Issues and Options
1. Introduction and consultation information
Every local authority in the country is tasked with preparing and adopting a local plan. The Government's policy document, the National Planning Policy Framework, describes a local plan as 'a plan for the future development of a local area, drawn up by the local planning authority in consultation with the community'.
Bedford Borough Council has prepared and adopted several local plans over the years. This means that planning policies are contained in more than one document and together those documents are known as the development plan. The development plan for Bedford borough is made up of policies in the following plans that the Borough Council has adopted:
- Local Plan 2002. Most policies have been replaced but some site specific policies relating to developments that are not yet complete are still needed (for example Wixams, north of Bromham Rd Biddenham and Wootton).
- Allocations and Designations Local Plan 2013. Some policies have been replaced but others remain relevant and up to date.
- Local Plan 2030. Recently adopted. Policies making provision for growth will need to be updated but most other policies will not need to be replaced.
- Neighbourhood plans made. At the time of writing, these cover the parishes of Carlton & Chellington and Oakley.
These documents are important because the law says that the local planning authority must make decisions on planning applications in line with adopted policies unless there are good reasons (known as material considerations) not to. If councils don't have up to date policies then it is very difficult to control where development takes place.
The Local Plan 2030 was adopted in January 2020 following an independent examination in public. National policy now requires that local plans are reviewed and if necessary updated every five years, but in Bedford's case the examination resulted in the inclusion of a new policy in the Local Plan 2030 committing the Council to a more challenging review timetable. An updated or replacement plan must be submitted for examination by January 2023.
The first reason given for this by the examining Inspectors was that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible. They agreed that because of the uncertainty about Arc–related development and infrastructure needs post 2030, the plan they had been asked to consider should not try to do that, but that the next plan should do so fairly quickly. The second reason related to the speed with which new development would be built in coming years and the progress being made by local communities with their own neighbourhood plans, which the Local Plan 2030 relies upon to identify housing sites. The Inspectors saw that an early review of the Local Plan 2030 offers the opportunity for the Council to intervene if necessary, in order to maintain house building rates.
The Oxford to Cambridge Arc
The Government has a long-term ambition to see economic growth in the Oxford to Cambridge Arc. The area within the Arc is shown in Figure 1. It extends to include Buckinghamshire and Oxfordshire authorities in the south and west to Cambridgeshire authorities in the east and north. Bedford borough lies in the centre of the Arc.
Figure 1 Defining the Oxford – Cambridge Arc
Taken from 'The Oxford-Cambridge Arc: Government ambition and joint declaration between Government and local partners'
In a document published by the Ministry of Housing, Communities & Local Government in 2019 the Government explained its ambition in more detail and, through the document, the local authorities across the Arc and other organisations (including the Local Enterprise Partnerships) have agreed to work together to consider the area's long term potential, and how that might be achieved.
More detail can be found in the document itself 'The Oxford –Cambridge Arc: Government ambition and joint declaration between Government and local partners'.
The Government has designated the Arc as a key economic priority and expressed its ambition for up to one million new homes to be built across the area by 2050. It has committed to completing a new East West Rail route joining Oxford to Cambridge as well as a new expressway, whilst improving the environment for the future. The joint declaration committed to a broad, joint public engagement exercise over summer 2019, and at the time of the Local Plan 2030 examination (and discussion about the plan's review policy) this engagement was anticipated as a means of taking forward discussions about how and where in the Arc this scale of growth might be accommodated.
However, the engagement has yet to take place and questions have been asked about the need for the expressway in the western section of the Arc. The section between the Black Cat roundabout and Caxton Gibbet is further advanced. In its Annual Monitoring report 2020 the National Infrastructure Commission acknowledged that 'there is still a long way to go and no clear plans have been brought forward to increase the delivery of new homes to reach the level needed'. In the report the NIC called on Government to clarify its position on and agreeing the route for the Oxford – Cambridge Expressway, maintain momentum on East West Rail, develop a spatial vision for the Arc, announce the locations of new settlements connected to key transport infrastructure, establish clear ministerial ownership for the Arc and publish the final report of its economic study into the area.
The corridor for the new East West Rail route has now been announced and further consultation (expected in late 2020 / early 2021 will help to identify the best alignment (Figure 2). The corridor chosen is good news for Bedford as it will bring the route through Bedford Midland Station, connecting the town directly to Oxford and Cambridge and supporting economic growth and prosperity by attracting businesses and jobs to the area. With this route East West Rail is forecast to bring over £20 million of additional economic activity to the borough.
Figure 2 The preferred corridor for East West Rail north of Bedford.
From the above it can be seen that little progress has been made on how the high-level ambitions for the Arc can or will translate into identifying where strategic growth is likely to be delivered.
Work on this local plan will therefore focus on how to meet Bedford Borough's own growth requirements based on the Government's published standard method for calculating housing need. This alone will be a significant challenge because it represents a 35% increase in the annual level of housing growth contained in the Local Plan 2030. Further detail about this is given below.
Twenty neighbourhood plans are being prepared in Bedford Borough and those that are identifying sites to meet growth targets in the Local Plan 2030 are making good progress. Two have so far been 'made' following local referendums meaning that they are now part of the development plan along with the plans that the Borough Council has prepared. Up to date information about neighbourhood plans can be found on the Council's neighbourhood planning web pages.
In due course parish councils with neighbourhood plans in place will decide if they want to review those plans to allocate development beyond 2030, either in accordance with the local plan review or because there is a local need to do so. If parish councils do not want to update neighbourhood plans then they can work with the Borough Council to include in the local plan review any additional sites that are needed.
