Bedford Borough Local Plan 2040 Plan for Submission

Without prejudice to the emerging development strategy, O&H have concerns that the Introductory section (summarised in paragraph 1.34) is over reliant on external influences which, at present, are uncertain.

It is understood that the requirement for the early review is to reflect emerging national policies for the Oxford-Cambridge Arc. However, progress on the Spatial Framework has not kept to the published timetable and the suggestion now is that growth targets and the vision should be locally led. At the time to writing, it is not known what shape this will take. This does not alter the fact that growth in the Arc is supported by Government and it is a sustainable and sensible location for growth, as portrayed in the Economic Prospectus. Further, this area is under significant housing pressure and the review of the Local Plan is necessary even in the absence of top-down housing figures from Government.

The concern is that underpinning the Local Plan on the Ox-Cam Spatial Framework potentially undermines what is an otherwise sustainable growth strategy in an area of housing pressure.

A similar point could be made about the shape of the town and country planning system. At the time of writing, it is not known how the system might change in the future and this is particularly difficult to predict given current Government priorities.

O&H believe that the locally derived evidence underpinning the emerging Local Plan is robust and that the Introduction should explain that this forms the justification for the development strategy.

The Local Plan is definitive about what will happen as part of the East West Rail project and that this “has a bearing on this plan and its success”. O&H are generally supportive of the East West Rail scheme and agree that it will bring economic and sustainability benefits along the route. However, at the time of writing, there is no certainty about what the shape of the proposals will be along the Bletchley to Bedford section.

East West Rail Co. are behind their originally published programme and there is currently no certainty over when they will move to their statutory consultation. There are also unhelpful statements coming from the current Secretary of State for Transport about the future of the project.

The success of the development strategy and the whole Local Plan cannot hinge on whether the current Government enables this piece of regional infrastructure. The whole Oxford – Cambridge rail route should be delivered in the future, and hopefully by 2030, but the project is currently not progressing as planned and the evidence base for the Local Plan could be weakened if the Council continue to determine its success by projects that are out of its control.

The Local Plan cannot pre-judge what the rail improvements might be. However, the South of Bedford already benefits from the Marston Vale Line, which is due to be improved by virtue of the improvements permitted through the 2020 Transport and Works Act Order. This baseline position provides excellent opportunities for sustainable growth, which are a rare opportunity that should not be overlooked.

O&H support the South of Bedford Policy Area but there is currently no firm proposal for a Stewartby Hardwick station. O&H are generally supportive of the East West Rail scheme and agree that it will bring economic and sustainability benefits along the route. However, at the time of writing, there is no certainty about what the shape of the proposals will be along the Bletchley to Bedford section.

Sustainable, rail based growth is a real possibility in the area to the south west of Bedford even without the enhancements being talked about by East West Rail Co. The development strategy should continue to focus on this area but recognise the potential that already exists along the Marston Vale Line.

It is acknowledged that there is not currently a firm proposal for Wixams station but the planning application has been officially scoped and a planning application is anticipated later this year.

Further, the wording of the criterion is not clear as it refers to “community building”. O&H assumes that at this policy level the Council are referring to the creation of a new community rather than a physical community building.

The Council’s own Local Housing Needs Assessment demonstrates that housing pressure on the Borough is going to increase by 40% as we move towards 2040. These figures are locally derived and do not factor in any additional growth that may come forward through the Ox-Cam Spatial Framework.

This is important because the Council describe the remit for the Local Plan review as stemming from potential changes within the Arc. However, the evidence shows that change is needed locally irrespective of what happens in the wider region.

The context for the Local Plan should reflect this locally derived housing position as well as the Borough’s role in delivering housing for the Borough and the wider community.

O&H wish to make two points on the section relating to stepped growth, the principle of which is broadly supported.

Firstly, the Council are advancing the position that their development strategy is dependent on the completion of East West Rail improvements. It is assumed, given the cut-off date of 2030, that they are referring to the anticipated improvements that should soon be moving to a statutory consultation process in advance of submitting a Development Consent Order application. However, the improvements planned by virtue of the Transport and Works Act Order 2020 could be delivered in advance of / instead of the next round of improvements and will also impact on in-migration and housing demand.

It should not be assumed that the south of Bedford becomes an unsustainable location if the East West Rail proposals from Bletchley to Oxford fail to materialise as currently anticipated. Paragraph 4.28 is supported as it provides flexibility in relation to a review of the Local Plan.

