Question 3
No answer given
It is noted that other authorities within the Arc are considering preparing plans over a longer period to 2050 (including West Northamptonshire and Milton Keynes). Having consistency across the Arc would be beneficial in aligning strategies for growth and infrastructure across local authority boundaries. Further, this would align with the announcement in the Government’s Budget of March 2020 to prepare a long-term spatial framework in the Oxford to Cambridge Arc up to 2050. This Local Plan Review could clearly have a role in informing the content of the Government’s spatial framework, particularly so if it aligns with its timeframe.
It is noted that other authorities within the Arc are considering preparing plans over a longer period to 2050 (including West Northamptonshire and Milton Keynes). Having consistency across the Arc would be beneficial in aligning strategies for growth and infrastructure across local authority boundaries. Further, this would align with the announcement in the Government’s Budget of March 2020 to prepare a long-term spatial framework in the Oxford to Cambridge Arc up to 2050. This Local Plan Review could clearly have a role in informing the content of the Government’s spatial framework, particularly so if it aligns with its timeframe.
It is noted that other authorities within the Arc are considering preparing plans over a longer period to 2050 (including West Northamptonshire and Milton Keynes). Having consistency across the Arc would be beneficial in aligning strategies for growth and infrastructure across local authority boundaries. Further, this would align with the announcement in the Government’s Budget of March 2020 to prepare a long-term spatial framework in the Oxford to Cambridge Arc up to 2050. This Local Plan Review could clearly have a role in informing the content of the Government’s spatial framework, particularly so if it aligns with its timeframe.
No answer given
I agree with the plan period as it stands. The speed of innovation in response to health, climate change and other emergencies may well affect perspectives in development. It seems realistic to have a relatively short time frame whilst being alert to the need for modification/contingency planning.
Yes I do ,
The plan period is a plausible maximum with current multi-factor uncertainty (Covid19, Brexit, and climate crisis). There is a need to question the level of housing growth - The latest 2018 ONS data means that the Standard Method Calculation, as per Government guidance, gives a much reduced figure for housing need of 800 dwellings per year. The Oxford – Cambridge Arc, and the enormous associated development and population growth has not been subjected to Public Consultation or Environmental Impact Assessment, and thus it is not appropriate to take into account SEMLEP’s Industrial Strategy.
The Plan Period to 2040 is appropriate in the circumstances although because of the wide range of possible housing numbers, as referred to in Section 3, any period at this stage can only compound the uncertainty.
The plan period is a plausible maximum with current multi-factor uncertainty (Covid19, Brexit, and climate crisis). There is a need to question the level of housing growth - The latest 2018 ONS data means that the Standard Method Calculation, as per Government guidance, gives a much reduced figure for housing need of 800 dwellings per year. The Oxford – Cambridge Arc, and the enormous associated development and population growth has not been subjected to Public Consultation or Environmental Impact Assessment, and thus it is not appropriate to take into account SEMLEP’s Industrial Strategy.
I agree with policy of limiting this plan period to 2040 due to the inherent difficulty of predicting what will be needed in 20 years.
No answer given
We do not have a strong view, 2020-2040 is acceptable.
Given the details provided within the Strategy & infrastructure section locations outside of any currently identified areas of development - no issues with timescales proposed.
The Plan Period to 2040 is appropriate in the circumstances although because of the wide range of possible housing numbers, as referred to in Section 3, any period at this stage can only compound the uncertainty.
2050 to complement the plan for the Oxford Cambridge Arc
Hallam does not agree with the shortest local plan period. Hallam considers that the local plan should be prepared to cover a much longer-term period to be more effective. The plan should cover a plan period suitable for meeting a strategy that is enduring for accommodating growth across the Borough, in a way that meets the needs of the Borough and contributes effectively to growth ambitions of the Oxford Cambridge Arc. A longer-term plan period would allow the Borough Council to plan more appropriately for future strategic development allocations / locations which would in turn inform more strategic and longer-term infrastructure requirements. A shorter-term approach is more likely to repeat the cycle of creating local plans that risk being out of date upon adoption, require immediate review, and generate continued uncertainty about how the Borough accommodates development in the future. Shorter term planning is also likely to only enable infrastructure provision that is more piecemeal, short term, and of insufficient capacity, compromising the Borough’s longer-term future growth potential. Hallam proposes a plan end date of 2050 to align with strategic and infrastructure planning in the Oxford-Cambridge Arc.
