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New Electoral Arrangements for Bedford Borough Council Draft Recommendations September 2020

New Electoral Arrangements for Bedford Borough Council Draft Recommendations September 2020

New electoral arrangements for Borough Council Draft Recommendations September 2020

Translations and other formats:

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Licensing:

The mapping in this report is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Keeper of Public Records © Crown copyright and database right. Unauthorised reproduction infringes Crown copyright and database right.

Licence Number: GD 100049926 2020

A note on our mapping:

The maps shown in this report are for illustrative purposes only. Whilst best efforts have been made by our staff to ensure that the maps included in this report are representative of the boundaries described by the text, there may be slight variations between these maps and the large PDF map that accompanies this report, or the digital mapping supplied on our consultation portal. This is due to the way in which the final mapped products are produced. The reader should therefore refer to either the large PDF supplied with this report or the digital mapping for the true likeness of the boundaries intended. The boundaries as shown on either the large PDF map or the digital mapping should always appear identical.

Contents

Introduction 1 Who we are and what we do 1 What is an electoral review? 1 Why Bedford? 2 Our proposals for Bedford 2 How will the recommendations affect you? 2 Have your say 3 Review timetable 3 Analysis and draft recommendations 5 Submissions received 5 Electorate figures 5 Number of councillors 6 Ward boundaries consultation 6 Draft recommendations 7 North East Bedford 8 South East Bedford Town 13 North West Bedford Town 16 19 South Bedford 21 East Bedford 23 North Bedford 25 West Bedford 27 Conclusions 31 Summary of electoral arrangements 31 Parish electoral arrangements 31 Have your say 35 Equalities 39 Appendices 41 Appendix A 41 Draft recommendations for 41 Appendix B 44 Outline map 44 Appendix C 46 Submissions received 46 Appendix D 47 Glossary and abbreviations 47

Introduction Who we are and what we do

1 The Local Government Boundary Commission for England (LGBCE) is an independent body set up by Parliament.1 We are not part of government or any political party. We are accountable to Parliament through a committee of MPs chaired by the Speaker of the House of Commons. Our main role is to carry out electoral reviews of local authorities throughout England.

2 The members of the Commission are:

• Professor Colin Mellors OBE • Amanda Nobbs OBE (Chair) • Steve Robinson • Andrew Scallan CBE (Deputy Chair) • Jolyon Jackson CBE • Susan Johnson OBE (Chief Executive) • Peter Maddison QPM

What is an electoral review?

3 An electoral review examines and proposes new electoral arrangements for a local authority. A local authority’s electoral arrangements decide:

• How many councillors are needed. • How many wards or electoral divisions there should be, where their boundaries are and what they should be called. • How many councillors should represent each ward or division.

4 When carrying out an electoral review the Commission has three main considerations:

• Improving electoral equality by equalising the number of electors that each councillor represents. • Ensuring that the recommendations reflect community identity. • Providing arrangements that support effective and convenient local government.

5 Our task is to strike the best balance between these three considerations when making our recommendations.

1 Under the Local Democracy, Economic Development and Construction Act 2009.

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6 More detail regarding the powers that we have, as well as the further guidance and information about electoral reviews and review process in general, can be found on our website at www.lgbce.org.uk.

Why Bedford?

7 We are conducting a review of Bedford Borough Council (‘the Council’) as the value of each vote in borough elections varies depending on where you live in Bedford. Some councillors currently represent many more or fewer voters than others. This is ‘electoral inequality’. Our aim is to create ‘electoral equality’, where votes are as equal as possible, ideally within 10% of being exactly equal.

8 This electoral review is being carried out to ensure that:

• The wards in Bedford are in the best possible places to help the Council carry out its responsibilities effectively. • The number of voters represented by each councillor is approximately the same across the borough.

Our proposals for Bedford

9 Bedford should be represented by 46 councillors, six more than there are now.

10 Bedford should have 29 wards, two more than there are now.

11 The boundaries of all but two wards should change.

How will the recommendations affect you?

12 The recommendations will determine how many councillors will serve on the Council. They will also decide which ward you vote in, which other communities are in that ward, and, in some cases, which parish council ward you vote in. Your ward name may also change.

13 Our recommendations cannot affect the external boundaries of the borough or result in changes to postcodes. They do not take into account parliamentary constituency boundaries. The recommendations will not have an effect on local taxes, house prices, or car and house insurance premiums and we are not able to consider any representations which are based on these issues.

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Have your say 14 We will consult on the draft recommendations for a 10-week period, from 29 September 2020 to 7 December 2020. We encourage everyone to use this opportunity to comment on these proposed wards as the more public views we hear, the more informed our decisions will be in making our final recommendations.

15 We ask everyone wishing to contribute ideas for the new wards to first read this report and look at the accompanying map before responding to us.

16 You have until 7 December 2020 to have your say on the draft recommendations. See page 35 for how to send us your response.

Review timetable 17 We wrote to the Council to ask its views on the appropriate number of councillors for Bedford. We then held a period of consultation with the public on warding patterns for the borough. The submissions received during consultation have informed our draft recommendations.

18 The review is being conducted as follows:

Stage starts Description

18 February 2020 Number of councillors decided 25 February 2020 Start of consultation seeking views on new wards 4 May 2020 End of consultation 8 June 2020 Extension of consultation seeking views on new wards End of consultation; we begin analysing submissions and 20 July 2020 forming draft recommendations 29 September Publication of draft recommendations; start of second 2020 consultation End of consultation; we begin analysing submissions and 7 December 2020 forming final recommendations 30 March 2021 Publication of final recommendations

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Analysis and draft recommendations

19 Legislation2 states that our recommendations should not be based only on how many electors3 there are now, but also on how many there are likely to be in the five years after the publication of our final recommendations. We must also try to recommend strong, clearly identifiable boundaries for our wards.

20 In reality, we are unlikely to be able to create wards with exactly the same number of electors in each; we have to be flexible. However, we try to keep the number of electors represented by each councillor as close to the average for the council as possible.

21 We work out the average number of electors per councillor for each individual local authority by dividing the electorate by the number of councillors, as shown on the table below.

2019 2026 Electorate of Bedford 130,131 148,921 Number of councillors 40 46 Average number of electors per 3,253 3,237 councillor

22 When the number of electors per councillor in a ward is within 10% of the average for the authority, we refer to the ward as having ‘good electoral equality’. All of our proposed wards for Bedford will have good electoral equality by 2026.

