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

Support

Representation ID: 7929

Received: 20/09/2021

Respondent: Pavenham Parish council

This response to Bedford Borough Council’s emerging Local Plan 2040 – Strategy Options and Draft Policies Consultation is submitted on behalf of Pavenham Parish Council.
The Parish Council would wish, at the outset, to record its thanks to the Borough Council for the extension in time granted so as to enable the Parish Council to formulate its response and in so doing, apologises that by reason of its late submission, it has not been possible to complete its submission on-line.
To place this response in context, it should be noted that the Parish Council is currently promoting its own Neighbourhood Plan. That Plan is now in an advanced stage – albeit awaiting final consultation and exhibition - and full account will be taken, insofar as is practicable and legally acceptable, of the Borough Council’s emerging Plan as it impacts on the Bedford Local Plan 2030 and the Parish.
The Parish Council recognises the very real challenges the Borough Council now faces in meeting the Government’s latest housing provision required target. The 33% housing provision uplift when compared with the locally-calculated housing growth which was planned for in the Local Plan 2030, (paragraph 1.11 of the Consultation Document) is recognised and the Parish Council’s comments on housing provision are made in the context of the Borough Council’s obligations.
In addition to this required substantial housing provision uplift are the challenges created by the Oxford to Cambridge Arc – the policies and proposals for which are at this stage, general in the extreme – the “Arc Spatial Framework” which is to a large extent dependent on the collaboration of all of the other local authorities within the Arc – whilst also having to deal with the challenge of a failing town centre and the long-lasting impact of the pandemic.
The Parish Council notes that the current updating exercise for the 2040 Plan is being undertaken in the context of the Local Plan 2030 which was only adopted last year. The Parish Council agrees that there is no need for a radical review of the extant Plan. That means, of course, that the final adopted Local Plan 2040 will constitute only a partial update of the 2030 Plan. The Parish Council hopes, however, that the final published version of the Local Plan 2040 will be produced as a single standalone document, as opposed to a Plan which cross references still current policies extant in the 2030 Plan, thereby effectively requiring a constant need for cross reference between two documents. Bearing in mind the growing list of related development control policy documents, a single comprehensive principal published Local Plan, containing new, updated and saved policies in one place would be far more “user-friendly” for the general public.
The final point that the Parish Council would wish to make in this introduction is that it has deliberately tried to avoid providing a NIMBY – “not in my back yard” response. That said, the Parish Council does note that some of the proposed shifts in policy, whilst small in number, may have far-reaching effects for the Parish and total objectivity may not always be possible.

Support

Representation ID: 7930

Received: 20/09/2021

Respondent: Pavenham Parish council

As indicated above, the Parish Council recognises the challenges facing the Borough Council in terms of the required 33% increase in housing provision above the allocated provision in the Local Plan 2030, the Oxford-Cambridge Arc and even the promised improvements to the Black Cat junction on the A1. The Parish Council is concerned, however, that – although probably unavoidable – the Borough Council is having effectively to speculate and plan for what only might happen.
The Parish Council has noted the substantially increased housing provision target leading to the need to allocate 12,500 new dwellings – in simplistic terms 1,275 new dwellings a year – as opposed to the figure of 970 dwellings a year as contemplated by the Local Plan 2030.

Whilst the Parish Council notes the possible option of a “stepped trajectory approach” and indeed recognises the underlying logic, the Parish Council would caution whether such an approach brings with it serious attendant risks. To achieve a target provision of 970 dwellings a year up to 2030 and then increasing the target somewhat radically to 1,580 dwellings a year for the last 10 years of the Plan period would make the Borough Council entirely dependent on the successful implementation of both the East West Rail section through Bedford Borough (including new and remodelled stations) and the completion of the Black Cat junction improvements. The Parish Council does not currently see the successful completion of either project within the Borough Council’s contemplated timescale as a certainty. It is acknowledged that practicality and what can actually be achieved on the ground enters the equation, but the Parish Council believes that a stepped trajectory approach should not be adopted as a core principle.

The Parish Council notes that Policy 58S (Affordable Housing) and 59S (Housing mix) will be updated once the draft Plan’s viability exercise has been completed and the Parish Council, in light of its own proposed residential allocation, will be happy to assist in terms of comment.

As far as identifying the locations for future growth is concerned, the Parish Council notes that the Borough Council has identified seven options, ranging from growth in the urban area, growth in villages and/or new town settlements in the A6 or A421 corridor.

The Parish Council also, however, notes from the wording of this Consultation Document that whilst the Borough Council has identified a number of preferred options, all or a mix of the identified options remain open for consideration. In this context, the Parish Council has carefully reviewed the Borough Council’s Issues and Options paper (June 2021) and fully supports the conclusions that have been drawn from that earlier consultation.

