Issues and Options

Yes

Since the publication of this consultation document, we have seen one of the biggest proposed changes in the planning system since it was first established, we recognise and sympathise with the Policy Team in trying to plan in these uncertain times. Despite the proposed changes it is clear that Planning remains a plan led system and that the Local Plan will form a fundamental bedrock of the planning system. The work that is currently being undertaken by Bedford Borough Council (BBC) is commended and considered to be a proactive approach which is much needed in times of economic uncertainty. 1.7 The Local Plan should seek to identify the need and direct development to the most appropriate areas. Given the recent adoption of the Local Plan 2030, many of the policies are likely to be considered sound and the Revised Local Plan should focus on reviewing the adopted development strategy and making new land allocations to meet the identified housing and employment needs, as was suggested by the Inspector in finding the Local Plan 2030 sound. 1.8 The list of topics in the Issues and Options document suggest that the Local Plan will make such allocations and will have policies to ensure that this growth is sustainable and delivers high quality development, which is supported. 1.9 The inclusion of policies to control the location of food outlets is not considered necessary, particularly in light of the changes to the Use Class Order that comes into force on the 1st September 2020. It is also considered that reviewing such policies will dilute the core focus of the review which should be sustainable development. 1.10 The quantum of housing growth to be planned for does not seem to have been included within the scope of the plan. It is vital that the level of development required is identified so that it can be sufficiently planned for in a sustainable way. 1.11 As is indicated in the document (pages 6 and 16), the current Standard Methodology is proposed to be used to form the basis of the housing requirement for the borough. This requires a minimum of 1,305 dwellings per annum over the period to 2040. At this time, it should be this level of growth, as a minimum, that the Local Plan seeks to provided. In reality, depending on the proposed strategy and the risk to the delivery of allocated sites, the plan will need to plan for 10-20% additional growth above this figure to ensure the minimum need is met. Furthermore, the recent changes announced include a change to the Standard Methodology. In relation to BBC, this is unlikely to represent a significant increase from the 1,305 dwellings per annum, but the Local Plan must ensure that there is sufficient flexibility within the Plan to accommodate additional housing if required. This will create a strong housing market which ensures choice and affordability while not compromising the sustainability of the development. Bedford Borough Local Plan Issues and Options Response Land at Cotton End 1.12 The Oxford to Cambridge Arc has been identified as a key growth area from Government. It is anticipated that the Arc could deliver 1 million new homes and 1.1 million new jobs by 2050 in addition to significant infrastructure investment. It is therefore paramount that the authorities within the Arc plan positively for the predicted growth. BBC have planned for their existing growth projections however these are not considered to go far enough to enable the level of development and growth that is being proposed. 1.13 Given the Government’s objective of significantly boosting the supply of homes, originally set out in the 2017 Housing White Paper and reiterated in the current White Paper consultation, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge Arc and the current consultation on the Standard Methodology, it is clear that the current level of housing requirement of approximately 970 dwellings per annum will be unrealistic and insufficient to meet the needs of this growth area. 1.14 The scope of the Local Plan should therefore be to accommodate a minimum of 15,000 additional homes on top of existing completions in addition to any Neighbourhood Plan allocations. 1.15 The second key issue not addressed in the questions is the extent to which the ambitions for the Oxford to Cambridge Arc are addressed in the review. Whilst there is currently no arc-wide spatial strategy, progress has been made on a number of key infrastructure projects in the area and there is a clear intent from the Government to drive forward growth in the Arc. 1.16 As part of the most recent Budget announced in March 2020, it was confirmed that: The government has designated the corridor of land connecting Oxford, Milton Keynes, Bedford and Cambridge (the OxCam Arc) as a key economic priority. Earlier this year, the government announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… The Budget announces plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the OxCam Arc. This will support the area’s future economic success and the delivery of the new homes required by this growth up to 2050 and beyond. The government is also going to examine and develop the case for up to four new Development Corporations in the OxCam Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge, which includes plans to explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development.” 1.17 It is therefore clear that the Government remains committed to the Arc with the expectation being that there will be significant residential development to support the economic potential of the area. 1.18 The Government’s position, alongside the fact that Policy 1 of the adopted Local Plan requires the review to address Arc related issues, suggest that the scope of the Local Plan review needs to give more emphasis to assessing the implications of the Arc related policy announcements and infrastructure investment decisions, particularly as they relate to the level of growth to be planned for and spatial decisions. Bedford Borough Local Plan Issues and Options Response Land at Cotton End 1.19 The significant changes currently being proposed by the Government in terms of the Arc, Standard Methodology and the White Paper are likely to evolve in parallel to the revised Local Plan, it is therefore paramount that sufficient flexibility is incorporated within the Local Plan review to enable it to adjust quickly to any changes required to ensure it is in accordance with national planning policy.