Submissions received 23 See Appendix C for details of the submissions received. All submissions may be viewed at our offices by appointment, or on our website at www.lgbce.org.uk

Electorate figures 24 The Council submitted electorate forecasts for 2026, a period five years on from the scheduled publication of our final recommendations in 2021. These forecasts were broken down to polling district level and predicted an increase in the electorate of around 14% by 2026.

25 We considered the information provided by the Council and are satisfied that the projected figures are the best available at the present time. We have used these figures to produce our draft recommendations.

2 Schedule 2 to the Local Democracy, Economic Development and Construction Act 2009. 3 Electors refers to the number of people registered to vote, not the whole adult population.

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26 The Conservative Group disputed the Council’s electoral forecast in its warding submission, arguing that elector growth had been overestimated in the Bedford town area, resulting in a general overestimation of 10,001 electors across the borough. However, the submission did not provide an alternative breakdown of projected electors by polling district, and the Group’s submission conceded that it was “unable to identify with sufficient accuracy where [the Council has] overestimated development and elector numbers”. Therefore, while we carefully considered the Conservative Group’s criticism and alternative methodology, we remain satisfied that the Council’s projected figures are the best available at the present time.

Number of councillors

27 Bedford Borough Council currently has 40 councillors. We have looked at evidence provided by the Council and have concluded that increasing the council size by six will ensure the Council can carry out its roles and responsibilities effectively.

28 We therefore invited proposals for new patterns of wards that would be represented by 46 councillors: for example, 46 one-councillor wards or a mix of one-, two- and three-councillor wards.

29 We received one submission about the number of councillors in response to our consultation on warding. The submission was developed by a working group of Bedford councillors and considered that the Council required an increase in members in order to strengthen strategic leadership, accountability and community leadership. It cited heavy councillor workloads, a lack of capacity to create a seventh scrutiny committee, and changes in the Council’s size and structure to support an increase. Having carefully considered the evidence received, we have therefore based our draft recommendations on a 46-member council.

Ward boundaries consultation

30 We received 89 submissions in response to our consultation on ward boundaries. These included two borough-wide proposals from the Liberal Democrat and Conservative groups and a partial proposal from the Labour Group. The Labour Group’s proposal focused on the areas of Bedford town, Kempston, , Bromham, , and . The remainder of the submissions provided localised comments for warding arrangements in particular areas of the borough.

31 The two borough-wide schemes provided mixed patterns of one- and two- councillor wards for Bedford. The partial scheme submitted by the Labour Group provided a mixed pattern of one-, two-, and three-councillor wards. We carefully considered the proposals received and were of the view that the pattern of wards

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proposed by the Liberal Democrat Group resulted in good levels of electoral equality in most areas of the authority and generally used clearly identifiable boundaries.

32 Both the Conservative and Labour groups’ submissions contained multiple wards with high electoral variances, so did not form the basis of our recommendations. However, elements of both schemes have been adopted in our draft recommendations, where we considered that they more closely reflected the statutory criteria than the Liberal Democrat Group scheme.

33 Our draft recommendations also take into account local evidence that we received, which provided further evidence of community links and locally recognised boundaries. In some areas we considered that the proposals did not provide for the best balance between our statutory criteria and so we identified alternative boundaries.

34 Given the travel restrictions, and the social distancing, arising from the Covid- 19 outbreak, there was a detailed virtual tour of Bedford. This helped to clarify issues raised in submissions and assisted in the construction of the proposed draft boundary recommendations.

Draft recommendations 35 Our draft recommendations are for 17 two-councillor wards and 12 one- councillor wards. We consider that our draft recommendations will provide for good electoral equality while reflecting community identities and interests where we received such evidence during consultation.

36 The tables and maps on pages 8–29 detail our draft recommendations for each area of Bedford. They detail how the proposed warding arrangements reflect the three statutory4 criteria of:

• Equality of representation. • Reflecting community interests and identities. • Providing for effective and convenient local government.

37 A summary of our proposed new wards is set out in the table starting on page 41 and on the large map accompanying this report.

38 We welcome all comments on these draft recommendations, particularly on the location of the ward boundaries, and the names of our proposed wards.

4 Local Democracy, Economic Development and Construction Act 2009.

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North East Bedford Town

Number of Ward name Variance 2026 councillors 2 4% 2 -6% 2 -1% 2 -1% 2 -1%

Brickhill 39 We received four submissions for Brickhill ward: one from Brickhill Parish Council, and the rest from the Liberal Democrat, Conservative, and Labour groups. The parish council’s submission requested that its boundaries were not split between more than two wards, as at present, and that 10 properties which are included in the existing ward, but which are not within the parish boundaries be transferred to Putnoe and De Parys wards. The submission highlighted that these anomalous properties were identified in the 2013 and 2017 Community Governance Reviews.

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40 This request is reflected in the Liberal Democrat scheme, which is otherwise identical to the Conservatives’ proposed ward, in broadly following the boundaries of Brickhill parish with the exclusion of polling district BD (the area south of Brickhill Drive). The Labour scheme follows the current boundaries of the ward, which omits the Woodlands Park area while including the housing and Council offices off Brickhill Drive and the housing off Ellis Road, albeit with the addition of part of Clapham Park. All three schemes assign two councillors to represent the ward and have good levels of electoral equality, with the Conservative and Liberal Democrat wards achieving variances of 4% and the Labour ward 1%.

41 Having considered the submissions received, we believe the Liberal Democrat scheme best reflects our statutory criteria for Brickhill ward, being in accord with the submission received from Brickhill Parish Council, and largely maintaining the integrity of the parish boundary and the community it represents. Brickhill will have good electoral equality by 2026.

De Parys 42 We received three submissions for De Parys ward in the schemes submitted by the party-political groups. The Labour scheme follows the present ward boundaries, represented by two councillors, resulting in an electoral variance of -9%. The Conservative ward boundaries are similar, albeit with the omission of De Parys Avenue, , Rugby Club, the observatory and part of polling district BV ( of Bedford, and the estate between Haylands Way and Putnoe Lane – though which part is not specified). This ward would be represented by one councillor. As the Conservative Group proposed transferring De Parys Avenue to an adjoining ward, it suggested renaming the ward Kimbolton or Polhill. However, even with the complete omission of polling district BV, this results in an electoral variance of 25% based on the Council’s forecast. While we appreciate that the Conservative Group disagrees with the Council’s expectation of an increase in the student population in De Parys ward, we have had to apply the Council’s forecast to their proposals.

