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

Object

Representation ID: 6658

Received: 14/09/2021

Respondent: Stevington Parish Council

National Context and Plan Period: SPC is aware that the spatial framework for the Oxford Cambridge Arc and the East West rail route are still in the process of being finalised. The spatial framework for the Arc will not be available until January 2023. As the content of this framework will affect the 2040 local plan, SPC accept that the council needs flexibility in the planning process to take account of this as circumstances change and details emerge. In particular we expect the Borough council to adapt plans to address escalating climate change impacts.

Object

Representation ID: 6659

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 1.6 refers to the governments ambition for growth up to 1million new high-quality homes by 2050. Given current climate change circumstances such an ambition is clearly unsustainable and although the recent parliamentary debate, makes it clear that 1 million homes is not government policy, there is clearly an intention to develop a significant number of new houses to support economic growth in the region. We believe council needs to limit the scale and nature of growth to levels that are environmentally sustainable and enable Net Zero to be achieved at the fastest possible rate. Communities are relying on the Borough Council to make this a high priority.

Object

Representation ID: 6660

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 1.6 refers to the governments ambition for growth up to 1million new high-quality homes by 2050. Given current climate change circumstances such an ambition is clearly unsustainable and although the recent parliamentary debate, makes it clear that 1 million homes is not government policy, there is clearly an intention to develop a significant number of new houses to support economic growth in the region. We believe council needs to limit the scale and nature of growth to levels that are environmentally sustainable and enable Net Zero to be achieved at the fastest possible rate. Communities are relying on the Borough Council to make this a high priority.

Object

Representation ID: 6661

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 2: Vision and Objectives Theme 1 : Achieving a Net Zero borough
Although policies related to existing assets and community consumption of energy and products are not intended to be part of LP2040. The delivery of Net Zero borough will need policies for growth to align with policies to support existing communities in making the transition to low carbon homes (e.g., insulation and electrification), and the transition from petrol to Electrical vehicles.
Economic growth will lead to a significant increase in local population, while it may be feasible to ensure new housing developments are low carbon and can demonstrate a habitat based net biodiversity gain, we need the borough’s policies to urgently address carbon emissions from the existing borough population, its housing stock and farming land, which are large carbon emission sources.
LP2040 needs to be updated to reflect this escalating emergency with greater urgency placed in delivering reductions in carbon emission and preparedness to address climate change across the Borough. This must address both existing and growth infrastructure. The council must identify all possible means to support current and future local communities in carbon sequestration and biodiversity growth (tree and hedge planting, wildflower meadows, garden biodiversity enhancement) as well as technology changes including electrification of transport and homes, hydrogen ( if/when that becomes feasible), local renewable power generation.

Object

Representation ID: 6662

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 3: Growth and spatial strategy option Subsections 3.1 to 3.10
Level of housing growth required: The borough council have proposed a housing requirement of 1275 /yr. Oakley parish have determined that this figure is higher than it should be. According to estimates prepared by Lichfield Planning Consultancy (see Oakley parish submission), the borough council’s figures are higher than those for surrounding Local Authorities and one of the highest outside the London Metropolitan Area. The borough council should produce a further calculation based on up-to-date ONS data to create realistic figures.
SPC are surprised that given the significant disparity between Bedford Borough’s housing ‘target’, when compared to other local or near neighbour authorities, or any authority outside of London for that matter, that the Borough has not already challenged the use of the government methodology by proposing the use of a more accurate estimation model utilising the latest ONS data.
The current housing ‘target’ also seems to include a very significant increase in net migration to the Borough, SPC would question the sustainability of this approach given the very likely negative impact this new demand would have on housing availability and affordability for existing residents. Our expectation would be that a Local Plan should first and foremost be a tool for ensuring future development meets the needs of the local communities within the plan area, and that desirability of migration to the Borough is a reflection on meeting that objective rather than, as it seems right now, inward migration being one of the primary drivers of the local plan.
Growth and strategy Options: SPC has concerns with the significant uplift in the housing target that is being proposed with the Local Plan 2040. Although cognizant that the government standard method of assessment is being proposed, this method has been widely criticised as being potentially flawed given its reliance on stale and out of date data.
It is also not clear how an uplift of 32% from the current LP housing target can be considered environmentally sustainable when the majority of the land to be allocated in the Local Plan is not brownfield but greenfield, with much of it Grade 2 arable land. Given the growing awareness and importance of producing food locally, this approach would appear to be taking Bedford Borough backwards not forwards in terms of Environmental Net Gain.
If BBC is unable or unwilling to challenge the housing targets identified in the proposed local plan then SPC would be generally supportive of the approach detailed under point 3.5, Growth and spatial strategy options.
Stevington Parish Council have reviewed the four options presented in the Development Strategy Topic Paper and the draft Local Plan 2040. SPC welcome the approach of focusing growth of housing in the Southern parishes of the county. However, councilors have concerns over the proposed level of housing developments generally and feel that the number of dwellings should be minimised as far as possible. Of the four options proposed, although there is little difference between them in terms of their direct impact on Stevington Parish, option 2c is marginally preferred as this appears to have the least overall number of planned dwellings. Whichever option is finally chosen, we ask the Borough Council to ensure that the selected minimises carbon emissions and biodiversity loss.
Although the plan indicates there is to be very little additional housing in Stevington parish, SPC are concerned about the increase in traffic flow through the village that will occur from planned growth of 500 homes in each of Bromham, Clapham, Great Barford and Sharnbrook. This needs to be significantly reduced (halved) in each village as the road network will not be able to cope There are particularly concerns regarding levels of pollution from petrol cars, vans and lorries and also increased safety hazards that this growth will bring.
As there is significant uncertainty on how future work and travel patterns are likely to evolve, post COVID-19, as well as the likely impact of the Oxford to Cambridge Arc Spatial Framework to the plan then it would make sense to take a more prudent approach to year on year development delivery targets in the first half of the plan period. This would allow for future validation of the accuracy of the current net migration and housing demand forecasts and allow the remainder of the plan target to be based, in part, on actual real world rather than forecast data.
Given the significant potential impact of EWR on the LP and the future development of Bedford Borough, SPC would question why the Council opted not to include a section for feedback on the route selection as part of the overall LP consultation phase. Most of the new development options have a reliance, at least in part, on the delivery of EWR to provide the supporting infrastructure for connectivity, so would play a major part in the feasibility and delivery of the Local Plan, but opinion on what is a major decision for the Borough community is not being sought? We find this lack of consultation concerning and view this as a missed opportunity by the Borough.

