Planning Policy Committee – 19 February 2018

Agenda Item 6

Emerging Local Plans – engagement with neighbouring local planning authorities

Purpose of report The Local Plans for Huntingdonshire, Peterborough and Bedford are all at an advanced (pre- submission) stage of preparation. This report notes the Council’s previous engagement with Huntingdonshire District Council, Peterborough City Council and Bedford Borough Council in preparing their respective Local Plans. It also highlights any significant implications of these Local Plans for East Northamptonshire Council. Attachments Appendix 1: Previous officer response to 2017 Consultation Draft Huntingdonshire Local Plan to 2036 Appendix 2: Previous (2016/17) officer response to draft Peterborough Local Plan (to 2036) Appendix 3: Previous (2017) officer response to draft Bedford Local Plan 2035 Appendix 4: Draft consultation response(s) to pre-submission draft Bedford Local Plan

1.0 Background

1.1 The replacement Local Plans for Huntingdonshire District, Peterborough City and Bedford Borough have all reached the pre-submission consultation stage. This is the final (statutory) stage in preparing these Local Plans, prior to submission of each to the Secretary of State for examination.

1.2 These consultations are undertaken in accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012 (Regulations 19-20). The closing dates for responding to the Local Plan consultations are as follows:

 Huntingdonshire Local Plan – 5 February 2018;  Peterborough Local Plan – 20 February 2018; and  Bedford Local Plan – 5 March 2018.

1.3 Under the statutory Duty to Cooperate (introduced as a revision to the 2004 Planning and Compulsory Purchase Act under the 2011 Localism Act), the Council is required to actively engage with neighbouring local planning authorities at all key stages of Local Plan preparation. To this end, officers have responded to previous consultations for the Huntingdonshire, Peterborough and Bedford Local Plans.

1.4 This report seeks to inform Members of the officer responses to the Huntingdonshire and Peterborough Local Plans. It also seeks Member approval for the Council’s response to the Bedford Local Plan 2035.

2.0 Huntingdonshire Local Plan to 2036 consultation response

2.1 On 9 January 2018, officers responded to the Proposed Submission consultation for the Huntingdonshire Local Plan. The Proposed (pre-submission) consultation relates to the ‘Tests of Soundness’, against which the Local Plan will be examined. These are that the plan:

 has been ‘positively prepared’;  is ‘justified’; 1  is ‘effective’; and  is ‘consistent with national policy’

2.2 The officer response, submitted on 9 January 2018, stated that:

“Regarding the Tests of Soundness, we have no objections to the Proposed Submission Plan. As a neighbouring local authority, in order to ensure compliance with the Duty to Cooperate, our previous comments describe those issues that could have implications for East Northamptonshire. To reiterate, we note that there are no significant development proposals to the west of the A1/ East Coast Mainline corridor.”

2.3 The Council’s response to the previous (preliminary) draft Local Plan consultation was submitted on 22 August 2017 (Appendix 1). This highlighted the following considerations for the Huntingdonshire Local Plan:

 It was noted that construction work for the A14 realignment was due to commence imminently  Nene Valley (Elton) – Correctly identified as a green infrastructure corridor, in accordance with the Nature Improvement Area (NIA) designation;  All of the villages near to the ENC boundary are designated small settlements and it was noted that no significant growth is proposed to the west of the A1 (Great North Road)/ East Coast Mainline railway corridor;  Cross boundary connections (services and facilities); e.g. Covington/ Hargrave, Thurning/ Winwick, Great Gidding/ Luddington in the Brook, Elton/ Nassington/ Warmington, Stibbington/ Wansford/ Yarwell;  No site specific policies/ proposals for RAF Molesworth (previously mooted during earlier consultations).

2.4 Officers have previously expressed support for the Huntingdonshire Local Plan. To reiterate, it is not considered that the plan policies and proposals would have any significant implications for East Northamptonshire.

3.0 Peterborough Local Plan consultation response

3.1 Peterborough City Council launched the Proposed Submission consultation for the Local Plan on 8 January 2018. This was accompanied by a request to also seek our views under the Duty to Cooperate requirements (section 33A of the Planning Compulsory Purchase Act (as amended by the 2011 Localism Act)).

3.2 Officers have previously responded to earlier draft versions of the Local Plan. A response was submitted in February 2016 (Appendix 2). This was followed by a supplementary response in February 2017, which reiterated earlier comments. Previous representations highlighted the following cross-boundary issues:

 Wittering Airfield;  Wansford;  Green infrastructure (e.g. Nene Valley NIA);  Objectively assessed need (OAN) for housing – no proposals to seek delivery of Peterborough OAN within East Northamptonshire.

3.3 The officer response, submitted in respect of the pre-submission on 10 January 2018, stated in full:

“As you acknowledge, we have submitted feedback in response to your earlier consultations, with reference to the Duty to Cooperate and Objectively Assessed Need (OAN) for housing. We recognise that it is important to ensure that Peterborough City and East Northamptonshire Councils cooperate and work collaboratively to ensure strategic priorities are properly coordinated in our respective Local Plans in order to meet the requirements of the Duty to Cooperate:

 24 February 2016 – with reference to OAN, we concluded that: “It is noted that Peterborough City Council feel they have met their OAN and have no intention to seek or offload any of their own need. This is fully supported by East Northamptonshire Council who, themselves are not intending to offload or seek any addition need from its own area”. Overall, we were satisfied that there is nothing in the draft Peterborough Local Plan that would require any joint plan preparation.  On 7 February 2017 we submitted further comments in response to the subsequent draft Local Plan consultation, reiterating our previous comments but also stating that: “Particular reference is made to the importance of the Nene Valley for ecosystem services. The Nene Valley Nature Improvement Area (NIA), covering the river valley between Wansford and Peterborough, remains an important mechanism to deliver ecosystem services and its importance should be highlighted through the Peterborough Local Plan”.