What is this consultation about?
The process for the preparation of a local plan is set out in Government legislation and includes consultation with the public and statutory bodies at set stages. The purpose of this paper is to ask for your comments on the scope of the plan; the issues that its policies should cover and the options available to address them. Our website will be kept up to date with all of the relevant information www.bedford.gov.uk/localplanreview.
While the scale of housing and associated growth is set by the Government, there are a number of different ways in which this can be achieved. We are asking residents and people who work in the borough, as well as statutory consultees and others with an interest in our plan, for your opinions to help us plan for future development and identify what issues are important. This is your first opportunity to help shape the local plan review.
Sustainability appraisal and scoping report
Sustainability appraisal is a process that makes sure that the environmental, social and economic effects of a plan, and reasonable alternatives to the plan, are being considered. As a first step, a Scoping Report has been prepared in consultation with the Environment Agency, Natural England and Historic England to identify the key sustainability issues that are relevant to the new local plan and develop a framework for appraisal. This framework will be used to test the social, economic and environmental impacts of emerging options for the local plan. It will help in developing the most sustainable strategy for future development in the borough and identifying where measures are necessary to mitigate any negative effects that cannot be avoided. The results of this testing will be included in a draft Sustainability Appraisal Report which will be published alongside the draft local plan for public consultation next year.
How to get involved
Questions on key matters are highlighted in various places in the document and you should answer these on the separate response form; however you do not have to answer every question. The easiest way to comment is by using this on-line consultation page (for example where you see comment icons next to questions). We prefer you to use this facility because it is easy for you to use, helps us and you to maintain accurate records and also helps at later stages with the formal local plan examination process. You can save and go back to your questionnaire responses at any time during the consultation period so you do not have to complete it in one go. The system will also enable you to keep track of the comments you make at each stage of the plan's preparation going forward.
Alternative ways to comment:
Download the word version of the questionnaire available on the webpage. Once you have completed it please send it to firstname.lastname@example.org.
Complete a paper questionnaire (which can be requested by calling the Planning Policy Team on 01234 718070). When completed this should be sent to (please use a stamp):
Planning Policy Team
Bedford Borough Council
Bedford, MK42 9AP
A paper copy of the Issues and Options Paper can be viewed by appointment at the Council's Customer Service Centre at 2 Horne Lane, Bedford MK40 1RA (01234 267422). It will also be available in all libraries in the borough as well as Biggleswade, Rushden, Flitwick and St Neots libraries during normal opening hours should access restrictions be lifted before or during the consultation period.
Responses received will be published on the Council's web site and attributed to source (this may include your name and a reference number). All responses will be treated in accordance with the Data Protection Act 2018. The Privacy Statement relating to the local plan can be viewed here.
Do you have questions or need further information?
You may have questions or require more information before you feel able to comment. Ordinarily we would hold drop in sessions around the borough, however due to current COVID19 restrictions we are unable to do this. To assist you we have a Question and Answer web page which covers common queries and information which may help you. If not, you can email your question to email@example.com – ideally put 'consultation question' as the title of your email. Additionally we have a dedicated phone line (01234 718300) where you can leave an answer phone message. We will monitor these and ensure the most appropriate officer calls you back within three working days. Please give a summary of your question and leave your name and contact number.
The consultation will close at 5pm on 4th September 2020
Please note the closing date for submitting potential development sites is 14th August 2020 – see call for sites.
The next steps and timetable
The responses to this issues and options consultation will help us write a draft plan, which you will have an opportunity to comment on in mid-2021. This will help us gauge public reaction to proposed draft allocations and policies and make changes to improve the plan. A further consultation on a final 'plan for submission' will take place during summer 2022, after which we will consider responses and submit the plan to the Secretary of State for independent examination. More details about this timetable are set out below:
Local Plan review timetable
Autumn – winter 2020
Autumn 2021- Spring 2022
Evidence base gathering
Issues and options consultation
Consider responses to Issues and options consultation and call for sites information
Undertake site assessments
Evidence base gathering
Prepare draft plan
Draft plan consultation
Consider submissions to draft plan and prepare plan for submission
Plan for submission consultation
Consider responses to plan for submission consultation and prepare final plan and supporting documents
Submit plan to Planning Inspectorate
Examination in Public involving public hearing sessions
Likely to include consultation on main modifications
Publication of Inspectors report
Adoption of plan
National policy sets out the broad planning principles that local plans must comply with. Importantly it explains that the local plan is the basis for making decisions on planning applications and that is why it is important that the plan is up to date.
More information on publicity and consultation in the local plan process and guidance on how to make effective comments are contained in the Statement of Community Involvement 2019 (www.bedford.gov.uk/SCI) as temporarily amended to take account of restrictions in place during the COVID19 pandemic.
Scope of the plan
This plan review will focus mainly on growth and infrastructure (housing, employment and supporting infrastructure). It is the Council's view that because they have been recently adopted, the majority of the development management policies in the Local Plan 2030 do not need to be updated. However, some of our policies are older and local evidence or national guidance means that those policies need to be brought up to date.
Through the local plan review we propose to
- develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements
- include new policies for the repurposing of the town centre
- include policies to improve the quality of development
- include a policy to deliver self & custom build opportunities
- consider the need for additional policies to address climate change
- consider the need for policies to control the location of food outlets
- consider the need to update open space standards to be provided alongside new development
- consider the need to change current policies for the natural environment following the publication of the Environment Act
Do you agree with the proposed scope of the local plan review? If you think that other areas of existing policy should be updated or new policy areas added to the list, please explain what they are and your reasons for wanting them to be included in the plan.