Bedford Borough Council – Local Plan 2035
Please use this form to respond to the questions raised in the Local Plan 2035 Consultation Paper. It should be read alongside the consultation paper and technical documents referred to; copies of the documents are available to view on the Council’s website at www.bedford.gov.uk/localplan2035 or in hardcopy at our Customer Service Centre (at 2 Horne Lane, Bedford MK40 1RA) and all libraries in the borough during normal opening hours. Documents are also available at Rushden, St Neots, Biggleswade and Flitwick libraries outside of the borough.
Please send your response electronically if possible or as a WORD document via email to firstname.lastname@example.org.
Alternatively responses can be sent by post. Please attach a stamp and send to:
Bedford Borough Council,
Local Plan 2035 consultation,
Planning Policy Team,
Bedford, MK42 9AP
PLEASE DO NOT SUBMIT COMMENTS IN MORE THAN ONE FORMAT OR SEND TO MORE THAN ONE EMAIL ADDRESS. If you have submitted comments electronically you do not need to print and post them.
All responses (electronic and paper) must be received by 5pm on Friday 9 June 2017.
Your contact information will be kept on the Planning Policy database so that we can keep you up to date about this and other planning policy documents. We do not share contact details with other parts of the Council or other organisations. If you do not want your details to be retained (which would mean no further updates from us about the Local Plan 2035) please let us know by sending an email to email@example.com.
All responses will be made public.
Name Alan Apling
Job title (if applicable) Chairman
Organisation (if applicable) Cardington Parish Council
Address 8 Yeomans gate, Cardington
Postcode MK44 3SF
Telephone Number 01234 838068
AGENT DETAILS (if applicable)
Name Michael Dewar
Job title (if applicable) Clerk
Organisation (if applicable) Cardington Parish Council
Address 3 The Green, Cardington
Postcode MK44 3TE
Telephone Number 01234 838547
If you are using an agent, who would you prefer any correspondence to go to?
(Please mark X one box only)
Your interest (Please mark X one box only)
Please specify ‘Other’
1a) Do you agree or disagree that one or more of the four new settlement proposals should form part of the development strategy? (Please mark X one box only)
1b) If you disagree, the 2,200 dwellings identified for new settlement(s) as part of the preferred strategy will need to be provided elsewhere: where should the development go instead? (Please write in)
See our response to Question 11), in which we both query the assessment of need for over 8000 houses, over and above the 11000 already permitted or allocated, and argue for additional independent assessments of the number of additional houses that could be sustainably supplied with transport infrastructure, water supply, and waste and surface water treatment facilities. We cannot accept that there is an unquestionable need for these 2200 dwellings, either in one or more new settlements or distributed elsewhere around the borough.
2a) Do you agree or disagree that the brownfield site opportunity at Stewartby brickworks should form part of the preferred development strategy? (Please mark X one box only)
2b) If not, the 1,000 dwellings proposed at Stewartby Brickworks as part of the preferred strategy will need to be provided elsewhere: where should the development go instead? (Please write in)
3a) Do you agree or disagree with the principle that all suitable and available sites in and on the edge of the urban area should be allocated? Currently this amounts to 1,988 dwellings. (Please mark X one box only)
3b) If you think that not all of this should be allocated for development where should the development go instead? (Please write in)
4a) Do you agree or disagree with the proposed allocation of urban and edge of urban sites listed in table 1 and table 3? (Please mark X one box only)
4b) Are there any sites which you think should not be allocated or any other sites which you think should be allocated and why? (Please write in)
5a) Do you agree or disagree with the amount of development identified for the Group 1 villages as part of the preferred development strategy (2,600 dwellings)? (Please mark X one box only)
5b) If not, should the amount be higher or lower, what should the number be and how should the strategy change as a result? (Please write in)
6a) Do you agree or disagree with the list of potential development sites in each Group 1 village (tables 4 – 8)? (Please mark X one box only)
6b) Which sites in Group 1 villages would you prefer to see allocated and why? Which of the options do you prefer and why? Are there other combinations of sites? (Please write in)
7a) Do you agree or disagree with the amount of development identified for the Group 2 villages as part of the preferred development strategy (225 dwellings)? (Please mark X one box only)
7b) If not, should the amount be higher or lower, what should the number be and how should the strategy change as a result? (Please write in)
8a) Do you agree or disagree with the shortlist of sites for each Group 2 village (tables 9 – 14)? (Please mark X one box only)
8b) If not, which sites should be included or excluded from the list? Which sites do you think should be allocated in each village to meet the strategy requirement? (Please write in)
9a) Do you agree or disagree with the approach for Group 3 and Group 4 settlements in the preferred development strategy (that rather than having specific sites allocated in the local plan there should be a local plan policy to allow small amounts of development if supported by the local community)? (Please mark X one box only)
9b) If not, how should Group 3 and Group 4 settlements be treated in the development strategy? Do you have any comments on the wording of the draft policy for Group 3 and Group 4 settlements? (Please write in)
We fully support the draft policy for Groups 3 and 4 settlements. In particular we feel it is helpful to very small communities, like Cardington, where there are insufficient local resources to undertake the preparation of a Neighbourhood Plan but where there remains the possibility for individual small, community-lead developments to come forward.
