Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10249

Received: 29/07/2022

Respondent: Central Bedfordshire Council

1. General Comments
1.1 CBC recognises that following the adoption of the current Bedford Local Plan in 2020, the review was commenced in line with adopted Policy 1, and that whilst the plan period is rolling forward by 10 years, this is a partial review of the plan, undertaken to ensure the Policies remain up to date and to take account of changing government guidance.
1.2 We therefore note that the review and this consultation focuses on the following key policy areas:
• Vision and objectives
• Climate Change
• Spatial strategy to 2040 and site allocations
• Town centre and retail policies
• New and updated Development Management policies

1.3 Whilst CBC recognises the context within which the plan review commenced, we are mindful that there are numerous references to the Oxford to Cambridge Arc and the previously planned Arc Spatial Framework. Government have more recently indicated that the Arc will not be being taken forward as envisaged with a government-led strategy, but rather that any future growth within the geographical area of the Arc should be ‘locally-led’. We do recognise the many benefits of emulating the Arc Principles that many local authorities, including Bedford, have previously signed-up to, particularly in relation to climate change, economic growth and the natural environment, however, it is considered that the plan would benefit from reflecting the lesser role and influence that the Arc will now have on local planning.
1.4 With regard to transport matters, our comments are set out in detail below. However, both Central Bedfordshire and Bedford, alongside other stakeholders, including National Highways, are involved in ongoing meetings in relation to both M1 Junction 13 and the A1/A428 Junction and wider A1 Corridor. These meetings were initiated as all parties involved recognise and acknowledge that there are issues and opportunities at these two locations that can only be resolved through collaborative working and the joint consideration of existing growth proposals and future opportunities. Discussions are at the early stages and whilst solutions are yet to be identified, CBC hopes that these wider discussions will continue, and that progress can be made towards a resolution that meets the needs and aspirations of all.
1.5 It is also noteworthy, that whilst CBC are not looking to Bedford Council to meet any of Central Bedfordshire’s housing or employment growth at this time, that this is in the absence of any future discussions with other authorities about any potential unmet housing and economic needs.

Comment

Representation ID: 10250

Received: 29/07/2022

Respondent: Central Bedfordshire Council

2. Vision & Objectives
2.1 CBC support the positivity of the vision for Bedford, which states that by the end of the plan period “The borough will have become a greener, more sustainable, more attractive and prosperous place to live and work. Tackling climate change and adapting to and mitigating its effects will be at the heart of new development throughout the borough”. The four themes identified within the Submission plan are also generally supported as they provide a clear direction as to how the vision could be achieved.
2.2 It is noted within Theme 2 relating to accessibility, that there is an emphasis on improving east-west connectivity and enhancing multi-modal travel, through the construction of the East West Rail line. As the EWR proposals are still being considered and timeframes for delivery are still to be determined, it is considered that it may be prudent to also identify alternative means for improving connectivity within the Borough.
2.3 CBC also considers that it may be beneficial to reference within the vision and objectives for the plan, the potential improvements to east west connectivity that could also be realised through the Bedford to MK Waterway.

Comment

Representation ID: 10251

Received: 29/07/2022

Respondent: Central Bedfordshire Council

3. Climate Change
3.1 It is noted that Bedford Borough Council is seeking to incorporate carbon neutrality in all its strategies, including the Local Plan 2040 and this is welcomed and supported by CBC. Having declared a Climate Emergency, Bedford Borough Council has committed to become carbon neutral by 2030. This will require decisive actions and strong targets for new developments to ensure carbon neutrality is achieved without the need for retrofitting in the future.
3.2 Within the submission local plan, the proposed spatial strategy for growth to 2040 proposes a pattern of development which seeks to encourage fewer greenhouse gas emissions, by focussing development in the urban area and at locations with greater accessibility to new and existing rail stations and through the creation of walking neighbourhoods. Whilst this approach is broadly supported, the climate change section of the submission plan could be clearer about what tools and evidence have been used to support policy decisions. It is also considered that the policy could be strengthened by:
a) drilling down to local Carbon Budget data expressed by the Tyndall tool for the Bedford Borough area;
b) the inclusion of an additional policy point on infrastructure related to the decarbonisation of heat, power, and transport;
c) positive messaging that retrofitting should be encouraged where possible; and
d) setting clear policy expectations in regard to embedding considerations such as lowering and offsetting carbon.
3.3 It is also considered that the plan would benefit from a borough-wide energy strategy that could inform policy actions and targets as well as identifying infrastructure requirements to meet the commitment to became carbon neutral by 2030. CBC would be interested to understand if consideration has been given to identifying sites within the Borough for renewable energy infrastructure such as wind and solar farms, or if the Council have made the conscious decision not to do so.
3.4 Furthermore, CBC considers that specific reference could be included within the plan in relation to water resilience and the Bedford to MK Waterway, particularly given the benefits that could be realised with regard to climate change and carbon reduction due to proposed allocations within close proximity to the waterway.