43 The Liberal Democrats’ proposed ward also broadly follows the current boundaries, represented by two councillors, albeit with the addition of polling district BD (see paragraph 40) and the omission of all properties north of Chiltern Avenue and Goldington Academy. This achieves a -6% electoral variance for De Parys ward by 2026, the best proposed according to the Council’s forecast. On the basis of the evidence received, we are persuaded that the Liberal Democrat Group’s proposals will ensure electoral equality while reflecting local community identities and interests. We have therefore based our draft recommendations for this ward on these proposals.

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Goldington 44 We received five submissions from residents and one from Parish Council on Goldington ward. These were in addition to the three party political schemes. All three of the schemes propose wards broadly following the current boundaries, represented by two councillors. The Liberal Democrat Group’s proposed ward adds housing either side of Putnoe Street from polling district BBF while omitting NL (two housing estates north of Norse Road – see paragraphs 76–79), resulting in an electoral variance of -1% by 2026. The Conservative ward omits housing either side of Queen’s Drive between The Boundary and Putnoe Street, resulting in an electoral variance of -16%, according to the Council forecast. The Labour ward omits the Maskell Drive and Markham Rise estates north of Norse Road, resulting in a variance of -5%.

45 The submissions from residents and Renhold Parish Council largely concerned the three housing estates north of Norse Road, all of which lie within Renhold parish, but which are currently split between the urban Goldington and rural Great Barford wards. All were unanimous in their view that the three estates should be contained within one ward, though most differed on whether this should be the urban or rural ward. One submission, from a former councillor who had worked on the previous review, argued that the estates should be either all in Goldington or all in a Renhold & ward – the important thing being they were united in a single ward. While some residents argued that the estates had a suburban rather than rural character and should therefore be placed in Goldington, Renhold Parish Council argued that residents looked to Renhold for their amenities, including the , shop, and pub, and that the areas were linked by footways and footpaths.

46 We have carefully considered the evidence received. Our virtual tour of the area appeared to show that the Norse Road estates are somewhat removed from Renhold village, while being close to supermarkets and schools in Goldington ward. However, placing the estates in Goldington ward would result in a very high electoral variance and would require a complete redrawing of Bedford town borough wards, for which we currently have no supporting evidence. Furthermore, we recognise the potential advantages, in terms of effective and convenient local government and community identities, of placing these estates in a single ward. Therefore, we have decided to base our draft recommendations on the Liberal Democrat proposal, but would be particularly interested to receive well-evidenced alterative warding patterns for this area, and Bedford town borough wards if necessary, during the current consultation.

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Harpur 47 In addition to the three party political schemes, we received one submission from a resident regarding Harpur ward, suggesting that Beverley Crescent be included in the ward “as Bromham Road feels like a natural boundary for the Queens Park area”. However, it should be noted that the current boundary – used as a ward boundary by the Liberal Democrat and Labour groups – is the railway line, which provides an effective and easily identifiable boundary.

48 All three party group wards were represented by two councillors. The Liberal Democrat ward follows the existing ward boundary, with the exception of the area of polling district BAH south of the properties on Tavistock Street, with an electoral variance of -3%. The Labour Group’s proposed ward follows a similar pattern, instead running the boundary through the middle of Tavistock Street, resulting in a -2% variance. The Conservative Group’s proposed ward is similar to the current boundaries but excludes housing between Bromham Road, Shakespeare Road, the railway line and the river, and includes polling districts BQ (from the A6/A600 roundabout to the boundary of Clapham parish) and housing along Brickhill Drive to Ellis Road. This would result in a 0% electoral variance according to the Council’s forecast. However, the inclusion of Brickhill Drive results in an odd protrusion from the ward which lacks clear boundaries, and would therefore not be conducive to effective and convenient local government.

49 We have therefore based our draft recommendations for Harpur ward on the Liberal Democrat Group’s proposal, owing to its inclusion of properties on both sides of Tavistock Street in Castle ward. However, we have added polling district BQ. This of Bedford town is included in the Liberal Democrats’ proposed Clapham, Renhold & Ravensden ward and, at present, includes only 15 electors. However, these are expected to be joined by a further 143 in a planned development on the southern boundary of the polling district. This development will be bounded to the south by , Aldi, Sainsbury’s, and a number of other amenities on which these new residents will rely. To the north, however, there is virtually nothing and, while the development will be only a short distance from existing properties off Manton Lane and Shakespeare Road in Harpur, it will remain a considerable distance from Clapham village. We have therefore included this area in our proposed Harpur ward, which will have an electoral variance of -1% by 2026.

Putnoe 50 We received three submissions in relation to Putnoe – two from residents and one from Brickhill Parish Council – in addition to the three party political schemes. The parish council requested that six properties outside its boundaries but included in the current Brickhill ward be moved to Putnoe ward (see paragraphs 39 and 40), while one resident suggested moving the estates north of Norse Road into Putnoe ward and the other suggested moving the area north of Queen’s Drive and west of

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Church Lane from Goldington to Putnoe ward, as it “feels more like Putnoe.”

51 The party political group submissions for Putnoe broadly followed the current ward boundaries, save for their changes made to Brickhill, De Parys and Goldington wards, discussed earlier in this report. The Labour and Conservative wards result in electoral variances of -7% by 2026, while the Liberal Democrat Group’s proposed ward achieves a variance of -1%. In the absence of any compelling evidence to the contrary, we have therefore adopted the Liberal Democrat scheme in our draft recommendations for this ward.

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South East Bedford Town

Number of Ward Variance 2026 councillors Britannia 1 -5% Castle 2 8% Cauldwell 2 9% Kingsbrook 2 -4% Newnham 2 -4%

Britannia 52 Britannia is based on a one-member ward in the Liberal Democrats’ scheme, which joined the area of the current Castle ward south of the river with an area of Cauldwell, producing an electoral variance of 11%. The Labour Group’s proposed ward included most of this area within a three-member Cauldwell ward with a variance of -9%. The Conservative Group’s scheme created a one-member St John’s ward very similar to our proposed Britannia ward, albeit with the addition of most of the housing between Rope Walk and Barford Avenue from Kingsbrook ward, with a -5% variance.

