, the amount and distribution of housing growth, and development in rural areas (settlement policy areas and development in small settlements) should be reviewed to assess whether there is scope to expand small settlements (in the widest use of the phrase rather than the Local Plan 2030’s limited definition) with housing and infrastructure developed at commensurate rates. This would facilitate changes in the position/status of settlements within the settlement hierarchy or their coalesce with other settlements in the form of urban expansion. We propose that a new category/definition of settlement be included in the local plan review to cover “potential areas for development and growth”. For example, Little Barford, the majority of which is in one ownership and within one parish, is defined in the current Local Plan 2030 as “countryside”. However, as representations to the Call for Sites consultation (4 September 2020) demonstrate, development options in relation to Little Barford range from the expansion of the settlement to provide 270-340 new homes (option AL1), 1,115-1,305 new homes (option AL2) and 3,385-3,955 new homes (option AL3) with all three options providing between circa 6,500sqm-20,250sqm of employment floor space. A new category of settlement defined as “potential areas for growth and change”, would enable the settlement to grow through phasing of development and infrastructure over the plan period, without the need to cap its potential by inserting it into a tier of the settlement hierarchy that does not provide flexibility over the plan period. The scope of the local plan review should include consideration of the location of development to capitalise on the strategic infrastructure to the east of the borough. It is particularly important for Bedford Borough Council (BBC) to develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements and BBC’s location at the heart of the Oxford-Cambridge Arc. In order to successfully deliver targets, the necessary supporting infrastructure will be required. We therefore contend that the scope of the review of the local plan, should be extended to include an updated Bedford Borough Local Transport Plan, Infrastructure Delivery Plan and CIL Charging Schedule. To unlock sustainable sites, to achieve strategic growth potential, strategic local infrastructure requirements and securing their delivery through inter alia developer delivery, compulsory purchase and/or BBC fulfilling a brokerage role need to be investigated through the early stages of plan review.

In general terms we support the draft vision as set out on pages 13 and 14 of the Issues and Options – Consultation Paper, Summer 2020. We support the vision’s emphasis on transport links and connectivity providing opportunities within the borough for development. However, the third paragraph of the vision should be expanded to acknowledge that some of the strategic infrastructure, which will assist in unlocking growth potential in the borough, is at the edge of or beyond the borough’s boundaries. The vision should acknowledge the potential for major infrastructure to influence the location of residential and employment development and deliver additional locations with good access via sustainable transport modes, to benefit from the new station as part of the East West Rail project to be located between Little Barford and Church End. The following amendments would achieve this: “The development of East-West Rail through Bedford will be complete. Bedford will benefit from a new town centre transport interchange including links to Oxford and Cambridge, increasing connectivity, investment and growth. The East-West Rail will also provide a new station to the south of Little Barford to the east of the borough, which combined with the A428 Black Cat roundabout to Caxton Gibbet improvements will see the east of the borough grow and prosper. Collaboration with neighbouring local planning authorities to the east and other stakeholders, will deliver a spatial growth strategy with the distribution of growth recognising the intrinsic potential of the settlements and areas adjacent to the boundaries between Bedford Borough, Central Bedfordshire Borough and Huntingdonshire District. Local development will be well served by transport links and speedy internet access integrated into the planning process and completed commensurate with before residents movinge in. Bedford borough will continue to attract new business through the completion of significant infrastructure projects, in and close to the borough and through the development of high quality commercial and office spaces.”

I agree with this plan period

We support the Plan period of 2020-2040. A 20 year plan period allows sufficient time for the major infrastructure schemes to progress and ultimately be completed; the A428 Black Cat roundabout to Caxton Gibbet improvements expected to be open to traffic in 2025/2026 and the East West rail link from Bedford to Cambridge proposing to have services running before the end of the decade.