Comment

Representation ID: 10252

Received: 29/07/2022

Respondent: Central Bedfordshire Council

4. Spatial Strategy to 2040
4.1 CBC supports the use of the Standard Methodology for calculating the housing requirement for the period from 2020 to 2040. It is recognised that this results in a total requirement of 27,000 new homes (1,355 dwellings per year), and that taking account of existing commitments, completions and an allowance for windfall, which amount to 14,824 dwellings, there is a need to identify sufficient land for 12,276 dwellings within the Bedford local plan to 2040.
 
4.2 As stated in our response to the Strategy Options and Draft Policies Consultation in September 2021, CBC is 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 Council therefore welcomes the approach taken within the submission local plan for new development to be focussed firstly on brownfield sites within and adjacent to the urban area, as well as town centre sites that offer regeneration opportunities. Policy DS5(S) is therefore supported to the extent that it identifies that the urban area will accommodate 1,200 new homes, whilst 1,500 new homes will be delivered in strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale, incorporating the Bedford Milton Keynes Waterway Park and the Bedford River Valley Park.
4.3 Policy DS5(S) also identifies that 10,850 new homes (and 73ha of employment land) will be delivered at two growth locations on the A421 corridor – south of Bedford including a new settlement, and Little Barford new settlement.
4.4 It is considered that the emphasis placed on these two growth locations to deliver such a substantial quantum of growth is likely to have significant impacts upon Central Bedfordshire and our communities. The Council has significant concerns about the transport implications that will undoubtedly arise for Central Bedfordshire as a consequence of this growth being focussed on the EWR / A421 transport corridor and therefore cannot support these two proposals at this time.
4.5 In the assessment of the options, the Pink, Yellow and Brown options focus development around the A421 corridor and the assumed East-West Rail corridors. Whilst the yellow option was one of the two options detailed within the evidence as performing the best in terms of the assessment metrics that were applied, it results in sub-options where development is focused to the south and east of Bedford and therefore with the most immediate potential for impact on the transport network within CBC, including the A421 and A1 corridors. When considering the future 2040 reference case it is also noted that the A421 and A1 (strategic cross boundary routes into Central Bedfordshire) are the routes that the modelling predicts will undergo the greatest levels of increase in terms of background traffic.
4.6 Four sub options (2a- 2d) were then considered, each being variants of the yellow option, resulting in an overall preferred option, which focuses development around the A421 and East-West Rail. In testing these options, the modelling report identifies flow increases on routes in CBC including the A1, A421, C94 with associated increases in both delay and volume/ capacity ratios. There are also increases predicted on the B530.
4.7 The proposed package of mitigation works, which predominantly provides a strengthened ring road to the south and west of Bedford, appears to have the general effect of releasing suppressed trips onto the wider major road network, in particular the A1, A421 and B530, all of which sit, at least partially within CBC. This is of immediate concern to CBC, especially in the context of our own growth strategy and allocated sites in our Adopted Local Plan (July 2021).
 
4.8 Including a focus on sustainability within Theme 2 of the Bedford Submission Local Plan is critical to managing growth and is welcomed, but we suggest that East West Rail and the reintroduction of ‘faster north- south travel’ (presumably on the Midland Mainline but this is not clarified) is not strictly an objective of the Plan as both interventions are in part controlled by external parties.
4.9 In terms of policy DS2, the South of Bedford policy area raises some specific concerns with regard to the A421 corridor and M1 junction 13 which we address in further detail later on in our response. Rail based development as a concept around Stewartby Hardwick and Wixams is supported, but this must be delivered alongside a robust highways mitigation strategy due to the nature of planned growth across the whole A421 corridor. Similarly, the Little Barford policy area raises concerns around impact on the A1 corridor and erosion of future capacity of the new Black Cat roundabout and realigned A428.

