Question 3
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 be 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.
We support the local plan review period as proposed.
A shorter plan period eg to 2040 will allow the Local Plan to incorporate a vision which is aspirational but deliverable, in line with the requirements of NPPF paragraph 16. Looking beyond 2040 with the level of growth envisaged for the borough and wider Oxford to Cambridge arc is likely to be more challenging than with a shorter timeframe. The Issues and Options Consultation seeks views on a housing figure in the range of 800 –1,305 dwellings per annum. It identifies that an annual figure of 1,305 dwellings per annum would represent an increase of 35% on the current adopted Local Plan 2030 figure of 970 dwellings per annum and that the 800 figure represents an estimate of the possible figure were the standard methodology to be reviewed and based on the 2018-based population projections rather than the 2014-based figures. Taking into account existing commitments, the Issues and Options paper identifies that BBC may need to make new allocations to provide between 5,000 and 15,000 additional new dwellings over a plan period to 2040, depending on the Government’s formula. The consultation should identify a single figure rather than a range in order to meet objectively assessed need, as a minimum. Using current data it is possible to calculate housing need, based on the standard methodology set out in the 2019 NPPF. This utilises two separate data sets. The first is the household projections and second the affordability ratio of earnings to house prices. In this case, Government has set out that the 2014-based household projections should be used as the 2016-based ones do not reflect Government policy to increase housing supply. The latest population projections (2019) continue the trend of reducing population growth in England. It remains to be seen what Government response is to this data and this may have a future effect on the levels of growth. Guidance requires the use of projections for the start year (2020) and for ten years from that start date (in this case 2020). The projections set out a figure of 73,182 households in 2020 and 83,033 in 2030. This equates to a ten year household growth figure of 9,851 new homes required over the ten year period. This requires an average delivery of a minimum of 985.1 new homes per annum for the next ten years. The above figure has to be adjusted to reflect the level of affordability of housing in Bedford. The latest data shows that house prices are 9.82 times the average household income. As such, an upward adjustment has to be made to the demographic figure. Using this adjustment, the total number of new homes per annum required to address affordability increases to 1,343 new homes per annum. It is therefore considered the housing figures identified in the Issues and Options Paper of between 800 and 1,305 dwellings will need to be reviewed. A figure lower than the objectively assessed need would be unsound. Furthermore, given the specific strategic development context of the Borough within the Oxford -Cambridge Arc, this figure should be exceeded.
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 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. 2.5 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. 2.6 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. 2.7 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. 5 2.8 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. 2.9 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.
The plan period should be sufficient to dovetail with the timeframe of the Oxford-Cambridge Arc and to ensure Place Making can be developed and embedded. Too short a timescale will ensure piecemeal development and unbalanced communities with partially delivered infrastructure.
We support the Plan period of 2020-2040. A 20 year plan period allows sufficient time for the major infrastructure schemes to progress and ultimately be completed; the A428 Black Cat roundabout to Caxton Gibbet improvements expected to be open to traffic in 2025/2026 and the East West rail link from Bedford to Cambridge proposing to have services running before the end of the decade.
Long enough to give some certainty but short enough to enable planning in the near future. Predicting housing needs further into the future is just not feasible, given that the East West rail route is still apparently ‘undecided’ and the process is anything but open, honest and transparent. It may be necessary to extend the time period as the E-W rail will have a huge impact on any development and to have an honest dialogue to allow for meaningful discussion, consideration and negotiation will take considerable time. The plan must be kept current, up to date and meaningful during that extended period-particularly as we have yet to hear about the long term development and housing needs of the Oxford to Cambridge arc.
3.1 The NPPF (paragraph 22) sets out that the strategic policies for an area ‘should look ahead over a minimum 15 year period form adoption’. It is currently assumed that the revised Local Plan will be adopted in the winter of 2023, meaning the plan period should run until at least the end of 2038. 3.2 However, this assumes that the Local Plan is prepared and adopted in line with the expected timetable. Given the current level of uncertainty the adoption of the Local Plan by winter 2023 may be difficult to achieve and would only give some 12 months of flexibility in the plan production process to ensure that the plan looks 15 years ahead from the date of adoption. It is therefore considered more achievable to look to 2045, this would provide sufficient headroom if the plan production were to slip as well as ensuring a comprehensive approach is provided. 3.3 Starting the plan period in 2020 is considered suitable and is supported given this is when the evidence base will be gathered to support the Revised Local Plan.
4.1 The NPPF (paragraph 22) sets out that the strategic policies for an area ‘should look ahead over a minimum 15 year period form adoption’. It is currently assumed that the revised Local Plan will be adopted in the winter of 2023, meaning the plan period should run until at least the end of 2038. 4.2 However, this assumes that the Local Plan is prepared and adopted in line with the expected timetable. Given the current level of uncertainty the adoption of the Local Plan by winter 2023 may be difficult to achieve and would only give some 12 months of flexibility in the plan production process to ensure that the plan looks 15 years ahead from the date of adoption. It is therefore considered more achievable to look to 2045, this would provide sufficient headroom if the plan production were to slip as well as ensuring a comprehensive approach is provided. 4.3 Starting the plan period in 2020 is considered suitable and is supported given this is when the evidence base will be gathered to support the Revised Local Plan.
