Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Ended on the 3rd September 2021
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1.0 Introduction

Why we are preparing the Local Plan 2040

1.1 Bedford Borough Council has an up to date local plan that makes provision for growth to 2030. Normally local plans are reviewed every five years but this update is required sooner in order to reflect emerging national policies for the Oxford to Cambridge Arc. Policy 1 of the Local Plan 2030 requires that the review is progressed swiftly, with the submission of the plan to government for examination by January 2023 so that examination in public can commence. If that deadline is missed, then for the purposes of determining planning applications our local plan policies will be deemed to be 'out of date' in the same way as they would if we were to be unable to show a five year supply of housing land, meaning that local control over where development will happen will be much reduced.

1.2 The timetable set for the Council's plan review was challenging before the Covid-19 pandemic began, but the change in working practices and limitations placed on the Council's staff, partner organisations and the Council's consultants over the past 15 months has meant that keeping on-track has been extremely difficult. Progress has been slowed as a result of the switch to remote working, restrictions on site visits (especially during the first half of 2020) and depleted staff resources across the Council and within other agencies.

1.3 Nevertheless, a first Issues and Options consultation took place as scheduled during summer 2020. The purpose of that first stage was to invite comment on the scope of the review, the time period that an updated plan should cover and the kinds of locations where future growth might take place. The responses to that consultation have informed this document and in particular have helped to shape the growth options that appear in later sections. A summary of consultation comments is available (see Table 1) and all responses are published in full on-line.

1.4 At the same time the Council issued a 'call for sites' to update information received during 2014 and 2015 about land that owners wish to make available for development. Around 430 sites were submitted to the Council and similarly these have been available to view on the Council's web site since autumn 2020.

National context and plan period

1.5 National Policy requires that strategic policies in local plans should look ahead over a minimum of 15 years from adoption[1]. With adoption planned for late 2023, the shortest end-date for this plan would be 2038. A longer timescale would have the advantage of giving certainty for a longer period but, as is explained in the paragraphs below, many important strategic decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years. As a result, and having considered the 2020 consultation responses, the Council's view is that 2020 - 2040 is an appropriate time period for this plan. With a requirement now for five-yearly local plan reviews there will be sufficient opportunity to plan beyond 2040 once the regional planning context is clearer.

1.6 The government's ambition for the Oxford to Cambridge Arc is well-reported. In the document 'The Oxford-Cambridge Arc Government Ambition and Joint Declaration between Government and Local Partners' (2019) lead Ministers recognise the existing qualities of the location and its potential to attract additional higher quality jobs for existing and new communities. They promote taking a long term view to 2050 and beyond, and commit to embedding 'natural capital' thinking throughout the government's approach to growth, which includes an ambition for up to one million high-quality new homes by 2050.

1.7 The declaration itself is silent on housing numbers. It recognises that the Arc is first and foremost an area of significant economic strength and opportunity, and through the joint declaration the partners (including the then 43 local authorities across the Arc) set out to meet the Arc's full economic potential for the benefit of existing and future local communities and businesses, and in the national interest. There is acknowledgement that to achieve this will demand collective determination over the long-term, to deliver significantly more homes in the Arc, of the right quality and in the right places to meet its needs. Also that this might include the expansion of existing as well as the development of new settlements. It will require long-term commitments to provide the enabling infrastructure and to deliver that ahead of the arrival of new communities, and to meet economic and housing ambitions while overall improving rather than degrading the environment in the Arc, in line with commitments in the government's 25 Year Environment Plan[2].

1.8 In February 2021 the government published a policy paper entitled 'Planning for sustainable growth in the Oxford-Cambridge Arc: an introduction to the spatial framework'. It explains why the government is committed to developing a spatial framework for the Arc; what it will mean for growth, spatial planning and infrastructure provision in the area; and how government will work with communities and local partners to develop it. The intention is to '…develop a long-term Spatial Framework for the Arc that will support better spatial planning, provide a blueprint for better-targeted public investment, give investors and businesses greater long-term certainty over growth plans, and allow communities to shape the long-term future of places across the region. The nature and content of the Spatial Framework will be subject to the outcome of both detailed consultation and sustainability appraisal' (para 2.1). A first public consultation is planned for summer 2021 which is two years later than initially intended in the joint declaration.

