Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 9953

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DM11 (Outdoor Sports Space in Association with Development) requires all new residential development which results in additional dwellings to contribute to outdoor sports provision either through the enhancement of existing facilities or the provision of new facilities. The policy is supported by a Playing Pitch and Outdoor Sport Strategy and Action Plan (July 2021), which has been published as part of the BBLP40 evidence base.
IM Land support the principle of ensuring there is adequate outdoor sports provision with the Borough and have no comments regarding this policy.

Support

Representation ID: 10343

Received: 29/07/2022

Respondent: Barton Willmore

Draft Plan’s ‘Vision’ is set out at paragraph 2.1, which states that its purpose is to demonstrate the focus and direction of the Local Plan.
2.2 The second paragraph of the Vision states that by the end of the plan period “well-planned growth supported by appropriate infrastructure… will enable the creation of strong, safe and resilient communities in environments that facilitate healthy and independent living for all.” However, there is no specific reference to healthcare infrastructure, and we are of the view that this is an important element that should be included within the Vision (as mentioned in our previous Representations).
2.3 The fifth paragraph of the Vision briefly makes reference to the transformation of “brownfield sites on the western side of the town and south of the river”, the latter of which we assume relates to the Policy 14 Area which includes some of Bedford Hospital South Wing site and wider car parking land to the northeast of Britannia Road. Again, we are of the view that explicit reference to the Bedford Hospital sites should be made within the Vision, as these are key locations for development and improvement during the local plan period to 2040.
2.4 The Plan sets out four ‘Themes’ that are intended to reflect the Vision, including: Greener; More Accessible; More Prosperous; and Better Places.
2.5 We note that one of the objectives under Theme 3 (More Prosperous) has been amended since the Draft Plan, to include reference to health:
“Deliver the necessary health and social infrastructure to increase well-being in both the urban and rural areas of the borough.”
2.6 We support this amended objective and recognition of the importance of health infrastructure to support wellbeing and development.
2.7 Theme 4’s objectives include the following, which remains unchanged from the Draft Plan, and which we continue to support:
“Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives.”

Object

Representation ID: 10344

Received: 29/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

In terms of the Plan’s strategic policies, Policy DS1(S) Resources and Climate Change states that development must support a move to carbon neutrality. It then sets out a detailed series of points under the following headings:
(A) Minimising carbon emissions;
(B) Maximising carbon storage and sequestration;
(C) Mitigating and adapting to the impacts of climate change;
(D) Responding to the economic and policy changes that are likely to accompany climate change;
(E) “New development will be required to demonstrate through Sustainability and Energy Statements how it will take account of embedded carbon and contribute to mitigating and adapting to climate change and to meeting targets to reduce carbon dioxide emissions having regard to the above”.
2.9 The Trust corporate objectives support the national agenda and objective of achieving net zero carbon and is underpinned by an Estate Strategy and Net Zero Carbon plan, both of which inform the Trust’s Site Master Plan. The Trust’s Estate Strategy includes significant infrastructure development to deliver this approach on their estate, and this will likely include new sub-stations, an energy centre, new efficient buildings and green space. We therefore support the Council’s aspirations and strategic approach towards addressing climate change and minimising environmental impacts. However, we are concerned that setting out a broad and extensive policy – as in Policy DS1(S) – could result in an overly onerous policy context. For example, point (E) refers to Sustainability and Energy Statements as a requirement for new development. However, this is not qualified in terms of which developments would be expected to provide such statements. This requirement would be excessive for many minor developments and could create a barrier to appropriate and sustainable development.
2.10 Most environmental and performance standards associated with new development are managed through Building Regulations, and it is important that planning policies do not seek to replicate these. There is the risk that policies will quickly become outdated and inconsistent when Building Regulations are revised and updated. This causes confusion and, as mentioned, can create a context which negatively impacts on new development coming forward.
2.11 We suggest that Policy DS1(S) is clearly identified as a strategic policy – setting out the Council’s aspiration and objective regarding resources and climate change.