As it is already near the end of 2020 and the current plan does not end until 2030 it would make better sense to start at 2025 and extend to 2045.
Yes
4.0 QUESTION 3 – PROPOSED PLAN PERIOD 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 2,758 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. 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. These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options for large-scale development, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 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 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.
3.1 The Vision is generally appropriate but fails to recognise that the Local Plan Review is required to fulfil and maintain opportunities for sustainable development that were not fully grasped in the Local Plan 2030. This is as a result of its foreshortened plan period, provision for a reduced housing requirement and deferred allocation of sites to Neighbourhood Plans. 3.2 In principle the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 enables is welcomed. However, it should be recognised that the level and distribution of growth planned for was below that identified in the Council’s evidence base as equally or more sustainable based on a higher capacity for development in the Borough’s rural settlements. 3.3 The Council’s proposed Vision acknowledges and accepts uncertainties regarding strategic locations for growth and significant infrastructure projects will determine the delivery of growth over the plan period. This is understandable in terms of details of the projects themselves (e.g. East-West Rail) but the Vision should provide a greater emphasis on the solutions that the Review of the Local Plan will provide, upon adoption, to meet the substantial increase in the housing requirement and deliver the Borough’s needs in full. 3.4 In relation to the proposed Vision and strategy options that the Council has identified for further testing, pp.15 of the consultation document states (with reference to the Local Plan 2030): “This [strategy] reflects the availability of facilities, services and accessibility by public transport. It safeguards the intrinsic character of a living and working countryside. Although this strategy works for the current local plan, it does not deliver sufficient growth to meet the anticipated needs over the longer period that the new local plan will have to provide for.” 3.5 There are three main flaws with this statement as set out by the Council, which underpin the conclusion (as previously given by the Council itself when preparing the Local Plan 2030) that a greater proportion of needs could however be sustainably met in the rural area: • The Council has previously tested options apportioning greater levels of growth to the rural area that it accepted would deliver similar effects on sustainability as selected options. • Delivery of growth in Key Rural Service Centres and Rural Services Centres has been delayed as a result of deferring site allocations to Neighbourhood Plans. • The distribution of growth as set out in Policy 4S of the Local Plan 2030 is based on arbitrary assumptions for the apportioned requirement to each settlement, rather than a clear understanding of their capacity and suitability for growth. 3.6 It is therefore essential that the Vision does not preclude the Local Plan Review maximising the opportunities for sustainable development comprising less-constrained spatial options. We identify these elements of an appropriate strategy, which require greater emphasis in the proposed Vision, as the equally sustainable (as determined by the Council) ‘Dispersed’ strategy for growth in the rural area. A substantially greater contribution towards annual requirements for development at settlements including Sharnbrook and Oakley than the levels currently indicated by Policy 4S of the adopted Local Plan 2030 is entirely in accord with this scope for a positively prepared Vision. 3.7 These components of an appropriate strategy should complement an aspirational but realistic approach to delivering within and adjoining the Urban Area (including Town Centre sites and deliverable locations adjoining the existing urban edge). 3.8 We have identified three main elements of the Council’s proposed Vision where amendments BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 19 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission to the text are required to reinforce the Borough’s commitment to meeting needs in full and maximising opportunities for sustainable development as part of this: “Well-planned growth avoiding areas of high flood risk will support the creation of strong, safe and sustainable local communities in environments that facilitate healthy and independent living for all. The distribution and delivery of growth across the Borough will ensure that its requirements for housing have been met in full within the plan period through support for outcomes that maximise net gains from development. Sustainable development and transport, the use of sustainable and renewable energy technology, green infrastructure and new green spaces will all contribute to reducing the borough’s carbon footprint and securing a net-gain in biodiversity.” “The borough’s countryside, its intrinsic character and beauty including areas of tranquil retreat will be recognised. The role and function of Key Service Centres and Rural Service centres will have been sustained and enhanced through encouraging a sustainable contribution towards meeting the borough’s overall housing needs and fully reflecting the capacity and priorities for growth in each settlement. Rural communities will embrace sensitive development including, where appropriate, through neighbourhood plans that conform to the Borough’s strategic policies and allocations for growth, providing for much needed housing and employment, rural facilities and services, including public transport. Locally important green spaces and valued local landscapes will be protected and enjoyed by all.”
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 2,758 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. 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. These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options for large-scale development, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 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 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.