53 We received one submission from a resident arguing that Castle ward should not cross the river, on the basis that the communities on each side had little in

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common. We considered the Liberal Democrats’ use of the A5140 provided a stronger south-eastern boundary to the ward than the Conservative Group’s proposal, which included housing cut off from the rest of the ward by a large industrial estate.

54 However, the Liberal Democrats’ proposed Britannia ward has poor electoral equality at 11%. The proposed ward also includes an area comprising Station Road, St Leonard’s Avenue, and St Leonard’s Street which, upon our virtual tour of the area, we considered to have poor access to the rest of the proposed ward. It is also surrounded by commercial properties. We have therefore transferred this area into Cauldwell ward in our draft recommendations, resulting in a -5% electoral variance in Britannia ward and 9% in Cauldwell. We would be particularly interested to receive the views from residents on our proposals during the current consultation.

Castle 55 We received eight submissions from residents regarding Castle ward in addition to three schemes from the party political groups. All but one of these submissions concerned the eastern boundary of Castle ward north of the river, most arguing that the eastern boundary of the ward should be Newnham Avenue, thus including all of Castle Road in one ward. Two submissions argued the western boundary should follow Bedford High Street. These boundaries form the basis of the Labour Group’s proposed two-member ward. However, this would result in an electoral variance of -22% for this ward, which would be bounded to the west by a one-member Bedford Central ward with a variance of 27%.

56 The Conservative Group’s scheme uses the existing boundary between Castle and Newnham for their one-member Castle ward, with a western boundary following the High Street, and adjacent to a one-member Town Centre ward. However, the electoral variances for these wards are 80% for Castle and 11% for Town Centre ward, based on the Council’s forecast. We have therefore adopted the Liberal Democrats’ proposed two-member Castle ward as part of our draft recommendations, which makes minor changes to the current boundaries north of the river. This ward will have an electoral variance of 8% by 2026.

Cauldwell 57 We received three schemes from the party political groups for Cauldwell ward, all of which made relatively minor changes to the existing boundaries. However, for reasons discussed in paragraphs 52-54, we have based our draft recommendations for the ward on the Liberal Democrats’ scheme, with the exception of a small area which we have transferred to our proposed Britannia ward.

Kingsbrook 58 We received one submission from a resident on Kingsbrook ward, in addition to three schemes from the party political groups. This submission argued that the

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estate on Meadowsweet Drive ought to be in an ward, rather than Kingsbrook, as it was considered part of the same estate as an adjoining one in Elstow. While it was not specified, it is assumed this was in reference to the estate on Abbey Fields, which joins from Meadowsweet Drive. However, moving this area from Kingsbrook to Elstow & ward would result in electoral variances of -26% and 24%, respectively. We have therefore not adopted this proposal.

59 The Kingsbrook wards in the three party political group schemes made only minor changes to the existing boundaries, with the Labour proposal resulting in an electoral variance of 9%, the Conservatives 5%, and the Liberal Democrats -4%. In the absence of any other compelling evidence, we have adopted the Liberal Democrats’ proposals as part of our draft recommendations.

Newnham 60 We received four submissions from residents regarding Newnham ward, most of which were concerned with the eastern boundary of Castle ward (see paragraph 55), and one of which asked whether Newnham ward could be abolished. The three schemes we received from the party political groups made mostly minor changes to the existing boundaries. The Conservative Group’s proposal adds only an unspecified section of polling district BV (an arc from the University of to Putnoe Lane) to the two-member ward. This results in a -4% variance if the entire polling district is added, according to the Council forecast. However, the residences in BV are separated from the rest of Newnham ward by the large expanse of the University of Bedfordshire and Goldington Academy campuses. This would create an unusual protuberance out of the ward and therefore not result in clearly identifiable ward boundaries. We have therefore not adopted this proposal in our draft recommendations.

61 The Labour Group’s proposal transfers the area west of Newnham Avenue into Castle ward, which we have not adopted in our draft recommendations, as this would create an electoral variance of -22% by 2026. The remaining one-member Newnham ward has an electoral variance of 20%. The Liberal Democrat scheme extends the existing boundaries of the ward westward between Bower Street and Pembroke Street, resulting in an electoral variance of -4% by 2026. Based on the evidence received, we have decided to adopt this proposal as part of our draft recommendations.

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North West Bedford Town

Number of Ward Variance 2026 councillors Allen Park 2 -8% Biddenham 1 -9% 1 -1% Queens 1 -7%

Allen Park 62 Allen Park ward has been based on the Liberal Democrat Group’s proposals, which split the existing one-councillor Queens Park ward into a one-councillor Queens ward and a two-councillor Allen Park ward. This ward will have an electoral variance of -8% by 2026. The Conservatives’ two-councillor ward, named Queens Park, is very similar, though it also contains polling district BBK (housing between Hurst Grove, Ford End Road, Bromham Road and the railway line) and an area south of Winifred Road. However, this results in an electoral variance of 16%. The

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Labour Group made no changes to the existing Queens Park ward boundaries, but increased representation to three councillors, resulting in a variance of -8%.

63 While both the Liberal Democrat and Labour schemes have their merits, and achieve similar electoral variances, we believe the Liberal Democrat scheme offers a better reflection of local communities and more effective and convenient local government. We have therefore based our draft recommendations on the Liberal Democrat scheme for Allen Park ward.

Biddenham 64 Biddenham ward is based on the Liberal Democrat and Conservative schemes, which follow the boundaries of Biddenham parish and would be represented by one councillor. The proposed ward will have an electoral variance of -9% by 2026. The Labour scheme maintained the present Bromham & Biddenham ward boundaries as a two-councillor ward, albeit without the housing estate along Biddenham Turn, Main Road, and Church End, with a variance of 4%. However, given the extensive development and rapid growth of Biddenham parish, we do not believe it would be appropriate to keep it together with the still very rural Bromham Parish – particularly if this requires splitting off part of Biddenham into another ward. We have therefore not adopted the Labour scheme.

65 We received three submissions from residents, one of which was content to keep Bromham and Biddenham parishes together – or with Great Denham if necessary – and two which suggested moving the new estate on Bromham Road from the existing Queens Park ward to Biddenham. One of these residents also suggested splitting Bromham and Biddenham ward. While we appreciate that the new estate on Bromham Road looks more to Biddenham than Queens Park, and is part of a larger planned development which crosses into Biddenham, this would involve moving around 400 electors from Queens ward, resulting in an electoral variance of 3% for Biddenham but -20% for Queens. We have therefore not adopted this proposal. Our proposed Biddenham ward will have good electoral equality by 2026.