Comment

Representation ID: 10258

Received: 29/07/2022

Respondent: Central Bedfordshire Council

8. Transport Strategy
8.1 CBC considers that mirroring the 5 point Plan of Action and Principles from the EEH Transport strategy is sensible and supports aligned action across the EEH area. The stepped trajectory approach is wise when there are many external factors influencing the delivery of critical infrastructure, many of which will either not be complete until at least 2030 or their certainty level is still unknown.
8.2 However, whilst a stepped approach is supported, it is noted that with the higher development rates in the second half of the plan period from 2030 onwards, there will be limited scope to bring forward sites to address any shortfall which may arise in the early years of the plan. CBC consider that contingency sites should be identified to maintain housing delivery in the event that the large strategic sites planned at the end of the plan period do not materialise.

Object

Representation ID: 10260

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

9. Employment
9.1 The Council generally supports the economic ambitions of Bedford Borough Council and recognises the desire to attract a variety of employment opportunities that span a range of sectors with jobs related to R&D, office and industrial, as well as strategic warehousing and distribution, which is in accordance with the plan vision and strategy to create a high-value, highly skilled, economy. It would have been helpful if individual maps had been included within the Submission consultation plan to clearly indicate the locations of the proposed allocations EMP1 to EMP8.
9.2 The Bedford Economic Growth Ambitions Topic Paper (April 2022) states that the allocation of employment land, and the attraction of non-B8 jobs as a result of policy intervention, would provide the opportunity for Bedford to develop a more balanced, productive and therefore higher value economy.
9.3 However, the proposals for 26,700 additional jobs on up to 142ha of land within the plan period, as set out within the Submission plan, is a significant increase from the 8,642 new jobs proposed in the Strategy Options and Draft Policies Consultation (Sept 2021). It is noted that the Borough Council have used the ORS employment growth forecast, derived from its population forecast and that the dwelling-led population growth scenario shows an increase in employment from about 87,800 in 2020 to about 114,500 in 2040, an increase of about 26,700 or 30%. Over the same period, the EEFM scenario shows an increase of only 15% to about 102,200 in 2040, some 12,300 fewer jobs.
9.4 Whilst CBC recognises the justification provided for the ambitious figure within the submission Local Plan and supporting technical documents, this is a substantial change which CBC had not been aware of until now. CBC may want to reflect on these figures further and through discussions with the Borough Council.
9.5 CBC would support the employment proposals set out within Policies EMP1 to EMP5 of the submission consultation plan, as they either make the best use of previously developed land or are immediately adjacent to existing employment and retail areas within the urban area of Bedford.
 
9.6 However, whilst it is understood why the Council would want to be ambitious in relation to economic growth, CBC considers that in relation to the proposed employment allocations outside of the main urban area, the Borough Council should more carefully consider the likely detrimental impacts on the strategic road network, as well as issues such as sustainable travel, accessibility of the location for future employers and employees, and out-commuting from areas such as Central Bedfordshire, especially given the close proximity of some of the proposed allocations to our administrative border.
9.7 The Council have significant concerns about the proposed employment allocations as set out within policies EMP6-EMP8 due to the likely impacts on the strategic road network as detailed at paragraphs 6.6 to 6.9 above in relation to the A1, Black Cat Junction and the A428, as well as the implications for Central Bedfordshire as noted above.
9.8 Central Bedfordshire therefore objects to Policies EMP6, EMP7 and EMP8 on the basis of our transport concerns as detailed above.
9.9 Further employment land is also identified to be allocated within the new settlements proposed at allocations HOU12 (South of Bedford) and HOU19 (Little Barford). Whilst CBC supports the delivery of mixed use sustainable developments, we do have some concerns about the proposed allocations, the impacts upon the strategic road network and the implications for Central Bedfordshire, as set out at paragraphs 6.1 to 6.9 above in relation to the A421 corridor, the A1, the Black Cat Junction and the A428.

