Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9912

Received: 28/07/2022

Respondent: EF Wootton and Sons and Sarrosons

Agent: Phillips Planning Services

The Council’s proposed Spatial Strategy, as defined under Policy DS2(S) is undermined by the risks of adopting the Stepped Trajectory set out in Policy DS3(S).

The proposed Spatial Strategy does not address the potential for delays in the delivery of East-West Rail, and other key infrastructure required to support the proposed strategic allocations on the East-West Rail / A421 transport corridor.

Progress with East-West Rail between Bedford and Cambridge and slow, and there are uncertainties surrounding when this piece of major infrastructure will be delivered. The Stepped Trajectory is reliant upon this infrastructure to meet the identified housing and employment needs, set out in Policy DS3(S). There is a high-risk of a slower rate of housing delivery, or a delay in the commencement of development on the identified new settlements South of Bedford and at Little Barford that would undermine the strategy.

The Council’s proposed residential development trajectory in the years 2030-2040 is therefore not realistic nor deliverable. We would contend that East-West Rail will take longer to come forward, and that the Council is likely to fall far short of achieving the requisite 1,700 dwellings per annum in the years 2030-2040.

The risks surrounding the delivery of EWR are acknowledged in the ‘Development Strategy Topic Paper’ (June 2021).

We recognise that the Council has acknowledged these risks stating it will monitor the provision and delivery of infrastructure and, if necessary, bring forward a review of the Local Plan. However, for the plan to be positively prepared and effective, we would suggest that he plan needs to mitigate these risks through the allocation of additional sustainable sites in line with the general locational strategy, such as adjoining or within a short distance of the edge of the Bedford Urban Area.

This Spatial Strategy is therefore not effective, nor is it positively prepared to address the potential weaknesses in the strategy during the plan period. We would contend that this would make the plan, as submitted, UNSOUND.