Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10516

Received: 29/07/2022

Respondent: St Neots Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

The strategy of developing Little Barford as a location for potential Bedford Borough Council
housing fails three of the four tests under NPPF paragraph 182 Tests of Soundness.
SNTC feels that the inclusion of policy HOU19 within the current proposed Bedfordshire
Borough Council Local Plan fails:
the "justified test" ( the plan should be the most appropriate strategy, when
considered against the reasonable alternatives )
● option 2a is a viable alternative ( without the associated impact relating to
Little Barford )
the "effective test" ( the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities )
● limited if any cross boundary joint working in relation to the risks to St Neots
ranging from flood risk to demands on an already stretched infrastructure.
the consistent with national policy test ( the plan should enable the delivery of
sustainable development in accordance with the policies in the framework )
● fails to meet NPPF chapters:
○ ( section 13 ) protecting green belt land
○ ( section 14 ) meeting the challenge of climate change and flooding
○ ( section 15 ) conserving and enhancing the natural environment
○ ( section 16 ) conserving and enhancing the historic environment
The majority of SNTC's concerns remain as vocalised within the earlier St Neots Town
Council response document ( September 2021 ) and the related queries remain
unanswered.

During the earlier stages of the development of this plan, St Neots Town Council requested
cross boundary cooperation with Bedford Borough Council to ensure that proposals that
directly or indirectly affected the town were adequately investigated to mitigate or minimise
the impacts felt on the town and the residents.
St Neots Town Council is concerned that this Local Plan preempts the OxCamArc
consultations, and goes against this spirit of "region-wide planning". SNTC are disappointed
that no attempt has been made by Bedford Borough Council to engage with St Neots Town
Council during the consultation phase for the 2040 plan.
“To realise the full opportunities – and overcome the challenges – will require coordination
of planning functions across the region. Local councils cannot do this on their own because
of the level of coordination needed across the area, and because they do not have all the
levers needed to develop a genuinely integrated plan. Government needs to play a supporting
role to bring together a strategic approach at the Arc level to support better planning and
ultimately better outcomes for the economy, environment and communities.”
The proposed new settlement of Little Barford makes reference to the proposed upgrade of
the Caxton Gibbet to the Black Cat section of the A428 in isolation along with the proposed
East West Rail again in isolation. Nowhere are these entities combined to understand how
the area and therefore the proposed development would be impacted. If you then exclude
areas of the site at risk to flooding the site becomes less attractive.
There still remain too many unknowns relating to HOU19, the majority of these have been
left to be written and or developed after the consultation process and therefore too late in our
opinion ( see comments within policy wording in later section: NPPF Paragraph 182 ).
NPPF PARAGRAPH 182
The NPPF states that the local plan will be tested by the Planning Inspectorate as follows:
"NPPF paragraph 182 Tests of Soundness
The Local Plan will be examined by an independent inspector whose role is to assess
whether the plan has been prepared in accordance with the Duty to Cooperate, legal and
procedural requirements, and whether it is sound. A local planning authority should submit a
plan for examination which it considers is “sound”, namely that it is:
• Positively prepared – the plan should be prepared based on a strategy which seeks to
meet objectively assessed development and infrastructure requirements, including unmet
requirements from neighbouring authorities where it is reasonable to do so and consistent
with achieving sustainable development;
• Justified – the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint
working on cross-boundary strategic priorities; and
• Consistent with national policy – the plan should enable the delivery of sustainable
development in accordance with the policies in the Framework."
SNTC feels that the inclusion of policy HOU19 within the current proposed Bedfordshire
Borough Council Local Plan fails:
the "justified test" ( the plan should be the most appropriate strategy, when
considered against the reasonable alternatives )
● option 2a is a viable alternative ( without the associated impact relating to
Little Barford )
the "effective test" ( the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities )
● limited if any cross boundary joint working in relation to the risks to St Neots
ranging from flood risk to demands on an already stretched infrastructure.
the consistent with national policy test ( the plan should enable the delivery of
sustainable development in accordance with the policies in the framework )
● fails to meet NPPF chapters:
○ ( section 13 ) protecting green belt land
○ ( section 14 ) meeting the challenge of climate change and flooding
○ ( section 15 ) conserving and enhancing the natural environment
○ ( section 16 ) conserving and enhancing the historic environment
The majority of SNTC's concerns remain as vocalised within the earlier St Neots Town
Council response document ( September 2021 ) and the related queries remain
unanswered.

