Initial Comment:
This is a Group response and should not be taken as the complete response of any individual councillor, each of whom may have particular concerns in relation to their particular wards.
A weakness of the 2030 Plan, which we articulated at the time, was that it did not, as confirmed by the Inspector, adequately take account of future needs. That was perhaps inevitable given the uncertainty around the impact of the Oxford- Cambridge Arc and the impossibility of assessing how it will affect any given local authority within its area. That uncertainty remains and the Group regards it as absurd that the Borough is required to submit its plans for development up to 2040 without knowing what will be proposed in the Government’s Spatial Framework for the Arc; that is expected in early 2023, almost exactly when the Borough’s 2040 Plan must be submitted for approval.
The Group will support any attempts to persuade the Government that more time needs to be allowed so that the Spatial Framework can be taken into account in the preparation of this plan. Not to do so creates a clear risk that the areas identified for growth in the Local Plan will differ from those similarly identified in the Spatial Framework. It is not joined up government.
We are disappointed that the full range of options set out in the Development Strategy Topic Paper has effectively been excluded from full consideration both by the absence of any open debate in Council about strategy and by the restricted list of options set out in the Summary Paper sent out to residents. For most that will be the only document they see and for it to include only four options is not open government.
There is an added difficulty for those rural residents in locations named in the various options; for example the various “transport corridors”. The fact of possible inclusion offers no clue as to what the impact might be in practice given the areas covered by the locations and the numbers of villages they contain.
INTRODUCTION
1.6 -1.13 :
As stated above the extent to which, if at all, the Arc will affect Bedford’s housing requirements and in particular the number and their location, is wholly unknown and will remain so until after the Local Plan is finalised. If, as is highlighted in para. 1.8, it is the Government’s intention to “… develop a long-term Spatial Framework …that will support better spatial planning…better targeted public investment….and allow communities to shape the long-term future of places..” the insistence on Bedford going ahead as required before the release of the Spatial Framework is plainly absurd.
1.46 – 1.51:
The continued commitment to neighbourhood planning is welcomed but the potential for growth that suits the locality and which does not strain the local infrastructure needs more fully to be explored without forcing smaller communities to undertake the lengthy and resource intensive formalities entailed in preparing neighbourhood plans. We remain of the view that the potential for small scale developments is greater than assumed in this draft 2040 plan and should be more fully taken into account. It is our experience that rural communities understand the need for natural growth which, if properly accounted for, lessens the need for large and inappropriate developments in the larger villages. We refer to this further below.
VISION AND OBJECTIVES
2.1 :
We broadly support the vision as set out although believe that it is too town oriented and is contradicted much of what is included elsewhere. For example, as we will point out later, the several references to sustainability are not consistent with the continued emphasis on rural growth. As the Sustainability Appraisal clearly shows that the most sustainable strategy is that of urban development yet this, as with the 2030 Plan provides only a small part of the total in the options put before residents.
GROWTH AND SPATIAL STRATEGY OPTIONS
3.1- 3.7 :
We recognise that the Council has no choice but to follow the revised national standard method of assessment which requires 12,500 new dwellings in the plan period over and above the existing provisions of the 2030 plan which are for 13,000 dwellings. However, we are aware that the standard method is challenged and under scrutiny. Furthermore, as pointed out in the Housing Needs Assessment, the increase is largely due to the anticipated inward migration arising from the Oxford-Cambridge project. This is further evidence of the need to defer the preparation of the plan as the determinants of where that inward migration might go are not within the control of the Council.
We are a densely populated county and the fact that our imposed target for future housing growth greatly exceeds that of neighbouring authorities emphasises the need for this issue to be publicly aired.
3.10 – 3.17:
As we have noted above, we are concerned that only 4 options have been put to residents and that each of those 4 has only 1500 dwellings proposed for the urban area. This approach necessitates, once again, an unacceptable impact on the rural area which we regard not only as lazy planning but irresponsible planning. As previously pointed out the Council’s own sustainability appraisal clearly states that urban growth is the most sustainable on virtually all criteria and village related growth the worst. The Council has declared a Climate Change emergency and there is a position statement on Climate Change at para 8.2 et seq, yet it is disappointing to note how little that has influenced this draft plan; it is a lost opportunity
We believe that properly planned urban development, inevitably entailing some expansion, albeit retaining green spaces between communities, and including areas of enhanced density housing, is not only the most sustainable, as confirmed by the Sustainability Appraisal, but more closely meets the needs of the main growth sectors as noted in the Local Housing Needs Assessment. Accordingly we believe that a variant of Option 1b, the variation to include some expansion and some rural growth is strongly to be preferred.
