Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10265

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU16 - Land East of Wixams
10.16 Central Bedfordshire Council objects to this allocation on the basis of our transport concerns as detailed above.
10.17 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.
10.18 HOU16 is proposed to be located to the east of the A6 and the existing Wixams development. It is noted that the proposed policy states, ‘The development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan’ and that ‘Traffic mitigation (will be required) for the existing roundabouts off A6 to accommodate the new development;.
10.19 Without further details as to the nature of the transport mitigation required, and the concerns identified at paragraphs 6.4 and 6.5 above, it is impossible to fully understand potential impact and implications upon Central Bedfordshire. The Council therefore at this time, cannot support this proposal.
 
10.20 However, if transport implications can be resolved and the allocation is retained within the plan, 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. In these circumstances, CBC would welcome early engagement in relation to the proposed SPD for the site.
10.21 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.

Object

Representation ID: 10266

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU19 - Land at Little Barford
10.22 Central Bedfordshire Council objects to this allocation on the basis of our transport concerns as detailed above.
10.23 Little Barford is proposed in the Submission Local Plan for a new settlement, delivering at least 4,000 new homes, approximately 3,800 of which would be within the plan period to 2040, and around 4ha of employment land. The draft policy suggests that the new settlement will be a community located in close proximity to the proposal for a new station on the East West Rail line and that it will provide all the key services and facilities to address its own needs, including health, education, retail, culture and community components.
10.24 This proposed allocation is particularly reliant on new strategic infrastructure that is outside of the authority’s control, including a new junction on the realigned A428 (not in the scheme currently subject to the DCO process) and a new EWR station, neither of which have a high enough level of certainty in our view to be included in a core transport modelling scenario at this stage. Given the levels of uncertainty surrounding significant infrastructure requirements associated with the proposed allocation, Central Bedfordshire has concerns about the overall sustainability of the proposals and would seek clarification as to whether the proposals could still be delivered without a new junction of the A428 and / or if the proposals for a new EWR station do not materialise within necessary timeframes.
10.25 Furthermore, a site of this size and scale in this location should also be identifying and delivering a specific mitigation strategy for the A1 junctions in the vicinity due to the likely implicatins for communities along the A1 corridor. We would also suggest, if the scheme is taken forward, that the design of the Barford Road bridge currently forming part of the package of works for the A428 scheme could benefit the site if the design was revisited in discussion with National Highways to allow for walking and cycling, to futher enhance the ‘accessible’ section of policy HOU19.
10.26 Given the above, and our detailed concerns set out in our review of the supporting transport modelling in sections 4 to 8 above, Central Bedfordshire cannot support this proposed allocation.

Comment

Representation ID: 10267

Received: 29/07/2022

Respondent: Central Bedfordshire Council

11. Gypsies, Travellers and Travelling Show People
11.1 In relation to Gypsies, Travellers and Travelling Show People, the Council supports the identified need for an additional 46 Gypsy and Traveller pitches and 13 Travelling Show People plots and that Bedford Council is planning to meet this identified need in full. However, noting our objections relating to the two new settlements within which this provision is to be made, the same concerns would apply in terms of meeting this demand.
11.2 As noted within our response in September 2021, it is unclear as to why there should be no criteria-based policy to assess new planning applications for private pitches which will likely also come forward in the plan period.

Comment

Representation ID: 10268

Received: 29/07/2022

Respondent: Central Bedfordshire Council

12. Town Centre and Retail Policies
12.1 CBC supports the aims of the submission local plan in ensuring the vitality of town centres, particularly on the back of the struggles many town centres faced, and are still facing, as a result of the pandemic.
12.2 In order to ensure the longevity of town centres and retail outlets, Policy TC1(S) and TC2 are considered to identify an appropriate town centre hierarchy and approach to retail, leisure and office development.

Comment

Representation ID: 10269

Received: 29/07/2022

Respondent: Central Bedfordshire Council

12. Town Centre and Retail Policies
12.1 CBC supports the aims of the submission local plan in ensuring the vitality of town centres, particularly on the back of the struggles many town centres faced, and are still facing, as a result of the pandemic.
12.2 In order to ensure the longevity of town centres and retail outlets, Policy TC1(S) and TC2 are considered to identify an appropriate town centre hierarchy and approach to retail, leisure and office development.

Comment

Representation ID: 10270

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Affordable Housing
13.1 In relation to Policy DM1(S), we note that the proposed policy indicates that the First Homes will deliver with a discount of 50% against the open market value. It is considered that the inclusion of a discount percentage that deviates away from the minimum 30% against the open market value, has the potential to impact the viability of the scheme. This approach also has the potential to impact on the quantum of affordable housing provision delivered and also has the potential to reduce the quantum of social rented / affordable rented delivered (which currently represents the most acute tenure of need).

Comment

Representation ID: 10271

Received: 29/07/2022

Respondent: Central Bedfordshire Council

First Homes Exception Sites
13.2 CBC are generally supportive of the proposed Policy DM4 - First Homes Exception Policy. The policy makes clear the potential for the inclusion of other forms of affordable housing within a First Homes Exception Site which CBC consider will be key to enabling the delivery of a number and variety of dwellings for the most acute tenure of need through the provision of social rented and affordable rented housing.
13.3 It is considered that the inclusion of other forms of affordable housing within a First Homes Exception site will be beneficial to providing for an inclusive, mixed and integrated community.

Comment

Representation ID: 10272

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Quality of development and space standards
13.4 Paragraph 6.52 of the submission local plan identifies a number of supplementary guidance documents, some of which appear to be quite dated. It may be beneficial if these documents were reviewed and updated as part of the forthcoming design guide. The preparation of a new design guide is supported by Central Bedfordshire Council, and we would welcome being consulted on the scope and content of this document in due course.

Comment

Representation ID: 10273

Received: 29/07/2022

Respondent: Central Bedfordshire Council

13.5 Central Bedfordshire Council also support the requirement for residential space standards in line with Nationally Described Space Standards. However, as identified within our response to the previous consultation in September 2021, the policy (DM6) requires all residential developments to conform to the standards ‘as a minimum’. This implies that there may be cases where higher space standards may be sought. If this is the case, the scenario/type of development to which higher standards may be sought should be set out in the policy or the supporting text.

Comment

Representation ID: 10274

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Natural Environment policies
13.6 CBC support the proposed new policy DM7 – Environmental Net Gain, which aims to increase overall Environmental Net Gain, over and above just Biodiversity Net Gain.
13.7 However, the supporting text alongside the policy references the Arc Environmental Principles, which all Local Authorities within the Central Area, including Bedford in June 2021, have signed up to. Whilst it is appreciated that the Government are no longer taking forward the Arc as previously anticipated, it is considered that the Environmental Principles are a robust foundation upon which to deliver environmental and biodiversity net gain.
13.8 It is therefore surprising that whilst proposed policy DM7 specifies a requirement to secure a minimum of 10% BNG in relation to major proposals, the policy or supporting text does not specifically make reference to the 20% ambition set out within the Arc Environmental Principles.
13.9 It is also noted that Policy DM7 does not apply to sites below 10 units or <0.5ha. As identified within our response to the consultation in September 2021, in relation to smaller development schemes that come forward, we would be interested to understand how will it be ensured that BNG and NEG will be addressed?