Little Barford ( extracted from proposed local plan )
4.92
Land at Little Barford is allocated as a new settlement, contributing to the delivery of the
Bedford Local Plan’s spatial growth strategy. The development of Little Barford will make a
key contribution towards the additional homes required to be delivered across the borough
by 2040, delivering at least 4,000 new homes overall, of which an estimated 3,800 will be
within the current plan period.
SNTC: described as a 'key contribution' but is this 'justified' ( NPPF paragraph 182 ) due to
the remote location in relation to Bedfordshire Borough Council as a whole. Option 2a of the
earlier consultation documents contains similar numbers of housing but delivered in a more
logical form.
St Neots is already straining under the demands of historical growth ( the town has grown
significantly since the post war period ). It is currently undergoing expansion to the East of
the town ( well outside the influence of the River Great Ouse ) a core strategy within
Huntingdon District Council's local Plan. Development of the green field site at Little Barford
would see additional strain put on St Neots and the infrastructure.
4.93
The new settlement is located to the north east of Bedford, close to the neighbouring town of
St Neots. The East Coast Main Line railway line runs north to south through the site and the
proposed A428 Black Cat to Caxton Gibbet relief road runs through the site providing an
opportunity for a strategic road junction. In addition, EWR will be crossing in the vicinity,
possibly through the site, and will include a station offering the opportunity of a highly
sustainable site accessible by rail and the strategic road network. In addition to the allocation
site there is further land within the same ownership which is identified as a contingency area,
should land be required to facilitate the EWR route and / or station within the site. The
allocation site and contingency land are illustrated by the plan below.
SNTC: EWR route and planning is not confirmed and therefore policy HOU19 is somewhat
premature.
4.94
The proximity of the site to the existing Little Barford employment area to the north offers the
opportunity to locate new employment development by way of extension and / or in other
areas of the site to benefit the local economy and provide further employment opportunities.
SNTC: Little Barford employment area to the north of the proposed development is
landlocked by the river to the west, the county border to the east and St Neots to the north.
Therefore new employment development is not possible due to these constraints.
4.95 The site has unique locational strengths and qualities which, if properly realised and guided
by appropriate design principles, will enable it to be an exemplar for low carbon living and
innovation.
SNTC: Part of the unique locational strengths stem from the fact that this is good quality
farming land, sat adjacent to the Great River Ouse and on the flood plain of the same. There
are a number of historical assets within the proposed development and the area is used as a
local 'recreational asset'.
4.96
The potential to designate a conservation area at Little Barford is being investigated by the
Local Planning Authority.
SNTC: Surely this should have been investigated and confirmed prior to submission of the
local plan.
Policy HOU19 Little Barford New Settlement
As identified on the Key Diagram and Policies Map, land at Little Barford is allocated as a
new settlement to create a landscape led beautiful, healthy and sociable community located
in close proximity to the proposal for a new station on the East West Rail line delivering at
least 4,000 new homes and in the region of four hectares employment. It will provide all the
key services and facilities to address its own needs, including health, education, retail,
culture and community components, and will foster a strong local community based
approach to the ownership and long-term stewardship of assets.
SNTC: Zoning of good quality farming land as potential employment ( i.e. extending the
existing employment zone situated between the railway lines to the east and river to the west
) does not sit comfortably with the proposed ethos of "a landscape led beautiful, healthy and
sociable community".
The new settlement will have a distinct identity based on a landscape led approach which
values and enhances the natural environment and responds directly to its context. The
settlement will be developed to a high design quality achieved through a process of master
planning and design coding and will incorporate a range of homes, employment, an
integrated and multi-purpose green infrastructure network lending context and character to
walking neighbourhoods which will enable residents to meet the majority of their day to day
needs locally and achieve access to the new East West Rail station by active travel modes.