Once again, on behalf of East Northamptonshire Council I would reiterate that we are entirely content that the Peterborough Local Plan does not seek us to make provision for any of the OAN for housing from the Peterborough Housing Market Area (HMA) within the District. Similarly, we are not seeking through our Local Plan Part 1 (North Northamptonshire Joint Core Strategy 2011-2031, adopted July 2016) to request that the Peterborough Local Plan should seek to accommodate any of the OAN for East Northamptonshire or the wider North Northamptonshire HMA.

Finally, I have reviewed your Statement of Compliance with the Duty to Cooperate Jan 2018 (CD14) and note that a verbatim version of our previous consultation response has been included within the document at Appendix 3/ p35”.

3.4 Overall, Peterborough City Council’s approach to preparing the Local Plan is supported. It is not considered that the plan policies and proposals would have any significant implications for East Northamptonshire.

4.0 Bedford Local Plan 2035 – background to proposed spatial strategy and previous consultations

4.1 Bedford Borough Council launched the Regulation 19/20 consultation for the Local Plan on 22 January, with a view to submitting the plan for examination to the Planning Inspectorate by the end of March 2018. The proposed Bedford Local Plan spatial strategy has potentially significant implications for East Northamptonshire, and represents a fundamental change from that of the previous (2008) Core Strategy in that the Borough are now seeking to provide future growth through new settlements.

4.2 Between April and June 2017 Bedford Borough consulted on the draft Local Plan spatial strategy, outlining where future growth might be located, along with a series of site options to accommodate that growth. The Plan proposed four potential sites for one or more new settlements within the Borough, three of which would be accessed via the A6 corridor. The sites were:  Lee Farm Sharnbrook (Colworth Garden Village) – A6 corridor,  Thurleigh Airfield – A6 corridor;  Land at Twinwoods – A6 corridor and  Wyboston Garden Village – A1 corridor, near to St Neots.

4.3 The previous officer response, to the draft spatial strategy (June 2017), noted that any of the three potential sites along the A6 corridor could have implications for the District (Appendix 3). Bedford Borough Council has now proposed that the Sharnbrook site (Colworth Garden Village) is the preferred site, to include 4,500 dwellings (2,500 by 2035) and associated infrastructure.

3 5.0 Bedford Local Plan 2035 – draft response to pre-submission draft Local Plan

5.1 Officers have reviewed the Bedford Borough Local Plan 2035 – Draft Submission Plan, which raises a number of issues which this Council would request Bedford Borough Council to take into consideration in producing its Local Plan. In addition, objection is raised in respect of the adequacy of traffic modelling undertaken to support the delivery of the proposed new settlement identified as Colworth Garden Village.

5.2 Whilst detailed representation is attached to this report (Appendix 4 refers), in summary it is advised that the decision to promote the development of Colworth Garden Village (west of Sharnbrook) could give rise to potentially significant impacts within East Northamptonshire, particularly in relation to the A6 running through the southern part of the District.

5.3 It is acknowledged that Duty to Co-operate meetings have been held with this Council and Bedford Borough Council, which have included Northamptonshire County Council, and the principle of the approach to meeting future development requirements within Bedford Borough is not objected to.

5.4 However, in respect of the transport modelling undertaken to date, this Council is concerned that there are apparent inadequacies in the approach taken, which can be summarised as follows:  The model on which the published outputs are based does not extend into Northamptonshire and therefore does not accurately reflect trips north on the A6  The implications of not factoring in this work are exaggerated by the future delivery of the Rushden East Sustainable Urban Extension to the east of Rushden (which includes 2,500 new homes and employment provision) which in turn could affect trips south along the A6  Trip levels indicated in the modelling appear low, especially in the p.m. period  The modelling work does not have appeared to have included the trips generated by the additional 7.25 ha employment provision at Colworth Garden Village  Northamptonshire County Council has raised concerns over the potential impact of these issues and has (through the Duty to Co-operate meetings) agreed to examine assumptions further.

5.5 It may be possible to address these concerns by updating the model, including undertaking additional data collection. However, without this information the outcomes and potential mitigation measures remain unclear. Therefore, until this position is resolved, this Council raises objection.