Great Denham 66 We received four submissions from residents suggesting that Great Denham parish ought to be separated from and established as its own single-member ward. This was in recognition of the extensive growth in the parish, both completed and planned. There was also a recognition of the parish’s distinct character which, in the words of one resident, is “neither Kempston nor Rural”.

67 This was reflected in both the Labour and Liberal Democrat schemes, which separated Great Denham from Kempston Rural as a one-member ward. The Liberal Democrats’ proposed ward follows the parish boundaries of Great Denham, with a -1% electoral variance by 2026, while the Labour scheme adds an area of

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Biddenham parish, resulting in a variance of 26%. The Conservatives’ Kempston Rural ward would have an electoral variance of 6%. Having carefully considered the evidence received, we have decided to base our draft recommendations on the proposal from the Liberal Democrat Group, as this provides an effective balance between our three statutory criteria. In particular, it will ensure good long-term electoral equality.

Queens 68 For reasons discussed earlier in this report, we have adopted the Liberal Democrat Group’s proposed Allen Park ward rather than Labour’s and the Conservatives’ Queens Park wards and have declined to move the new estate on Bromham Road from the existing Queens Park ward into Biddenham. The Liberal Democrats’ Queens ward is a single-member ward which will have an electoral variance of -7% by 2026. The Conservatives’ Poets ward is similar, omitting the housing between Ford End Road, Hurst Grove, Bromham Road and the railway line and housing south of Winifred Road, but would have a forecast electoral variance of 16%. We have therefore based our draft recommendations on the Liberal Democrats’ proposal for this area.

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Kempston

Number of Ward Variance 2026 councillors Kempston Central & South 2 3% & East 2 4% 1 8%

Kempston Central & South, Kempston North & East, and Kempston West 69 We received three submissions from residents on Kempston, two of which suggested moving the southern boundary of Kempston West ward from the parish boundary to the A6 bypass, and one which suggested moving the existing western boundary of Kempston Central & East to St Johns Street, so the shopping arcade would be in Kempston West.

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70 We received three schemes from the party political groups for the Kempston area. The Labour and Conservative schemes made few changes to the existing four wards, except that the Conservative Group proposed to split Kempston Central & East into two wards and to move the southern boundary of Kempston West to the A6. The Labour Group proposed to move the said boundary to the edge of Kempston Rural and Wootton parishes. However, both these schemes result in several wards with high electoral variances, so have not been adopted in our draft recommendations.

71 The Liberal Democrat scheme creates three very different wards with the stated aim of “tidying up” boundaries which split communities between two wards, and to accommodate major housing developments in Kempston West. These wards demonstrated good electoral equality, with the exception of Kempston West, at 12%. We have therefore moved the north-eastern boundary from the rear of properties on the south side of High Street to the middle of High Street, having observed on our virtual tour that this is a predominantly residential road. This results in a variance of 8% for Kempston West and 3% for Kempston Central & South. We would be particularly interested to hear from residents about this decision.

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South Bedford

Number of Ward Variance 2026 councillors Elstow & Shortstown 2 2% Wilshamstead 1 7% & 2 6%

Elstow & Shortstown, Wilshamstead, and Wixams & Stewartby 72 We received two schemes for this area, from the Liberal Democrat and Conservative groups, which achieved mostly good electoral equality. In addition, we received seven submissions from residents, one from Wilshamstead councillor Graeme Coombes, and one from Elstow Parish Council.

73 Elstow Parish Council advised that it wished to be kept apart from Wixams and Stewartby parishes, with which it said it has no relationship or similarity. The parish council preferred that it be kept in a ward with Wilshamstead parish. Two residents suggested that all of Wixams ought to be within one ward, as presently a retirement village to the north of the parish is in the current Elstow & Stewartby ward. One of the residents suggested that Wixams be separated from Wilshamstead ward owing

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to the significant growth in Wixams parish.

74 The Conservative scheme places Elstow, Stewartby and the western half of Shortstown parishes into a two-member Elstow, Stewartby & Shortstown ward with a variance of -5%; the eastern half of Shortstown and parishes in a one- member Cotton End & New Cardington ward with a variance of 7%; and Cardington and parishes in a larger two-member Great Barford ward with a variance of -13%. Owing to the poor electoral equality of this Great Barford ward, the division of Shortstown Parish Council between wards, and the pairing of Elstow with Stewartby against Elstow Parish Council’s wishes, we have not adopted this scheme.

75 Our draft recommendations for the area are instead based on the Liberal Democrat proposals, which achieve good electoral equality in all three wards, separate high-growth parishes from those without major development projects, and maintain parish boundaries within wards.

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East Bedford

Number of Ward Variance 2026 councillors Great Barford 1 -2% Renhold & Ravensden 1 -2% 1 -10%

Great Barford, Renhold & Ravensden, and Wyboston 76 We received six submissions from residents and Renhold Parish Council for this area, half of which concerned the estates off Norse Road on the boundary between Renhold parish and Goldington ward, as discussed in paragraphs 44 and 46. Two residents suggested the creation of a Renhold & Ravensden ward from the

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existing Great Barford ward, one arguing that residents of the two parishes do not feel adequately represented as part of Great Barford. Another resident suggested moving Wilden parish out of the existing Wyboston ward and into Great Barford, with which it has more in common.

77 The Conservative scheme maintains the existing boundaries of Wyboston as a one-member ward with a variance of -4% by 2026, and makes minor changes to the existing Great Barford ward – moving Woodlands Park into a Clapham & Oakley ward – with a variance of -13%.

78 The Liberal Democrat scheme moves Wilden parish from Wyboston ward into a one-member Great Barford ward while moving Renhold and Ravensden parishes from Great Barford into a two-member Clapham, Renhold & Ravensden ward. This results in a -2% variance in Great Barford, -10% in Wyboston and 11% in Clapham, Renhold & Ravensden. This scheme has formed the basis of our draft recommendations in this area owing to supporting evidence from residents and Renhold Parish Council.

79 In order to achieve good electoral equality, we have adopted resident suggestions to create a one-member Renhold & Ravensden ward with a variance of -2%, and moved Clapham parish into a two-member Clapham & Oakley parish with a variance of 7% (see paragraphs 45 and 85–87).