Object

Representation ID: 10345

Received: 29/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

South of the River / Bedford St Johns Station
3.2 Paragraphs 4.51-4.54 refer to the South of the River Area, as allocated for development in the adopted Local Plan 2030 under Policy 14. Whilst much of the text is focused upon the plan to deliver circa 1,000 dwellings in this Area, we note the following statement under paragraph 4.54:
“The land at Britannia Road provides potential for Bedford Hospital to expand to accommodate planned growth, including a new multi-storey car park and attractive links to Bedford St Johns station.”
3.3 We support this reference to the Bedford Hospital, the Trust’s planned growth and the acknowledgement of the Hospital’s role within the Policy 14 Area. Regarding the reference to “attractive links to St Johns station”, we would highlight that the Trust has not committed to any land disposal or agreed to any projects in this regard. The Hospital’s landholdings are tightly constrained in this area and a masterplanning process will be required.

Comment

Representation ID: 10346

Received: 29/07/2022

Respondent: Barton Willmore

As referred to in the Introduction, the Trust is a key stakeholder within Bedford, providing essential healthcare provision to the population of the town and wider area from their established sites at South Wing (Kempston Road) and North Wing (Kimbolton Road).
South Wing Site
4.2 The Bedford Hospital South Wing Site provides a range of essential healthcare services to the population of Bedford and beyond, including an Emergency Department, operating theatres, pathology, x-ray, inpatient wards and outpatient services. It is located circa 1km southwest of Bedford town centre, to the south of the River Great Ouse and southwest of the Bedford St John’s Railway Station. The Hospital’s main buildings lie to the southeast of Kempston Road, southwest of Britannia Road and the northwest of the A6 Ampthill Road. These buildings provide clinical, clinical support and essential non-clinical support functions. To the northeast of Britannia Road, the wider Hospital site includes essential non-clinical support buildings and car parking areas.
4.3 The Trust’s current clinical strategy requires the strategic estate development of the Bedford South Wing site over the next 15 years. This has been agreed by the Executive and includes significant infrastructure development to support the corporate and national agenda and objectives to achieving net zero carbon; additional operating theatres; additional outpatient capacity; and inpatient provision for elective day care. The clinical strategy will inform the creation of a new ‘development control plan’ for the South Wing Site. Once this has been prepared, the Trust will be keen to share this with the Council and other stakeholders and partners.
4.4 The strategy for the wider South Wing Site will need to take account of a range of factors, including the proposed changes to the railway line and Bedford St Johns Station as a result of East West Rail. The proposed realignment will result in improved accessibility via public transport. However, there will be impacts on car parking provision at the Hospital, as around 1,000 car parking spaces are currently leased on the former Danfoss site. The car parking and access strategy for the Site will need to be progressed alongside the development control plan, and ultimately a new multi-storey car park will be required on Trust-owned land between Britannia Road and the railway. This has been discussed in principle with Council Officers in respect of the emerging Development Brief for the Land South of the River (Policy 14) Area, and the Trust is keen to work with the Council and other partners in developing plans for this area of change.
North Wing
4.5 The Bedford Hospital North Wing Site is a health village for Bedford. Located circa 1km northeast of the town centre, adjacent to Kimbolton Road, it includes Gilbert Hitchcock House, Florence Ball House, Enhanced Services Centre, Shires House, Dental Care Centre, Archer Unit, Cedars House and Fountains Court. Land is under a variety of ownership and clinical service management is aligned to several organisations. In partnership with other commissioners, the Trust are co-leading a strategic estate programme to enhance the delivery of primary and some secondary care from the North Wing Site. The Trust is keen to work with the Council and other partners to deliver a strategic estate programme for enhanced healthcare provision from the North Wing Site.
Planning Approach
4.6 In previous representations to the Bedford Local Plan 2040, we had suggested that a ‘Special Policy Area’ (SPA) designation for the South and North Wing sites would be an appropriate policy response. This would include identifying the sites for major redevelopment and change during the forthcoming plan period, and setting out a policy (or policies) related to the proposed development.
4.7 We understand from further discussions with Planning Policy Officers that specific designations and policies to cover the Hospital Sites are not considered to be necessary, given the location of the sites within urban areas and the general presumption that development would be acceptable subject to the usual development management tests. Instead, Officers have suggested that a Masterplan approach or Pre-Application process would be more appropriate.
4.8 The Trust is keen to work closely with the Council as their clinical strategy develops into a programme for the redevelopment of their estates, and we will continue to engage with Officers regarding the Development Brief for Land South of the River (Policy 14).