5.6 In addition to the above, the following issues are raised as concerns:

 Colworth was only chosen as the preferred location for the Garden Village at the Pre-Submission stage;  The Colworth Garden Village proposal (Policy 27) should also be supported by more robust evidence in relation to, green infrastructure and local connectivity, in particular opportunities exist to link into green infrastructure planned for Rushden East (such as the Greenway) the potential for cross boundary public transport provision (including links between Rushden East, Rushden Lakes and the future Parkway rail station which forms part of the Colworth Garden Village proposal)  Clarification is necessary, regarding the status of the Garden Village within the Spatial strategy (settlement hierarchy) and town centres hierarchy;  Clarification is necessary regarding current progress and the status of the proposed Colworth/ Sharnbrook Parkway Station as a specific strategic transport infrastructure project supporting the delivery of the Colworth Garden

4 Village Proposal.

5.7 The pre-submission draft consultation requires the Council’s representations to be made with reference to the Tests of Soundness (paragraph 2.1, above). The draft response to the Plan has been prepared using Bedford Borough Council’s Local Plan 2035 template. Members are asked to consider the content of the response while recognising the parameters of the current Local Plan consultation; i.e. the Tests of Soundness.

6.0 Equality and Diversity Implications

6.1 There are no equality and diversity implications arising from the proposals.

7.0 Legal Implications

7.1 There are no legal implications arising from the proposals. The Council has engaged with neighbouring local authorities at previous stages of their Local Plan preparation in order to comply with the statutory Duty to Cooperate.

8.0 Risk Management

8.1 There are no significant risks associated with the draft Huntingdonshire and Peterborough Local Plans.

8.2 There are potential risks associated with the Colworth Garden Village proposals in the Bedford Borough Local Plan 2035 – Draft Plan for Submission, as these stand. The draft representations set out officers’ concerns with the Draft Plan for Submission, as well as recommended changes to the Plan that could help to overcome these concerns.

9.0 Resource and Financial Implications

9.1 There are no resource and financial implications arising from this report.

10.0 Constitutional Implications

10.1 There are no constitutional implications arising from this report.

11.0 Customer Service Implications

11.1 There are no customer service implications arising from this report.

12.0 Corporate Outcomes

12.1 The relevant Corporate Outcomes are:

 Good Quality of Life – sustainable development, strong communities and high quality built environment  Effective Partnership Working – effective joint working with neighbouring local planning authorities, in accordance with the Duty to Cooperate

13.0 Recommendation

13.1 The Committee is recommended to:

(1) Note the officer response regarding the Proposed Submission Huntingdonshire Local Plan to 2036 (paragraph 2.2, above)

(2) Note the officer response regarding the Proposed Submission Peterborough Local Plan (paragraph 3.3, above) 5

(3) Raise objection to the pre-submission draft Bedford Local Plan 2035 (Appendix 4), in respect of the adequacy of transport modelling undertaken to date in support of the promotion of the new settlement proposal at Colworth Garden Village.

(Reason – To allow Members to consider the wider Local Plan context beyond the District, and to agree the Council’s formal response to the pre-submission draft Bedford Local Plan 2035)

Power: Planning and Compulsory Purchase Act 2004 Legal Localism Act 2011 Other considerations: N/a Background Papers: North Northamptonshire Joint Core Strategy 2011-2031 (adopted July 2016) Proposed Submission Huntingdonshire Local Plan to 2036 Proposed Submission Peterborough Local Plan (to 2036) Bedford Local Plan 2035 – Draft Plan for Submission Person Originating Report: Richard Palmer, Planning Policy and Conservation Manager  01832 742142  [email protected] Michael Burton, Principal Planning Policy Officer  01832 742221  [email protected] Date: 13 February 2018 CFO MO CX

6 Appendix 1: Previous officer response to 2017 Consultation Draft Huntingdonshire Local Plan to 2036

Dear Sir/ Madam

I write with reference to the Consultation Draft Huntingdonshire Local Plan to 2036. My colleagues and I have reviewed the document and, in line with the “Duty to Cooperate”, have prepared an officer response. This should be read in conjunction with representations or comments that we have submitted at earlier stages of the Local Plan preparation process.

It is noted that the Local Plan proposes no significant growth to the west of the north- south A1 (Great North Road)/ East Coast Mainline railway corridor. The major strategic development sites at Alconbury Weald and St Neots East are also noted. The following observations are made regarding the draft Plan:

 It is noted that the Plan recognises that construction work for the A14 realignment (Huntingdon/ Brampton/ Godmanchester southern bypass) is due to commence imminently.  The Nene Valley at Elton is correctly identified as a green infrastructure corridor, in accordance with the Nature Improvement Area (NIA) designation. This, together with the Grafham Water, the Great Fen and Great Ouse valley, are recognised as priority locations for delivering ecosystem services.  All of the villages within Huntingdonshire that are near to the ENC boundary are designated small settlements; although the following villages are noted as being in proximity, or having close functional connections: o Covington/ Hargrave o Thurning/ Winwick o Great Gidding/ Luddington in the Brook o Elton/ Nassington/ Warmington o Stibbington/ Wansford/ Yarwell

 It is noted that there are no site specific policies or proposals for RAF Molesworth if/ when this is vacated, although these were previously mooted during earlier Local Plan consultations.

It is reiterated that we have been engaged with Huntingdonshire District Council throughout the Local Plan preparation process. It is also recognised that the major development proposal at Alconbury is a longstanding commitment, and no strategic developments are proposed to the west of the A1 (Great North Road). The designation of the Nene Valley as a green infrastructure corridor at the northern boundary of the District is also noted. At a local level, recognition should be given to functional connections between villages on Huntingdonshire’s western boundary.

Overall we have been engaged with Huntingdonshire District Council throughout the Local Plan preparation process. In this regard, we are satisfied that the District Council is complying with the statutory Duty to Cooperate.

