Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9592

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

U&C recognise that in the Central Area (as defined in the Emerging Plan), no existing or potential location for strategic growth can be considered in isolation. All options relate to, or are dependent upon, the same elements of strategic infrastructure investment to a greater or lesser degree. Furthermore, the advantages arising from investment have potential to be supercharged, to the benefit of existing and new communities, if planned comprehensively. This applies especially to energy, green infrastructure, biodiversity, water conservation and sustainable modes of transport.
Our representations in September 2020 (Issues and Options) recognised the challenge of moving ahead with the Bedford Borough Local Plan, given a lack of strategic context. We were nevertheless firm in calling for: ‘more than just effective cross boundary relationships. It is now time for effective joint planning to establish a framework to meet short term needs and deliver long term potential.’ U&C were hopeful that Policy 1 of the Adopted Local Plan, which refers to strengthening cross boundary relationships but also hints at a possible joint plan, was not a hollow prospect. U&C has been and is supportive of and has lobbied for strategic growth to be locally led through effective collaboration.
The Submission Plan does not address this challenge and opportunity.
While the Borough Council’s commitment to respond positively to strong economic, social and environmental drivers within the Central Area is evident in the opening pages of the emerging Plan, the translation of that ambition into policy does not address cross-boundary issues and does not adequately address significant delivery issues, which are clearly identified within the evidence base, published in support of the Plan. These shortcomings are not confined to the proposals for two new settlements, assumed to come later in the plan period (although they are not subject to any policy controls on timing), but it is in respect of these proposals that U&C now focuses its objection. These allocations present greatest risk to coordinated development within the Central Area, threaten to frustrate or delay development in adjoining areas and do not adequately address wider cumulative impacts.

Object

Representation ID: 9593

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is


an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.

• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.

Object

Representation ID: 9594

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is


an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.

• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.

Object

Representation ID: 9595

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is


an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.

• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.

Object

Representation ID: 9597

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

In the Summary of Comments document (on the Issues and Options stage) the need for effective cross boundary planning is not properly addressed, despite our representation and others in a similar vein.
The Duty to Co-operate Submission Statements (amongst the supporting documents to the Submission Plan) provide no further reassurance, in fact they serve to highlight the inadequacy of the co-operation. It is stated that the discussion with neighbouring authorities has proceeded without any disclosure of potential allocations, so it is difficult to see how it might have yielded effective outcomes. There is no evidence of engagement with South Cambridgeshire, which would seem to be vital given the implications for the A421. Furthermore, the statements identify a long list of cross boundary considerations noting potential significant impacts arising from what is proposed. These are precisely the matters that should have been subject to detailed discussion and resolution, to inform policy formulation, particularly the approach to the delivery and the timing of development relative to cross boundary infrastructure. Instead, these critical considerations are identified as ‘requiring further co-operation’ and the relevant strategic policies fail to address delivery issues entirely. The Statement records no progress on the relevant matters and as such is not in the spirit of or reflective of the approach required by the NPPF (paragraphs 24-27). On this basis, the Plan is at risk of being found not to be effective in the terms of the NPPF: the allocations reliant on cross boundary infrastructure ‘are not deliverable over the plan period, based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground.’ The stated position in the DtC Submission Statements is that all major issues are deferred.


U&C are used to working in circumstances where there is an absence of clarity on infrastructure timing and delivery. Bedford Borough Council must be applauded for wanting to get on with the job, even though so much contextual information and infrastructure commitment is lagging. It is not, however, appropriate to simply ignore the very significant burden that uncertain infrastructure requirements place upon development and make allocations without constraint or regard for the potential implications. Where allocations are dependent upon significant, future infrastructure investment, policy should be clear that the development must either deliver that infrastructure (identify developer contributions) or cannot proceed until there is a clear commitment to delivery. The lack of clarity in the Policies, contingent upon investment in East West Rail or other significant infrastructure, risks delivery of the Plan allocations and potentially compromises the proper planning and delivery of growth elsewhere within the Central Area.
It appears to be possible to shape allocations for the earlier part of the Plan period, which can be justified by the evidence base, as it stands (it appears comprehensive in respect of localised need and impacts) and then to shape more broadly scoped policies for longer-term growth locations. While the NPPF/PPG provides limited guidance on the form of such policies, it does point to them shaping a process as a way forward, including further work required. In our experience as a master developer, it is helpful if such policies:
• are explicit about the limitations of the evidence base at the point the Plan is prepared.
• identify the issues and inter-dependencies that are relevant to determining the future scale and location of growth within the broad parameters identified;
• are clear about the pre-requisite infrastructure requirements and associated triggers (or addresses the need to resolve this at a later date, when there is further clarity);
• scope the further work and the cross-boundary collaboration which is necessary to safeguard comprehensive and co-ordinated development.