Comment

Representation ID: 10524

Received: 26/07/2022

Respondent: Barton Willmore

Paragraphs 1.5 to 1.34 of the plan for submission set out the national context and the Council’s reasoning for extending the plan period to 2040.
Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long term requirements, for example major improvements in infrastructure. Paragraph 22 goes on to state that policies should be set within a vision which looks further ahead (at least 30 years), where larger scale developments form part of the strategy. The Council acknowledges within paragraph 1.5 that a longer timescale would have the advantage of giving certainty for a longer period. However, decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years, which has influenced the proposed Plan period of 2020-2040. We agree with the Council’s view and consider that the Plan period is appropriate in the circumstances, particularly given the context of the Arc Spatial Framework, which is discussed in further detail below.
Paragraphs 1.6 to 1.22 provide further background in terms of the Oxford – Cambridge Arc, and the Arc Spatial Framework, which is currently being prepared to provide a long-term strategic plan to help coordinate the infrastructure, environment and new developments in the area. The first consultation on the development of the Spatial Framework ran from the 12th of July 2021 and closed on the 12th of October 2021. The feedback from the consultation is currently being analysed. Within the July 2021 consultation document, it was advised that the development of the Spatial Framework would be supported by two further public consultations including one in Spring 2022 and Autumn 2022, however no further public consultation has taken place as of yet.
Within paragraphs 1.13 to 1.16, the Council acknowledges that the timetable for the production of the Arc Spatial Framework has changed over recent years and has been delayed for several reasons including the Covid 19 pandemic. In response to this, some local authorities within the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. In Bedford’s case however, this is not considered to be a viable option for the reasons relating to policies becoming “out-of-date”. As such, it is vital that the Council work alongside the Oxford-Cambridge Arc to ensure the BBLP 2040 and the Spatial Framework align as far as possible.
As the timescales for the preparation and submission of the BBLP 2040 do not allow the plan making process to follow the publication of the Spatial Framework, and given that progress with the Framework appears to be slow, we would encourage the Council to commit to a further early review to ensure that the Borough’s Local Plan remains aligned with the Spatial Framework and to be able to fully take advantage of and support the opportunities brought to the Borough by the Oxford-Cambridge Arc.
Paragraphs 1.23 to 1.28 provide further information in terms of the proposed East West Rail (EWR) and how the delivery of this national project has a bearing on the Plan and its success. It is being introduced in three stages, which are as follows:
• Stage One – Oxford to Bletchley / Milton Keynes
• Stage Two – will extend that service to Bedford
• Stage Three – will connect Oxford all the way to Cambridge
Paragraph 1.5 states that the track between Oxford and Bicester is already complete, and the next part from Bicester to Bletchley is underway. The section to Bedford involves refurbishing existing lines and is expected to follow on from Stage One. The last stage is advised to be more challenging because it involves the construction of a completely new stretch of track from Bedford north towards Sandy / St Neots and Cambourne, then on to Cambridge. No detailed route alignment has however been chosen. Paragraph 1.26 states that the full route is expected to be operational by 2030.
It is our understanding that plans for Stages 2 and 3 are still being developed, with no funding yet to be received for these stages1. Whilst it may be the case that this is quite common with a lot of infrastructure projects of this nature, it does suggest that there are still a large number of unknowns associated with the EWR.
Paragraph 1.29 refers to another significant infrastructure project as being the upgrade of the road route between the Black Cat Roundabout (A421 / A1 junction) and the Caxton Gibbet roundabout on the A428. Similarly, there are still some unknowns in this respect, with the Secretary of State still yet to issue a decision / grant a Development Consent Order2. The deadline for the Secretary of State to make a decision is the 18th of August 2022.
Based on the above, it is considered that significant infrastructure projects should not be over relied upon within the Plan in the event of any delays in delivery, funding etc., with some growth concentrated within areas that are already in sustainable locations, that are already well served by alternative transport links.

Support

Representation ID: 10525

Received: 26/07/2022

Respondent: Barton Willmore

Paragraphs 2.1 to 2.3 set out the vision and objectives of the Local Plan 2040. We agree with the vision and the four themes (‘Greener’, ‘More Accessible’, ‘More Prosperous’ and ‘Better Places’) that feed into the overall vision. In line with the vision and the four themes, the proposed development will provide a high-quality, inclusive and safe environment which promotes healthy living and values. A mixture of house types / tenures and the delivery of affordable dwellings will assist in providing appropriate amounts and types of housing, suitable to meet the needs of the Borough.