Yours sincerely

Mike Burton Principal Planning Policy Officer East Northamptonshire Council

It should be noted that this is an officer response, sent on behalf of East Northamptonshire Council. There has been no Member involvement in the preparation of these comments.

Appendix 2: Previous (2016/17) officer response to draft Peterborough Local Plan (to 2036)

Cedar Drive THRAPSTON Northamptonshire NN14 4LZ Telephone 01832 742010 Email: [email protected] www.east-northamptonshire.gov.uk

Peterborough Local Plan Consultation Sustainable Growth Strategy Peterborough City Council Town Hall Bridge Street Peterborough PE1 1HF [Representation submitted by email to [email protected]

Please ask for Tel Our Ref. Your Ref. Date: EN/PLP/ 24 February 2016

Dear Sir/Madam

I write with reference to your Local Plan consultation. I have studied the consultation document and do not have any specific comments on policies within the plan. As such, my comments are on general themes of the consultation document.

Duty to Cooperate As a neighbouring Local Authority, it is important to ensure that Peterborough City and East Northamptonshire Councils cooperative and work collaboratively to ensure strategic priorities are properly coordinated in our respective local plans in order to meet the requirements of the Duty to Cooperate.

Recently, at the closing examination session for the North Northamptonshire Joint Core Strategy (JCS) 2011-2031 (27 November 2015), the Inspector confirmed that the JCS (Local Plan Part 1) had fulfilled the Duty to Cooperate. It is important to achieve a similarly positive outcome for the Peterborough Local Plan. This response is intended to assist Peterborough City Council in complying with the Duty to Cooperate requirements and will assess whether there are any cross border strategic matters.

Cross Boundary Connections The two Local Authority areas are separated partly by field boundaries to the North and partly by the Wansford Road to the South of the adjoining boundary.

Wittering Wittering Airfield is a shared facility with the two authorities but under Peterborough City jurisdiction. It is noted that there are no parishes looking at producing a neighbourhood plan in the West of the Peterborough Authority area. If any parishes were to look at preparing a Neighbourhood Plan, it would be good practice to open dialogue adjoining parishes in East Northamptonshire to establish any similar ideas or concerns.

Wansford

Council for the District of East Northamptonshire The village of Wansford lies within three Local Authority areas (East Northamptonshire, Huntingdonshire and Peterborough). Wansford is important as it performs a local service function, e.g. the Doctors Surgery is situated within East Northamptonshire District (Yarwell Parish). Therefore, it is important that the new Local Plan for Peterborough recognises the role of Wansford in providing local services and facilities for the area to the South of Stamford.

Green Infrastructure It is also important to ensure effective collaborative working between key partners of shared green infrastructure such as County Wildlife Sites, and National Nature reserves. The recent Nene Valley Nature Improvement Area (NIA) project should also be referred to as a shared land management corridor.

Objectively Assessed Need (OAN) It is noted that Peterborough City Council feel they have met their OAN and have no intention to seek or offload any of their own need. This is fully supported by East Northamptonshire Council who, themselves are not intending to offload or seek any addition need from its own area.

It is noted that there are no new allocations within this version of the plan and these will be reviewed in a future version. East Northamptonshire would seek to be consulted on any sites that will affect it.

Summary East Northamptonshire Council is satisfied that there is nothing in this plan that would require any joint plan preparation.

East Northamptonshire Council is keen to remain as a consultee for any further revisions/consultations. Please could the address of planningpolicy@east- northamptonshire.gov.uk be added to the consultee list if it has not already been done so.

I hope that these comments are helpful and we look forward to future progression of the Local Plan.

Yours faithfully,

Ed Norris Planning Policy Officer

Council for the District of East Northamptonshire Planning for the Future Reference: BBC606673 Local Plan 2035 "Planning for the Future" Consultation

Please use this online 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; these can be found on the Council’s website www.bedford.gov.uk/localplan2035.

Once completed and submitted, a copy of the form will be sent for your records, to the email address you provided.

All responses must be received by 5 pm on Friday 9th June 2017 . This form and any information it contains may be published on the Council’s website and attributed to source (this may include your name and a reference number).

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 protected].

If you would like to attach any accompanying documents, please do so at the end of the form. Contact Details

Title: Name: Job Title (if applicable): Principal Planning Policy Officer Organisation (if applicable): East Northamptonshire Council Address:

Postcode: Telephone No: Email Address: Do you have an Agent? No Your interest (Please select one box only) Other Please specify 'Other': Neighbouring local planning authority 1a) Do you agree or disagree that one or more of the four Agree new settlement proposals should form part of the development strategy? 1b) If you disagree, the 2,200 dwellings identified for new In accordance with the Duty to Cooperate, East settlement(s) as part of the preferred strategy will need Northamptonshire Council responded to the previous to be provided elsewhere: where should the development Bedford Local Plan consultations, since its launch go instead? (2014). We note that the Local Plan proposes a new spatial strategy that is fundamentally different to the BedfordKempston focused strategy in the current (2008) Core Strategy.

We note that the proposed replacement spatial strategy involves delivering over 50% of the current housing requirement at one or two entirely new settlements:

Three potential sites in the vicinity of Sharnbrook and the A6 Bedford/ Rushden/ Kettering corridor; One site at Wyboston, in the vicinity of St Neots and the A1 Great North corridor.