Secondly, it should be acknowledged that growth post 2030 would need to be planned from the mid 2020s onwards. Work on the proposed Supplementary Planning Document should feature early in the Local Development Scheme and be in place by 2025/26 to allow for the preparation of outline planning applications well in advance of the 2030 date. If required, evidence can be provided on the lead-in times for strategic outline planning applications and their start dates.

O&H support the South of Bedford Policy Area but there is currently no firm proposal for a Stewartby Hardwick station. O&H are generally supportive of the East West Rail scheme and agree that it will bring economic and sustainability benefits along the route. However, at the time of writing, there is no certainty about what the shape of the proposals will be along the Bletchley to Bedford section.

Sustainable, rail based growth is a real possibility in the area to the south west of Bedford even without the enhancements being talked about by East West Rail Co. The development strategy should continue to focus on this area but recognise the potential that already exists along the Marston Vale Line.

The land at Kempston Hardwick is held under more than one ownership. The arrangements for funding joint work should be split proportionately and it would be helpful for this to be established at the Local Plan stage. O&H are willing to fund the production of a Supplementary Planning Document on the understanding that costs are split fairly with other landowners and promoters. The production of the SPD should aim to stick to an agreed programme to enable subsequent outline planning applications to be properly resourced and programmed.

O&H are supportive of the principles that underpin the future South of Bedford Framework. They are currently advancing an outline planning application for 5,000 homes at Marston Valley in Central Bedfordshire (planning ref: 18/01969/OUT) and have pursued a landscape-led approach to the development proposals. The Kempston Hardwick New Settlement would advance the placemaking strategy that O&H have begun in the south of the Marston Vale and this is wholly supported.

Indeed, the main text of Policy HOU14 does not contain any requirements that O&H wish to object to.

The query about soundness relates to the reliance on emerging East West Rail proposals and the certainty around a Stewartby Hardwick station. This point has been made elsewhere but are repeated here for clarity.

There is currently no firm proposal for a Stewartby Hardwick station. O&H are generally supportive of the East West Rail scheme and agree that it will bring economic and sustainability benefits along the route. However, at the time of writing, there is no certainty about what the shape of the proposals will be along the Bletchley to Bedford section.

Sustainable, rail based growth is a real possibility in the area to the south west of Bedford even without the enhancements being talked about by East West Rail Co. The development strategy should continue to focus on this area but recognise the potential that already exists along the Marston Vale Line.

It is acknowledged that there is not currently a firm proposal for Wixams station but the planning application has been officially scoped and a planning application is anticipated later this year.

O&H are the promoters of Wixam Park, the planned southern expansion land of Wixams new settlement and have an outline planning application lodged with Central Bedfordshire Council (planning ref: 21/00148/OUT). This application benefits from an approved master plan document which guides the principle of development. One of the key aspects is the provision of a deep landscape buffer along the eastern edge to preserve views from villages to the west.

The Bedford Borough Council proposal for Land South of Wixams touches the edge of Wixam Park on the western corner. The landscape and visual impact of residential development at Land South of Wixams has not yet been considered, indeed, page 194 of the Sustainability Appraisal Appendices acknowledges that the impact of the proposal on landscape and the sense of place in settlements is unknown with the appraisers reporting that, “It is uncertain how the proposal will affect this objective”.

Consideration should be given to the impact of this allocation on the local landscape as well as the functional relationship with planned development in Central Bedfordshire Council. Wixams is a cross-boundary new settlement and it should be shown in its entirety on Figure 8. This small change would allow all parties to assess the impact of further growth at Wixams.

As currently drafted, Policy DM8 is unclear, overly restrictive and will be difficult to interpret and apply.

The criteria of the draft policy use the term ‘existing employment areas’ as the reference point for determining the acceptability of future development proposals, but this is an undefined term and does not pertain to a fixed boundary. Is an ‘existing employment area’ the hard edge of a current employment site, or a cluster of business that have grown organically over time?

With reference to a specific case, O&H Strategic Land own a small, 3 acre, greenfield site in the countryside. It is not a viable proposition for an agricultural unit and demands an alternative use. It is contained by a former landfill site, a builders yard and a car breakers yard. With good highway access it could contribute towards the Borough’s demand for low technology industrial growth. However, it is unclear whether this cluster constitutes an ‘existing employment area’ and therefore whether Policy DM8 allows such a logical site to be brought forward for development.