Comment

Representation ID: 10526

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS1 (Resource and Climate Change) provides a number of requirements for development, in order to support a move to carbon neutrality and (a) minimise carbon emissions (b) maximise carbon storage and sequestration and (c) mitigate and adapt to the impacts of climate change (d) respond to the economic and policy changes that are likely to accompany climate change (e) provide a Sustainability and Energy Statement demonstrating how mitigating and adapting to climate change has been considered.
The wording of the policy and the move towards carbon neutrality is supported by IM Land, who are committed to creating a sustainable future and have a proactive Environmental, Social Governance programme to deliver a range of benefits to communities. The proposed development at Rushden Road, Wymington will support Bedford Borough’s target for carbon neutrality and comply with draft policy DS1 by way of the following:
• In accordance with criteria A) i. and D) i. of the draft policy, key local amenities are located within walking distance of the Site, which will minimise the need to travel by private vehicle. There are bus stops on Rushden Road, approximately 400m from the Site, which provide services to Bedford and Kettering. Wellingborough railway station is approximately 6.2 miles away (a 16-minute drive or 34 minute cycle) and this offers regular services to Corby via Kettering and London St Pancras via Bedford and Luton airport;
With regards to A) iii. the proposals will retain and enhance the public rights of way on site for pedestrian and cycle usage. New routes are also proposed which will enhance the sustainable connections through the Site and provide improved accessibility to local facilities and the surrounding countryside;
• In terms of A) v. and vi., the homes at Rushden Road will be constructed to meet the full Future Homes Standard and will therefore produce 75% less carbon emissions than homes delivered under current regulations. This means homes will be heated and powered by renewable heat provided by a heat pump and use renewable electricity powered by roof mounted solar PV cells. Homes will also be designed to specify sustainable materials, considering the whole life cycle of materials to reduce the embodied carbon of development;
• In relation to B) ii. and C) ii. the proposed development will retain and enhance existing hedgerows and planting across the Site and along the Site boundaries;
• With regards to C) i. the development is located entirely within Flood Zone 1 and therefore has a low risk of flooding from the river or sea, making it suitable for development. Sustainable Drainage Systems will be used throughout the development to provide amenity and biodiversity improvements;
• In relation to C) iii. areas of formal and informal public open space are proposed. The existing allotments will also be retained and potentially expanded which promote social interaction;
• Criteria C) iv. refers to delivering an environmental net gain. The Site is presently arable land and of relatively low ecological value and therefore a 10% net gain on site is achievable;
• In accordance with C) v. new homes will achieve a water consumption rate of 110 l/p/d by incorporating water efficiency measures. All homes with gardens will be provided with water butts to capture rainwater for re-use.