A strategic masterplan and design code is to be prepared by the Council in conjunction with
the landowners, stakeholders and local community and adopted as a Supplementary
Planning Document.
This document will need to be produced ahead of the submission of any planning application
and will demonstrate how the new settlement will deliver the policy principles below and will
include:
● A Natural Capital impact assessment and biodiversity study with appropriate
mitigation and enhancements;
● A Green Infrastructure strategy;
A transport and movement strategy including infrastructure needs and the
relationship to East West Rail;
● A phasing strategy to ensure that infrastructure investment is provided in
tandem with or ahead of the development it supports;
SNTC: what infrastructure investment is being proposed
● An infrastructure delivery plan setting out the timing, funding, and provision of
green, social, and physical infrastructure, including schools, community
facilities and local centres in tandem with housing development;
● Character assessment and master planning;
● Design coding;
● A strategy for sustainable long-term governance and arrangements for the
stewardship of community assets;
● A detailed assessment of the mineral resource within the Mineral
Safeguarding Area to examine quantity, quality and feasibility of extraction;
● A site specific flood risk assessment including identifying opportunities to
reduce surface water run-off and flood risk on and off site;
SNTC: the site is located on the flood plain of the Great River Ouse. Bedfordshire
catchment drains into the Cambridgeshire catchment of the Great River Ouse at St
Neots just to the north of this site. It is not acceptable that a flood risk assessment
would be restricted to the red line of the site but rather should include the potential to
increasing the existing risk of fluvial flooding to St Neots.
● A detailed heritage impact assessment.
SNTC: see 4.96 above
In order to ensure that the new settlement is brought forward in a high quality, strategic and
comprehensive manner, planning permission will only be granted following the adoption of
the strategic masterplan and design code. Development must demonstrate how it has been
holistically planned to accord with the objectives of the Local plan and the specific principles
below:
GREENER
i. The provision of high quality planning, design and place-making, and management
of built and public realm so that the Little Barford new settlement is characterised as
a distinctive place that capitalises on local assets and establishes environments that
promote health, and wellbeing;
ii. The provision of a multifunctional green infrastructure which: retains, enhances,
connects, and increases accessibility to the green infrastructure network including
the River Great Ouse and on site woodland areas; provides well-integrated green
space (formal, natural and allotments); and provides environmental net gains;
SNTC: the existing area is high quality countryside with existing access and rights of way.
The proposals do not retain and enhance these
iii. As part of the green infrastructure network, cycle and pedestrian links to facilitate
active travel within the neighbourhoods and surrounding areas iv. Integration of Sustainable Drainage Systems into the network of open spaces, to
mitigate potential flood risk, and measures to ensure resilience to climate change
including measures to ensure the efficient use of energy and water in accordance
with Policy 93;
SNTC: flood risk cannot be looked at in isolation as a site risk, but required to be integrated
with the broader area.
v. The Council will consider whether any areas of the Little Barford settlement merit
designation as a Conservation Area. In the event of its designation, development
must preserve and where opportunities arise, enhance its special interest.
vi. The protection and / or enhancement of heritage and biodiversity assets within
and surrounding the site, to include:
● Any new development should contribute positively to local character
and distinctiveness and enhance or better reveal the significance of
any designated heritage assets affected,
● Pre-determination archaeological evaluation in all areas which will
potentially be impacted by development and where the nature and
significance of the archaeological resource does not necessitate
preservation in situ,
● Development should also seek to sympathetically reuse built heritage
and retain those non-designated heritage assets of archaeological
interest in situ, including above ground settlement and associated
earthworks, which make a positive contribution to the appearance,
understanding, appreciation and interpretation of the historic
settlement,
● Submission of a biodiversity report with appropriate mitigation and
enhancements.
SNTC: development of this site would be detrimental to both heritage and
biodiversity within the site.