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North Bedford

Number of Ward Variance 2026 councillors Harrold 1 2% Riseley 1 0% 1 -6%

Harrold, Riseley, and Sharnbrook 80 We received three submissions from residents regarding this area, two of which were one-sentence submissions with no supporting evidence. The third suggested Harrold, Carlton, Odell, and Turvey parishes be in one ward, owing to shared school use. We also received schemes from the Conservative and Liberal Democrat groups. The Conservatives made no changes to the existing wards, resulting in a -15% electoral variance in Riseley by 2026, and 13% in Sharnbrook. We have therefore not adopted this proposal.

81 The Liberal Democrats’ proposals make minor changes to the existing boundaries, moving parish from Sharnbrook to Riseley ward and parish from Riseley to Wyboston ward, achieving a 0% variance in Riseley

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and -6% in Sharnbrook. We are persuaded that this proposal will ensure good electoral equality in all three wards and have therefore adopted this proposal in our draft recommendations.

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West Bedford

Number of Ward name Variance 2026 councillors Bromham 2 -6% Clapham & Oakley 2 7% Wootton & Kempston Rural 2 0%

Bromham 82 We received six submissions from residents and one from a councillor for Bromham ward, in addition to the three schemes we received from the party political groups. One resident suggested separating the existing Bromham & Biddenham

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ward into two wards, while another suggested grouping the existing ward with Great Denham. Four submissions suggested breaking up the existing Kempston Rural ward, in recognition of the extensive development which has taken place, and the need to separate newly suburban parishes from rural. Two of these suggested that and Turvey parishes be kept together in a ward and apart from Great Denham (see paragraphs 66 and 67).

83 The Labour scheme maintains the boundaries of the existing Bromham & Biddenham ward, with the exception of Woodlands Park, which is transferred to Great Denham ward, creating a 4% electoral variance by 2026 in Bromham & Biddenham but 23% in Great Denham. We have therefore not adopted this scheme in our draft recommendations. The Conservative scheme brings Stagsden, Turvey, and Kempston Rural parishes together in a truncated two-councillor Kempston Rural ward with an electoral variance of 6%. The Conservative Group also proposed that Bromham, , and parishes form a two-councillor Bromham ward with a variance of -21% according to the Council forecast. Given this variance, we have not adopted this scheme as part of our draft recommendations.

84 The Liberal Democrat scheme groups Bromham, Stagsden, and Turvey parishes in a two-councillor Bromham ward with an electoral variance of -6% by 2026. We are persuaded that these proposals will ensure community identity is reflected while keeping electoral variances to a minimum. We have therefore adopted this scheme as part of our draft recommendations.

Clapham & Oakley 85 We received three submissions from Clapham, Oakley, and Pavenham parish councils, in addition to the three schemes from the party political groups. Clapham Parish Council requested no change to the existing ward boundaries, which encompass the parish boundaries and polling district BQ from the unparished urban centre. This is reflected in the Labour scheme but results in a 24% electoral variance in a one-member ward and has therefore not been adopted in our draft recommendations.

86 Oakley Parish Council advised it was content with the present grouping of Oakley, Pavenham, and Stevington parish councils in the existing Oakley ward. This was reflected in the Liberal Democrat scheme, with a -5% variance in a one- councillor ward. Pavenham Parish Council expressed a preference for being grouped with smaller parishes, such as Carlton & , , Milton Ernest, and Stevington, and requested it not be grouped with Clapham parish, owing to its much larger size. However, while this grouping would produce acceptable electoral equality, it would have the consequential effect of unsustainable wards in the wider area, particularly to the north.

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87 The Conservative scheme groups Clapham and Oakley parishes together in a two-councillor Clapham & Oakley ward with a 0% electoral variance by 2026. This ward notably excludes the area between the A6/A600 roundabout to the southern boundary of Clapham parish from the unparished urban area, placing this in Harpur ward. Following our changes to the Liberal Democrat scheme in Renhold & Ravensden ward (see paragraphs 76–79), we have decided to adapt the Conservative proposal to also include Stevington and Pavenham parish councils in a two-councillor ward with an electoral variance of 7%. While we recognise that Pavenham Parish Council requested that it not be grouped in a ward with Clapham, the grouping of larger and smaller is often an electoral necessity in rural areas. The alternative would be to group Clapham with Renhold and Ravensden parishes in a ward as in the Liberal Democrat scheme, as these are villages of a similar size to Pavenham. Our proposed Clapham & Oakley ward will have good electoral equality by 2026.

Wootton & Kempston Rural 88 We received a submission from Wootton Parish Council proposing that the ward’s representation be increased to two councillors, but that its boundaries – which are contiguous with those of the parish – are not split or enlarged. This was reflected in the Conservative scheme for the area, which made only a minor adjustment to the boundary between the existing Kempston Rural and Kempston West wards (see paragraph 70). The Conservative Group also proposed no changes to the boundaries of the existing Wootton ward. However, this creates a -15% electoral variance by 2026, according to the Council’s forecast, and we have therefore not adopted this proposal in our draft recommendations.

89 The Liberal Democrat scheme groups the parishes of Wootton and Kempston Rural into a two-councillor Wootton & Kempston Rural ward, having also moved the boundary between the ward and Kempston West to the A6 bypass. This creates a 0% electoral variance by 2026. We consider this proposal will provide an effective balance between our statutory criteria and have therefore adopted it as part of our draft recommendations.

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Conclusions

90 The table below provides a summary as to the impact of our draft recommendations on electoral equality in Bedford, referencing the 2019 and 2026 electorate figures with the new council size and wards from our draft recommendations. A full list of wards, names and their corresponding electoral variances can be found at Appendix A to the back of this report. An outline map of the wards is provided at Appendix B.

Summary of electoral arrangements

Draft recommendations

2019 2026 Number of councillors 46 46 Number of electoral wards 29 29 Average number of electors per councillor 2,829 3,237 Number of wards with a variance more than 10% 15 0 from the average Number of wards with a variance more than 20% 5 0 from the average

Draft recommendations Bedford Borough Council should be made up of 46 councillors serving 29 wards representing 12 single-councillor wards and 17 two-councillor wards. The details and names are shown in Appendix A and illustrated on the large maps accompanying this report.

Mapping Sheet 1, Map 1 shows the proposed wards for the Bedford Borough Council. You can also view our draft recommendations for Bedford Borough Council on our interactive maps at www.consultation.lgbce.org.uk

Parish electoral arrangements

91 As part of an electoral review, we are required to have regard to the statutory criteria set out in Schedule 2 to the Local Democracy, Economic Development and Construction Act 2009 (the 2009 Act). The Schedule provides that if a parish is to be divided between different wards it must also be divided into parish wards, so that each parish ward lies wholly within a single ward. We cannot recommend changes to the external boundaries of parishes as part of an electoral review.