Paragraph 22 of the NPPF requires that strategic policies should look ahead over a minimum 15 years period from adoption to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Based on the expected timetable for the adoption of the Local Plan Review, 2040 should be the minimum period that this Plan covers. The Oxford to Cambridge Arc is however a key economic priority for the Government with ambitions for significant economic and housing growth, supported by major improvements in infrastructure that are expected to be delivered during the period to 2050. As a result, the Budget announced in March 2020 that it plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the Ox Cam Arc up to 2050. Indeed, both Oxfordshire and the Cambridgeshire and Peterborough Combined Authority, either side of Bedford Borough, are preparing Strategic Plans to guide future plans and investment up to 2050. On this basis, we would suggest that serious consideration is given to extending the Plan period to 2050.
3.1 We consider that an end date for the plan of 2040 generally accords with the NPPF (paragraph 22) requirement which sets out that the strategic policies for an area ‘should look ahead over a minimum 15- year period form adoption’. Assuming the current timetable is followed then an end date of 2040 would satisfy this requirement. 3.2 However, Taylor Wimpey advocate the review looking beyond 2040 which a) ensures the 15-year requirement can be achieved in light of any programme slippage and b) reflects the nature of growth which is likely to be included in the reviewed Local Plan. 3.3 As already set out, Taylor Wimpey are promoting a new settlement which could deliver up to 10,000 new homes. Given the lead in time with any new settlement, it is likely that should a new settlement be included in the strategy it would not be completed by 2040. It would therefore be sensible to consider the contribution the spatial strategy could make to development needs beyond 2040. 3.4 Irrespective of the end date of the revised Local Plan, it is considered that a plan period which starts at 2020 is appropriate given that that this will be the base date for the evidence gathered to support the Plan.
I agree with this Plan timescale. This is a period of rapid change and also uncertainty re future jobs, growth and how people travel to work, if at all. Better to limit the Plan date than it become out of date.
The plan period should be a minimum of 20 years to allow security of long terms planning and to ensure the necessary infrastructure can be planned positively.
We would generally agree that for a strategic plan of this nature a Plan period of 20 years (2010-2040) would be appropriate. However, Bedford’s location within the Oxford-Cambridge Arc is in our opinion sufficient justification to take a differing approach. The NPPF at paragraph 22 outlines 4 that “Strategic Policies should look ahead over a minimum of 15-year period, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure”. There is however no upper limit applied and as such it is up to the discretion of the LPA to plan for an appropriate timeframe having regard for its localised circumstances. 2.4 All constitute Council’s within the Arc have agreed to the Joint Declaration of Ambition between Government and the Arc and as such should act in a way which aligns with this declaration. The seventh paragraph of the declaration states “We recognise that meeting all these ambitions for the Arc requires us to take a long-term view, at least to 2050…”. Given the significant housing, employment and infrastructure requirements required to deliver the aims of the Arc, we consider taking a more strategic, long-term view to not only be pragmatic, but paramount to ensuring the Arc’s aims are realised. 2.5 Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, as set out above, it is clear that there will need to be a substantial increase in housing delivery across the Arc to ensure this target can be delivered. This increase will also need to begin early in the Plan period and continue throughout. It is unlikely to be able to deliver this uplift by late-Plan period increases in housing requirements or stepped trajectories, this simply pushes back delivery. 2.6 Looking ahead further allows the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term. Whilst not a statutory development plan document, the Leicester and Leicestershire Strategic Growth Plan offers a good example as to how looking at a longer timeframe can assist in meeting strategic needs. 2.7 To deliver the required levels of housing over the Plan period, the Local Plan review may need to make provision for further strategic urban extensions to existing urban areas, that will inevitably deliver later in the Plan period. This includes sites such as Land West of Box End. However, there should not be an overreliance on such delivery and this should remain a single facet of overall supply. 2.8 Across the Arc itself, there is again likely to be some reliance on significant allocations to assist in increasing delivery rates. If they are to be delivering at pace before 2050, having regard for research on lead in times for strategic development and recent experience within other Arc authorities, plans 5 will need to look for suitable sites at a priority. As such, it is an entirely pragmatic approach to take to plan ahead to 2050, to ensure any necessary strategic sites have sufficient lead in time set out before being expected to deliver. Not having sufficient strategic sites allocated in a timely manner will almost certainly frustrate development in the longer term, particularly 2041-50.