Support

Representation ID: 6663

Received: 14/09/2021

Respondent: Stevington Parish Council

Section 3: Growth and spatial strategy option Subsection 3.18 to 3.28
Transport Strategy
SPC largely agrees with the 5 points of the EEH strategy in section 3.22. However, in light of the recent IPCC AR6 report, the borough council must make sure that it delivers on this commitment in practice, especially the need for decarbonisation which will fundamentally change road as well as rail transport
Road transport: SPC would like more roads and streets to accommodate electric vehicles with many more charging points around town and in villages. We would also like to see far more done to accommodate the needs and safety of cyclists and pedestrians on roads and streets.
Rail transport: SPC wish the Borough Council to ensure that EW Rail transport is electrified from the beginning of the service and that environmental impact and biodiversity loss during construction phase and later in operation is kept to the bare minimum.
Digitalisation: Many residents in Stevington, especially those who run micro businesses and those who need to work from home are frustrated by the lack of speed of data upload and down load. SPC want the Council to support programmes which accelerate installation of optical fibres to all homes and businesses.

Support

Representation ID: 6664

Received: 14/09/2021

Respondent: Stevington Parish Council

It is difficult for SPC to comment on individual sites within the Parish as none of the assessments are as yet fully completed or certainly appear to be missing elements from at least one or more of the assessment categories, we assume this will be more widely publicised when the exercise is complete.

Support

Representation ID: 6665

Received: 14/09/2021

Respondent: Stevington Parish Council

SPC largely supports the comments in 5.4 and is pleased that they are informing council’s polices (5.4). SPC Supports Policy (TC2), that new retail, leisure and office development should locate in town centres. However, the retail area in the Centre of Bedford is in desperate need of regeneration. SPC urge Council to ensure that all 4 themes objectives are given a high priority in town centre “uses” developments.
SPC is generally supportive of the Borough’s policies to help sustain and develop the town centre, although there would be value in integrating specific polices with the Infrastructure Delivery Plan. Ease of access and traffic congestion in and around town centre can often be a significant influence on where consumers choose to shop, improving both would make the town centre a more desirable destination.

Support

Representation ID: 6666

Received: 14/09/2021

Respondent: Stevington Parish Council

With regard to policy TC3 and TC9, SPC would urge council to ensure that the various “uses” companies and services that make up town and other district centres have low carbon emissions and encourage and support low energy usage and maximization of renewable energy sources.
Council should also consider a policy of reducing night time lighting on streets, in shops and shop displays, except where it is needed for legal, safety or security purposes. Recent research indicates that at least some of loss in insect biodiversity is due to light pollution. A reduction in night light emissions would therefore benefit both carbon reduction efforts and contribute to reversing biodiversity losses.

Support

Representation ID: 6667

Received: 14/09/2021

Respondent: Stevington Parish Council

SPC is generally supportive of the employment policies although it may well be sensible to consider the addition of a policy condition to the supply timeline similar to point 3.5 (Growth and spatial strategy options) that allows for employment site delivery to be linked to known housing demand as the two are intrinsically linked.
SPC would support particular attention being paid to attracting companies and employment opportunities which will support local efforts to decarbonise the economy (e.g., electrification of transport and homes)
and enhance the biodiversity of the borough (e.g., many more ecologists/ wild life /environmental specialists will be needed to enable the county to deliver a greener more biodiverse environment.