Nothing chosen

Page 16 of the Issues and Options consultation document states, “this consultation seeks views on a housing figure in the range of 800-1,305 dwellings per annum. It should be borne in mind that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum.” It goes on to state, “Once existing commitments, currently around 11,000 dwellings, are taken into account (including allocations in earlier local plans, neighbourhood plans, and planning permissions granted) BBC considered that it may need to make new allocations to provide between 5,000 and 15,000 additional new dwellings over a plan period to 2040.” The proposed new standard method for BBC is 1,153 dwellings per annum. The six locations considered on pages 18 to 24 of the Issues and Options – Consultation Paper, Summer 2020 have acknowledged advantages and disadvantages. The majority appear to be based on planning principles of sustainability. However, no one locational strategy can deliver the growth needed in the borough and we therefore support an approach that would combine the best and deliverable elements of these as set out below. Brown – urban based growth We support the broad principles of urban based growth as part of a mixed distribution strategy. We are encouraged by BBC’s consideration of urban extensions to settlements adjacent to the eastern boundary of the borough specifically St Neots in the neighbouring authority of Huntingdonshire District. However, we have concerns regarding the legitimacy of an urban expansion where integration with the main settlement is limited by the A1. The A1 which acts as a barrier would cause considerable challenges in terms of sustainable transport links to St Neots. Integration of a western expansion to St Neots is further frustrated by the built context on the St Neots side of the A1 which prevents suitable connections being constructed to cross the A1. A reasonable alternative and we contend a more sustainable option, is the expansion to the south of St Neots at Little Barford. Development has already expanded south of St Neots beyond the existing A428 which is to be reclassified once the A428 expressway is open. There are no major barriers to the integration of a new community at Little Barford with St Neots to the north. Additionally, Little Barford benefits from its proximity to the new East West Rail station to the south. Whilst the exact location for the station is to be confirmed, access to the south is provided in the form of a road overbridge enabling the existing Barford Road to cross the A428 Black Cat roundabout to Caxton Gibbet road improvement. Yellow – A421 based growth The diagram on page 18 Issues and Options – Consultation Paper, Summer 2020 extends growth north of the A421 along the A1. Given the limitations of the A1 to serve and integrate new development by sustainable means of transport the yellow line on the diagram should stop at the Black Cat roundabout. Should BBC wish to continue growth beyond the A421 road corridor an alternative would be to extend the yellow line along the A428 Black Cat roundabout to Caxton Gibbet improvement insofar as it exists within the borough. Pink – rail growth Bedford Borough is centrally located within the area defined as the Oxford-Cambridge Arc. The government has designated the arc as a key economic priority and expressed its ambition for up to one million new homes to be built across the area by 2050. The Oxford-Cambridge Arc: Government Ambition and Joint Declaration Between Government and Local Partners, March 2019 states that meeting “the long-term economic and housing delivery ambitions of the arc will require long-term commitments to provide enabling infrastructure, in the widest sense, that communities and business will need.” We agree with BBC’s assertions that the East West Rail route and associated new locations for new stations and the A428 Black Cat to Caxton Gibbet improvements (expressway) are fundamental schemes for unlocking the arc’s growth potential. Of the six options this is the growth strategy we believe has the potential for delivering sustainable development. Although the exact location of the East West Rail station has not been confirmed the area of search extends from Little Barford in Bedford Borough south to Church End in Central Bedfordshire. Growth at Little Barford would benefit from sustainable transport connections to St Neots. In addition, due to location and context of the land and the ability to design in sustainable transport and associated facilities to accommodate journeys between development at Little Barford and the new station this option has significant potential to provide sustainable travel choice. Whilst we acknowledge Central Bedfordshire’s choices related to growth surrounding Tempsford, we consider that whatever the outcome of Central Bedfordshire’s local plan, Bedford Borough can also benefit from the area of search for the location of the new station. We consider the land around Little Barford (refer to drawings 068-001-004 (AL1), 068-001-005 (AL2), 068-001-006 (AL3) and 60830-PP-005) is an area within Bedford Borough that would be suitable to deliver rail based growth. The submissions made during the Call for Sites process by CODE on behalf of the Executors of the late Nigel Alington for the land to the east and west of Barford Road, Little Barford are in the location of the potential development location shown on page 19 of the Issues and Options - Consultation Paper, summer 2020. Those submissions included proposals ranging from 270 – 3,955 dwellings and circa 6,500sqm-20,500sqm of employment plus associated infrastructure commensurate with the scale of development. Figure 2 on page 6 of the Issues and Options – Consultation Paper, Summer 2020 identifies the preferred corridor for the East West Rail north of Bedford. Whilst the exact route is not yet decided it provides a clear indication of where the line will go and those locations which could benefit. The “potential EWR station St Neots/Sandy area” provides additional opportunities. The construction of a station creates an additional access point to the rail network and an opportunity to promote sustainable transport methods. The station would provide north-south (East Coast Main Line) and east-west (Cambridge to Oxford) travel choices both for short journeys to St Neots and Bedford and longer journeys to Cambridge, London and Oxford and beyond. Areas such as Little Barford which are convenient and accessible by modes other than the private car should be the focus of growth in the plan period 2020-2040. Orange – East-West Rail northern station growth A rail station north of Bedford is not part of the East West Rail route proposal so we have no further comments on this growth strategy. Grey – dispersed growth We support the broad principles of a dispersed growth strategy subject to full investigations of sites for potential development. The diagram shown on page 20 of the Issues and Options - Consultation Paper, Summer 2020 only identifies settlements defined in the current Local Plan 2030. Such an approach excludes and fails to assess reasonable alternatives such as Little Barford. Currently, Little Barford is a settlement that does not have a defined development boundary in the Local Plan 2030 and therefore is defined as “countryside” for development management purposes. We do not consider this a justified reason to rule out development in the future through a review of the local plan. The level of growth required in Bedford Borough and Little Barford’s proximity to both St Neots and the “potential EWR station St Neots/Sandy area” and the A428 expressway providing a defined boundary to the east, elevates Little Barford as a sustainable location for growth of varying scales. Over the plan period to 2040, development around the historic core of Little Barford could grow to create a sustainable settlement. The scale of the settlement is not constrained by ownership as the land is in one ownership. Phasing of the development commensurate with infrastructure and the character of the existing settlement provides an opportunity to create a place which has its own identity whilst benefiting from its proximity to St Neots and a new East West Rail station to the south of the settlement. The dispersed growth strategy should be broadened to include “potential areas of growth and change” to consider areas in locations that can benefit from the planned strategic infrastructure of the East West Rail route stations and changing status of the existing A428 following the opening of the A428 expressway. Red – new settlement based growth We also support, in broad terms, a growth strategy that considers the potential for new settlements. However, given the changes that have emerged since the adoption of the Local Plan 2030, especially regards housing numbers the potential locations for these new settlements should not be limited to Wixams and the four new settlements put forward for the Local Plan 2030. A small number of large sites can mathematically achieve this number, however, consideration needs to be given to whether the specifics of larger strategic sites will enable “multiple starts” on site by different housebuilders and whether the site can be marketed in a way that would enable small and medium size housebuilders to compete with the nationals. In this way and in parallel with other mechanisms, variety and a sense of place can be created whilst at the same time delivering homes in the early years of the plan period. We consider that the existing built form of Little Barford, its wider locational context and the spatial shift required in the distribution of Bedford Borough’s growth due to the East West Rail route and new station requires Little Barford and the land promoted by the Executors of the late Nigel Alington as a reasonable alternative for a new settlement. The above comments demonstrate how the sites AL1, AL2 and AL3 at Little Barford can support a number of the proposed growth strategies put forward in the Issues and Options - Consultation Paper, Summer 2020. We emphasise that there is a need for BBC to consider all possible locations and sites that would support these strategies.