4.1 The proposed plan period of 2020 to 2040 is accepted in principle and the Council acknowledges that this would satisfy the requirements to provide for a minimum 15-year period upon adoption. The Council also proposes to incorporate years from 2020 into the proposed plan period, which captures the years during which the Local Plan Review is to be prepared, examined, and adopted. This aspect is supported. 4.2 Planning Practice Guidance in relation to monitoring of housing completions against planned requirements sets out that: “Under-delivery may need to be considered where the plan being prepared is part way through its proposed plan period, and delivery falls below the housing requirement level set out in the emerging relevant strategic policies for housing.” (PPG ID: 68-031-20190722 4.3 This is relevant as the Council proposes to base the calculation of local housing need on the ‘current year’ of 2020. In practice this means that where supply falls below the proposed requirement (i.e. 1305 based on the most recent calculation) this shortfall is incorporated in provision made within the Review of the Local Plan 2030 upon adoption. 4.4 This would represent a positively prepared and effective approach to plan-making and would, in effect, ‘make up the difference’ between local housing need as calculated by the government’s standard method and the objectively assessed need of 970dpa used to inform the adopted Plan. The Council’s most recent ‘5 Year Supply Deliverable Housing Sites Report’ (June 2020) forecasts 2758 completions for the period 2020/21 to 2022/23 i.e. an under-delivery (i.e. shortfall) of 1,157 units to be addressed upon adoption. 4.5 Within this context and given the background to the adopted Local Plan 2030 it is important that options for the length of the plan period do not facilitate any further delay to meeting needs in full. This does not preclude the potential for longer-term options to be considered as potentially contributing towards development needs outside of the minimum 15-year plan period, but the Borough Council continues to accept substantial uncertainties regarding options related to New Settlements or East-West Rail. 4.6 In accordance with Planning Practice Guidance the approach adopted by the Council should support the prioritisation of sites that can be delivered early in the plan period, including those where supporting infrastructure is in place (ID: 68-021-20190722). Likewise, it may not be BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 21 appropriate to consider a longer plan period or anticipate a substantial contribution towards requirements from options with no reasonable prospect for development within the 15 year minimum plan period.
5.1 The proposed plan period of 2020 to 2040 is accepted in principle and the Council acknowledges that this would satisfy the requirements to provide for a minimum 15-year period upon adoption. The Council also proposes to incorporate years from 2020 into the proposed plan period, which captures the years during which the Local Plan Review is to be prepared, examined, and adopted. This aspect is supported. 5.2 Planning Practice Guidance in relation to monitoring of housing completions against planned requirements sets out that: “Under-delivery may need to be considered where the plan being prepared is part way through its proposed plan period, and delivery falls below the housing requirement level set out in the emerging relevant strategic policies for housing.” (PPG ID: 68-031-20190722) 5.3 This is relevant as the Council proposes to base the calculation of local housing need on the ‘current year’ of 2020. In practice this means that where supply falls below the proposed requirement (i.e. 1305 based on the most recent calculation) this shortfall is incorporated in provision made within the Review of the Local Plan 2030 upon adoption. 5.4 This would represent a positively prepared and effective approach to plan-making and would, in effect, ‘make up the difference’ between local housing need as calculated by the government’s standard method and the objectively assessed need of 970dpa used to inform the adopted Plan. The Council’s most recent ‘5 Year Supply Deliverable Housing Sites Report’ (June 2020) forecasts 2758 completions for the period 2020/21 to 2022/23 i.e. an under-delivery of shortfall of 1,157 units to be addressed upon adoption. 5.5 Within this context and given the background to the adopted Local Plan 2030 it is important that options for the length of the plan period do not facilitate any further delay to meeting needs in full. This does not preclude the potential for longer-term options to be considered as potentially contributing towards development needs outside of the minimum 15-year plan period, but the Borough Council continues to accept substantial uncertainties regarding options related to New Settlements or East-West Rail. 5.6 In accordance with Planning Practice Guidance the approach adopted by the Council should support the prioritisation of sites that can be delivered early in the plan period, including those where supporting infrastructure is in place (ID: 68-021-20190722). Likewise, it may not be appropriate to consider a longer plan period or anticipate a substantial contribution towards requirements from options with no reasonable prospect for development within the 15 year minimum plan period.
