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

Object

Representation ID: 5945

Received: 08/09/2021

Respondent: Staploe Parish Council

Staploe Parish and especially the residents of HONEYDON (including myself) could be profoundly and permanently affected by the decisions made in this plan and yet we have been unable to meet as a community in public or other local residents to discuss this until very recently. Plus it’s been difficult to cascade and discuss about the 25% increase in the area of the Dennybrook (site 977) site because it was made public at short notice 8 months after the call for sites deadline closed and only one month before the consultation opened!!.

Object

Representation ID: 5948

Received: 08/09/2021

Respondent: Staploe Parish Council

I did not agree that this consultation is sound or fair. I agree with Staploe Parish Council who responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or under utilised land. Our whole parish is classed as open countryside for planning purposes. Our rural hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.

I had read and believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots and Biggleswade retail park which are already under eminence pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here to make sustainable travel choices – we have one bus on Thursday 10am pick up and drop off around 3.30-4pm so would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would not improve viability of retail and leisure in Bedford Borough and it would also significantly increase traffic congestion towards Bedford, but most people would go to St. Neots, as like myself, I don’t go into bedford.”
I strongly feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.

It is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.

In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses: Number of respondents = 315

• 222 were from within the borough – out of a total estimated population of 174,687. This is a pitiful 0.12% response rate
• 93 were from outside the Borough or did not give a postcode
• 53% were from individuals.
Top areas for numbers of responses:
1. Bedford 46
2. Sharnbrook 23
3. Staploe 18 (a 6% response rate which was 50 times the Borough average)

By contrast – no other areas were in double figures. This brings into further question the validity of the consultation.
100 word Summary
I believe that the Issues and Options consultation is invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2).
We would also call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.
A rail based growth strategy policy may be required if growth is to be located around rail.

Object

Representation ID: 5950

Received: 08/09/2021

Respondent: Staploe Parish Council

I am very concerned and disappoint by the transparency that this call for sites initially showed Dennybrook (site 977) as a much smaller site beyond the boundaries of Honeydon. We were only informed in May 2021 (an astonishing 8 months after the call for sites closed) that the site boundary had expanded by approximately 25% to engulf the whole of the hamlet of Honeydon and Begwary. The new site showed many existing homes, including mine of 13 yrs surrounded on all sides by housing estates. Therefore I believe that the call for sites was not conducted in an open and transparent manner. Residents and myself only had one month to gather our thoughts about this enormous new development of up to 10,800 homes which engulfs our properties before the draft consultation opened. I do not believe this is a fair consultation!

Duloe Field (3420) was also added late. We do not believe sites submitted after the deadline should be considered.
100 word summary
The site at Dennybrook expanded in area by around 25% after the call for sites closed to engulf the hamlets of Honeydon and Begwary. I was informed only 8 months after the call for sites closed (sept 2020) about this expansion which left only 4 weeks for myself and other residents to consider this and seek advice before the consultation on the Draft Local Plan opened. Duloe Field (site 3420) was also submitted after the deadline. We do not believe sites submitted after the deadline should be considered and certainly not very large sites submitted 8 months after the deadline.

Object

Representation ID: 5951

Received: 08/09/2021

Respondent: Staploe Parish Council

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
100 word summary
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Representation ID: 5952

Received: 08/09/2021

Respondent: Staploe Parish Council

The Oxford-Cambridge Arc identifies a delivery period of 2050. Bedford Borough Council consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales and transparency. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.

Object

Representation ID: 5953

Received: 08/09/2021

Respondent: Staploe Parish Council

I do not agree that there should be extensive new housing development within the Oxford Cambridge arc. Much of it is rural and with productive agricultural land which we believe should be retained. I strongly believe that any large scale allocations over 2,500 homes should not be permitted until the Oxford Cambridge arc has developed its spatial strategy.