Diagram from 'Planning for sustainable growth in the Oxford-Cambridge Arc: an introduction to the spatial framework'

1.9 In response to this delay, some local authorities in the Arc have adjusted their local plan production timetables so that planning activity follows the development of the Arc Spatial Framework in order to create a more joined up process. Government however has urged Councils in the Arc to carry on with plan-making and, in Bedford Borough's case, the consequences of not doing so could be significant for the reasons relating to policies becoming "out of date" described above; so preparation of this local plan must continue. The relationship between the local plan timetable and the published timetable for the preparation of the Arc Spatial Framework is shown below.

1.10 Whilst this local plan will progress alongside the development of the Spatial Framework it shares many of the overarching principles relating to economic growth and the natural environment. In these respects, the two will be aligned.

1.11 A review of business space will inform the allocation of new employment land in order to support the expansion of existing businesses and to attract inward investment. Where housing growth is concerned, as a result of existing commitments (including those made and to be made in neighbourhood plans) and new allocations to be made in this plan, Bedford Borough will make provision for significantly more homes as described in the Arc joint declaration. It will do this as a result of government's new standard method for calculating housing need which means an uplift of 33% when compared to the locally-calculated housing growth planned for in the Local Plan 2030.

1.12 The Council already has strong planning policies to protect and enhance the natural environment and as the new Environment Bill passes through its various parliamentary stages, the Council will consider how any of these policies need to change to bring them up to date. Strategic work to map the location of natural capital assets across the Arc is being translated to a more localised geography and we will look to see how our policies might embrace this new way of identifying environmental value and potential to achieve net gains alongside development.

1.13 Local Plan 2040 and Arc Spatial Framework Timetables

 

Summer 2021

Autumn 2021 – Spring 2022

Summer 2022

Autumn 2022

January 2023

Throughout 2023

Winter 2023

Local Plan 2040

Consultation on draft development strategy options, draft policies and submitted sites

Consider responses and prepare plan for submission

Plan for submission consultation

Consider responses, prepare final plan and supporting documents

Submit plan to Planning Inspectorate

Examination in Public involving public hearing sessions. Consultation on main modifications

Publication of Inspector's report

Adoption of plan

Arc Spatial Framework

Consultation - developing a vision for the future of the Arc

Spring 2022 - Consultation on options for turning the vision into policy

Consider responses

Consultation on draft spatial framework

 

Implement final Arc Spatial Framework

 

 

The scope of the plan

1.14 The Local Plan 2040 will be a partial update of existing policies. The Local Plan 2030 was adopted only last year and the vast majority of its policies are up to date and do not need to change. Remaining policies in the earlier Allocations and Designations Local Plan have been reviewed and, in the majority of cases, they remain fit for purpose and similarly do not need to change at this time. We asked for views about the scope of the plan during last year's consultation and the responses have helped us to focus on the following key policy areas:

  • Development Strategy to 2040 and delivery of growth in order to meet national policy requirements
  • Town centre and retail policies in order to support a more flexible future for our centres with a reduced focus on retailing
  • Updated development management policies (those used to help make decisions on planning applications) to do with
    • Self-build and custom homebuilding
    • Quality of development and residential space standards
    • Environmental net gain

1.15 The reasons why new policies for other subjects are not proposed in this paper are explained in Section 8.0 below.

1.16 Appendix 1 shows which current planning policies would be replaced by proposed new ones.

1.17 Following on from last year's consultation we have considered comments about the different locations for growth and have developed combinations that could deliver new jobs and homes. A long list of options is given in the Development Strategy Topic Paper and a fuller list in the Sustainability Appraisal.

1.18 The Council's emerging preferred options are listed below in Section 3 but your comments are now invited on all options before a choice is made, and we ask you to tell us of others that you think should be considered.

1.19 Before deciding on a strategy and selecting land for development we are also inviting comments on the call for sites submissions. The assessment work so far completed by the Council is available to help you.

1.20 In addition, we are publishing for comment the latest evidence base documents. These may be updated in the light of comments we receive and, along with other evidence including a plan wide viability appraisal, will be available again for you to comment on at the next stage (during 2022).