We would generally agree that for a strategic plan of this nature a Plan period of 20 years (2010-2040) would be appropriate. However, Bedford’s location within the Oxford-Cambridge Arc is in our opinion sufficient justification to take a differing approach. The NPPF at paragraph 22 outlines 4 that “Strategic Policies should look ahead over a minimum of 15-year period, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure”. There is however no upper limit applied and as such it is up to the discretion of the LPA to plan for an appropriate timeframe having regard for its localised circumstances. 2.4 All constitute Council’s within the Arc have agreed to the Joint Declaration of Ambition between Government and the Arc and as such should act in a way which aligns with this declaration. The seventh paragraph of the declaration states “We recognise that meeting all these ambitions for the Arc requires us to take a long-term view, at least to 2050…”. Given the significant housing, employment and infrastructure requirements required to deliver the aims of the Arc, we consider taking a more strategic, long-term view to not only be pragmatic, but paramount to ensuring the Arc’s aims are realised. 2.5 Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, as set out above, it is clear that there will need to be a substantial increase in housing delivery across the Arc to ensure this target can be delivered. This increase will also need to begin early in the Plan period and continue throughout. It is unlikely to be able to deliver this uplift by late-Plan period increases in housing requirements or stepped trajectories, this simply pushes back delivery. 2.6 Looking ahead further allows the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term. Whilst not a statutory development plan document, the Leicester and Leicestershire Strategic Growth Plan offers a good example as to how looking at a longer timeframe can assist in meeting strategic needs. The site is in a sustainable area within Kempston and would constitute a brownfield site, therefore there is sufficient infrastructure and facilities / amenities existing already to support the development of the site. 2.7 To deliver the required levels of housing over the Plan period, the Local Plan review may need to make provision for further strategic urban extensions to existing urban areas, that will inevitably deliver later in the Plan period. However, there should not be an overreliance on such delivery and this should remain a single facet of overall supply. Allocating sites within the Bedford Urban Area is another facet of overall supply that should be considered. 5 2.8 Across the Arc itself, there is again likely to be some reliance on significant allocations to assist in increasing delivery rates. If they are to be delivering at pace before 2050, having regard for research on lead in times for strategic development and recent experience within other Arc authorities, plans will need to look for suitable sites at a priority. As such, it is an entirely pragmatic approach to take to plan ahead to 2050, to ensure any necessary strategic sites have sufficient lead in time set out before being expected to deliver. Not having sufficient strategic sites allocated in a timely manner will almost certainly frustrate development in the longer term, particularly 2041-50.
BDW agree with the proposed plan period ending in 2040. This would ensure the plan is consistent with the minimum 15-year plan period for strategic polices as required by paragraph 22 of NPPF. However, we do question the start date of the plan being 2020, given the plan is unlikely to be submitted before 2023 and not adopted until 2025.
The Plan needs to be reviewed in line with changes to local demand.
As has been set out, the examination of the 2030 Local Plan established that the requirements for this ‘immediate’ review is to address the development ambitions of the Oxford – Cambridge Arc and to maintain adequate house building rates in the context of the Inspectors noting that the 2030 Local Plan relied on Neighbourhood Plan housing sites. Although it is acknowledged that it will challenging, it would appear logical to suggest that the plan period should correspond with the growth ambitions of the Oxford – Cambridge arc, and accordingly it is considered that the plan period should be extended to 2050.
As has been set out, the examination of the 2030 Local Plan established that the requirements for this ‘immediate’ review is to address the development ambitions of the Oxford – Cambridge Arc and to maintain adequate house building rates in the context of the Inspectors noting that the 2030 Local Plan relied on Neighbourhood Plan housing sites. Although it is acknowledged that it will challenging, it would appear logical to suggest that the plan period should correspond with the growth ambitions of the Oxford – Cambridge arc, and accordingly it is considered that the plan period should be extended to 2050.
As has been set out, the examination of the 2030 Local Plan established that the requirements for this ‘immediate’ review is to address the development ambitions of the Oxford – Cambridge Arc and to maintain adequate house building rates in the context of the Inspectors noting that the 2030 Local Plan relied on Neighbourhood Plan housing sites. Although it is acknowledged that it will challenging, it would appear logical to suggest that the plan period should correspond with the growth ambitions of the Oxford – Cambridge arc, and accordingly it is considered that the plan period should be extended to 2050.