10a) Do you agree or disagree with the selection of Local Green Spaces? (Please mark X one box only)
10b) If not, and given the site assessment work that has already taken place, which sites do you think should be removed from or added to the list? (Please write in)
We are disappointed that none of the Local Green Spaces proposed for Cardington has been selected. We continue to maintain that all of them contribute to the rural village character of Cardington by presenting to residents and visitors aspects and views both close and distant of the rural and agricultural surroundings at 9 sites spread throughout the village. However, the approach for Groups 3 and 4 settlements in the preferred development strategy would mean that the future of their Green Spaces will be solely in the hands of the local community. We will not therefore challenge the non-selection of our Green Space proposals in this consultation but we reserve the right to do so in future should the approach for Groups 3 and 4 settlements change in later versions of the Local Plan 2035.
11) Do you have any comments on any of the updated or new evidence base? (Please write in)
- Challenge the Strategic Housing Market Assessment. The remaining requirement of 8103 homes is inflated and is likely to be more like 4000 or even less. Needs reviewing
- Concerned about the missing elements of the evidence base; sustainability levels of traffic and water resources.
1.We have challenged the assessments of housing need in the 2 consultations to date, as evidenced by our last response to the Local Plan 2032 as follows;
“We repeat first our response to question 8 of the Issues and Options Paper Consultation, 2014;
The growth models that are the basis for the range are all derived from linear extrapolations of trends from previous years. To be in any way realistic, predictions of future housing growth should incorporate elements of futures modelling that include anticipating possible reductions in the rate of growth within the period to 2032 and the inevitable stabilisation of demand, possibly by or even before 2032. In the absence of such a thorough and peer-reviewed analysis of future housing growth we could only support 650 dwellings completed per year as the maximum of any range to be considered.
The Report, “Objectively Assessed Need for Bedford”, [Local Plan 2032] is not in our opinion the thorough analysis that we considered necessary and neither has it been peer-reviewed. Much of the demand for housing identified seems to come from outside the Borough and no account seems to have been taken of the sustainability of a large increase in the proportion of the population commuting to outside the Borough in terms of transport, health, education and social services, resources, in particular water supplies, and the impact on the environment through sewage treatment, surface water drainage and water abstraction.”
We have the same concerns about the Bedford Strategic Housing Market Assessment Update 2016. It has not been peer-reviewed. If it had there would certainly have been criticism of the complete lack of an estimate of uncertainty in the estimates both from the consideration of alternative assessment methodologies as well as the inevitable uncertainty inherent in any future projection. The projected need to build 19000 homes by 2035 should be assessed for uncertainty both in terms of its validity as a central estimate and of the range of uncertainty about the central estimate. The potential consequences are massive. A revision of the central estimate of demand by only -10% would almost eliminate the need for any new settlement in Bedford Borough.
2. We are concerned that in up-dating the evidence base for Local Plan 2035 the sustainability of the projected number of additional homes has once again been ignored. No evidence-based assessments have been advanced either in the consultation paper itself or in the accompanying documents to show how;
- the increased demand for water will be supplied.
- the impact of increased water abstraction, sewage treatment. and surface water drainage can be sustainably managed.
- the increased demand for private and public transport infrastructure can be sustainably supplied.
- the additional social infrastructure, including health, education and social services will be established.
Without such independent studies being carried out, the Local Plan cannot be assumed to be sustainable.
12) Specifically in relation to the new settlement proposals, do you have any comments on our initial appraisal of the sites that have been put forward, set out in the study “New Settlements Assessment Framework Methodology and Initial Site Assessment”? Having read the initial appraisal do you have a preference for which settlement(s) the Council should investigate further with a view to allocation? (Please write in)
See our response to Question 11). The need for new settlements depends on the assessment of the need for new homes. A peer-review of the Strategic Housing Market Assessment Update 2016 and/or a reduction in the housing numbers resulting from assessments of social and environmental sustainability may eliminate that need. We look forward to these additions to the supporting evidence base in the published draft Local Plan expected in early 2018.