In the case of the three potential A6/ Sharnbrook sites (Lee Farm, Thurleigh and Twinwoods), the transport/ infrastructure modelling should take account of significant development commitments along the A6 corridor; notably the Rushden East (2500 dwellings; 1450 by 2031), Irthlingborough West, Wellingborough East (Stanton Cross) and Kettering East urban extensions. It is therefore important that the proposed fundamental changes to the current spatial strategy could be justified at examination, taking account of all of these major developments within the North Northamptonshire area.

We note that, of the three sites along the A6, the Lee Farm site would in practice represent an extension to the established village of Sharnbrook (designated a rural service centre in the current Local Plan/ Core Strategy); such that Sharnbrook would effectively become part of a new town, situated mid way between Bedford and Rushden. Concerns have been expressed by some Rushden (Avenue Road/ Bedford Road area; south east of the main urban area) residents, including:

Potential impacts of the proposed Lee Farm development for the A6, and services and facilities at Sharnbrook; Impacts of the Lee Farm and (to a lesser extent Thurleigh and/ or Twinwoods proposals), in conjunction with the other proposals for a further 600 dwellings at Sharnbrook; Loss of high value countryside around Sharnbrook and Souldrop.

In accordance with the Duty to cooperate, we, as a neighbouring local authority, need to pass on any local concerns that have been expressed. Given the radical change of direction to the spatial development strategy that is being proposed for the new Local Plan, it is also important to ensure that the Sustainability Appraisal is extremely robust, in terms of objectively measuring the relative merits of all reasonable alternatives. While we do not object to the revised spatial strategy in principle, we emphasise the importance of being able to justify this change at the submission/ examination stage. 2a) Do you agree or disagree that the brownfield site Nothing selected opportunity at Stewartby brickworks should form part of the preferred development strategy? 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? 3a) Do you agree or disagree with the principle that all Nothing selected suitable and available sites in and on the edge of the urban area should be allocated? Currently this amounts to 1988 dwellings. 3b) If you think that not all of this should be allocated for development where should the development go instead? 4a) Do you agree or disagree with the proposed allocation Nothing selected of urban and edge of urban sites listed in table 1 and table 3? 4b) Are there any sites which you think should not be allocated or any other sites which you think should be allocated and why? 5a) Do you agree or disagree with the amount of Nothing selected development identified for the Group 1 villages as part of the preferred development strategy (2,600 dwellings)? 5b) If not, should the amount be higher or lower, what should the number be and how should the strategy change as a result? 6a) Do you agree or disagree with the list of potential Nothing selected development sites in each Group 1 village (tables 4 – 8)? 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? 7a) Do you agree or disagree with the amount of Nothing selected development identified for the Group 2 villages as part of the preferred development strategy (225 dwellings)? 7b) If not, should the amount be higher or lower, what should the number be and how should the strategy change as a result? 8a) Do you agree or disagree with the shortlist of sites Nothing selected for each Group 2 village (tables 9 – 14)? 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? 9a) Do you agree or disagree with the approach for Group Nothing selected 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)? 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? 10a) Do you agree or disagree with the selection of Local Nothing selected Green Spaces? 10b) Given the site assessment work that has already taken place, which sites do you think should be removed from or added to the list?

11) Do you have any comments on any of the updated or new evidence base ’ ?

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? The response to Q1(b) above is an officer response only, on behalf of East Northamptonshire Council. It reflects local issues that have been raised regarding the new settlement proposals in the emerging Bedford Local Plan. At an officer level we do not object to the significant changes to the spatial strategy that are proposed. Rather, in the spirit of the Duty to Cooperate, we wish to ensure that colleagues at the Borough Council are aware of any local issues. Colleagues from the North Northamptonshire Joint Planning and Delivery Unit and East Northamptonshire Council are due to attend your "Duty to Cooperate" meeting next week. We hope that this will provide greater clarity about the emerging spatial strategy, although we are surprised that the meeting is being held AFTER the current consultation closing date.

Please attach accompanying document, if required: Appendix 4: Bedford Borough Local Plan 2035: Draft East Northamptonshire Council representations

Representation form for the Bedford Borough Local Plan 2035: Plan for Submission (Regulation 19 publication)

Part B – Your representation(s) – PARAGRAPH 6.13 (Appendix 4a)

5. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be legally compliant? n/a

Yes No Don’t know

If NO, is this because it is: (Please tick all that apply)

 Not prepared in accordance with the Local Development Scheme

 Not prepared in accordance with the Statement of Community Involvement

 Not consistent with the regulatory requirements for consultation

 Not compliant with the Duty to Co-operate

 Not accompanied by a compliant Sustainability Appraisal

Please give details of why you consider the Bedford Borough Local Plan 2035: Plan for Submission is not legally compliant. Please be as precise as possible.

6. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be sound?

Yes No Don’t know x

If NO, is this because it is: (Please tick all that apply)

 Not positively prepared

 Not justified

 Not effective X

 Not consistent with national policy

6a. To which part of the Bedford Borough Local Plan 2035: Plan for Submission does this representation relate? (please select one option only)

Paragraph 6.13 – Spatial strategy (key service centres)

Policy

Supporting documents

Please explain your answer to question 6. Please be as precise as possible.