1.21 The evidence base documents are as follows. If you have any comments to make on them at this stage please make them against the relevant paragraph numbers:

Evidence base

1.22 Bedford Borough Natural Capital Assessment Report - Natural Capital Solutions

1.23 Bedford Borough Transport Model New Settlements and the A6 - AECOM

1.24 Bedford Borough Transport Model New Settlements and the Black Cat junction - AECOM

1.25 Bedford Borough Transport Model New Settlement West of Wyboston - AECOM

1.26 Bedford Borough Transport Model Local Plan Assessment Report - AECOM

1.27 Bedford Borough Transport Model Local Plan Assessment Summary Report - AECOM

1.28 Development Strategy Topic Paper - BBC

1.29 Bedford Employment Land Study – 2021 (Part 1) - BBC

1.30 Bedford Employment Land Study – 2021 (Part 2) - BBC

1.31 Gypsy & Traveller Accommodation Assessment - ORS

1.32 Healthy Weight Environments Topic Paper - BBC

1.33 Issues & Options Consultation - summary and responses - BBC

1.34 Landscape Character Assessment - LUC

1.35 Local Housing Needs Assessment (LHNA) - ORS

1.36 Bedford Town Centre Study - NEXUS

1.37 Self-build Topic Paper - ORS

1.38 Town Centres and Shopping Policies Topic Paper - BBC

1.39 Site Selection Methodology – update June 2021 - BBC

1.40 Site Assessment Pro formas - BBC

1.41 Small Sites Topic Paper - BBC

1.42 Strategic Flood Risk Assessment (part 1) - JBA

1.43 Strategic Flood Risk Assessment Appendices - JBA

1.44 (Draft) Sustainability Appraisal Report - BBC

1.45 The following documents are not yet available for comment, but will be finalised in order to support the plan for submission (2022).

Evidence Base document title

Status

Bedford Borough Playing Pitch Strategy

Commissioned

Crematoria and burial capacity

Commissioned

Hotel and visitor accommodation

Commissioned

Infrastructure Delivery Plan

BBC to prepare alongside site allocations

Housing and Employment Land Availability Assessment

Draft methodology consulted on in July 2020. Update to be prepared

Settlement Hierarchy (September 2018)

Review underway

(Final) Sustainability Appraisal Report

To be prepared

Plan wide viability assessment

To be commissioned

 

Neighbourhood planning

1.46 Several of the borough's parish councils have already played a significant role in progressing commitments for housing growth in the 2020 - 2040 plan period. Given the opportunity back in 2017, ten local communities chose to prepare neighbourhood plans and make their own allocations for development in accordance with requirements in the Local Plan 2030. Despite the challenges presented by Covid-19, all but one have submitted their neighbourhood plans to the Council and six are now formally 'made'.

1.47 In total we estimate that the made and emerging neighbourhood plans will deliver around 2,260 dwellings. This contribution is acknowledged as the local plan strategy is rolled on to 2040.

1.48 Discussions with parish councils will continue during the preparation of the Local Plan 2040. If the favoured strategy involves additional development in and around villages where there is a genuine choice of site available, we will ask parish councils if they would like to select site(s) in a new or reviewed neighbourhood plan.

1.49 We would not expect neighbourhood plans to make large strategic allocations in locations where there is not a choice of site (for example a new settlement), including those that in some cases cross parish boundaries. These will be allocated in the Local Plan 2040.

1.50 As has already been the case, communities may decide to make neighbourhood plans and allocate development sites even though the local plan strategy doesn't require growth to be located there. Should this continue to happen, it will add choice and flexibility on top of allocations made in the Local Plan 2040.

1.51 We will continue to encourage groups to prepare neighbourhood plans and to support and work with local councils in a joined-up way to make sure that local and neighbourhood plans work together to support planning at the local level.

Summary

1.52 Whilst there remain many uncertainties about planning for our borough area as a result of the emerging Oxford to Cambridge Arc Spatial Framework, the selection of a route for East West Rail following their recent consultation and indeed the timing of the introduction of a new national planning system following consultation by government on the 'Planning for the Future' White Paper[3], the progression of this local plan will enable the Council and local communities to maintain control over the selection of locations for growth.


[1] NPPF 2019 Para 22. Town Centre policies to look ahead at least 10 years Para 85.

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