Question 3
1.9. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy cover the period to 2050. 1.10. It is therefore appropriate to plan for a longer period in line with the Arc strategy.
1.8. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy cover the period to 2050. 1.9. It is therefore appropriate to plan for a longer period in line with the Arc strategy. We consider the plan should cover the period to 2045 if not 2050.
1.8. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy cover the period to 2050. 1.9. It is therefore appropriate to plan for a longer period in line with the Arc strategy. We consider the plan should cover the period to 2045 if not 2050.
1.8. As described above, during the examination of the 2030 Local Plan it was made clear by the Inspectors that a key reason for this immediate review was that there was a need to address the development ambitions of the Oxford to Cambridge Arc. The Arc strategy covers the period to 2050. 1.9. It is therefore appropriate to plan for a longer period in line with the Arc strategy. We consider the plan should cover the period to 2050 in recognition of the major infrastructure investment running itno billions of pounds that is planned to improve both road and rail connections from Oxford to Cambridge during the 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 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. 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. Whilst we appreciate that there is presently no agreement as to how the one million dwellings are to be distributed throughout the Arc, 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 need to commence early within the Plan period and continue throughout. To deliver this uplift late within the -Plan period through increases in housing requirements or stepped trajectories, simply pushes back delivery. Therefore, to achieve the objective of a swift step change in delivery it is important that a mix of sites is allowed within the Plan to cater for locations where demand is high to allow swift delivery within the Plan period. Looking beyond 2040 enables the Plan to consider alternative options such as the delivery of infrastructure and how this could unlock development in the longer term.
2.6 MGH supports the proposed plan period ending in 2040 to ensure that it is consistent with the minimum 15-year plan period required by national policy.
3.1 O&H consider the Authority should be more ambitious and seek to draft a plan with a plan period from 2020 – 2050. 3.2 The Authority should consider more than the quantum of housing that would be required when determining the length of the Plan period. Rather, the Authority should be ambitious and seek to a be leader for long-term strategy within the O2C Arc. 3.3 The Government’s ambitions for the O2C Arc along with the Government’s commitment to achieving "net zero" greenhouse gases run until 2050. There would be merit in aligning the Authority’s strategy for the development of the Borough with Government’s ambition for the O2C Arc and commitment to net zero. 3.4 A plan period of 2020 – 2040 would fail to capture the benefits of aligning the plan period with the ambition for the wider O2C Arc and the Government’s environment commitments. 3.5 This Local Plan review present an opportunity for the Authority to offer a greater degree of certainty to developers and local communities than any other Authority within the O2C Arc. It also offers the opportunity to secure the infrastructure necessary for future needs long before it may be required.
Although uncertainties exist with forecasting beyond 2040 and in the changing legislative environment it is sensible that the plan extends to 2050, This will match wider planning schedules across the Arc and will provide insight into longer term objectives which impact more immediate plans. The Plan should indicate assumptions and uncertainties so that expectations and ultimately budgets are realistic.
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.
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.
3.9 The plan period is suggested to be 20 years. This plan period is considered suitable, and it is likely that further information about the Cambridge-Oxford Arc and the delivery to the east-west train line would require a further review of the Local Plan review during that time. 3.10 The 20 year plan period should remain.
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.
Yes, plans become increasingly speculative as time periods extend. One argument in favour of a longer plan period would be if it generated additional funding for significant commitments such as infrastructure, but we are not aware of any such benefit.
Paragraph 22 of the National Planning Policy Framework (NPPF) states that strategic plan policies should look ahead over a minimum 15 year time frame, whilst para 33 requires local plan reviews to occur every five years, where the level of review should take into account changing circumstances affecting the area. This Local Plan Review is therefore supported, and there is no objection to the proposed Plan period, which would be sound and in accordance with national policy.
