Bedford Borough Council – Local Plan Review Issues & Options Consultation Paper Response Form Cardington Parish Council Response

Bedford Borough Council – Local Plan Review

Issues & Options Consultation  Paper Response Form

CONTACT DETAILS

 Personal details

 Title                                       Dr

 Name                                     Alan Apling

 Job title (if applicable)          Chairman

 Organisation (if applicable) Cardington Parish Council

Address                                 8 Yeomans Gate, Cardington, Bedford

 Postcode                                MK44 3SF

 Telephone Number               01234838068

 Email                                     vchapplin@gmail.com

                       

AGENT DETAILS (if applicable)

 Title                                        Mr

 Name                                      Michael Dewar

 Job title (if applicable)          Clerk

 Organisation (if applicable) Cardington Parish Council

 Address                                 3 The Green, Cardington, Bedford

 Postcode                                MK44 3TE

 Telephone Number               01234838547

 Email                                      cardingtonpc@gmail.com

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 Parish Council

  Q1   Do you agree with the proposed scope of the local plan review? If you think that other areas of existing policy should be updated or new policy areas added to the list, please explain what they are and your reasons for wanting them to be included in the plan.

We do NOT agree with the proposed scope of the Local Plan Review. It lacks any commitment to develop policies designed to ensure that the new development allocated will be sustainable in terms of natural resources, natural capital, agriculture and food production and climate change.

To address our concerns, we would want to see the scope of the revision revised along the following lines;

Retain the first bullet point,

  • Develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements

Add bullet points as follows,

  • Include new policies to ensure that the totality of new allocated development, when fully completed, would be sustainable in terms of natural resources, in particular water supply and treatment of waste and surface water, would maintain, and if possible improve, the level of natural capital, and would maintain, and if possible improve, the agricultural and food production assets of the borough.
  • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change.
  • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change.

Omit bullet point 4,

  • Consider the need for additional policies to address climate change

  Q2   Do you have any comments on the draft vision?  If you think that it can be improved, please tell us how.

 We broadly welcome the aspirations of the Draft Vision for the future of the borough, (with one major omission which we deal with below) but the Vision has no practical significance if it is not explicitly connected to the policies to be developed in the revised Local Plan. This could be put right by expanding the heading as follows;

By the end of the plan period, and by the application of the new policies developed within it:

The borough will have become etc. etc..

  1. The omission which concerns us is the future health of the Great Ouse and the health of the entire water courses and groundwater system within the borough. Increasing water demand, pollution from waste and surface water run off and the increasing effect of weather extremes pose serious threats to the health of the Great Ouse and its tributaries and to agriculture, natural ecosystems and the built environment through extremes of high and low flows and the reliability of groundwater levels. If the Vision is to be credible as a comprehensive view of the borough then it must include explicit reference to the natural water system linked to plan policies designed to protect it from the impacts of new allocated development.

 Q3  In line with Government policy, the shortest plan period would be 2020 to 2040. Do you agree with this plan period? If you think the plan period should be longer, what plan end-date would you suggest and why? 

 No comment

 Q4  Having considered the potential locations for growth illustrated above, and the pros and cons in Table 1, which one(s) if any do you support? It may be that the local plan strategy will need to combine elements from more than one of the locations to achieve the scale of growth required. Can you suggest other locations?   

The cursory analysis in Table 1 of the pros and cons of the potential locations for growth does not provide a sufficient basis for choosing a preferred option. First, the analysis as it stands is inconsistent. One example is the con comment for the Red option, “New settlement based growth”, that “There could be an adverse impact on local landscapes, loss of agricultural land and countryside”. This exact comment could equally apply to the Grey, Orange, Pink and Yellow options.

More fundamentally however is the need to subject all location strategies to an analysis of how they could achieve the objectives of new policies along the lines of those we propose in answer to Question 1, namely;

  • Include new policies to ensure that the totality of new allocated development, when fully completed, would be sustainable in terms of natural resources, in particular water supply and treatment of waste and surface water, would maintain, and if possible improve, the level of natural capital, and would maintain, and if possible improve, the agricultural and food production assets of the borough.
  • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change.
  • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change.
 

No comment

 

 

 

 

Q5  Infrastructure needs building in from the start to ensure new development is suitably accessible and supported. What infrastructure do you consider is key to the delivery of growth in Bedford borough?

 We cannot comment on priorities for infrastructure as they will depend on the final location strategy.

However, we are concerned that the infrastructure necessary to provide sustainably for the water demand of additional development, and for the sustainable management of waste and surface water, has not been included in previous Local Plans. This issue becomes increasingly important with every increment in proposed growth in the borough and with the need to take into account the increasing climate change impacts on rainfall patterns in this already water stressed region.

 Q6  More employment sites will need to be allocated alongside housing growth. Where do you think new employment sites can be located in Bedford borough?

 No comment

  Q7  Connectivity to other economic centres, including Oxford and Cambridge, will improve with East-West Rail. How do we capture the benefits of this greater connectivity to these economic centres, to improve and increase the value of the economy of Bedford?  

 No comment

 Q8  Do you have any further views to add to those listed in the Town Centre Plan (see Consultation Responses above)?

 No.

  Q9   Do you agree that the Council should produce further guidance for developers on how to respond to climate change? If so, what should be included in it?  

The analysis needed to formulate the proposed new policies on climate change, (See Q1) namely –

  • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change.
  • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change.

will necessarily involve identifying the construction techniques and standards that developers will have to apply in planning applications. Any further guidance need only be to provide detail to the policy requirements.

Q10  The Government is developing new house-building standards to be implemented through building regulations. Is there any local evidence or need to go beyond national standards?

       

 

 

 

 

 

If there is it will emerge during the analysis needed to formulate the proposed new policies.

 

Q11  What do you think would encourage people in Bedford borough to make greater use of sustainable modes of transport?

 No comment

  Q12 If you think that our existing planning policies to protect and enhance the natural environment fail to cover important national or local issues, please give details.

 We refer you to Cardington Parish Council’s response to planning application 20/00901 where we cite 7 existing planning policies that we believe the application contravenes. This is in addition to planning permission already having been given to the site area extending into the Rural Area, contrary to existing planning policy.

 Q13 Is there anything else that is addressed in the new Government guidance that is not adequately covered by existing policies? 

 No comment

  If you have any other comments to make please add them below.

  If you would like to put forward a potential development site (Call for Sites) for consideration please visit the website www.bedford.gov.uk/localplanreview for further information and advice.