Object

Representation ID: 5956

Received: 08/09/2021

Respondent: Staploe Parish Council

I believe it is important to map the soil (which forms part of the natural capital) and therefore the agricultural land grades much more closely as this is a key part of the National Planning Policy Framework. The agricultural land classification map published by Natural England presents a number of difficulties: it is only available at a scale of 1:250,000 and so it is not easy to identify individual parcels of land. The map states that it “represents a generalised pattern of land classification grades and any enlargement of the scale of the map would be misleading”. The webpage states that the map “is intended for strategic uses” and is not “sufficiently accurate for use in assessment of individual fields or sites and any enlargement could be misleading”. The map is based on old survey information and circumstances may have subsequently changed. The map does not differentiate between Grades 3a and 3b. Grade 3a is included in the NPPF’s definition of best and most versatile agricultural land (along with Grades 1 and 2). Of the larger sites as far as we can see Dennybrook (site 977) (along with all land in Staploe Parish) is all grade 2 land with possibly a bit of grade 1 near Wyboston. Great Barford and Colworth are largely grade 3 and Twinwoods is grade 2 but has a significant proportion of brownfield land. However, we believe Bedford Borough Council should commission a more detailed survey of the agricultural land quality in the Borough.
100 word summary
I believe it is important to map the soil (which forms part of the natural capital) and therefore the agricultural land grades much more closely as this is a key part of the National Planning Policy Framework and consider brownfield sites 1st. The agricultural land classification map published by Natural England is not sufficiently detailed. High quality agricultural land should not be used for development and therefore more detailed information is needed before decisions about site allocations are made.

Object

Representation ID: 5957

Received: 08/09/2021

Respondent: Staploe Parish Council

The scope of the Local Plan is broadly acceptable. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
NB: St Neots has a population of around 36,110 already, and adding Dennybrook on it’s boarders would create another 20,000 people. As you can see from the rail stats from last couple of years, current railway stations are at full capacity. I’ve travelled into London for the last ten years plus and now I can’t get a seat on the train to London !!! So adding 10K more houses, the rail network will be unable to cope re the demand.

Object

Representation ID: 5958

Received: 08/09/2021

Respondent: Staploe Parish Council

I object to the presentation of the 4 options in the summary leaflet that residents received regarding the draft plan. There is just one small statement saying that other options are available in the summary leaflet and I believe this is misleading – most people will only respond based on the summary document and are unlikely to look up the alternative options.

We also object in the strongest terms to the fact that Dennybrook (site 977) (land west of Wyboston) is presented as a development of only 2,500 homes and it is not made at all clear in the summary leaflet that this is the first phase of a large town of 10,800 homes.

A number of our residents have told me and Staploe Parish that they believe they have to choose from the 4 options and that they believe Dennybrook would remain a site of only 2,500 homes based on the information they have seen in the consultation. This demonstrates that it is misleading.

It is stated in the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.

I would like to request that the decision about which sites to choose for development be made at full council with Borough Councillors being given the opportunity to vote on it before it reaches the “is it sound and is it legal” stage of the plan – regulation 19. We would ask that the decision is therefore not made by the Mayor of Bedford’s executive powers. We would also like to request that, where a Borough Councillor is conflicted due to a conflict of interests, an alternative Borough Councillor representing the same party is permitted to vote on the matter in their stead. Our Borough Councillor Tom Wootton is conflicted regarding the proposed site at Dennybrook (site 977) and we would like Councillor Moon to vote in his stead.
100 word summary
The consultation on the draft plan is misleading. It is not sufficiently clear that alternative options can be proposed other than the 4 presented. It is not made clear that the new settlement at Dennybrook would be the first phase of a development of 10,800 homes. The full impacts of Dennybrook and Little Barford as new settlements should be fed into the assessment of the options independently. Please make the decision re choice of sites in a full council meeting (not executive) and permit Councillor Moon to vote in place of Tom Wootton as the latter is conflicted re Dennybrook.

Object

Representation ID: 5959

Received: 08/09/2021

Respondent: Staploe Parish Council

I will be commenting on site submissions in our parish, Little Barford (907), Twinwoods (883) and Colworth (1002). See comments under each of these site assessments.