28. The need for an early review of the Local Plan is in large part due to an acknowledgement that the recently adopted Local Plan does not appropriately respond to the longer term growth requirements of the Oxford – Cambridge Arc. As set out earlier in these representations, the Government’s ambitions in respect of the Arc initially relate to the period up to 2050 and, as announced in the March 2020 Budget, involve the preparation of a Spatial Framework to cover that period. On this basis it would be prudent for the Local Plan Review period to cover 2020 to 2050. 29. As discussed in our response to the Question 4 (below), there will unquestionably be a need to allocate one or more new settlements in order to achieve the increased housing requirement resulting from both the standard methodology for assessing housing need and the further uplift required to achieve the Government’s aim of delivering up to one million new homes within the Arc by 2050. New settlements necessarily have longer lead in times than smaller developments and as such it is logical to ensure that the plan period is sufficiently long to cover their delivery and/or to enable them to make a significant contribution to the housing requirements of the plan period(particularly where considerable upfront infrastructure is necessarily required).
We would agree with the proposed plan period ending in 2040. This would ensure that the plan is consistent with the minimum 15-year plan period required by national policy. Potential locations for housing growth (Question 4) The consultation document sets out a number of options broad question that we will not seek to answer directly. Largely, the decision as to where to build will depend on many factors ranging from the availability of developable sites through to the location of infrastructure both now and in the future. The HBF cannot comment on or promote specific locations for development but in our experience the most effective approach to delivering the levels of development required in Bedford is to ensure a wide variety of sites are allocated both in terms of size and location. In particular we consider it important that the Council should look to identify sites that will ensure consistent delivery across the plan period by avoiding an over concentration of development in a specific area or an over reliance on large strategic sites. This is particularly important for areas like Bedford where there is still an acute need for new homes and already a significant number of strategic sites that are being delivered through the current local plan. Therefore, whilst the consultation document sets out a range of possible development scenarios for Bedford, we would urge the Councils not to fall on a single strategy at this early stage of plan preparation. It is more likely that the spatial strategy will include elements from many of the potential options set out in the consultation document The Council must also ensure that spatial strategy will not prevent the Council from delivering the objective set out in paragraph 68 of the NPPF which requires at least 10% of its housing supply to be delivered on sites no larger than one hectare. These can be identified either in the Council’s Brownfield Register or in the local plan itself, but they should not be part of an assumed level of supply within windfall estimates. The introduction of the 10% target for delivery on small sites was to reduce the risk of developing such sites that comes from an allocation in the local plan which would in turn encourage the growth in the number of smaller housebuilders operating across the Country. In turn the provision of small siters will improve early delivery in the plan period and the diversity of homes offered across Bedford.
The plan period should be 2020-2040 in accordance with Government policy. As mentioned in our response to Q1, the Council should consider if there is a need to commit to an ‘early review’ of this Local Plan Review due to the continued uncertainty regarding the Oxford to Cambridge Arc.
The plan should be to 2040 as it is very difficult to predict the future beyond this date. The NPPF requires the Local Plans to be reviewed every 5 years so that it can be updated as the economy requires. The absence of a question on housing growth is a deficit in this consultation. We understand that the government is currently consulting on a new Standard Method. The potential figures of 800-1300 represent at worst a 35% increase compared to current Local Plan 2030 this will have detrimental impact on the urban and rural environment. Where is the industrial and commercial strategy to support this level of housing growth?
The UK as a whole is currently facing the Covid-19 pandemic – which of itself has introduced a high degree of uncertainty into the way people work, where they live, how they travel to work and how they socialise. The Parish Council does not see this current inevitable and unavoidable uncertainty resolving itself in the foreseeable future. In addition, as the Borough Council is only too aware, the Government has recently published its Planning White Paper “Planning for the Future” and related Consultation Documents. The question obviously to be faced by the Borough Council is whether the White Paper’s proposals will receive statutory recognition during the emerging plan process and at present, every likelihood is that the Government will attempt to fast track the new regime. Whilst it is appreciated that the Borough Council cannot delay the promotion of its new Local Plan – in that to do so would cause serious problems in terms of housing supply provision – the Parish Council would be interested to know whether the Borough Council intends to proceed on the basis of the Government’s current housing provision figures – or whether it intends to adopt the, at present, untested but significantly larger housing requirements announced in the White Paper? With such uncertainty, the Parish Council cannot see how the Borough Council has any choice but to select the shortest plan period available to it, namely to 2040, so as to avoid a rigorous application of housing provision figures which could be out-of-date even before the emerging Plan has been adopted.