Support

Representation ID: 7931

Received: 20/09/2021

Respondent: Pavenham Parish council

As noted above, Pavenham Parish Council is currently preparing its Neighbourhood Plan. The Plan, in draft form, has already been very helpfully reviewed by officers of the Borough Council. The Parish Council’s proposed policies will be entirely in line with the overarching Local Plan, both 2030 and hopefully, subject to timing, the emerging 2040 Plan. The Parish Council would, however, wish to draw the Borough Council’s attention to the fact that, with a view to protecting the Parish from what could potentially be a grab for development sites within the Parish boundary, and noting that the Borough Council in its emerging 2040 draft Plan proposes to retain its 2030 allocation for the Parish – namely a nil allocation – the draft of the Neighbourhood Plan as it currently stands, allocates two sites for residential development - subject to compliance with policy considerations and conditions for residential development totalling nineteen units – sixteen on one site, three on the other.
1.3 In this context, paragraphs 1.48 and 1.49 of the Consultation document are welcomed and in this context the Parish Council would wish formally to record its thanks for the constructive advice and assistance that it has received from officers of the Borough Council in relation to our draft Plan.

Support

Representation ID: 7932

Received: 20/09/2021

Respondent: Pavenham Parish council

Whilst the Parish Council fully applauds and supports the laudable Vision and Objectives – there is just a slight residual concern as to whether they may be more idealistic than realistic.
2.2 As the Plan progresses, the Parish Council would welcome more practical information in relation to the following aspirations –
(a) Flood risk – that development in high flood risk will be avoided. Many local authorities across the country have a less than enviable record in this respect and whilst it is acknowledged that the Local Plan looks to such a strategy, it is one thing to have a policy – quite another to resist the overtures of developers intent on development and offering as inducements short-term financial gains in the context of the overriding need of the Borough Council to identify an increased number of sites for residential development. A “catch-22” scenario.
(b) The East-West Rail Arc - as a concept, is fully supported by the Parish Council. It is queried, however, whether in the context of the proposed link, the Borough Council can justifiably assume that as a result of the delivery of the Arc – if it is delivered - “up-front transport links” and “speedy internet” will also be delivered. Whilst “greater connectivity” must clearly be an objective, the Parish Council is firmly of the view that as currently proposed, local transport links to the north of the town will suffer and we fail to understand how the East-
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West Rail Arc will actually improve internet connectivity. This seems to us to be little more than political hype. It should be noted in this context, that the Parish Council opposes the northern option for East-West Rail which appears to the Parish Council to have no commercial nor environmentally sustainable justification.
(c) Bedford Town Centre – the Parish Council queries whether the entirely laudable objectives expressed by the Borough Council in terms of re-invigoration will ever be achieved. The Parish Council believes that the ‘town centre” as a concept, certainly for Bedford, is under serious threat – as and indicated by the Borough Council, requires both reinvigoration and possibly reinvention. The Parish Council supports the strengthening of independent outlets – ideally with improved parking provision at a lower or no cost? We do, however, believe that serious consideration should be given to residential growth within the town centre - particularly in light of the consequences of the Pandemic. Indeed, in this context, the Parish Council suggests that more emphasis should also be placed on hotel growth and tourism – the “staycation” effect. Bedford Borough has a great deal to offer in terms of attractions and tourism and the long-term impact of the pandemic ironically presents, in this context, positive opportunities for the Borough. The Parish Council notes the Borough Council intention to consider this matter further as noted in its Position Statements.
(d) Better places – the natural environment and the Embankment – these objectives of the Borough Council are fully supported by the Parish Council as indeed are the “Themes”, subject to the caveat sounded in relation to the East-West Rail link.
In this context we would also draw specific attention to the River Great Ouse Valley which it is suggested, should be formally addressed by the borough from its point of entry at Turvey to where it exits the borough in the East. The River Valley is the single most important environmental feature in the Borough – not just for its environmental and habitat value – but for the positive contribution that it offers for recreation and better understanding of the history of the area.

Support

Representation ID: 7933

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council has carefully considered all of the options identified by the Borough Council. It wishes, at this point, to underline the fact that this response should not be viewed as a NIMBY response, and that by indicating a preference for a development option that looks to the east of the Borough, the Parish Council is also very conscious that the views of Parish Councils most likely to be affected by these options will quite properly carry considerable weight.

That said, Pavenham Parish Council’s preferred option is Option 2c, namely “Development in and around the urban area, plus A421 transport corridor with rail based growth parishes plus two new settlements.

By selecting Option 2c as its preferred option, the Parish Council should point out that such a preference is entirely consistent with the views that it has expressed over the past 5 years. Regardless of the route eventually consented for the Bedford to Cambridge rail link, it is entirely logical that any future growth within the Borough should be concentrated within the central urban area and along the rail and transport corridors for reasons of connectivity.