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92 Under the 2009 Act we only have the power to make changes to parish electoral arrangements where these are as a direct consequence of our recommendations for principal authority warding arrangements. However, Bedford Borough Council has powers under the Local Government and Public Involvement in Health Act 2007 to conduct community governance reviews to effect changes to parish electoral arrangements.

93 As a result of our proposed ward boundaries and having regard to the statutory criteria set out in schedule 2 to the 2009 Act, we are providing revised parish electoral arrangements for Brickhill parish, Kempston parish and Kempston Rural parish.

94 We are providing revised parish electoral arrangements for Brickhill parish.

Draft recommendations Brickhill Parish Council should comprise 15 councillors, as at present, representing five wards: Parish ward Number of parish councillors East 4 North 4 South 2 West 3 Woodlands Park 2

95 We are providing revised parish electoral arrangements for Kempston parish.

Draft recommendations Kempston Town Council should comprise 21 councillors, as at present, representing three wards: Parish ward Number of parish councillors Central & South 8 North & East 9 West 4

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96 We are providing revised parish electoral arrangements for Kempston Rural parish.

Draft recommendations Kempston Rural Parish Council should comprise nine councillors, as at present, representing two wards: Parish ward Number of parish councillors The Ends 4 Wilkinson 5

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Have your say

97 The Commission has an open mind about its draft recommendations. Every representation we receive will be considered, regardless of who it is from or whether it relates to the whole borough or just a part of it.

98 If you agree with our recommendations, please let us know. If you don’t think our recommendations are right for Bedford, we want to hear alternative proposals for a different pattern of wards.

99 Our website has a special consultation area where you can explore the maps and draw your own proposed boundaries. You can find it at www.consultation.lgbce.org.uk

100 Submissions can also be made by emailing [email protected] or by writing to:

Review Officer (Bedford) LGBCE PO Box 133 Blyth NE24 9FE

101 The Commission aims to propose a pattern of wards for Bedford Borough Council which delivers:

• Electoral equality: each local councillor represents a similar number of voters. • Community identity: reflects the identity and interests of local communities. • Effective and convenient local government: helping your council discharge its responsibilities effectively.

102 A good pattern of wards should:

• Provide good electoral equality, with each councillor representing, as closely as possible, the same number of voters. • Reflect community interests and identities and include evidence of community links. • Be based on strong, easily identifiable boundaries. • Help the council deliver effective and convenient local government.

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103 Electoral equality:

• Does your proposal mean that councillors would represent roughly the same number of voters as elsewhere in Bedford?

104 Community identity:

• Community groups: is there a parish council, residents’ association or other group that represents the area? • Interests: what issues bind the community together or separate it from other parts of your area? • Identifiable boundaries: are there natural or constructed features which make strong boundaries for your proposals?

105 Effective local government:

• Are any of the proposed wards too large or small to be represented effectively? • Are the proposed names of the wards appropriate? • Are there good links across your proposed wards? Is there any form of public transport?

106 Please note that the consultation stages of an electoral review are public consultations. In the interests of openness and transparency, we make available for public inspection full copies of all representations the Commission takes into account as part of a review. Accordingly, copies of all representations will be placed on deposit at our offices and on our website at www.lgbce.org.uk. A list of respondents will be available from us on request after the end of the consultation period.

107 If you are a member of the public and not writing on behalf of a council or organisation, we will remove any personal identifiers. This includes your name, postal or email addresses, signatures or phone numbers from your submission before it is made public. We will remove signatures from all letters, no matter who they are from.

108 In the light of representations received, we will review our draft recommendations and consider whether they should be altered. As indicated earlier, it is therefore important that all interested parties let us have their views and evidence, whether or not they agree with the draft recommendations. We will then publish our final recommendations.

109 After the publication of our final recommendations, the changes we have proposed must be approved by Parliament. An Order – the legal document which

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brings into force our recommendations – will be laid in draft in Parliament. The draft Order will provide for new electoral arrangements to be implemented at the all-out elections for Bedford Borough Council in 2023.

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Equalities 110 The Commission has looked at how it carries out reviews under the guidelines set out in Section 149 of the Equality Act 2010. It has made best endeavours to ensure that people with protected characteristics can participate in the review process and is sufficiently satisfied that no adverse equality impacts will arise as a result of the outcome of the review.

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Appendices Appendix A Draft recommendations for Bedford Borough Council

Number of Variance Number of Variance Number of Electorate Electorate Ward name electors per from electors per from councillors (2019) (2026) councillor average % councillor average % 1 Allen Park 2 3,760 1,880 -34% 5,985 2,993 -8%

2 Biddenham 1 1,869 1,869 -34% 2,935 2,935 -9%

3 Brickhill 2 6,682 3,341 18% 6,746 3,373 4%

4 Britannia 1 1,914 1,914 -32% 3,083 3,083 -5%

5 Bromham 2 5,247 2,624 -7% 6,058 3,029 -6%

6 Castle 2 5,555 2,778 -2% 6,976 3,488 8%

7 Cauldwell 2 6,292 3,146 11% 7,056 3,528 9% Clapham & 8 2 6,372 3,186 13% 6,957 3,479 7% Oakley 9 De Parys 2 5,114 2,557 -10% 6,085 3,043 -6%

Elstow & 10 2 5,111 2,556 -10% 6,630 3,315 2% Shortstown

11 Goldington 2 6,244 3,122 10% 6,389 3,195 -1%

12 Great Barford 1 2,701 2,701 -5% 3,158 3,158 -2%

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Number of Variance Number of Variance Number of Electorate Electorate Ward name electors per from electors per from councillors (2019) (2026) councillor average % councillor average % 13 Great Denham 1 2,787 2,787 -1% 3,203 3,203 -1%

14 Harpur 2 5,516 2,758 -3% 6,395 3,198 -1%

15 Harrold 1 3,231 3,231 14% 3,312 3,312 2% Kempston Central 16 2 6,644 3,322 17% 6,695 3,348 3% & South Kempston North & 17 2 6,580 3,290 16% 6,747 3,374 4% East