Functional relationship between Colworth Garden Village and Sharnbrook At paragraph 6.13, the Local Plan identifies Sharnbrook as a Key Service Centre. This raises the following question:

 Are Sharnbrook and Colworth Garden Village intended to function as separate settlements; or  Is it proposed that the two settlements, in combination, would effectively become a single functional entity?

Paragraphs 6.13-6.14 make no reference to the status of Colworth in the supporting text, despite its prominence within Policy 3(iv). The Key Diagram (p37) suggests that Sharnbrook and Colworth should be regarded as separate settlements, but this is not reflected within the supporting text to Policy 3 (i.e. paragraphs 6.13-6.14).

7. Please set out the changes that you consider are necessary to make the Bedford Borough Local Plan 2035: Plan for Submission legally compliant and/ or sound, including revised wording of any policy text, and reasons why the proposed change would make it legally compliant and/ or sound. Please be as precise as possible.

Proposed amendment to paragraph 6.13 If it is intended that Colworth and Sharnbrook should be regarded as entirely separate settlements/ entities, then this should be clarified in paragraph 6.13. The text should be amended by either:

 Additional reference to Colworth Garden Village as a proposed Key Service Centre; or  Reference to Colworth/ Sharnbrook Key Service Centre (e.g. by way of an explanatory footnote to explain that Colworth and Sharnbrook should be regarded as a single entity.

8. If your representation is seeking a change do you consider it necessary to take part and speak at the examination hearing(s) if invited to do so by the inspector?

Yes No x

If you wish to take part in the examination hearing(s), please outline why you consider this to be necessary: (please note the inspector will determine who will be invited to be heard at the examination hearing(s))

Although not in relation to all representations submitted

9. Do you wish to be notified of any of the following? (please tick all that apply)

 When the Bedford Borough Local Plan 2035: Plan for Submission has been submitted for independent examination under Section 20 of the X Planning and Compulsory Purchase Act 2004 (as amended).

 When the report of any person appointed to carry out an independent examination of the Bedford Borough Local Plan 2035: Plan for X Submission is published.

 When the Bedford Borough Local Plan 2035: Plan for Submission has been adopted X

Please attach any documents you wish to submit with your representation.

Part B – Your representation(s) – PARAGRAPHS 7.37-7.46 (Appendix 4b)

5. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be legally compliant?

Yes No Don’t know X

If NO, is this because it is: (Please tick all that apply)

 Not prepared in accordance with the Local Development Scheme

 Not prepared in accordance with the Statement of Community Involvement X

 Not consistent with the regulatory requirements for consultation

 Not compliant with the Duty to Co-operate

 Not accompanied by a compliant Sustainability Appraisal

Please give details of why you consider the Bedford Borough Local Plan 2035: Plan for Submission is not legally compliant. Please be as precise as possible

Consultation process regarding selection of Colworth as the location for a Garden Village The plan preparation process has been assessed against the Statement of Community Involvement (SCI). It is noted that the Local Plan preparation process in the SCI has been developed with reference to the Town and Country Planning (Local Planning) (England) Regulations 2012.

At previous consultation stages (within SCI Stage 1, Figure 2), consultation documents referred to the principle of developing a new Garden Village, with reference to four potential sites. There was no indication, at previous consultation stages, that Colworth was the preferred location. The site was only formally approved by the Borough Council’s Executive on 10 January 2018, at the same time that the Plan for Submission (SCI Stage 2, Figure 2) was approved for consultation.

The choice of Colworth as the location for the Garden Village was a fundamental decision for the Local Plan; such that it is not considered that the spirit of SCI paragraph 8.9 has been appropriately met. It is asserted that, in order to fulfil the spirit of the SCI, the choice of Colworth ought to have been subject of a bespoke (non-statutory) consultation in advance of the statutory “Plan for Submission” (Regulation 19) consultation.

6. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be sound?

Yes No Don’t know X

If NO, is this because it is: (Please tick all that apply)

 Not positively prepared

 Not justified

 Not effective

 Not consistent with national policy

6a. To which part of the Bedford Borough Local Plan 2035: Plan for Submission does this representation relate? (please select one option only)

Paragraph 7.37-7.46 – Colworth Garden Village

Policy

Supporting documents

Please explain your answer to question 6. Please be as precise as possible.

Consultation/ site selection process for Colworth Garden Village This representation relates to the consultation process for the choice of Colworth as the location for the proposed new Garden Village.

East Northamptonshire Council has raised no previous objections to the concept of developing a new Garden Village within Bedford Borough. Indeed, the overall concept is supported, recognising that this approach fits with the current national planning agenda,

It is, however, questioned whether the process of identifying Colworth as the chosen site fulfils the spirit of the SCI.

8. If your representation is seeking a change do you consider it necessary to take part and speak at the examination hearing(s) if invited to do so by the inspector?

Yes No X

9. Do you wish to be notified of any of the following? (please tick all that apply)

 When the Bedford Borough Local Plan 2035: Plan for Submission has been submitted for independent examination under Section 20 of the X Planning and Compulsory Purchase Act 2004 (as amended).

 When the report of any person appointed to carry out an independent examination of the Bedford Borough Local Plan 2035: Plan for X Submission is published.

 When the Bedford Borough Local Plan 2035: Plan for Submission has been adopted X

Please attach any documents you wish to submit with your representation.

