Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Support

Representation ID: 6364

Received: 13/09/2021

Respondent: CPRE Bedfordshire

The proposal to set the timescale for the plan to 2040 is supported. A 2040 plan creates a good balance by establishing a longer-term strategic perspective, alongside the recognition that strategic policies need to show the required agility to respond to evolving economic and social conditions.

Object

Representation ID: 6365

Received: 13/09/2021

Respondent: CPRE Bedfordshire

In the past CPRE Bedfordshire have criticised the Borough Council for what we perceive to be a lack of openness and transparency regarding the Council’s engagement with the government’s OxCam Arc Strategy. In this draft plan there appears to be a welcome shift in this respect as shown by the Council’s commentary on its view of the national context and national policy.

However, we are concerned that there is inconsistency and lack of clarity in the Council’s attitude to the government’s ambition for one million new homes by 2050 across the OxCam Arc and the implications for Bedford.

The Council is a signed-up partner in the ‘The Oxford-Cambridge Arc Government Ambition and Joint Declaration between Government and Local Partners’ but to our knowledge there has never been any open debate on the subject in any public Council meeting. CPRE Bedfordshire believe this represents a serious democratic deficit and undermines confidence in the Council’s Local Plan process.

The Joint Declaration should be added as one of the supporting documents for the Local Plan. Publishing the document is key to an open democratic process and would provide residents with full details of precisely what the Council has signed up to with Government.

The past lack of transparency on matters associated with OxCam has already caused acute embarrassment for the Council in the recent consultation on East West Rail, where the Council’s lack of transparency and engagement with local people about the development of their position in supporting for Route E was exposed. As a result, the Mayor and senior elected members of the Council embarked on a major effort to make up for lost ground through a series of virtual meetings with Parish Councils. This culminated in a special meeting of the Full Council where the subject was debated and a huge groundswell of opinion in opposition to the Council’s support for EWR Co’s preferred route became clear.

CPRE Bedfordshire is concerned that a similar situation now applies in regard to the housing growth implications associated with the OxCam strategy where we find it difficult to be confident that the Council is being fully candid and transparent. The Council claims to have no knowledge of how the OxCam strategy housing growth implications will impact in Bedford Borough. If this is the case, then it casts serious doubt over the credibility of the development of this local plan.

The Council is a member of the Central Area Growth Board. The Board was established over 3 years ago to provide the strategic leadership that will enable planning for economic transformation across the central area of the Oxford to Cambridge Arc. The Central Area Growth Board is a Joint Committee under s101 (5), 102 Local Government Act 1972.

One of the purposes of the board, as described in its Terms of Reference is; ‘To seek to establish Common Planning Areas to produce an integrated and holistic approach to strategic planning for employment, housing and infrastructure that builds on Local Plans, Local Transport Plans and Strategic Economic Plans.’

CPRE Bedfordshire are not closely familiar with the workings of such a body, although we believe that the Oxfordshire Growth Board has been instrumental in coordinating the agreement of a ‘Growth

Deal’ for Oxfordshire. We would like to know if the Central Area Growth Board is in the process of negotiating a similar agreement with the government for the central area. It is surprising the draft plan makes no mention at all of this body and its activities.

As a key partner in the OxCam Arc Strategy we would like to see the Council challenging the ambition for one million new homes by 2050 as unsustainable and unnecessary.

We would also like to see the Council making strenuous demands upon central government to make an agreement that the current expectation to submit a new local plan for January 2023 should be suspended pending the outcome of the OxCam Arc Spatial Framework and that the Council’s Local Plan 2030 should be recognised as being up to date until the implications of the Spatial Framework can be fully taken into account.

Alternatively, Bedford Borough Council could follow the example of Buckinghamshire County Council and withdraw from the Oxford to Cambridge 'ARC Leaders' Group'. Buckinghamshire made this decision because they considered that their top priority was to be in control of their own future economic development and housing decisions.

We ask, why would Bedford Borough be willing to forfeit their independence in regard to matters of such vital local interest?