Comment

Representation ID: 10527

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS2 (Spatial Strategy) sets out a spatial strategy for the local plan and the areas where new development will be directed. It states that development will be focused within the urban area of Bedford, and at specified strategic locations adjacent to the urban area and at growth locations within the A421 / East West Rail corridor. In seeking to meet the need over the Plan period for 27,100 homes, the spatial strategy depends on the delivery of significant development at Kempston Hardwick and a new settlement at Little Barford. Taken together, these locations are expected to deliver 7,200 homes over the final 10 years of the plan.
Whilst we do not object to the proposed allocations in principle, it is considered that the expected rates of delivery on the sites is too optimistic. In order to be considered ‘sound’ a realistic assessment of likely rates of delivery should be provided, in accordance with paragraph 73 (d) of the NPPF. If the housing trajectory was revised to be in line with available evidence on average annual build out rates for large schemes3, the Council will inevitably need to identify additional sites in order to ensure the housing needs of the Borough are met in full.
In identifying additional sites, it is considered that a greater proportion of housing should be directed to smaller sites in urban areas other than Bedford to secure more proportionate balanced growth, such as the Site at Rushden Road, which is located within the Bedford Borough but adjacent to the southern boundary of Rushden (located within North Northamptonshire Council). As demonstrated within the accompanying vision document, the Site is suitable, available and deliverable.
The North Northamptonshire Joint Core Strategy 2011-31 (adopted July 2016) recognises Rushden as a Growth Town (the highest tier of settlements) and defines its ‘spatial role’ as “to provide the focus for major co-ordinated regeneration and growth in employment, housing, retail and higher order facilities serving one or more districts”.
Furthermore, the East Northamptonshire Local Plan Part 2 was submitted to the Secretary of State for Housing, Communities and Local Government on the 29th of March 2021. The Hearing Sessions concluded on Thursday 5th of May 2022. Within the Part 2 Plan, Rushden is identified as a growth town, which will provide the majority of new housing and employment development during the plan period, through a new sustainable urban extension. This includes at least 2,500 dwellings and associated jobs and facilities. This is considered to demonstrate the suitability of Rushden as a location for new development. On this basis, we consider that the Site would align with the Plan’s vision for greener, more accessible, and more prosperous Borough.
Whilst it is acknowledged that ongoing or future infrastructure improvements e.g. Black Cat Junction improvements and the East West Rail section through the Borough are due to be completed later in the plan period, and this may inform the overall growth strategy and trajectory, there also needs to be consideration of smaller, sustainable sites (without extensive infrastructure requirements) that can come forward earlier in the plan period and take pressure off the delivery of a high number of sites and homes between 2030 and 2040 (especially those reliant on the delivery of infrastructure). The wording within the subtext to the policy which states that “the Council will monitor the provision and delivery of infrastructure and, if necessary, bring forward a review of the local plan” is supported.
Notwithstanding the above, the Viability Assessment that has been published as part of the Council’s evidence base to the BBLP40 highlights the challenges of achieving viability in complex urban areas such as Bedford, particularly where schemes may involve a degree of recycling existing buildings (paragraph 6.4). As such, the allocation of greenfield sites in other urban locations such as the Site at Rushden Road will ensure development comes forward in compliance with the Council’s policy requirements e.g. relating to affordable housing, whilst providing holistic / inclusive growth throughout the entire Borough.

Comment

Representation ID: 10528

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DS3 (Amount and Timing of Housing Growth) states that a provision of 27,100 new dwellings will be stepped as follows:
(extract table from DS3)
In order to support the policy, a stepped trajectory topic paper has been published as part of the Council’s evidence base, which seeks to illustrate why a stepped trajectory is justified. The paper states that the BBLP2040 requires a stepped trajectory as a result of the Standard method, which requires a 40% increase in the Borough’s housing delivery rate, when compared to the Local Plan 2030. The local plan strategy of an urban focus with rail-based growth is also set out as a factor, as it necessitates the delivery of large strategic sites with longer lead in times.
Whilst these factors are acknowledged, the principle of a stepped housing trajectory is not accepted. The Council should be ensuring that the housing needs are met at a consistent rate throughout the plan rather than deferring until later in the plan period, particularly when the resultant impact will be delivery later in the plan period of a scale which has not been achieved in the Borough in the recent past.
We agree that larger sites take significant lengths of time before development commences and optimum rates of housing delivery are achieved. The PPG provides further information on when a stepped housing requirement may be appropriate for plan-making (Paragraph: 021 Reference ID: 68-021-20190722). Whilst it acknowledges the reasons set out within the background paper, it states that stepped requirements will still need to ensure that planned housing requirements are met fully within the plan period, in order to avoid delays in meeting identified development needs.
Due to the uncertainties which surround the delivery of the major infrastructure on which the large strategic sites depend and given the viability challenges highlighted on some of the allocated ‘urban’ sites, the Local Plan should allocate sufficient smaller non-strategic sized sites in locations other than Bedford urban area to complement larger sites and to ensure HLS in the early to mid-term. In order for the strategy to be ‘sound’, the Council should consider sustainable sites (without extensive infrastructure requirements) that can come forward earlier in the plan period and take pressure off the delivery of a high number of sites and homes between 2030 and 2040 (especially those reliant on the delivery of infrastructure or a high level of enabling works that still have uncertainties and may be subject to delay). The Council recognises that meeting an increased minimum requirement of housing (compared to the adopted Local Plan 2030) will bring with it considerable challenges, and therefore must ensure that they also bring forward suitable and sustainable sites with less reliance on large scale infrastructure projects which are less likely to come froward within the timescale envisaged.