For those reasons we are strongly of the view that the listed 4 preferred development options fail to live up to the aspirations set out in the Council’s own Visions and Objectives referred to above.
Apart from the inadequacy of the urban growth element our objections to the various options are :
- They all entail excessive loss of agricultural land, particularly grades 1 &2.
- The so-called corridors are tenuous concepts that may seem coherent on a map but embrace differing villages of various sizes with little or no linking infrastructure capable of supporting significant growth.
- They all will increase reliance on non-sustainable modes of travel for all purposes.
- They all entail a further erosion of the open countryside which is one of Bedford’s most valuable assets.
We are strongly of the view that Options 3b, 3c, 4, 6 & 7 should be dismissed. The “key service centres” are already being changed beyond recognition and the strain on their immediate and surrounding infrastructure cannot sensibly be added to within the time span of this plan. In each case the loss of agricultural land that would follow the further expansion of these settlement areas and the dependence on unsustainable travel for all purposes plainly breaches all relevant sustainability criteria.
TRANSPORT STRATEGY
3.18-3.25:
We have no issue with the EEH strategy as set out at para.3.22. We do however question its relevance in dealing with the localised problems and pressures that already exist and which will be worsened by the majority of options now being put forward. Adults will still have to get to work, children to school, families to leisure and socialise and each of the options listed, other than 1a and 1b, will increase the pressure on transport networks.
HOUSING DEVELOPMENT ON SMALL SITES
3.26 – 3.28:
We believe that this section is a missed opportunity. While there is a good correlation between windfall and an adequate small sites delivery there is no good reason not to increase the target for small sites for the reasons set out in para 3.26. It would fit with the clear support in many villages for organic growth to meet local needs. We believe not merely that there should be a greater emphasis on small sites as defined but there should be positive encouragement for smaller sites that while exceeding one hectare still meet the criteria in para 3.26.
TOWN CENTRE & RETAIL POLICIES
General Comments
In our response of September 2019 to the previous local plan we described Bedford Town Centre as having an incredible offering including the magnificent Embankment and many brilliant independent retailers. This response updates our recommendations.
The decline, though painful, is a major regeneration opportunity to reshape Bedford Town Centre, making it a vibrant and successful town centre for generations to come. The government is supporting the town with welcome significant funding but we question whether the Town Centre Plan is currently strong enough.
RECENT CHANGES
5.1-5.6:
Footfall has continued to fall remorsely, out of town retailing pressure is undiminished, the Covid pandemic along with the sharp growth in internet retailing and home delivery has seen the closure of the towns three department stores, the loss of significant of multiple retailers through bankruptcy or retrenchment, some independent traders losses and the closure of the towns sole major supermarket pending. We have to recognise that for the foreseeable future Bedford Town Centre cannot and should not compete for big shops/ multiple retailers.
This creates a once in a lifetime opportunity to renew and repurpose the Town Centre to meet the evolving needs and wishes of Borough residents. If we get regeneration right there will be far more residents living in the town centre area, in converted offices and upper floors of empty retail units, as well as new build on old railway land and brownfield sites. While the amount of retail space needed will be less in the short term this planned population growth will ensure the future vitality of what will remain and attractive and unique town centre.
We would support the Council investing in appropriate units as they become available which would provide greater scope to implement the finalised Town Centre Plan.
TOWN CENTRE
5.7-5.29:
There should be a special conservation area for the town centre and an appraisal should take place to see which buildings positively contribute and which should ideally be replaced. This is important for establishing the built character visually signalling what kind of town centre it should be.
The town centre should be welcoming and have something for everyone, ensuring a variety of attractions for all age groups including a proper children’s play area. Currently there are inadequate facilities for families, but a play area would go a long way towards providing a family friendly environment.