2.1 Although it is acknowledged that the vision is still evolving, in its current form it lacks clarity and focus. The vision should be a short, bullet pointed explanation of what the Local Plan hopes to deliver. In its current form it is hard to understand what the main focus of the plan is. It needs explicit reference to what growth is being planned and where and how this growth will seek to improve the built environment while protecting and enhancing the natural environment. 2.2 Whilst there are references to the town center and the west of Bedford, where growth is already planned, there is no reference to the role of other settlements, how they relate to infrastructure enhancements nor how they will contribute to the overall aspirations for the Borough. This is an omission and will need to be amended in future iterations of the Vision. 2.3 It would perhaps be useful to establish a number of objectives which would clearly identify how the vision for the borough is going to be met. This would give greater clarity in terms of what is being proposed.

I do not agree with this plan period

3.1 The NPPF (paragraph 22) sets out that the strategic policies for an area ‘should look ahead over a minimum 15 year period form adoption’. It is currently assumed that the revised Local Plan will be adopted in the winter of 2023, meaning the plan period should run until at least the end of 2038. 3.2 However, this assumes that the Local Plan is prepared and adopted in line with the expected timetable. Given the current level of uncertainty the adoption of the Local Plan by winter 2023 may be difficult to achieve and would only give some 12 months of flexibility in the plan production process to ensure that the plan looks 15 years ahead from the date of adoption. It is therefore considered more achievable to look to 2045, this would provide sufficient headroom if the plan production were to slip as well as ensuring a comprehensive approach is provided. 3.3 Starting the plan period in 2020 is considered suitable and is supported given this is when the evidence base will be gathered to support the Revised Local Plan.

Nothing chosen

4.1 As stated within the Issues and Options document, the current development strategy will not deliver sufficient growth to meet the anticipated needs over the longer period that the Local Plan will need to provide for. In addition, there are a number of planned and emerging changes to national planning policy, including the Standard Methodology, the White Paper and the planned development of the Arc that will need to be considered to ensure that sufficient development is planned for to support the demand. 4.2 A minimum of 15,000 new homes will need to be delivered over the Plan period (assuming a 2040 end date) meaning land for around 16,500 -18,000 new homes will need to be planned for to ensure delivery. 4.3 The proposed development strategy must come forward in association with the infrastructure investment to ensure sustainable growth in areas that people want to live, work and relax in. 4.4 The Issues and Options document sets out 7 locations under consideration by the Council to accommodate growth. These are: ● Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites; ● Expansion of the Bedford / Kempston urban area; ● Expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; ● Development along the A421 corridor; ● Development around an East West Rail northern station; ● New settlements in locations with good accessibility; ● More dispersed development throughout the borough including the expansion of villages. 4.5 Given the level of growth that will need to be accommodated in the area, it is likely that the strategy will need to accommodate aspects of the majority of these options. 4.6 Our clients land is situated at Cotton End and therefore the particular growth option that is of relevance is the ‘Development along the A421 Corridor’. The site would however support other development strategies such as ‘urban based growth’ and ‘dispersed growth’. Bedford Borough Local Plan Issues and Options Response Land at Cotton End A421 based growth 4.7 Our client strongly supports a strategy which focuses a proportion of growth along the A421 corridor. This is the key route through the Borough which not only provides road access to the key centres of Milton Keynes and Cambridge but is also the focus of employment growth in the area and a key route for movement within the Borough linking the A1 to the M1. 4.8 As already noted, and referred to in the Issue and Options Paper, the A421 has seen considerable growth in employment floorspace over recent years given the location in both the Oxford to Cambridge Arc and the M1 corridor. Moving forward, it is to be expected that this demand will remain. Therefore a proportion of future housing growth should also be accommodated in the area where employment opportunities can be accessed easily. 4.9 Cotton End is well located to existing services and facilities as well as the employment opportunities in Cardington, Bedford and the neighbouring local centres. Outside of the main urban area. Cotton End has good access to the A421 in both directions from where employment, leisure and retail opportunities can be accessed with ease. 4.10 Importantly, it is close to the location of the proposed new East West Rail station to the east, which is likely to be accessible by sustainable modes of transport. East West Rail will be one of the key infrastructure investments in the area over the plan period and it is important that the opportunities associated with this significant investment are maximised. It will provide an important route between Oxford and Cambridge as well as linking to the wider train network. Cotton End is particularly well placed in close proximity to the proposed new station at Wixams as well as the existing station at Kempston Hardwick. 4.11 In addition, Cotton End has good links to Bedford via High Road. The level of development planned for this area will facilitate improvements to the main employment, leisure and retail areas. 4.12 Proposed development at Cotton End would not impact on the planned delivery of the East – West Rail.

