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

Support

Representation ID: 7870

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Thank you for consulting Central Bedfordshire Council (CBC) on the Strategy Options and Draft Policies consultation for the Bedford Local Plan 2040. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continued joint working moving forward.

CBC are supportive of Bedford Borough Council (BBC) in commencing a Plan Review in line with Policy 1 of their adopted Local Plan 2030. We have provided some comments below on the consultation document which we hope are useful. Please do not hesitate to contact us if you have any further questions.

Support

Representation ID: 7871

Received: 23/09/2021

Respondent: Central Bedfordshire Council

e recognise that the Bedford Local Plan 2040 will be only a partial update of existing policies, due to the Local Plan 2030 being adopted only last year and as a result the review finding that many of its policies were up to date and did not require changing.

We note that the review will focus on the following key policy areas:
• Development strategy up to 2040 and delivery of growth in order to meet national policy requirements.
• Town centre and retail policies
• Updated development management policies on: Self-build and custom homebuilding, Quality of development and residential space standards, and environmental net gain.

In the current round of plan-making, the plans of both CBC and North Hertfordshire District Council (NHDC) make provision to meet the unmet housing needs of Luton Borough Council, within the shared HMA. This involved the release of Green Belt land, which obviously requires the demonstration of exceptional circumstances (including the demonstration that all other options have been explored). Whilst any further unmet needs (arising from Luton’s next round of plan-making) are yet to be determined, if unmet needs do arise, it does need to be acknowledged that, bearing in mind supply in CBC and NHDC has already been maximised to meet the needs this time around, this is likely to need to be considered across a broader geographical area, including by Bedford Borough Council. It is considered that this should be acknowledged and addressed within the emerging Bedford Local Plan.

Further to this, we note the proposed timetable for the BBC plan to be submitted, ahead of the adoption of the emerging Ox/ Camb Arc Spatial Framework. We would be grateful for clarification on the relationship that is envisaged between the BBC LP and Arc Spatial Framework. Is it BBC’s intention to commence a further Local Plan review following the adoption of the Spatial Framework?

Support

Representation ID: 7872

Received: 23/09/2021

Respondent: Central Bedfordshire Council

We have reviewed the four emerging preferred options for growth and support the Council’s decision to consider their development strategy alongside the opportunities available to promote sustainable and healthy communities.

As stated in our previous response, CBC remains of the view that in the first instance, brownfield and previously development land should be utilised to its maximum capacity before looking to greenfield land to deliver growth. The urban based location options would offer huge benefits in terms of sustainability and growth could be successfully delivered without the need for new large-scale road infrastructure. Intensification of sites within Bedford should be fully considered in line with the estate regeneration objectives of the NPPF and the decisions around East West Rail that have now been taken, which provide confidence in terms of infrastructure in this area.

We are pleased to see that the Council has assessed the likely transport effects of four development scenarios, and we have reviewed the detail provided in the Transport Model Assessment Report and the Development Strategy Topic Paper. CBC would want to ensure that the full extent of planned growth within the recently adopted Central Bedfordshire Local Plan has been taken into account when considering the growth options and their potential impacts.

It is acknowledged in the Transport Assessment report that some of the existing roads are either close to/at capacity or in some cases exceeding capacity already. As such, it is absolutely essential that further, more detailed assessment is undertaken to ensure any potential growth locations do not have impacts on the network that cannot be mitigated. We note the Assessment Report makes no mention of capacity issues on the A1 or J13 of the M1, both of which are key connections to the A421 running through Bedford. These must be factored into any assessment when considering growth in BBC. Both were considered during the CBC Local Plan examination, and capacity constraints were acknowledged. Mitigation to accommodate the development proposed within the CBC Local Plan was agreed by Highways England for J13, but it is not clear that any additional capacity could be accommodated moving forward. This is a key junction, which will be impacted by growth within CBC, Milton Keynes (MK) and BBC. Joined up thinking is required to ensure we can all successfully achieve the growth required in each of our areas.

Some of the scenarios being considered in this plan are to create new settlements around Wyboston/Great Barford, which will be adjacent to the A1 and will clearly increase flows on that route. The capacity of the A1 must be a key part of any consideration of these sites and further work is required to fully understand its capacity and constraints, and potential solutions. Bearing in mind the known constraints here, this would likely involve the need for large-scale intervention, such as realignment. CBC would welcome the opportunity to be involved in such work. As stated in our previous response, we would question whether growth could be considered in these locations without a commitment to such interventions, which would undoubtedly require government funding.

It is also noted that these locations for growth are dependent on an EWR station coming forward in this location. Whilst considering locations in close proximity to rail infrastructure is welcomed, it should be noted that the plans for EWR are still at early consultation stage and a DCO application has yet to be submitted, as such, there can be no certainty attached to the potential location of any new stations.

Support

Representation ID: 7873

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Due to the early stage of these proposals, we do not intend to make detailed comments on specific sites at this stage. However, we do wish to continue to be involved throughout the process. Effective and ongoing engagement will be vital to the success of new development in both of our authorities due to the close links and interconnected nature of the two. We look forward to reviewing the future stages of work, once the detailed evidence is available to support the emerging proposals. We would like to request to be kept informed of decisions relating to sites and would request early engagement where a site is likely to affect Central Bedfordshire or our residents.

