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Bedford Local Plan 2040 Submission Version Consultation

25th July 2022

CPRE Bedfordshire has published its full response to the Bedford Borough Council (BBC) Local Plan 2040 Submission Draft Consultation. You can find a link to the document at the bottom of this page.

CPRE Bedfordshire believes in a democratic approach to planning and Local Plans are the cornerstone of our planning system. We commend Bedford Borough Council’s commitment to maintaining an up to date Local Plan and the efforts they have made to open up the plan making process for the involvement of local people.

There are many aspects of the draft plan that we support. However, the context for the draft plan in terms of national planning policy is complex and problematic. The key objections that CPRE Bedfordshire expresses in our consultation response are very much associated with aspects of national planning policy.

The principal objections to the Local Plan 2040 put forward by CPRE Bedfordshire relate to aspects of government policy aimed at boosting housing supply. Government ministers have stated that they are unwilling to show flexibility on the impact for Bedford of the government formula of assessing housing need (known as the Standard Method) because of concerns about delivery. However, we believe that these concerns are unjustified when Bedford Council has a record of consistently delivering or exceeding the housing requirement set in development plans in recent years.

Bedford Council’s strategy on housing growth is set out in the Introduction, the Vision and Objectives, and the Growth and Spatial Strategy sections of Local Plan 2040. The issues arising from this strategy give rise to our principal objections to the plan. CPRE Bedfordshire’s views on these areas are addressed collectively in in the first section of our response headed ‘Environmentally Unsustainable Housing numbers.’

Some of the other issues addressed in our response are listed below. More detail on all of these points can be found in the full submission which is linked at the bottom of this page.


River Great Ouse and Valley Area – a “Valued Landscape”

CPRE Bedfordshire commented in our initial consultation response that the Local Plan Vision fails to recognise the importance of the “River Great Ouse and its Valley Area” right across the Borough from its point of entry near Turvey to where it exits the Borough in the east. This is a serious omission that should be remedied.

The Great Ouse at Harrold

Climate Change

CPRE Bedfordshire commented in response to the Local Plan consultation of 2021 that we would like to see the plan go beyond general statements of intention to work towards making Bedford a carbon neutral borough and build in some stronger and more specific targets in support of this objective.



There remains a complete absence of any detailed recognition of the need for a sustainable network of safe segregated cycle routes across the Borough – e.g. North South linking Wixams (bridging the A421) to Milton Ernest through the centre of Bedford. There is also no mention of a safe segregated cycle route to Bedford Station – it is deeply
unsatisfactory that the there is still no segregated cycle route to Bedford station from any direction.


Rail Travel – “A Rail Strategy for Bedford” May 2022

It is deeply unsatisfactory that BBC has introduced an updated Rail Strategy without any public consultation and without it being discussed and agreed at a Full Council Meeting where councillors of all political parties are in attendance, members of the general public and the media. This paper is a major update of the previous Rail Strategy and in view of the considerable concern regarding the impact of East West Rail on our Borough this document should have followed an open democratic process.

East West Rail route corridor

Open Space Standards – Ownership of open green space on new developments

In the 2021 consultation CPRE Bedfordshire proposed that all open green space within new housing development should be handed over to Town & Parish Councils for long term maintenance and not held onto by developers who charge residents much higher maintenance costs. There have been many complaints from Parish Councils and residents regarding this practice. We can find no reference in the Submission Draft to any steps taken to remedy this problematic area.


Natural environment policies

Policy NE1 –Environmental Net Gain is welcomed but there remains unclear to us how the delivery of biodiversity net gain will work in practice.

Wildflowers, Oakley

Water & Sewage Supplies

Bedford Borough already has very serious water supply issues as recognised by the Environment Agency but nowhere in this Local Plan does BBC consider this issue. The Sewage System in Bedford Borough is also creaking at the seams and in need of massive investment just to keep the current housing stock properly serviced without polluting our River Great Ouse even further. Local Plan 2040 is silent about how this massive number of new homes will receive an environmentally sustainable sewage system.


Download the full response Submission version response LP 2040 July 22 Final

Read more about this consultation


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Priory Country Park, Bedford
Quernmore landscape