The A428 Black Cat roundabout to Caxton Gibbet road improvement (A428 expressway) and East West Rail scheme serve as development enabling schemes for the land around Little Barford. However, development of a site requires more than just enabling development, there will be further infrastructure requirements in order to deliver development. Once the A428 expressway is complete, the likelihood is that the existing A428 will be de-trunked. As a result, the responsibility for the current A428 is likely to transfer to the local highway authority. When this occurs, there is a possibility that the hierarchy of highway will reduce, and this brings the possibility of development/highway improvements being introduced as it will not be part of the Strategic Highway Network. The benefits this could bring to the local community may be better access from St Neots to the A428 travelling east if improvements were introduced. The proposed new rail station between Sandy and St Neots as part of the East West Rail scheme enables future development. In order to maximise the opportunity for growth around the station further infrastructure will be required. The scale of growth required within Bedford Borough and across the Oxford Cambridge Arc is such that the following should inter alia accompany the review of the local plan, updated Bedford Borough Local Transport Plan, Infrastructure Delivery Plan and CIL Charging Schedule. Additionally, to unlock sustainable sites in order to maximise growth potential, BBC should consider what mix of mechanism eg developer delivery, compulsory purchase, BBC fulfilling a brokerage role, will be needed. CODE would also encourage BBC not to shy away from, infrastructure schemes that would require compulsory purchase. Guidance on Compulsory Purchase Process and The Crichel Down Rules (July 2019) states that a compulsory purchase order should only be made where there is a compelling case in the public interest. With the proposed levels of housing growth contained in the Issues and Options consultation document coupled with the government’s ambition to deliver one million across the Oxford Cambridge arc by 2050 there is justified cause in the public interest to consider compulsory purchase in order to ensure these targets are met.

We consider land around Little Barford as a suitable site to accommodate employment growth. The proposals on drawings 068-001-004 (AL1), 068-001-005 (AL2), 068-001-006 (AL3) and 60830-PP-005 show an area to the north of Little Barford as an area for employment use filtering into an area of mixed-use development. This area to the north adjoins the existing Little Barford employment site designated by Policy 70 of the Local Plan 2030 as a key employment site. The policy explains, “The role and function of key employment sites which contribute to the economic function of the borough will be protected and further extension of employment uses and investment in premises will be supported.” The recently adopted local plan does not allocate new sites for employment because there was already enough land available that had not been occupied. However, that situation will change over this plan period up to 2040 and additional employment land will be required. As an extension to an existing employment area there is an opportunity for businesses similar to those currently operating from the site to cluster together. The site also benefits from access to St Neots and over the plan period will be benefit from the “potential EWR station St Neots/Sandy area” south of Little Barford which will provide access to both the north-south and east-west destination on the rail network. Page 27 of the Issues and Options consultation states, “Demand for buildings in Bedford with its excellent and growing transport links and proximity to other towns, including the capital within short journey times, will continue.” The site at Little Barford would deliver a site with immediate access to services in St Neots and any future development on the AL1, AL2, AL3 sites put forward as part of the call for sites process. Beyond the local context employment growth at Little Barford benefits from the improvements to transport links to neighbouring towns and further to Cambridge, London and Oxford.