PLACEMAKING
vii. Place making based on a landscape led approach to creating a vibrant place
which is sensitive to local character and creates distinctive neighbourhoods;
viii. The provision of a range of house types and tenures in accordance with the most
up to date assessment of housing need, including affordable housing in accordance
with required levels as set out in Policy DM1(S) to meet the needs of the wider
community including the ageing population;
ix. The provision of a mix of beautifully and imaginatively designed homes at a range
of densities reflecting the context and character of different parts of the site, in
particular lower densities in accordance with the historic character of the western
side of the site and higher densities in areas with higher accessibility to the East
West Rail station and local centres;
x. The provision for a wide range of construction opportunities, offering prospects for
a variety of house builders and developers including small and medium sized enterprises and including the provision of serviced plots for self-build and custom
homebuilding in accordance with Policy DM5;
xi. The provision of serviced sites for secondary and primary schools including early
years facilitates at the heart of the local neighbourhoods to serve the new
development, (2 x 5.5ha 4FE primary and 1 x 10.1ha 8FE secondary schools);
Due to the lack of capacity in existing schools, additional capacity will be required to
be open prior to the occupation of the first dwelling. Financial contribution towards
secondary school provision;
xii. The provision of pitches for Gypsy and Travellers and plots for travelling show
people where need is identified in a Gypsy and Traveller Accommodation
Assessment;
xiii. The provision of leisure and sports facilities at accessible locations in line with
current standards to serve the settlement;
xiv. The provision of multi-functional community space and healthcare facilities within
local centres at the heart of walkable vibrant sociable neighbourhoods;
xv. The fostering of healthy living through access to green space as a key driver of
the settlement design and opportunities for local food production;
xvi. The establishment at an early stage in the development of the new settlement of
appropriate and sustainable long-term governance and stewardship arrangements
for community assets including green space, public realm areas and community and
other relevant facilities. Such arrangements are to be funded by the development and
include community representation to ensure residents have a stake in the long-term
development, stewardship and management of their community;
xvii. Layout and design of the new settlement should incorporate appropriate
mitigation measures in relation to high pressure gas pipelines, overhead power lines
and noise sources including railway lines.
ACCESSIBLE
xviii. In accordance with the transport and movement strategy, the provision of a
balanced package of measures to encourage smarter transport choices to meet the
needs of the new development including the integration of technology to deliver ‘ondemand’
travel information and measures to reduce the number of single occupancy
car trips;
xix. Measures should maximise the opportunities for active travel through the
provision of a network of footpaths, cycle ways and bridleways to enhance
permeability within the site and to the adjoining area and will include:
● connections between communities across the East Coast Main Line at
a minimum of two locations,
● new footway and cycle routes including the integration of National
Cycle Network (NCN) route 12 through the site
● links to the East West Rail station including the provision of a
dedicated shuttle bus service from the site,
● measures to facilitate access by bus services across the site,
provision of charging points for electric vehicles,
● car clubs and mobility hubs,
● appropriate measures to facilitate autonomous vehicles,
SNTC: no details of integration into the existing infrastructure of St Neots nor
the issues relating to the existing A428 running west east to the north of the
site, potentially limiting integration with existing routes.
xx. A programme of measures to facilitate accessibility and minimise and mitigate the
traffic impacts on the local and strategic road network to include:
● widening of Barford Road and any necessary new junctions,
● widening of the existing footway and conversion to a cycle / pedestrian
route on Barford Road up to the A428 roundabout,
● provision of a multi-user route alongside River Great Ouse and
potential to cross the river,
● 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.
SNTC: major transport improvements are still in planning stages and are yet
to be confirmed, again it seems premature to be implementing a local plan
policy for Little Barford prior to understanding the impact of these on the
potential development.
PROSPEROUS
xxi. The delivery of new neighbourhoods that are sociable, vibrant, and walkable (20
minutes) neighbourhoods with equality of access for all. The new settlement will
provide a range of community services and facilities including health, education,
retail, culture, community meeting spaces, multifunctional open space and sports and
leisure facilities;
xxii. Approximately 3.6 ha of industrial and warehousing employment land, to be
located adjacent to and act as an expansion of the existing Little Barford employment
area;
SNTC: clause xxii. is in direct conflict with earlier statements of "a landscape led beautiful,
healthy and sociable community"
xxiii. Installation of super-fast broadband for all businesses and community facilities
and also for all dwellings to support home working, at the outset of each phase of
development.

See attachment - a map is included followed by a copy of the representation made to the draft plan.