We should deliver and promote a Clean, Safe, Secure town centre with free wifi availability.
Kempston is an undervalued and previously underinvested district centre. In addition to the proposals set out in the draft the Saxon Centre should be recognised as the heart of the community. New investment is required to encourage the sense of Kempston as a separate community with its own identity.
New Local centres where new residential development takes place these should be of sufficient size with a variety of offerings including, for example, a pharmacy to discourage unnecessary journeys. The aim must always be to ensure that, wherever possible both new and existing developments constitute “15-Minute Communities” with as many facilities and services as possible being within convenient walking or cycling distance.
Midland Road. A Special Area
There needs to be dialogue with residents, community groups and stakeholders to assess opportunities to improve the living environment in and around Midland Road and explore potential development. We acknowledge it has developed its own unique lifestyle, feel, character, with a great deal of shopping and leisure occurring in the evening. The business district of Midland Road between River Street and Prebend Street should be considered a Local Centre and developed separately from the Town Centre.
Parking
Given its importance to town centre viability, as emphasised by BID and almost all surveys of users, we are surprised by the almost absence of any reference to parking in this plan. We believe an accessibility survey is needed and the whole experience from car park to town centre and into shops should be reviewed to support those who have any mobility issues including, but not limited to, the elderly, wheelchair users and those with pushchairs / prams.
One of the town’s multi-storey car parks could support local retailers by becoming a collection hub for local purchases made on the internet. The internet pick-up point would encourage internet shoppers into town and support the very limited click and collect kerbside spaces.
Free car parking is a proven tool for retaining customers in declining town centres and providing two hours free every weekday, three hours Saturdays in the MSCPs with continuing free Sunday parking would provide a huge and continuing boost for businesses.
Where possible, parking bays should be widened to bring them to modern standards and there needs to be an assessment as to whether more parking will be required going forward.
More electric car charging points in the MSCPs will bring charging and shopping together giving the town an edge bringing visitors to use the town’s businesses while their cars batteries recharge.
Tourism and Leisure
Tourism and Leisure should play a larger role in regenerating Bedford and supporting surrounding villages. Bedford’s Borough’s hotels are the ideal base for longer tourism stays allowing exploration of attractions both inside and outside of the Borough.
Harpur Square should be the focus for events taking place in the town centre and the location for additional pop-up crafts and food stalls.
The Market and its offering, its look and feel are a key to the Town Centre success, uniqueness and vibrancy. Consideration should be given to adding a number of temporary individual wooden lockable pop up shed shops which handmade craft artists can rent during Christmas/Easter/ summer periods to coincide with planned town events.
EMPLOYMENT
6.28:
The recent proliferation of warehousing units, in particular in villages around the A421, such as Wootton and Wixams, suggests too great a reliance on this sector for economic development activity. While recognising that the switch from town centre to online retail requires additional warehousing capacity the Borough is failing to recognise the negatives for communities while gaining financial rewards for itself.
The over dependence on warehousing does not benefit local residents. Apart from the noise and safety issues of an endless train of HGV’s driving past their homes there is little or no local employment benefit. For example local residents were told that Innovation Park provide local jobs; it hasn’t; apart from being mainly poorly paid warehouse floor jobs the great majority of employees/agency workers do not come from the locality. This is not sustainable development and the reliance on road freight is at odds with the Borough’s stated climate change goals.
Accordingly we welcome the apparent change of emphasis as set out in Para 6.8. There needs to be much greater diversity with regard to economic development; too great a reliance on warehousing poses risks to the economic well-being of the Borough.
DEVELOPMENT MANAGEMENT POLICIES
7.14-7.29
We recognise that the Borough is governed by national policies and standards, and by the limitations of Planning Law. Within those constraints we would argue for enhanced standards of common facilities on new developments (we note and welcome para8.36 regarding the proposed Playing Pitch Strategy), greater attention to post development requirements such as maintenance and handover. We also wish to see more attention paid to site layout of the larger estates in particular the location and facilities allocated to the affordable homes. We believe that too often they are disadvantaged within the larger estates.
CONSERVATIVE GROUP: SEPTEMBER 2021