Object

Representation ID: 6366

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Paras 1.7 to 1.10 - OBJECT
Para 1.7 states that the Joint Declaration is ‘silent on the numbers’, but this is inconsistent with para 1.6 which reports the government’s ambition to deliver one million new homes by 2050. The fact is that the Government apparently no longer wishes to mention the fact that it has an ambition to build one million new homes across the Arc. This appears to be because to say so is now toxic as the public begin to realise what one million homes really means, i.e., 20 cities the size of Cambridge across an Arc 85 miles long.

It is not at all clear that building one million new homes is no longer the government’s ambition. If one million new homes is no longer the ambition of Government, the local authorities and LEPs that signed up to the Joint Declaration should all state that, and the Joint Declaration should be revised to show this significant change.

The comments in para 1.7 to 1.10 indicate that the Council’s stated position is to support the proposition that achieving the Arc’s full economic potential will demand collective determination over the long-term, to “deliver significantly more homes in the Arc.” This seems to imply that the Council figure for future housing requirements of 1,275 dwellings per year, as calculated in this draft plan according to the Standard Method, will need to be substantially increased to accommodate the implications of OxCam.

In its present form, Local Plan 2040 would write into council policy the Council’s support for the OxCam Arc ambition to deliver one million new homes by 2050 and acceptance that this will involve a significantly higher housing requirement for Bedford than the housing requirement put forward in this local plan.

CPRE Bedfordshire strongly object to the implications of these paragraphs as, for reasons stated later, we already believe that the figure for future housing requirements, calculated according to the Council’s interpretation of the government Standard Method, of 1,275 dwellings per year, is excessive and unjustified.

We have arrived at this understanding through a process of deduction. In our view the implications of paras 1.6 to 1.10 being written into council policy are not clear and transparent.

CPRE Bedfordshire believes that the Council should be challenging the implications for significant additional housing growth required by OxCam and should therefore revise these paragraphs accordingly.

If the Council is not willing to challenge these expectations, the Local Plan should at least be revised to highlight more clearly the implications of OxCam on Bedford’s future housing requirement.

Object

Representation ID: 6367

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 1.46 to 1.51 – OBJECT
CPRE Bedfordshire supports and commends the Borough Council’s positive approach to Neighbourhood Planning.

We support what appears to be a recognition that current expectations for housing growth delivery on Key Service Centres and Rural Service Centres should not be added to in this plan. It is our view that the new housing to be delivered through Neighbourhood Plans for Local Plan 2030 in rural villages should be allowed to mature during the plan period to 2040.

We look forward to seeing the Borough Council continuing to demonstrate their support for
neighbourhood plans by determining future planning applications according to neighbourhood plan policies where these are in place.

However, we continue to hold major concerns about the 2030 plan target for 2,000 dwellings to be contributed by the Key Service Centres. We believe this should be reduced by at least 50%. Our views on this are explained further in our comments on paras 3.1.to 3.5

Object

Representation ID: 6368

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 1.52 – OBJECT

CPRE Bedfordshire believe that the Council should not acquiesce with the uncertainties resulting from the timing of the emerging Oxford to Cambridge Arc Spatial Framework.

As stated earlier, we believe the Council should act with urgency to reach agreement with the government to suspend the submission date for this local plan until the requirements of the Spatial Framework are made known.

Without such an agreement, the Council and the local communities’ ability to maintain
control over the selection of locations for growth through this local plan is seriously compromised.

Alternatively, Bedford Borough Council could follow the example of Buckinghamshire County Council and withdraw from the Oxford to Cambridge 'ARC Leaders' Group' in order to remain in control of their own future economic development and housing decisions.

Object

Representation ID: 6369

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 2.1 – OBJECT

CPRE Bedfordshire believe that the Council’s vision is unacceptable because, as stated earlier, the uncertainties resulting from the timing of the emerging Oxford to Cambridge Arc Spatial Framework undermine the credibility of the draft plan. We believe the Council should act with urgency to reach agreement with the government to suspend the submission date for this local plan until the requirements of the Spatial Framework are made known. Without such an agreement, the ability of the Council and local communities to maintain control over the selection of locations for growth through this local plan is seriously compromised.

