Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9538

Received: 13/07/2022

Respondent: Ravensden Parish Council

Ravensden PC notes that many of the Policies in the adopted 2030 Local Plan and in the 2013 Allocations and Designations Local Plan, and even some in the 2002 Local Plan, will remain extant after the 2040 Local Plan is finally adopted (see Appendix 1 to the 2040 submission plan). That will mean that anyone using the development plan to formulate or determine development proposals anywhere in the Borough will have to consult up to 4 separate documents and, in the case of proposals in Neighbourhood Plan areas such as Ravensden, some 5 development plan documents, together with associated Design Guides etc. The plethora of documents and policies at Borough level will potentially be overwhelming and confusing, and could give rise to unnecessarily conflicting interpretations of policies. We suggest the Borough Council should take the opportunity to consolidate all the various Local Plan documents into a single publication.

Comment

Representation ID: 9539

Received: 13/07/2022

Respondent: Ravensden Parish Council

Ravensden Parish Council in principle welcomes the development strategy in the 2040 submission version plan, as it builds on our preferred option from the 2021 consultation (Option 2b), but subject to the reservations set out below. We also support the deletion of the proposed new settlement at Dennybrook which would have had significant traffic implications for the road network in the Parish, notably the B660.
At para 4.23 of the Submission Plan, it says that East West Rail is a “critical catalyst and pivotal to achieving the Plan’s vision”. The Local Plan 2040 should acknowledge that Government has yet to finally decide whether the section between Bedford and Cambridge should be constructed at all, or in a given timescale, or on a particular route. Therefore much of the strategy of the Plan could be undone if Government does not confirm the premature assumptions which the Borough Council has made with regard to this section of the proposed railway. The absence of a fall-back strategy in the Submission version of the Local Plan 2040 could be considered unsound.
For these reasons, EWR corridor E should be deleted from the Key Diagram. The scheme is not a commitment and it is outside the control of the Borough Council to deliver it through the Local Plan 2040.
The Parish Council notes that the greater part of the dwelling requirement for the Borough is to be met through the creation of new settlements in the A421 corridor, based on new stations at Kempston Hardwick and Wixams (as part of the wider South Bedford policy area), and at Little Barford. That strategy would be consistent with the creation of a sustainable and environmentally acceptable multi-modal corridor along the A421, and undermines the case for the railway to cross the undulating and environmentally sensitive landscape north of Bedford. If EWR is not built, then the south Bedford development strategy including a new settlement at Kempston Hardwick could still be achieved, as it would continue to be served by the Marston Vale line, plus the new committed station at Wixams on the Midland Mainline.
However, we are concerned that a new settlement at Little Barford would have no public transport rationale if EWR did not go ahead or if a more southerly route through Tempsford was chosen. Although it would lie within the A421 corridor following the completion of the Black Cat/Caxton Gibbett dual carriageway, much of the sustainability rationale for the Little Barford proposed new settlement would fall away if EWR was not constructed through the proposed allocation (see related comment below about the Key Diagram).

Comment

Representation ID: 9540

Received: 13/07/2022

Respondent: Ravensden Parish Council

Ravensden Parish Council notes the proposal for 30 hectares of employment land on two sites at the A421 Renhold junction (Policy EMP6). Whilst this is intended to be a research campus-style development, with elements of manufacturing, warehousing and distribution, we are concerned that the proposal could readily become a standard “sheds on the bypass” scheme, of which there are many similar examples along the A421 and which the property market invariably favours in locations well-served by strategic highways.
In any event the Parish Council is concerned about the potential traffic implications of this proposal. Already Oldways Road in our Parish is heavily used as a “rat-run” for traffic between the A6 and the A421. There is little or no provision on Oldways Road for pedestrians, cyclists, the mobility-impaired or equestrians, and the road safety risks are already considerable. The key junction of Oldways Road with the B660 at Ravensden Crossroads is agreed by the Borough Council as being over capacity. The B660 Bedford Road south of Wayside Farm Park has no facilities for pedestrians, and improvements are required here if the proposed country park extension (as part of the Ravensden Park permission) is to be sustainably integrated with the rest of the Parish. Cleat Hill is prone to large volumes of traffic and has a notable speeding problem.
Policy EMP6 can only exacerbate these issues and concerns.

Comment

Representation ID: 9541

Received: 13/07/2022

Respondent: Ravensden Parish Council

The Parish Council welcomes the Vision statement including that " development will reflect each areas unique local character" and the focus of Theme 1, which aims to secure a "Greener" Borough. The intention to develop a Green Infrastructure network will support the policies within Ravensden's emerging Neighbourhood Plan. Theme 1 also states that the Borough will "protect and enhance our natural resources". The Parish Council is keen to see strong protection for the high quality soils within Ravensden.

Comment

Representation ID: 9542

Received: 13/07/2022

Respondent: Ravensden Parish Council

Policy DM7 - Biodiversity Net Gain- will require major development to provide a minimum of 10% net gain. Within Ravensden, small scale development frequently leads to the loss of tree, hedge or shrubbery habitats of value for wildlife. The Parish Council would welcome a broader policy which requires all development to make a contribution to the natural environment, to avoid environmental loss. New trees and the planting of native species would enhance biodiversity and help to retain and enhance local character.
Protection of established and veteran trees needs to be given greater emphasis within the Plan.

Comment

Representation ID: 9543

Received: 13/07/2022

Respondent: Ravensden Parish Council

For reasons outlined above, the shaded notation for EWR corridor E should be removed from the Key Diagram.
The notation for a new station at Little Barford should be deleted as, if built at all, EWR could equally cross the ECML at Tempsford (in Central Bedfordshire) where the new station would be sited instead.
The Parish Council also notes that the housing allocation from the 2030 Local Plan at Graze Hill (Policy 24) is shown on the Key Diagram as a strategic housing commitment. Policy 24 is not a strategic policy in the adopted Local Plan 2030, so the notation on the Submission Plan Key Diagram should be amended, or removed entirely.