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

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Representation ID: 6561

Received: 13/09/2021

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

1.1 On behalf of our client FCC Environment (UK) Ltd (FCC), we set out our comments to the Bedford Local Plan 2040 Draft Plan Strategy Options and Draft Policies Consultation Document. Where necessary, these representations draw on the comments previously made to the 2020 Local Plan Issues and Options and Call for Sites submissions.
1.2 These comments relate to the Council’s growth and spatial strategy options as set out within Chapter 3 of the Draft Plan, reference is also made to the Development Strategy Topic Paper where relevant. It is acknowledged that there are an infinite number of growth locations/options which the Council could have considered. We believe a broad range of locations have been considered to enable the key issues of delivering growth across the Borough to be tested.
1.3 We support the growth based options which would allow growth in locations which already have existing infrastructure and good connections to Bedford town centre. Urban locations and those in close proximity to existing road and rail routes have the greatest potential for sustainable travel choices and the urban and rail based growth options would therefore target growth within the most sustainable locations.
1.4 The Development Strategy Topic Paper defines the five broad components of growth as follows:
• Within the urban area (sites within the urban area boundary).
• Adjoining the urban area (all or part of the site is within 0.5 miles of the urban area boundary).
• Village related (Key Service Centres and Rural Service Centres).
• New settlements (Wyboston, Little Barford, Twinwoods, Colworth).
• A421 transport corridor with rail based growth (stations at Kempston Hardwick, Stewartby, Wixams and at a location between St Neots and Tempsford).
− Transport corridor –growth focused on Kempston Hardwick, Stewartby and Wixams1 (rail-based growth)
− Transport corridor – south (the parishes of Wootton, Kempston Rural, Elstow, Wilstead, Shortstown, Cotton End)
− Transport corridor – east (the parishes of Cardington, Cople, Willington, Great Barford, Roxton, Wyboston and Little Barford)
− Transport corridor – growth focused on new settlements in the A421 corridor (Wyboston and/or Little Barford).
1.5 It is assumed for the purposes of our comments that FCC’s site at Elstow is located within the rail based growth parishes area. All of FCC’s site is within 0.5 miles of the urban area boundary, however the diagrams shown in the Draft Local Plan show the site within the rail based growth parishes and our comments are therefore provided on this basis.
1.6 We have reviewed all 7 growth options put forward within the Development Strategy Topic Paper and provide our comments below.
1.7 Option 1 (a and b) seeks to only propose growth within the urban area and does not seek to maximise growth within the transport corridor which we consider should be delivered. We therefore do not support this growth option.
1.8 Our preferred growth strategy is option 2 (2a-2d) which the Council have taken forward and included within the Draft Plan. This option seeks to deliver development in and around the urban area plus A421 corridor with rail based growth. It is supported that all development options focus development within the south of the borough where there is better rail and road infrastructure. This is in line with the sustainability appraisal which identified that the urban component of growth performs most strongly and the worst performing component was the village related growth component.
1.9 Of the Option 2 growth options, we support options 2b, 2c and 2d which seek to deliver the highest level of employment growth within the transport corridor.
1.10 These options seek to benefit from the existing and proposed infrastructure and would allow growth in locations which already have existing infrastructure and good connections to Bedford town centre. Urban locations have the greatest potential for sustainable travel choices and this growth option would therefore target growth within the most sustainable locations.
1.11 The Council should recognise that the delivery of new infrastructure is crucial to the development of Bedford as an economically prosperous, attractive and healthy borough. In order to maximise the delivery of growth the Council should seek to deliver a broad range of new infrastructure, including improving rail and public transport accessibility and improving / providing new link roads.
1.12 FCC’s site at Elstow, has been assessed and could provide land for a link road from the Bedford Business Park in the west to the A6 in the east which provides a direct connection to the south and the A421 in the north. The provision of this link road shown in Figure 1 could help to mitigate congestion on the edge of the urban area and would facilitate additional economic development in the surrounding area. FCC is aware of the highways concerns for the proposed business park development to the west. A link road through FCC’s site could alleviate and address those concerns. FCC has been working with surrounding landowners to ensure a holistic approach is taken to the development of the area.
1.13 We do not support the Option 3 growth options which seek to deliver high levels of growth within the rural area and within new settlements. We have previously commented on the disadvantages of this, the majority of rural areas would not have the existing infrastructure in place to accommodate growth if it was evenly dispersed throughout the borough. An even spread of growth across the borough and a lack of focused critical mass would make providing strategic infrastructure more difficult, as the locations would not benefit from economies of scale. As such, the growth options which target growth within areas of the borough with existing infrastructure or the ability to provide enhanced infrastructure should be supported.
1.14 Options 4-6 provide growth within the A421 transport corridor with rail based growth plus a range of dispersed growth across the borough. These growth options provide lower levels of employment across the borough than our preferred growth option (option 2). As set out above, we consider that growth should target the areas with existing services and infrastructure and not the more rural areas which do not benefit from high quality infrastructure.
1.15 Option 7 seeks to provide growth in two new settlements, plus key service centres, plus rural centres. We do not support this growth option as it does seek to deliver any growth in locations which benefit from existing and improving infrastructure.
1.16 As set out above, growth should be focused along intersections with existing major infrastructure which will create new opportunities for logistics and distribution industries, and are also most likely to support new settlements. The preferred option should ensure sufficient flexibility to meet the changing economic needs over the plan period.