The Local Plan Vision fails to recognise the importance of the "River Great Ouse and its Valley Area" right across the Borough from its point of entry near Turvey to where it exits the Borough in the east. This is a serious omission that should be remedied.

The river and valley area is the single most important environmental feature in the Borough bar none, and an area where very substantial biodiversity improvement can be achieved very quickly. It is the "Jewel in the Borough's Crown" across its entire length in the Borough, and not simply as a feature of the Town Centre as is often stated by Borough policy makers.
The absence of any recognition of this in the Local Plan gives the strong impression that the Council is preparing, as part of its Ox-Cam commitments, to allow substantial developments in or near the river and valley area.

The Council should state clearly and positively in the Local Plan 2040 that the "Protection and Enhancement of the River Great Ouse and its Valley Area" right across the Borough is one of its key objectives and that biodiversity improvement in the river valley area will be a primary focus of its Environmental and Climate Emergency strategy.

Support

Representation ID: 6370

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 2.2 – SUPPORT with comments

The vision themes which aspire to a ‘Greener’, more ‘Accessible’ and ‘Prosperous’, Borough with ‘Better Places’ for all to use and enjoy, provide a positive platform for the plan. However, without clearer and more specific targets and timescales to support the ambition to make “Bedford a net zero carbon emissions borough whilst improving, enhancing and creating green infrastructure and spaces,” the prospects of making substantial progress will be considerably weakened.

Object

Representation ID: 6372

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Para 3.1 to 3.5 – OBJECT
Calculation of Bedford’s housing requirement

The current Local Plan 2030 requires that the Council arrange for the development of 970 new homes per year over the Plan period. The proposed new Local Plan 2040 will increase this by 32% to 1,275 new homes per year over the 20 year period of the Plan – a total of 25,500 new homes.

The calculated housing requirement of 25,500 dwellings is equivalent to building around 25 new villages the size of Sharnbrook (approx. 1,000 homes) or six new towns the size of Ampthill (approx. 4,000 homes).

Existing commitments
A full breakdown of existing commitments, referred to as representing 13,000 dwellings (including allocations from current local plans and an allowance for windfall) should be provided so that the accuracy and reasonableness of this figure can be examined. In the absence of an analysis of the forward trajectory upon which this figure is based, the gap between the proposed housing requirement figure and existing commitments cannot be verified.

Key Rural Service Centres
In regard to the allocations from current local plans, CPRE Bedfordshire believe that the substantial inflation of the housing requirement in the 2030 plan as well as this draft 2040 plan has resulted in excessive expectations upon the Key Service Centres of Bromham, Clapham, Great Barford and Sharnbrook. The Council should be challenging the current government advice on the standard method so that the Council’s housing requirement can be recalculated based on the most up to date data from the Office for National Statistics (ONS). This would allow for the current expectations for new housing delivery from the Key Service Centres, currently totaling 2,000 homes, to be reduced by at least 50%.

CPRE Bedfordshire fully recognises the need for new homes for the people of Bedford
Borough and in particular, affordable homes and social housing. However, these huge
numbers are based on inaccurate and outdated 2014 housing data from ONS and the much criticised Standard Method algorithm which the government insist that local authorities use to determine housing need. This is despite considerable disquiet among government MPs and demographic experts, including the highly regarded company Opinion Research Services (ORS), which was responsible for preparing the Council’s Local Housing Need Assessment upon which the draft Local Plan 2040 is based.

ORS point out in the “Bedford Borough Housing Needs Assessment” (HNA) page 12, para 28, that the housing needs of all the people of Bedford Borough over the 20 year Plan period, including those people expected to migrate into the area from elsewhere in the UK, can be met by building 15,442 new homes, a very considerable reduction on 25,500 proposed in the Local Plan.

The government then insist however, that a further 8,877 new homes are added to the
15,442 to encourage even more inward migration into the Borough.

As ORS point out in a comment on page 74 of the HNA para, 6.16:
“This level of inward migration is notable ……… The extra 8,877 dwellings for inward
migration implied by the standard method represents an increase of 88% over and above
the inward migration already included in the most up to date household projection” i.e.
15,442 new homes.

This is a staggering increase with no justification from Government.