4.1 As per the wording of paragraph 22 of the NPPF, the strategic policies for an area: ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.2 If it is assumed that the preparation and adoption of the Local Plan happens in line with the expected timetable, with the revised Local Plan adopted in the winter of 2023 at the earliest, the plan period would run until the end of 2038. By specifying a plan end date of 2040, an allowance of 24 months would be established which would provide some flexibility in the plan production process to ensure the plan looks ahead 15 years from adoption. 4.3 However, recent experience has demonstrated how difficult it can be to deliver a Local Plan in line with the stated timetable; with delays emerging as part of both the plan preparation process and at the examination stage. Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would more appropriate and would provide flexibility in the timetable. 4.4 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.
4.0 Question 3 In line with Government policy, the shortest plan period would be 2020 to 2040. Do you agree with this plan period? If you think the plan period should be longer, what plan end-date would you suggest and why? 4.1 The Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change. Arrow Planning on behalf of Denison Investments LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 4 4.2 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for. 4.3 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas.
4.1 Taylor Wimpey UK Ltd consider 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. 4.2 Paragraph 22 of the NPPF states that the strategic policies for an area ‘should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure’. 4.3 Based on this assumption, the revised Local Plan will be adopted in the winter of 2023 and therefore the plan period will run until the end of 2038 at the earliest. 4.4 This assumes that the preparation and adoption of the Local Plan happens in line with the expected timetable, which recent experience has demonstrated can be difficult to achieve. Therefore, a plan end date of 2040 only provides the flexibility of 24 months in the production process to ensure the plan looks ahead 15 years from adoption. 4.5 Realistically, the plan should look beyond 2040 to ensure that this requirement can be achieved. An end date of 2045 would be more appropriate and would provide flexibility in the timetable.
Long enough to give some certainty but short enough to enable planning in the near future. Predicting housing needs further into the future is just not feasible, given that the East West rail route is still apparently ‘undecided’ and the process is anything but open, honest and transparent. It may be necessary to extend the time period as the E-W rail will have a huge impact on any development and to have an honest dialogue to allow for meaningful discussion, consideration and negotiation will take considerable time. The plan must be kept current, up to date and meaningful during that extended period-particularly as we have yet to hear about the long term development and housing needs of the Oxford to Cambridge arc.
Given the reliance on strategic infrastructure there is a case to have a strategic plan that runs to 2050. A longer outlook would provide an opportunity to plan strategically for how the area will develop in the long term and would possibly aid decisions around infrastructure investment.
Certainly not longer. Even up to 2040 the possible range of required housing is far too wide – between 5000 and 15000
4.1 The NPPF (paragraph 22) sets out that the strategic policies for an area ‘should look ahead over a minimum 15-year period from adoption’. It is currently assumed that the Local Plan Review will be adopted in the winter of 2023, meaning the plan period should run until at least the end of 2038. 4.2 However, this assumes that the Local Plan Review is prepared and adopted in line with the expected timetable. Recent experience has shown that this can be difficult to achieve, and a plan end date of 2040 gives only 24 months flexibility in the production process to ensure the plan looks ahead 15 years from adoption. 4.3 Axiom would therefore advocate the plan looking ahead beyond 2040 to ensure this requirement can be achieved. Looking to 2045 would provide flexibility in the timetable and would be a more appropriate end date for the plan. 4.4 Irrespective of the end date of the Local Plan Review, it is considered that a plan period which starts at 2020 is appropriate given that this will be the base date for the evidence gathered to support the plan.
The plan period from 2020 to 2040 is acceptable as a minimum period in which the plan would be active. It is important that suitable planning policies are worded within the plan, that require an early review of the plan in the event that housing or employment needs change during the plan period.
No comment.
4.1 The Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change. 4.2 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for. 4.3 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas.
It will be important to consider opportunities/issues relating to growth at Rushden through both plans. The timetable for the Bedford Local Plan is set out on page 10 of the document and includes Draft Plan consultation Summer 2021, Plan for submission consultation in Summer 2022 and adoption by Winter 2023. The potential timetable for the NN Strategic Plan agreed by the JPC at its 25th July 2019 meeting runs behind the Bedford Local Plan but includes Proposed Submission consultation in Winter 2022 and adoption in Winter 2023. It is considered that the timetables are sufficiently aligned to ensure cross-boundary issues can be fully considered through respective plan-making. To this end, it is noted that the proposed plan end date is 2040, and consideration should be given as to whether an end date of 2050 to align with the Arc would be beneficial.
2.4 We would generally agree that for a strategic plan of this nature a Plan period of 20 years (2020- 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 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. 2.5 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. 2.6 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 via increases in housing requirements or stepped trajectories, this simply pushes back delivery. 2.7 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. 5 2.8 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. Though, having regard for the failings of the 2014 Core Strategy, there should not be an overreliance on such delivery and this should remain a single facet of overall supply. 2.9 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.
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 or 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 infrastructures 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.