Part B – Your representation(s) – POLICIES 26 AND 27 (Appendix 4c)

5. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be legally compliant? n/a

Yes No Don’t know

If NO, is this because it is: (Please tick all that apply)

 Not prepared in accordance with the Local Development Scheme

 Not prepared in accordance with the Statement of Community Involvement

 Not consistent with the regulatory requirements for consultation

 Not compliant with the Duty to Co-operate

 Not accompanied by a compliant Sustainability Appraisal

Please give details of why you consider the Bedford Borough Local Plan 2035: Plan for Submission is not legally compliant. Please be as precise as possible

6. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be sound?

Yes No Don’t know X

If NO, is this because it is: (Please tick all that apply)

 Not positively prepared

 Not justified X  Not effective X

 Not consistent with national policy

6a. To which part of the Bedford Borough Local Plan 2035: Plan for Submission does this representation relate? (please select one option only)

Paragraph

Policy 26-27 – Garden Village Principles/ Colworth Garden Village

Supporting documents

Please explain your answer to question 6. Please be as precise as possible.

Policy 26 Policy 26 sets out the overall principles for Garden Villages. These are effectively replicated in the detailed Policy 27 criteria; such that it is not considered that two policies are needed with respect to Colworth Garden Village (CGV).

Policy 27 Transport/ infrastructure (xii) – Policy 27 sets out a number of criteria setting out how transport infrastructure anticipated to come forward as CGV is implemented. Questions are raised, however, as to whether the necessary supporting evidence base (specifically transport modelling) has been undertaken to justify the Garden Village proposal; such that the scheme as envisaged by policies 26 and 27 is not (considered to be) justified.

Furthermore, it is considered that given its scale, to be effective Policy 27 should give further consideration to the wider spatial implications of CGV beyond its immediate locality (Sharnbrook/ Santa Pod). To be justified (in accordance with the soundness test) policy criteria should give consideration to broader connectivity; with particular reference to green infrastructure, walking, cycling and public transport.

Overall, it is concluded that additional transport modelling is necessary in order to provide a justification for CGV and, therefore, to ensure the Local Plan is sound. Further details regarding East Northamptonshire Council’s concerns relating to transport modelling are set out below.

It is advised that the decision to promote the development of Colworth Garden Village (west of Sharnbrook) could give rise to potentially significant impacts within East Northamptonshire, particularly in relation to the A6 running through the southern part of the District. It is acknowledged that Duty to Co-operate meetings have been held with this Council and Bedford Borough Council, which have included Northamptonshire County Council, and the principle of the approach to meeting future development requirements within Bedford Borough is not objected to. However, in respect of the transport modelling undertaken to date, this Council is concerned that there are apparent inadequacies in the approach taken, which can be summarised as follows:  The model on which the published outputs are based does not extend into Northamptonshire and therefore does not accurately reflect trips north on the A6  The implications of not factoring in this work are exaggerated by the future delivery of the Rushden East Sustainable Urban Extension to the east of Rushden (which includes 2,500 new homes and employment provision) which in turn could affect trips south along the A6  Trip levels indicated in the modelling appear low, especially in the p.m. period  The modelling work does not have appeared to have included the trips generated by the additional 7.25 ha employment provision at Colworth Garden Village Northamptonshire County Council has raised concerns over the potential impact of these issues and has (through the Duty to Co-operate meetings) agreed to examine assumptions further. It may be possible to address these concerns by updating the model, including undertaking additional data collection. However, without this information the outcomes and potential mitigation measures remain unclear. Therefore, until this position is resolved, this Council raises objection.

Suggested amendments to policies 26 and 27, to make the Bedford Borough Local Plan 2035: Plan for Submission, sound Policy 26 It is considered that policies 26 and 27 effectively repeat one another. The more general/ overarching Garden Village principles would be better set out in an explanatory text box, in place of a separate policy.

Policy 27 Further policy criteria are considered necessary to ensure that the CGV proposal is sound (i.e. justified and effective). These would need to address the following issues:

 (xii) Impacts upon A6 corridor between Bedford, Rushden and Kettering, with reference to the further transport modelling that is asserted as being necessary to justify the CGV proposal;  (xv) Explicit reference to delivering green infrastructure (GI) connections between the proposed Rushden East Country Park and CGV, having regard to the Rushden – Soldrop Local GI Corridor (North Northamptonshire Joint Core Strategy Figure 17/ Policy 19);  (xiii) Consideration of potential for connections between East Northamptonshire Greenway and the proposed Colworth/ Sharnbrook station;  (xii) Public transport connectivity – improvements to bus services along the A6 corridor, between Rushden East and Sharnbrook.

Overall, it is emphasised that the site specific CGV policies, in view of the proposed scale of development, should give far greater consideration to the wider spatial implications of the proposal in order to be justified and effective, and therefore, sound.

8. If your representation is seeking a change do you consider it necessary to take part and speak at the examination hearing(s) if invited to do so by the inspector?

Yes No X

9. Do you wish to be notified of any of the following? (please tick all that apply)

 When the Bedford Borough Local Plan 2035: Plan for Submission has been submitted for independent examination under Section 20 of the X Planning and Compulsory Purchase Act 2004 (as amended).

 When the report of any person appointed to carry out an independent examination of the Bedford Borough Local Plan 2035: Plan for X Submission is published.