The ORS data shows that approximately 70% of the total of 25,500 new homes to be built in
the Plan period are to encourage a massive inward migration of people from elsewhere in
the UK to Bedford Borough.

This is a key part of the Government’s development plans for the OxCam Arc which the Mayor and the Council have signed up to without consulting local people.

These plans will not make housing cheaper or any more accessible for local people – driving
a huge inward migration of people into Bedford Borough will simply increase housing
demand and therefore increase the price of new homes and building land. The only people
to benefit from this will be developers and landowners/speculators.

If accurate, up to date ONS data is used from 2018 Housing Formation analysis, then the calculated housing need for the Borough would be similar to the current Local Plan 2030 housing requirement of 970 dwellings per annum.

CPRE Bedfordshire's position is that we are completely unable to accept the figure of 1,275
new homes per year which will destroy the Bedfordshire countryside at a time of:
• Climate Emergency
• Catastrophe of biodiversity loss - bird species in the UK have dropped by between 40% and 70% in the last 40 years and insect populations by similar numbers and the decline is increasing at pace.
• The UK’s ranking amongst the most nature depleted nations on earth.

The cause of much of this has been the "Growth At Any Cost Agenda" that has been
followed for many years. We urge the Council to reject this agenda and the "business as
usual" approach and to look towards different, more modern and more environmentally
sustainable objectives.

This means turning away from the government’s OxCam housing growth ambitions and
focus on building good quality affordable housing for local people (including a reasonable level of inward migration) and the protection and enhancement of the beautiful Bedfordshire countryside, not its destruction.

Bedfordshire is one of the smallest counties in England but the 13th most densely
Populated. Our countryside is therefore precious.

Comparisons with other Local Planning Authority housing targets

CPRE Bedfordshire has compared Bedford Council’s housing target, which has been calculated using the government’s discredited standard method algorithm, to the housing targets of other surrounding local authorities.

In this comparison, Bedford Council’s housing target of 1,275 new homes per year for the next 20-year duration of its draft Local Plan 2040 is shown to be:
• One of the highest of any local authority in the southeast of England outside of the Greater London Metropolitan area.
• Higher than that of the city of Cambridge or any local authority in Cambridgeshire.
• Higher than the housing target of the city of Oxford or any local authority in the county of Oxfordshire – in fact, it is almost double the target of each local authority in Oxfordshire
• Bedford Council’s housing target is over 30% higher than that of Huntingdonshire District Council, part of Cambridgeshire, and 18% higher than that of South Cambridgeshire Council. (Both of these Cambridgeshire authorities have similar
populations to that of Bedford Borough.)

The counties of Oxfordshire and Cambridgeshire are more than twice the size of Bedfordshire, which is one of the smallest counties in England.

Bedford Council’s housing target is 31% higher than that of North Hertfordshire, 180% higher than East Northamptonshire, 142% higher than Kettering and 266% higher than Wellingborough.

Detailed comparisons are shown in the appendix.

Support

Representation ID: 6373

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Paras 3.10 to 3.14 – COMMENT
The spatial strategy options put forward in the draft plan offer a helpfully wide range of choices for consultees to comment on.
The following principles should apply to consideration of the Council’s preferred development options:
• The plan should adopt a ‘brownfield first’ approach to the spatial strategy.

• The focus on transport corridors is supported, subject to the need to avoid development intrusion on high quality agricultural land, open countryside, and rural communities as far as possible.

• Developments should be delivered in a way that maximises environmental protection and enhancement opportunities

• Full weight should be given to the views of parish councils and local residents

Object

Representation ID: 6374

Received: 13/09/2021

Respondent: CPRE Bedfordshire

Paras 3.18 to 3.25 – OBJECT

There is a complete absence of any recognition of the need for a sustainable network of safe segregated cycle routes across the Borough, e.g., north/south linking Wixams (bridging the A421) to Milton Ernest through the centre of Bedford.

There is also no mention of a safe segregated cycle route to Bedford Station. It is deeply unsatisfactory that the there is still no segregated cycle route to Bedford station from any direction.

Cycling is the way forward at a time of climate change and biodiversity loss. It will improve the health and wellbeing of residents.