Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 9535

Received: 11/07/2022

Respondent: Clapham Parish Council

Please consider this the formal response to the public consultation on the draft Local Plan 2040.
Clapham Parish Council fully supports the approach to future development in the areas denoted in the draft Plan.
We recognise that Clapham has already had allocated significant development in the current plan and is glad the future Plan does not include further large development in its boundary.
We ask that Bedford Borough Council considers the planning and community needs of the villages outside the town, not only of rural villages, but also of those less rural villages such as Clapham which border the town, in considering the current and future pressure on transport infrastructure.
We remain concerned about the impact of the East West Rail proposals on Clapham, regardless of which route is ultimately chosen. We ask that future Local Plans consider the impact of EWR’s construction on Clapham, its residents and its environment and would like to develop partnerships with Bedford Borough Council to develop mitigation for the proposals.
We continue to support the need for active travel.

Comment

Representation ID: 9623

Received: 26/07/2022

Respondent: Clapham Parish Council

CPC has no objection to the Vision and Objectives of the proposed local plan noting that it aims for the requisite infrastructure is in place when the proposed growth is brought forward for delivery. To that end, of the total allocation of 27,100 dwellings 1700 dwellings are to be delivered post 2030. This is sensible.

The required supporting infrastructure is set out in the Infrastructure Delivery Plan. This includes the completion of East-West Rail (EWR) by 2030. This is important to note as it provides for the required modal shift to give resilience to the highway network. However, CPC has some concerns that given the complexity of the project EWR, it will not be completed by 2030.
EWR is at an early stage of development and has not commenced its statutory process and which through examination may significantly change its form, location and deliverability. Given this uncertainty, CPC has significant concerns in allocating housing and employment to sites which may ultimately not be facilitated by EWR in a timely manner.

CPC therefore considers the plan is not legally sound, credible or flexible. To make the plan sound, CPC considers the policy should have a fallback position, so if EWR does not come forward, is delayed, or there is a change in routeing, then either the allocated sites are not implemented until it is in place, or sufficient alternative infrastructure or other sustainable measures are identified to support the development sites.

CPC consider not taking this action, will potentially result in intolerable levels of highway congestion and delay to movements around Bedford, including to the residents of Clapham wishing to access Bedford or the A421 corridor.

Comment

Representation ID: 9626

Received: 26/07/2022

Respondent: Clapham Parish Council

Policy Omission: Strategic Gaps
The proposed plan allocates significant growth along the A421 corridor, notably at Kempston Hardwick New Settlement (HOU14), Land South of Wixams (HOU15), Land at East Wixams (HOU16) and Gibraltar Corner (HOU13). These sites effectively provide infill sites to the communities of Wootton, Stewartby and Wixams, creating a continous suburban extension.

These allocations continue the long term trend of coalescence of communities throughout Bedford and Kempston, and provides a dangerous precedence. CPC therefore request consideration is given to the inclusion of a specific policy for Strategic Gaps designed to protect the integrity and character of communities such as Clapham which are located close to, bit outside the urban area of Bedford. The purpose of the policy would be to provide a planning tool which:

Identifies areas of open land/countryside between existing settlements, with the aim to protect the setting and separate identity of settlements, and to avoid coalescence by retaining the existing settlement pattern through maintaining the openness of the land.

CPC would wish this to apply to the open land between Clapham and Bedford. There may be other communities to which this policy could be applicable. CPC suggest the following criteria for consideration

The land to be included within the gap is open and provides a sense of separation between settlements.
· The land to be included within the gap performs an important role in defining the settlement character of the area and separating settlements at risk of coalescence (in particular from land allocations in the Local Plan).
· In defining the extent of a gap, no more land than is necessary to prevent the coalescence of settlements should be included, having regard to maintaining their physical and visual separation.
Taking into account;
landscape character, landscape features (woodland, river valleys and landform), topography, distance, existing vegetation and land uses, the nature of settlement edges and how they integrate with the adjacent countryside, key views, the sense of leaving a place

Inclusion of this policy would align with:
Policy DS2(S) Spatial strategy
xiii. Safeguarding the intrinsic character of the countryside and the environment and biodiversity within it through the careful management of development to meet local needs whilst supporting the rural economy

Support

Representation ID: 9627

Received: 26/07/2022

Respondent: Clapham Parish Council

Housing is becoming significant more unaffordable for peoples within the borough and is exasperated by those moving into the area from more affluent areas. This will increase if East-West Rail is delivered when greater accessibility is provided. Therefore CPC supports the principle of the First Homes discount and Local eligibility criteria, and the policy should be enhanced to specifically reference the Local eligibility criteria

Object

Representation ID: 9628

Received: 26/07/2022

Respondent: Clapham Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

CPC is opposed to this policy, as whilst the principle is sound, it does not provide sufficient protection for speculative developments to be brought forward outside the adopted local plan. If the policy is to be included then potential sites should be identified through the relevant Neighbourhood Plan, rather than a speculative approach. It is not accepted that developers will have sufficient regard to the area, focusing primarily on its commercial potential, particularly with the inclusion of market value properties to gain affordability. Given the pressure on the local authorities to facilitate housing supply, if targets are not being met, then there is a risk that inappropriate sites will receive planning consent, irrespective of the policy being fully implemented

Comment

Representation ID: 9629

Received: 26/07/2022

Respondent: Clapham Parish Council

Given the increasing numbers of older persons living within our communities, the need for specific provision is becoming more important. This is particularly important with the opportunities for independent living with support. Consequently CPC supports this policy.
CPC has some concerns that the threshold of 500 dwellings is too high and suggest a lower thresholder of 350 or less.