We note that the proposed strategy will not include allocations for small sites (of less than one hectare), on the basis that evidence shows the number of dwellings built on small sites is consistently above the 10% required by the NPPF. Whilst the national policy requirement is being met, BBC may wish to consider a smaller threshold to ensure that it can appropriately plan for growth and vitality in smaller villages and towns, rather than relying on windfall.

Support

Representation ID: 7874

Received: 23/09/2021

Respondent: Central Bedfordshire Council

CBC welcome the positive approach to employment provision within Bedford Borough – however, confirmation is sought if the 8,642 jobs is the total for the plan period (2020-2040) and, if so, what is the breakdown between ‘B’ and ‘non-B’ jobs?

The high-level approach set out within the consultation material for the provision of employment land seems appropriate, however, clarification is sought to the statement at para 6.9 of the consultation document that ‘Once a strategy is chosen, appropriate sites for allocation will be identified in the plan for submission’. The consultation document sets out a strategy and does not consult on alternative options, CBC would be keen to understand what alternative strategies for employment provision are therefore also being considered.

In relation to the approach set out in the consultation document, the concept of providing 3 new business parks alongside smaller allocations across the Borough seems logical. However, CBC consider that additional provision for strategic warehousing should not be ruled out at this stage, and perhaps further assessment of demand is required. A strategy to provide higher skilled jobs cannot be used to rule out making provision for other uses where there is a clear need identified. It is noted one of the reasons for ruling out this provision is due to what is termed as ‘the already extensive opportunities for new warehousing and distribution facilities’ in nearby local authorities, such as CBC. Recent evidence produced to inform the latest CBC examination hearings, updating the employment supply and demand data, identified a much bigger and more localised demand for strategic warehousing than seen previously. Reliance on CBC to continue to meet this demand moving forward is not an appropriate strategy, particularly as CBC are yet to start work on a Local Plan review.

CBC appreciates that BBC are at the early stages of the review process and that sites for future delivery of growth are still being identified and considered – CBC looks forward to further discussions with BBC as part of the site selection process and consideration of any cross-boundary implications for Central Bedfordshire and our residents.

Lastly, given the Ox/Camb Arc Spatial Framework, it is important to understand what flexibility Bedford Borough has to address an emerging strategic plan for the area.

Support

Representation ID: 7875

Received: 23/09/2021

Respondent: Central Bedfordshire Council

CBC supports BBC’s aims in ensuring the vitality of town centres, particularly on the back of the struggles many town centres faced during the lockdowns brought about by Covid-19.

In order to ensure the longevity of town centres and retail outlets, Policy TC1S* is considered to provide the necessary support for town centres by providing a hierarchical approach.

Support

Representation ID: 7876

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Policy SB1 and the supporting text is well-worded and meets the legislation.
It is interesting to see the clearly defined set of site thresholds within the policy. This represents a graduated approach to the policy which ranges from circa 20% self-build delivery on the smaller applications, reducing to circa 7% on the larger sites.
It is also noted that applications of 100+ dwellings are able to negotiate on the level of provision, however this provides no certainly to BBC or the developers in terms of delivery of Self & custom build homes on large, strategic sites.

Overall, the graduated approach is sensible as it requires higher delivery (proportionately) to the smaller sites in order to target self-build delivery. This may accord with demand data from your register so it may be useful to make this clearer in supporting text if this is the case. It may also be useful to make some reference to any viability studies BBC has to evidence that delivery at these various site thresholds is viable.

CBC’s evidence demonstrates that self & custom build provision does not to diminish land value in any way and we would be happy to share any viability information with Bedford if this is helpful.

Support

Representation ID: 7877

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Paragraph 7.15 lists a number of supplementary guidance documents, some of which appear to be quite dated. It may be beneficial if these documents were reviewed as part of the forthcoming design guide. The preparation of a new design guide is supported by Central Bedfordshire Council, and we would welcome being consulted on the scope and content of this document in due course.

Central Bedfordshire Council also support the requirement for residential space standards in line with Nationally Described Space Standards. As drafted, the policy requires all residential developments to conform to the standards ‘as a minimum’. This implies that there may be cases where higher space standards may be sought. If this is the case, the scenario/type of development to which higher standards may be sought should be set out in the policy. Also, it would be worth noting whether this policy requirement has been viability tested.

Support

Representation ID: 7878

Received: 23/09/2021

Respondent: Central Bedfordshire Council

CBC support the Borough’s new Policy NE1 – Environmental Net Gain, which aims to increase overall Environmental Net Gain, over and above just Biodiversity Net Gain. This will support the recently endorsed Arc Environmental Principles. CBC would be interested to understand more about the evidence that underpins and informs this decision, particularly with regard to its potential implications for developers and any viability considerations.

Policy NE1 does not consider sites below 10 units or <0.5ha. For the smaller development schemes that come forward, how will it be ensured that BNG and NEG can still be addressed?

Support

Representation ID: 7879

Received: 23/09/2021

Respondent: Central Bedfordshire Council

operational carbon emission and embodied carbon in construction materials. To enable transition to low carbon future and achieve carbon neutrality, all operational and embodied emissions need to be addressed.

It would also be beneficial to address role of on-site renewable energy generation that is likely to be crucial in transition to a low carbon future. The Design and layout of developments should also be maximised and safeguard opportunities for renewable energy generation. It is considered that Policy 53 would benefit from adding this consideration.