Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10451

Received: 29/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As we have said in our response to the Draft Plan: Strategy Options and Draft Policies consultation we believe the consultation process referred to in Para 1.4 of the Introduction to the Draft Plan was flawed by the absence of the full range of options from the only document, the Development Strategy Topic Paper, that would have been seen by the majority of residents.
We have previously commented on the absurdity of not permitting the Council to delay the preparation of this plan until the long promised but still delayed Spatial Framework for the Oxford-Cambridge Arc has been published. We remain of that view and do not share the Councils apparent confidence (1.16) that the implications for economic growth and strategic housing will be unaffected should the Framework ever emerge.
We are equally sceptical about the significant dependence of the plan on the eventual completion of the proposed EWR to Cambridge (1.23-1.28). At the time of writing the future of this part of EWR looks at best uncertain yet several irreversible fundamental aspects of the plan are predicated on the existence of the railway.

Comment

Representation ID: 10452

Received: 29/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

The aspirations as set are laudable but not always matched by specific policy decisions set out subsequently. In particular, as we said in our response to the Draft Plan, the proposals crucially fails the tests of sustainability and the requirements of DS1(S) mean the plan is unsound for that reason alone.
The Council's own SA clearly states that urban growth is the most sustainable on virtually all criteria yet this Plan, despite that, is a lost opportunity.
We believe that properly planned urban expansion, including some areas of high density housing but inevitably entailing some expansion would not only be more sustainable but more closely meets the needs of the main growth sectors as noted in the LHNA. The failure to follow up that initial option (and to put it forward for consideration at the draft stage) means again we are presented with a plan which will lead to sprawling development, merging of communities and landscape degradation with resulting loss of amenity for all residents.

Comment

Representation ID: 10455

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

We support the objectives of the Transport Strategy although as stated do not agree with its dependence on EWR. However, there is no reference to the need for a comprehensive network of safe cycle routes. There has been some unstructured and piecemeal efforts made by the Council but nothing that meets the existing need or will encourage more people to use cycling as an option to car travel.
Similarly the reliance on current rural locations for over 10.000 of the proposed new dwellings also does nothing to encourage a reduced dependence on the car.

Object

Representation ID: 10456

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This proposed development is opposed by virtually all local residents who have had an additional 1200 home and also continuous warehousing developments. The addition of a further 500 houses will finally destroy the rural nature of Kempston Rural Parish. This proposal will mean a loss of yet more agricultural land, destroying the character of the area and will mean that there is a continuous sprawl of housing and warehousing from Kempston Town to Wootton contrary to the Council's own policies on coalescence and the NPPF s174.

Object

Representation ID: 10457

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This will similarly result in the effective merger of two distinct communities, Wixams and Wilstead, and lead to a what is in effect a continuous area of development from Stewartby, Wootton, through Kempston Hardwick and Wixams to Wilstead, Elstow and Shortstown. It will be an uncoordinated and unstructured urban sprawl with no oval coherence, grossly inadequate infrastructure and again will be dependent on car use.

Object

Representation ID: 10458

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The 1500 houses on College Farm allied to the 250 hoses on the DVSA site at Shortstown also raises the issue of the inadequate infrastructure including the problems of the A600, school provision and health provision. It will again lead to a sprawling development, dependent on car use, that will links Shortstown and Old Harrowden and with implications for Coton End.

Object

Representation ID: 10459

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

While this ste has the advantage of access to A421 its impact on the landscape will be disproportionate. The site is relatively elevated and will lead to effective coalescence with the proposed new development of 500 in what is to be called Great Barford West. This will have a disproportionate impact on both Water End and Green End, Renhold and lead effectively to continuous development from Great Barford to Bedford.

Object

Representation ID: 10460

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We support the aspirations for the town centres but believe that the unambitious and passive proposals listed remain as aspirations only rather than constituting robust policies.

We suggest that this section falls well short of the requirements set by the NPPF s86 in particular with reference to adaptation and residential development.

Object

Representation ID: 10508

Received: 29/07/2022

Respondent: Conservative Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

LP2040

I note that under the Local Plan 2030 Bedford Borough Council is obliged to submit a further local plan or risk not unplanned development due to a lack of a 5 year land supply. This is clearly problematic.