Development should be focused in locations that can maximise the gains from the connections to the economic centres in Cambridge and Oxford. The Issues and Options consultation paper notes that, “Bedford borough has a skilled workforce, an above average rate of employment and a high proportion of ‘top level’ occupations. The economy of Bedford is diverse and vibrant, however many of the most skilled jobs are located outside of the borough as Bedford benefits from good strategic connections to nearby economic centres.” Locating housing in areas with convenient and safe access to the rail network through the stations, improved and created by the East-West Rail will allow the borough to continue to attract residents with ‘top level’ occupations who may work outside of the borough but spend more locally. The Oxford Cambridge Arc declaration highlights the issues of housing affordability in Oxford and Cambridge where the affordability ratio is 12.34 and 13.35 respectively. By enhancing the connectivity to these two cities Bedford can capitalise on its increased relative affordability in comparison and provide an alternate location for employees to reside. There is also the opportunity to attract high level businesses to the area due to the connections across the region and Oxford Cambridge Arc that Bedford Borough’s location provides. The central location between Oxford and Cambridge would be an attractive proposition to business looking to take advantage of the high calibre work force available. Collaboration and clusters are often at the heart of promoting successful business locations and this is something that needs to be emphasised by BBC to attract these high-quality businesses. In order to achieve either of these things BBC needs to ensure that residential and employment development is located in areas with the highest connectivity. Land at Little Barford, subject to the completion of the East-West rail and construction of a new station is such a location and could serve as a melting pot for collaboration in employment and a suitable location for people working at either end of the Oxford Cambridge Arc. We consider the East West Rail route as the most significant infrastructure development to enhance the connectivity of Bedford Borough with other economic centres. Locations with convenient and safe access to the gateways to the rail network should be the focus of growth.

In order to encourage residents and those working in and visiting the borough to use sustainable modes of transport there needs to be convenient and save access to the different modes of transport. This starts in homes providing space for secure storage of bicycles, through safe and direct routes to bus stops, schools, shops, work and leisure (safe in terms of segregation from other uses eg vehicles, surface type, lighting and surveillance), real time information for public transport and facilities at destinations (storage, showers etc). It is important that infrastructure is designed in a way to encourage sustainable journeys eg priority of pedestrians/cyclist over vehicle at junctions. The proposals AL1, AL2 and AL3 seek to encourage the use of sustainable modes of transport through a range of means. Even at this early stage the schemes have considered accessibility to public transport to ensure homes are within 400m of the main public transport corridors with an improved frequency to meet demand and local circumstances. Accessible compliant bus stops and infrastructure would be introduced with Real Time Passenger Information (RTPI) provision proposed where appropriate to enable better communication to customers of the services provided. Additional segregated bus infrastructure routes could be introduced should major benefits be realised by providing these. Additionally, and subject to the overall scale of the development connections to the public rights of way (PRoW) adjacent to the River Great Ouse could be created and existing routes enhanced to encourage greater use by pedestrians and cyclists. Improved facilities on Barford Road will also be considered to gain access to St Neots. Footways and cycleways will be an integral part of the development infrastructure to deliver sustainable choices for residents, employees and visitors. The frequency and consistency of any public transport services are going to be vital in encouraging people to use the services. Sites AL1, AL2 and AL3 at Little Barford present unique opportunities for BBC in this regard. As a proposed new development at these sites provides the opportunity to build in walking, cycling and public transport facilities from the beginning rather than trying to retrofit existing settlements. This sustainable transport network then has the opportunity to tie into the East West Rail proposal creating a region wide network of sustainable transport. It is the provision of these high-quality facilities that is going to be key to encouraging the use of sustainable transport.

BBC should consider the use of strategic multifunctional green infrastructure sites that other development could contribute towards. Each strategic Suitable Alternative Natural Greenspace (SANGs) would have a carrying capacity in relation to the quantum of development it could support. The land to the west of sites AL1, AL2 and AL3 has been included as part of Lower Great Ouse River Valley, Zone 3 of Policy AD24 Green Infrastructure Opportunity Zones in the Allocations Land Designations Local Plan (2013). However, there is currently limited public access. Opportunities to secure this through the allocation of AL3 would be considered by the Executors of the late Nigel Alington.