18 Kempston West 1 2,984 2,984 5% 3,494 3,494 8%

19 Kingsbrook 2 6,278 3,139 11% 6,209 3,105 -4%

20 Newnham 2 6,095 3,048 8% 6,199 3,100 -4%

21 Putnoe 2 6,365 3,183 12% 6,413 3,207 -1%

22 Queens 1 2,397 2,397 -15% 2,996 2,996 -7% Renhold & 23 1 2,975 2,975 5% 3,164 3,164 -2% Ravensden 24 Riseley 1 3,227 3,227 14% 3,239 3,239 0%

25 Sharnbrook 1 2,536 2,536 -10% 3,031 3,031 -6%

26 Wilshamstead 1 3,461 3,461 22% 3,467 3,467 7%

27 Wixams & 2 3,598 1,799 -36% 6,884 3,442 6% Stewartby 42

Number of Variance Number of Variance Number of Electorate Electorate Ward name electors per from electors per from councillors (2019) (2026) councillor average % councillor average % Wootton & 28 2 5,729 2,865 1% 6,504 3,252 0% Kempston Rural 29 Wyboston 1 2,871 2,871 1% 2,911 2,911 -10%

Totals 46 130,131 – – 148,921 – –

Averages – – 2,829 – – 3,237 –

Source: Electorate figures are based on information provided by Bedford Borough Council.

Note: The ‘variance from average’ column shows by how far, in percentage terms, the number of electors per councillor in each electoral ward varies from the average for the borough. The minus symbol (-) denotes a lower than average number of electors. Figures have been rounded to the nearest whole number.

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Appendix B Outline map

Number Ward name 1 Allen Park 2 Biddenham 3 Brickhill 4 Britannia 5 Bromham 6 Castle 7 Cauldwell 8 Clapham & Oakley 9 De Parys

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10 Elstow & Shortstown 11 Goldington 12 Great Barford 13 Great Denham 14 Harpur 15 Harrold 16 Kempston Central & South 17 Kempston North & East 18 Kempston West 19 Kingsbrook 20 Newnham 21 Putnoe 22 Queens 23 Renhold & Ravensden 24 Riseley 25 Sharnbrook 26 Wilshamstead 27 Wixams & Stewartby 28 Wootton & Kempston Rural 29 Wyboston

A more detailed version of this map can be seen on the large map accompanying this report, or on our website: www.lgbce.org.uk/current- reviews/bedfordshire/bedford

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Appendix C Submissions received

All submissions received can also be viewed on our website at: www.lgbce.org.uk/current-reviews/bedfordshire/bedford

Political Groups

• Bedford Borough Conservative Group • Bedford Borough Labour Group • Bedford Borough Liberal Democrats Group • Bedford & Kempston Conservative Association • Mid Bedfordshire Conservative Association • North East Bedford Conservative Association

Councillors

• Councillor L. Bywater (Bedford Borough Council) • Councillor G. Coombes (Bedford Borough Council) • Councillor B. Foley (Bedford Borough Council) • Councillor J. Weir (Bedford Borough Council)

Parish and Town Councils

• Brickhill Parish Council • Clapham Parish Council • Elstow Parish Council • Great Denham Parish Council • Oakley Parish Council • Pavenham Parish Council • Renhold Parish Council • Wootton Parish Council

Local Residents

• 71 local residents

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Appendix D Glossary and abbreviations

Council size The number of councillors elected to serve on a council

Electoral Change Order (or Order) A legal document which implements changes to the electoral arrangements of a local authority

Division A specific area of a county, defined for electoral, administrative and representational purposes. Eligible electors can vote in whichever division they are registered for the candidate or candidates they wish to represent them on the county council

Electoral fairness When one elector’s vote is worth the same as another’s

Electoral inequality Where there is a difference between the number of electors represented by a councillor and the average for the local authority

Electorate People in the authority who are registered to vote in elections. For the purposes of this report, we refer specifically to the electorate for local government elections

Number of electors per councillor The total number of electors in a local authority divided by the number of councillors

Over-represented Where there are fewer electors per councillor in a ward or division than the average

Parish A specific and defined area of land within a single local authority enclosed within a parish boundary. There are over 10,000 parishes in England, which provide the first tier of representation to their local residents

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Parish council A body elected by electors in the parish which serves and represents the area defined by the parish boundaries. See also ‘Town council’

Parish (or town) council electoral The total number of councillors on any arrangements one parish or town council; the number, names and boundaries of parish wards; and the number of councillors for each ward

Parish ward A particular area of a parish, defined for electoral, administrative and representational purposes. Eligible electors vote in whichever parish ward they live for candidate or candidates they wish to represent them on the parish council

Town council A parish council which has been given ceremonial ‘town’ status. More information on achieving such status can be found at www.nalc.gov.uk

Under-represented Where there are more electors per councillor in a ward or division than the average

Variance (or electoral variance) How far the number of electors per councillor in a ward or division varies in percentage terms from the average

Ward A specific area of a district or borough, defined for electoral, administrative and representational purposes. Eligible electors can vote in whichever ward they are registered for the candidate or candidates they wish to represent them on the district or borough council

48 Translations and other formats: To get this report in another language or in a large-print or Braille version, please contact the Local Government Boundary Commission for England at: Tel: 0330 500 1525 Email: [email protected]

Licensing: The mapping in this report is based upon Ordnance Survey material with the permission of Ordnance Survey on behalf of the Keeper of Public Records © Crown copyright and database right. Unauthorised reproduction infringes Crown copyright and database right. Local Government Boundary Commission for Licence Number: GD 100049926 2020 The Local Government Boundary England Commission for England (LGBCE) was set LGBCE A note on our mapping: up by Parliament, independent of PO Box 133 Government and political parties. It is Blyth The maps shown in this report are for illustrative purposes only. Whilst best directly accountable to Parliament through a NE24 9FE efforts have been made by our staff to ensure that the maps included in committee chaired by the Speaker of the this report are representative of the boundaries described by the text, there House of Commons. It is responsible for may be slight variations between these maps and the large PDF map that conducting boundary, electoral and Telephone: 0330 500 1525 accompanies this report, or the digital mapping supplied on our consultation structural reviews of local government. Email: [email protected] portal. This is due to the way in which the final mapped products are produced. Online: www.lgbce.org.uk The reader should therefore refer to either the large PDF supplied with this report or the digital mapping for the true likeness of the boundaries intended. The boundaries as shown on either the large PDF map or the digital mapping should always appear identical.