 When the Bedford Borough Local Plan 2035: Plan for Submission has been adopted X

Please attach any documents you wish to submit with your representation.

Part B – Your representation(s) – POLICY 80 (Appendix 4d)

5. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be legally compliant? n/a

Yes No Don’t know

If NO, is this because it is: (Please tick all that apply)

 Not prepared in accordance with the Local Development Scheme

 Not prepared in accordance with the Statement of Community Involvement

 Not consistent with the regulatory requirements for consultation

 Not compliant with the Duty to Co-operate

 Not accompanied by a compliant Sustainability Appraisal

Please give details of why you consider the Bedford Borough Local Plan 2035: Plan for Submission is not legally compliant. Please be as precise as possible

6. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be sound?

Yes No Don’t know X

If NO, is this because it is: (Please tick all that apply)

 Not positively prepared

 Not justified

 Not effective X

 Not consistent with national policy

6a. To which part of the Bedford Borough Local Plan 2035: Plan for Submission does this representation relate? (please select one option only)

Paragraph

Policy 80 – Hierarchy of town centres

Supporting documents

Please explain your answer to question 6. Please be as precise as possible.

Hierarchy of town centres It is noted that Policy 80 sets out a detailed hierarchy of town centres (1-4). This approach provides a useful reference point for managing developments for main town centre uses.

A query is, however, raised as to the proposed status for Colworth Garden Village within the town centre hierarchy:

 Is Colworth to have its own new local (80(3)) or even district (80(2)) status, as is the case for Wixams; or  Is Colworth Garden Village intended to be covered by Sharnbrook local centre?

This matter needs to be clarified in order for the Plan to be effective. It is assumed that this is an unintentional omission, but this should be clarified and/ or corrected in order for the Local Plan to be made sound.

Suggested amendment to Policy 80, to make the Bedford Borough Local Plan 2035: Plan for Submission, sound Clarify the status of Colworth Garden Village and/ or Sharnbrook local centre within Policy 80.

8. If your representation is seeking a change do you consider it necessary to take part and speak at the examination hearing(s) if invited to do so by the inspector?

Yes No X

9. Do you wish to be notified of any of the following? (please tick all that apply)

 When the Bedford Borough Local Plan 2035: Plan for Submission has been submitted for independent examination under Section 20 of the X Planning and Compulsory Purchase Act 2004 (as amended).

 When the report of any person appointed to carry out an independent examination of the Bedford Borough Local Plan 2035: Plan for X Submission is published.

 When the Bedford Borough Local Plan 2035: Plan for Submission has been adopted X

Please attach any documents you wish to submit with your representation.

Part B – Your representation(s) – POLICY 94 (Appendix 4e)

5. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be legally compliant? n/a

Yes No Don’t know

If NO, is this because it is: (Please tick all that apply)

 Not prepared in accordance with the Local Development Scheme

 Not prepared in accordance with the Statement of Community Involvement

 Not consistent with the regulatory requirements for consultation

 Not compliant with the Duty to Co-operate

 Not accompanied by a compliant Sustainability Appraisal

Please give details of why you consider the Bedford Borough Local Plan 2035: Plan for Submission is not legally compliant. Please be as precise as possible

6. Do you consider the Bedford Borough Local Plan 2035: Plan for Submission to be sound?

Yes No Don’t know X

If NO, is this because it is: (Please tick all that apply)

 Not positively prepared

 Not justified

 Not effective X

 Not consistent with national policy

6a. To which part of the Bedford Borough Local Plan 2035: Plan for Submission does this representation relate? (please select one option only)

Paragraph 12.26-12.32

Policy 94 – Transport infrastructure and network improvements

Supporting documents

Please explain your answer to question 6. Please be as precise as possible.

Transport infrastructure and network improvements It is noted that Policy 94 specifies the strategic transport infrastructure projects that are anticipated to come forward during the Plan period (to 2035). Policy 94(iii) refers to the proposed Wixams railway station, but there is no equivalent reference to the proposed Colworth/ Sharnbrook Parkway railway station.

It is understood from previous Duty to Cooperate meetings that the process of bringing the proposed Parkway Station is already, involving the preparation of a feasibility study and engagement with Network Rail. However, it would be helpful to explain this within the supporting text to Policy 94 (paragraphs 12.26-12.32).

Suggested amendments to Policy 94 and supporting text, to make the Bedford Borough Local Plan 2035: Plan for Submission, sound Include further explanatory information regarding the proposed Colworth/ Sharnbrook Parkway Station within the supporting text to Policy 94 (paragraphs 12.26-12.32).

Clarify the status of the proposed Colworth/ Sharnbrook railway station within Policy 94.

8. If your representation is seeking a change do you consider it necessary to take part and speak at the examination hearing(s) if invited to do so by the inspector?

Yes No X

9. Do you wish to be notified of any of the following? (please tick all that apply)

 When the Bedford Borough Local Plan 2035: Plan for Submission has been submitted for independent examination under Section 20 of the X Planning and Compulsory Purchase Act 2004 (as amended).

 When the report of any person appointed to carry out an independent examination of the Bedford Borough Local Plan 2035: Plan for X Submission is published.

 When the Bedford Borough Local Plan 2035: Plan for Submission has been adopted X

Please attach any documents you wish to submit with your representation.