5.1 A significant amount of infrastructure investment is planned for BBC, including the A428 improvements and the East West Rail, both within the next plan period. These are however cross boundary infrastructure provisions, and as such it will be vital that BBC liaises with the neighbouring authorities such as Central Bedfordshire Council, Huntingdonshire Council, Milton Keynes Council and South Cambridgeshire District Council to ensure that a coherent and effective infrastructure strategy is developed. This will ensure that the benefits of the significant investment are maximised for all of the authorities. 5.2 At a more local level, it will be vital that the existing and proposed services and facilities are sufficient to meet the local requirements. Larger developments, such as the one proposed at Cotton End will enable a greater level of infrastructure to be provided as part of the development which would benefit new and existing residents.

6.1 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations, should these form part of the future development strategy. 6.2 Development at Cotton End could provide additional employment land to support and compliment the existing businesses in the area, it is proposed that smaller units are provided to support the large businesses, in particular the Cardington Hangers and their use for film, TV, media, etc.. This employment area could be expanded on within close proximity to new homes and help facilitate growth in this sector. A smaller scale employment area would also provide variety in the market and encourage fledgling businesses to grow within the district. 6.3 It is important to ensure that a range of business units are provided within Bedford Borough to encourage a range of businesses. Employment areas should be well located to the existing road network as well as near high quality housing.

7.1 As noted above, it will be important that new residential development is located close to the existing and proposed infrastructure. The employment land could help facilitate growth in the film, media and TV sector through its geographic connection to the Cardington Hangers. 7.2 It is also important that a variety of housing types and locations are provided to satisfy the needs of the residents who are likely to choose to live in and around Bedford and travel to work. This must include house types that reflect the different life phases, from starter homes to retirement homes, therefore ensuring that communities are able to stay within the Borough. 7.3 The provision of improved links to larger cities such as Cambridge, Oxford and Milton Keynes may attract more people that are living in the Borough and commuting out for work. If people are commuting via the transport hubs, particularly those created by the new stations, it is vital that sustainable travel methods are put in place for the ‘last mile’, i.e. people are able to get from their homes to the train stations in a sustainable way, this may include the provision of park and rides or cycle parking and cycle paths.

8.1 We do not have any further views on Bedford Town Centre.

I disagree

9.1 The NPPF (paragraph 20) makes it clear that planning measures to address climate change are a strategic matter. Therefore, the issue should be at the heart of decisions made about the spatial strategy. 9.2 Paragraph 149 of the NPPF states the Local Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity. 9.3 At a high level, this means development being avoided in areas which are more vulnerable to the impacts of climate change and ensuring that adaption measures, such as new green infrastructure, are built into plans. 9.4 The location of development is therefore the key aspect of how the Local Plan should respond to climate change, rather than detailed guidance for developers. As has already been discussed, ensuring development is well located in relation to transport infrastructure will be key to this, as will ensuring there are opportunities for existing rural settlements to remain viable with a range of services and facilities for new and existing residents. 9.5 Whilst guidance on how the layout of development and the design of buildings would be helpful to ensure matters such as orientation, massing and landscaping contribute to minimising energy consumption, the setting of standards to be achieved by new development should be avoided unless they relate to the application of the Government’s technical standards, as required by paragraph 150 of the NPPF.

10.1 Our client would strongly recommend that the national standards are used, this will provide competition in the market and ensure that BBC is a competitive place to develop. Without sufficient research and justification, increasing the house building standards could harm the housing market within BBC and stop much needed development.