Sustainability and Infrastructure
The plan fails to take into account the climate change emergency declared by the council and its own sustainability appraisal-it is too car centric- it therefore fails the sustainability test. In order to be made sound there needs to be a greater focus on modal choice (for example EMP6). There also needs to be a greater focus on providing infrastructure with developments, and indeed in advance of developments to ensure that people can live sustainably in their communities, for example shops, doctors, schools. Greater emphasis should be placed on 15 minute communities- which have historically been well delivered in Bedford Borough but this has recently been lost and is lost in this plan. Some of the proposed developments do not adjoin existing settlements nor do they provide facilities for new residents- this is not sustainable and is therefore unsound (such as HOU16).
There is also a risk of replacing agricultural land and genuine countryside being lost to more urban country parks which are then not managed or used effectively for leisure or biodiversity, or indeed food production.

East West Rail
The Plan is not sound because it makes it does not make it clear that the EWR route corridor is only proposed- it should be amended to reflect the stage that the EWR proposals are at.

Town Centre
The town centre proposals do not accord with the NPPF policy 86. Planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Planning policies should:
d) allocate a range of suitable sites in town centres to meet the scale and type of development likely to be needed, looking at least ten years ahead. Meeting anticipated needs for retail, leisure, office and other main town centre uses over this period should not be compromised by limited site availability, so town centre boundaries should be kept under review where necessary;
f) recognise that residential development often plays an important role in ensuring the vitality of centres and encourage residential development on appropriate sites.
The list of acceptable uses in policy TC3 is too restricted and fails to offer a wider range of opportunities for what the town centre could be in terms of services, businesses and health services. This therefore fails the test of being positively prepared. It also is not sound because it is not sufficiently supportive of residential uses in the town centre including new build residential.

It is also unclear what is meant by a ‘concentration of similar uses whose cumulative impact would be to the detriment of environmental quality, amenity or parking, or would increase the risk of anti-social behaviour or would create a significant length of inactive frontage at ground floor level’. To make the plan sound this should be made clearer.
In order to be made sound these policies need to be broadened to allow a greater scope for residential development and more uses in town centre- for example more leisure and health facilities. Greater clarity should be given on the cumulative impact policy.

Coalescence and Urban Sprawl
There is a real risk of coalescence between a number of settlements including Bedford-Renhold-Great Barford due to EMP6 and Shortstown and Cotton End due to Hou17 (Proposals secure country parks however they do at the cost of actual existing countryside).

Proposal Numbers
The policies in the plan do not clearly set out anticipated numbers on sites- it is therefore difficult to know with any degree of certainty the numbers of units (be it homes, or work places) that will be delivered on any site. To lack such level of detail is unsound and in order for the plan to be made sound there needs to be greater clarity on what is intended and what is acceptable on each site. Although information is provided elsewhere in order to be able to be relied upon it should be in each individual policy. This is a particular issue with Policy EMP6 as it unclear how much of the site will be used and what type of buildings would be on the site for example- quantity and scale of warehousing. In order to be sound further information must be provided as part of the policy, and where mixed use is being considered proportions envisaged should be included (albeit it that it is my submission that EMP6 is not sound).

Object

Representation ID: 10509

Received: 29/07/2022

Respondent: Conservative Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

EMP6
Detailed comments have been made on this site by Renhold PC. However I would like to iterate a number of points. EMP6 is not in a sustainable location- unlike Priory Business Park which is sited on a roundabout off the A421 and can be easily accessed through Priory Country Park, this site does not offer real travel choice- it is car centric. Instead if this use is required it should be placed where the employment use can be accessed by various modes including more sustainable options.

The maps provided by the Council fail to show the coalescence and urban sprawl that this plan would cause- the plans do not show the site allocated in the Great Barford Neighbourhood Plan for 500 homes. This site and the EMP6 are close together and would leave a minimal gap between the villages of Renhold and Great Barford. In turn Renhold itself is already adjacent to the urban area of Bedford via Salph End. These proposals would mean that Renhold would be accessed via the employment side off the A421 roundabout ending the village nature of Renhold.

There would be an unacceptable damage caused to wildlife and habitat as well as landscape harm. These sites in EMP6 are on high ground and will be highly visible from Great Barford and from Renhold – again this can be contrasted with the Priory Business Park which is more acceptably situated in the landscape.

The proposals in EMP6 will also unacceptably impact on the historic environment.

The proposals at EMP6 will also cause additional traffic issues in the Renhold and Great Barford area.

There is a great concern that if the science park does not come forward then udner the terms of the NPPF the site will instead be developed for warehousing or for housing. While the idea of a science park might seem attractive to some on the basis that there will be high quality jobs which to some might mitigate the harm caused by the proposals (as laid out above) there would be no such mitigation if the site were actually developed for or for general housing.