Comment

Representation ID: 10261

Received: 29/07/2022

Respondent: Central Bedfordshire Council

10. Site allocations
10.1 As noted above, CBC supports the use of urban, brownfield sites ahead of the allocation of greenfield sites. We therefore do not have any specific comments to make in relation to site allocations within the urban area of Bedford. We do, however, have comments in relation to the following proposed allocations.
Policy HOU12 - South of Bedford area
10.2 Central Bedfordshire Council objects to this proposal on the basis of our transport concerns as detailed above.
10.3 This is a significant expansion area to the south of Bedford which seeks to bring together and coordinate the delivery of various strategic sites. It is recognised that the area already contains a number of existing built areas and strategic allocations, however, the further expansion will likely have significant implications for Central Bedfordshire. Whilst it is a sensible approach to coordinate the delivery of growth in the area through this policy, we have signficant concerns about the overall impact of growth in this area on the road network, bearing in mind site allocations already committed within our own plan and therefore cannot support this proposal .These concerns are covered in detail in our review of the supporting transport modelling in sections 4 to 8 above.
10.4 It is noted that the Council proposes to prepare a Strategic Place Making Framework to guide development across the policy area which will be adopted as a Supplementary Planning Document. It is considered of paramount importance that if the proposed allocation is taken forward, Central Bedfordshire Council is engaged from the outset in the production of the Framework, to ensure that any impacts arising from the proposals on Central Bedfordshire residents, communities, serices and infrastructure, is identified and mitigation measures agreed prior to any development taking place.

Comment

Representation ID: 10262

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Policy HOU13 - Land at Gibraltar Corner
10.5 The submission local plan identifies that this allocation will contribute to the delivery of key green and blue infrastructure projects in the south of Bedford area including a section of the Bedford to Milton Keynes Waterway Park and the Forest of Marston Vale. These are both projects that CBC are supportive of - indeed, Central Bedfordshire and Bedford Councils have been working closely for some time with the Forest of Marston Vale Trust and are currently undertaking a joint consultation in relation to the Forest of Marston Vale SPD which will ultimately be adopted by both authorities. CBC therefore welcomes the proposed allocation at Gibraltar Corner and the resulting benefits that would also be afforded through this development to residents and communities within Central Bedfordshire.
10.6 However, whilst the submission plan identifies that this proposed allocation forms part of the wider South of Bedford Area, it is unclear how many homes would actually be delivered here. CBC would welcome clarification in regard to this as well as early engagement in relation to the proposed SPD for the site.
10.7 We would also welcome dicussions on bus routing, as this site will require a high quality link to deter driving to the future Wixams station. Presumably the bus route will be offered in parallel with parking management/ control at the destination end of the journey to prevent this.

Object

Representation ID: 10263

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU14 - Kempston Hardwick New Settlement
10.8 Central Bedfordshire Council objects to this allocation on the basis of our transport concerns as detailed above.
10.9 This site is proposed to deliver significant growth linked to the A421 corridor of at least 4,000 new homes and around 70ha of employment land, although it is unclear in the submission plan, what types of employment would actually be delivered here. It is considered that these proposals will have significant impacts upon Central Bedfordshire communities.
10.10 The policy recognises that the site is reliant on new rail infrastructure at Stewartby Hardwick (i.e. a new station delivered by the EWR rail project) and a new station at Wixams, but we would consider the Wixams scheme much more certain than that of EWR as no decision has yet been made as to the scheme (s) which will form part of the development consent order. Particular attention should be paid to forecasting flows towards the A421 and M1 J13 within any future detailed Transport Assessment. Despite what the site will offer, it is highly unlikely that it will be completely self sufficient as the policy wording suggests and the impact on routes such as the A421 is critically important to Central Bedfordshire.
 
10.11 We are concerned that the proposed new link between Fields Road and Manor Road will facilitate the use of the B530 as an alternative route when the A421 experiences congestion issues resulting from both growth and the proposed widening scheme further east.
10.12 It should also be made clear if ‘Stewartby Hardwick’ and ‘Broadmead’ are both referring to the new EWR station, as the names are used interchangably in the supporting evidence.
10.13 The Submission plan states that a masterplan and design code will be prepared for this site to show how the new settlement can be delivered in accordance with the South of Bedford Framework and will be adopted as SPD. It will be essential that Central Bedfordshire Council is engaged from the outset in the production of the masterplan and design code, to ensure that any impacts arising from the proposals on our residents, communities, serices and infrastructure, are identified and mitigation measures agreed prior to any development taking place.

Comment

Representation ID: 10264

Received: 29/07/2022

Respondent: Central Bedfordshire Council

HOU15 - Land South of Wixams
10.14 The submission plan identifies that the proposed allocation forms part of the wider South of Bedford Area, it is however, unclear how many homes would actually be delivered within the allocation.
10.15 CBC generally supports the further expansion to the south of Wixams within Bedford Borough. However, due to the cross boundary nature of the Wixams site as a whole, coordination between CBC and Bedford will need to be ongoing to ensure the area as a whole is delivered cohesively. CBC and BBC will also need to look at wider cross-boundary issues, including an access strategy and particularly treatment of the A6 junctions and extension of bus routes to create a network for the wider Wixams site.