The Parish Council would in this context also point out that in terms of connectivity, growth to the north of the urban area and away from the urban centre must be viewed as both impractical and illogical in terms of connectivity. The A6 to the north of Bedford is patently sub-standard is already under pressure – even without the current Sainsbury’s et al road works.

Looking at the proposed objectives – indeed requirements if the Borough is to meet its targets - namely, some 151 hectares of employment land and 12,500 new dwellings, it is queried in any case whether land north of the urban centre in the Borough could actually support such development in terms of basic infrastructure ranging from transport, drainage, sewerage, highway connectivity to modern systems of communication. Whilst it is appreciated that developers will always be able to provide answers to such questions – the means of providing those answers usually comes at great cost to the environment leading often to irreparable damage to an already fragile countryside.

The Parish Council appreciates that option 2a and 2b would meet essentially the same objectives and indeed considerable thought was given to whether Option 2a should be the preferred option.

It was felt, however, that on the assumption that the proposed Bedford to Cambridge rail link will actually be delivered – a new town settlement supporting the proposed new station at Little Barford seems a logical first step.

As far as a new town settlement at Wyboston is concerned, the Parish Council feels that a second settlement would avoid the risk of random development sites being identified by developers which in light of the high residential allocation targets in the Local Plan 2040 could be difficult for the Borough Council to refuse.

As noted above, the Parish Council is reluctant to comment on options that will affect Parishes to the east of the Borough and not its own administrative boundary. From the perspective of Pavenham Parish Council, however, it is considered that natural growth along the rail and road Transport Corridors would enable the affected Parishes to participate more effectively in the selection and allocation of sites. That said, whilst the Parish Council believes that there is a logic in supporting a new town settlement at Little Barford to serve the new East-West Rail Station, it follows that if the Parishes along the Transport Corridor prefer Options 2a, 2b, or 2d, then Pavenham Parish Council would be happy to defer to their view.

Support

Representation ID: 7934

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council fully supports the EEH Strategy as summarised in paragraph 3.22 of the Consultation and on that basis, it similarly supports the four Principles as set out in paragraph 3.23 with particular emphasis given to Principle 3, namely “opportunities for active travel and green infrastructure”.
The Parish Council agrees that the policies in the 2030 Plan are robust and do not require updating – subject to practical delivery when considering the housing growth site.
Housing development on small sites
In the context of this issue, the Parish Council agrees with the Borough Council’s conclusions as to the need for a specific policy but would also add that as well allocating two small sites for residential development within the Parish, its Neighbourhood Plan proposes a policy to permit windfall development – subject to a number of local policy conditions.

Support

Representation ID: 7935

Received: 20/09/2021

Respondent: Pavenham Parish council

The work that the BC has already undertaken with regard to the “call for sites” exercise and consequent allocation is noted and appreciated. To an extent, the proposed site allocation in the draft Neighbourhood Plan will confirm the Parish’s view once its draft Plan is finalised.

Support

Representation ID: 7936

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council provided its comments on the Town Centre and retail policies at the time of the Borough Council’s last consultation. Those comments do not need to be reiterated at this juncture save to say that the Parish Council welcomes the Borough Council’s recognition that the Strategic Centre, i.e. Bedford Town, is in urgent need of regeneration and support. Out of town retail, the pandemic and on-line shopping have reduced Bedford Town centre to a shell of its former self and it is queried whether its character as a retail centre can ever be fully restored.
On that basis, the Parish Council would welcome any initiative which would render the town centre safe and pleasant and it does re-iterate that regeneration in the form of residential/hotel provision would offer a positive way forward.
The Parish Council would certainly support a “town centre first” approach as advocated by the NPPF.
In this context, in relation to proposed draft Policy TC2, the Parish Council would express some concern with regard to any policy that promotes new out of centre retail development and would support the conditionality requirements and thresholds. In addition, a shift back from out-of-town retail to town centre retail would be much more environmentally sustainable with more people able to walk and use public transport to access shops, etc.

Support

Representation ID: 7937

Received: 20/09/2021

Respondent: Pavenham Parish council

The Parish Council fully supports draft Policy TC3 for the reasons expressed above.
The Parish Council does not consider that it in a position to comment on the “Local Centres” and would prefer to leave comment on those draft policies to those communities likely to be affected.

Support

Representation ID: 7938

Received: 20/09/2021

Respondent: Pavenham Parish council

That said, however, the Parish Council fully supports Policy TC8 – “Essential local shops and public houses”. Pavenham at present has no local shop – although the draft Neighbourhood Plan does contain a policy supporting the provision of an appropriately scaled local shop.
In addition, the village’s only public house is presently closed and its owner has placed it on the market for sale at a price which the Parish is unable to match. The Parish Council would oppose any attempt to demolish the public house or change its use.