No comments regarding plan period.
We agree that a 20-year plan is the shortest period it should cover. This is particularly pertinent in Bedford in light of the strategic infrastructure improvements, regeneration and new development opportunities that will be derived. Planning positively for such opportunities is essential to delivering the government’s housing targets.
It is proposed that the Bedford Local Plan could have a 2050 end date (rather than 2040); to correspond with the emerging Oxford to Cambridge Arc growth/ spatial strategy. This would also be consistent with other emerging Local Plan Reviews within the Oxford-Cambridge Arc; e.g. West Northamptonshire Strategic Plan, which will set out a spatial vision for the future of the area extended up to 2050.
It is inferred that the Council’s preference is for 2040; comment is sought on any alternative to this rather than to support the Council’s position. Nevertheless, we consider that the plan period should extend no further than 2040. Perhaps the single most important source of data for forward planning is the household projections produced by MHCLG. These project forward for a period of 25 years from a given base date. This might in itself lend support to a plan period extending beyond 2040. However, successive sets of these projections show how unpredictable the future actually is; a set may forecast a higher or lower figure for the end date than its predecessor published only two or three years earlier. In any event, forward planning should be regarded as a continuous rather than intermittent process. The Council’s decision to embark on a review almost as soon as the Local Plan 2030 was adopted is a good example of this, where the examining Inspectors have given firm guidance, as indicated on page 3 of the Consultation Paper. There will inevitably a further review long before 2040, if the Government’s guidance on timescales is maintained. Furthermore, the town and country planning system may need to take stronger measures within its scope to tackle climate change long before 2040. Eclipse Planning Services considers that the case for not setting an end date any further forward than 2040 is reinforced by the summary of the position on housing provision on page 16 of the Consultation Paper. In short, the extent of existing commitments (11,000 dwellings) means that the range of additional provision to 2040 varies by a factor of 3 (5,000 to 15,000 additional dwellings), arising from a factor of only 1.6 in the range of the annual requirement (800 to 1,305 dwellings). Furthermore, it would be very difficult to anticipate the affordability data due in March 2021 or the outcome of the review (“in its entirety”, as the document says) of the standard method.
2040 is OK in its own terms but my point above about the Oxford-Cambridge applies.
2.4 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. 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.
2040 is acceptable as an end date for the Plan. A statutory spatial strategy should be agreed before development begins on the Oxford/Cambridge arc and 2018 ONS data should be used to calculate housing need. 2018 data would reduce the number of new houses to be built from around 1,300 p.a. to around 800 p.a. and therefore represents a “meaningful” change under PPG 2a-016-20150227, paragraph 16. The need to use the latest available information was highlighted by the Inspectors of Central Bedfordshire Local Plan and if Bedford BC continues to use the standard method, they could be open to Judicial Review.
The uncertainty both of longevity and consequences of the Corona Virus and the delay in the finalisation of the East-West rail and road Links makes 2050 a much more realistic probability.
The plan period is more than adequate. Proposals need to be implemented sooner rather than later.
I think you may have to extend it to 2050 to see it finished.
The Plan period should not extend beyond 2040 given the uncertainties of longer term forecasting. Even up to 2040, the range of potential housing requirements (5000 to 15000 additional dwellings) is too wide to form a sensible basis for development and infrastructure planning, and ignores any additional requirement relating to the Oxford-Cambridge Arc. The dwelling requirement for the plan period should be clarified more precisely as soon as possible. Beyond 2040 the Review could consider outlining a spatial framework to accommodate Oxford-Cambridge Arc development requirements that are appropriate to the Borough.