Question 1
There should be more open spaces in the villages owned by the parish councils for parishioners to use, currently Wymington have no amenities for out door activities in the village
The scope of the Local Plan Review should be informed by the Government’s proposed reforms to the planning system. Whilst the detail of those reforms is not yet clear, the publication of the Planning White Paper provides a direction of travel that should inform how the local plan review progresses in parallel with the Government’s intentions. For instance, any development management policies should clearly be specific to particular areas or proposed allocations.
The scope of the Local Plan Review should be informed by the Government’s proposed reforms to the planning system. Whilst the detail of those reforms is not yet clear, the publication of the Planning White Paper provides a direction of travel that should inform how the local plan review progresses in parallel with the Government’s intentions. For instance, any development management policies should clearly be specific to particular areas or proposed allocations.
The scope of the Local Plan Review should be informed by the Government’s proposed reforms to the planning system. Whilst the detail of those reforms is not yet clear, the publication of the Planning White Paper provides a direction of travel that should inform how the local plan review progresses in parallel with the Government’s intentions. For instance, any development management policies should clearly be specific to particular areas or proposed allocations.
really think outside the box. A new sustainable village for housing, a redevelopment of the high Street to utilise all empty units as housing or use of old office space as housing.
The scope of the Local Plan Review should be informed by the Government’s proposed reforms to the planning system. Whilst the detail of those reforms is not yet clear, the publication of the Planning White Paper provides a direction of travel that should inform how the local plan review progresses in parallel with the Government’s intentions. For instance, any development management policies should clearly be specific to particular areas or proposed allocations.
No answer given
No answer given
The proposed the plan does make reference the east-west rail infrastructure project enough, which is a significant omission due to the scale of the project.
Biodiversity gain should be explicitly included to ensure measurable, substantial Biodiversity Net Gain is achieved, and is monitored effectively. Ecology and ecological networks should specifically be part of the scope, to prevent fragmentation of networks. Ownership of publicly accessible Open Green Space and housing development boundaries should be included – There should be policies on the long term ownership and maintenance of all publicly accessible Open Green Spaces of all types, formed as part of new developments. By default these spaces should be owned and maintained by the authority, rather than developers, making them accountable to residents, with appropriate financial contributions from the developers to enable this.
We are required to assess the options against a background of considerable uncertainty. The pre-covid economic case can no longer be relied upon; in particular there is the probability of permanent changes in work and travel patterns, there are probable changes in the housing targets independently of any assessment of the above point and there is the clear possibility of a lengthy economic depression which will affect not just housebuilding rates but the deliverability of the necessary infrastructure upon which the plan must be based. There is also continued uncertainty over what is entailed in the “Oxford -Cambridge Arc” concept as well as the extent to which East -West Rail might play in terms of contributing to local transport infrastructure given that a station between Bedford and St.Neots/Tempsford currently plays no part in its planning. In summary, the objective of the new plan which is to “respond appropriately to longer term growth requirements” is something which cannot be met within the timescale set and we recommend that an amended timetable be sought. There also a need for design to be given a high priority (it shouldn’t just be where, it should also be what) and that this must be addressed during the preparation of this plan (either in the plan, or in a supplementary planning document). The planned growth must also support the regeneration of the town centre.
Biodiversity gain should be explicitly included to ensure measurable, substantial Biodiversity Net Gain is achieved, and is monitored effectively. Ecology and ecological networks should specifically be part of the scope, to prevent fragmentation of networks. Ownership of publicly accessible Open Green Space and housing development boundaries should be included – There should be policies on the long term ownership and maintenance of all publicly accessible Open Green Spaces of all types, formed as part of new developments. By default these spaces should be owned and maintained by the authority, rather than developers, making them accountable to residents, with appropriate financial contributions from the developers to enable this.
Electric vehicle policy
No answer given
We agree with the scope, but consider policies and standards on climate change, natural environment (including Biodiversity Net Gain and Environmental Net Gain) and updated open spaces policies to be essential (not just “to be considered” and that these need to be considered alongside all other policy to ensure there is a consistent approach to issues such as the environment and climate change – isolated policies which are not properly embedded risk being perceived as less important/more peripheral. It will also be essential for the Local Plan to incorporate the requirements of the Environment Act when it comes into force in 2021. The Local Plan should also consider the impacts of the introduction of a potential Development Corporation.
Proposed scope is very broad & covers ‘policy’ areas. No further comment at this stage.
We are required to assess the options against a background of considerable uncertainty. The pre-covid economic case can no longer be relied upon; in particular there is the probability of permanent changes in work and travel patterns, there are probable changes in the housing targets independently of any assessment of the above point and there is the clear possibility of a lengthy economic depression which will affect not just housebuilding rates but the deliverability of the necessary infrastructure upon which the plan must be based. There is also continued uncertainty over what is entailed in the “Oxford -Cambridge Arc” concept as well as the extent to which East -West Rail might play in terms of contributing to local transport infrastructure given that a station between Bedford and St.Neots/Tempsford currently plays no part in its planning. In summary, the objective of the new plan which is to “respond appropriately to longer term growth requirements” is something which cannot be met within the timescale set and we recommend that an amended timetable be sought. There also a need for design to be given a high priority (it shouldn’t just be where, it should also be what) and that this must be addressed during the preparation of this plan (either in the plan, or in a supplementary planning document). The planned growth must also support the regeneration of the town centre.
Agree with the scope
Hallam Land Management Limited (hereon referred to in our response as “Hallam”) agrees with the proposed scope of the local plan review. However, it is considered that the emerging preferred development strategy will need to be aligned with the Oxford Cambridge Arc spatial strategy as it emerges, which will have implications on the housing requirement for contributing towards the ambitions of the Oxford Cambridge Arc, as well as for meeting the Borough’s own housing needs. The Arc strategy will also have implications on the Borough’s preferred development strategy which will need to be aligned with the Oxford Cambridge Arc and be effective at meeting the Borough’s own growth requirements. Consideration will need to be given also to the potential impacts of Government’s review of the wider planning system. Hallam supports a strategy to accommodate growth that will meet national policy requirements and recognises that this will be very challenging but essential in context of the anticipated changes. The existing Standard Methodology anticipates an increase in the housing requirement from the 970 homes per annum planned for in the adopted Local Plan 2030 to 1,305 dwellings per annum (which will need to be addressed in the Local Plan 2030 to avoid a cumulative shortfall in housing delivery). The Oxford Cambridge Arc, proposed changes to the Standard Method and their impacts of growth requirements are key issues need to be addressed. In this context deliverable options need to be considered to facilitate higher levels of growth in sustainable locations that can deliver growth relatively easily, prior to the more strategic options coming forward. Additionally, Hallam supports the need to address quality of development. This should not however be purely aesthetic but be considered in the context of whole communities – considering how new development delivers quality outcomes for existing residents as well as new residents – supporting infrastructure improvements, the range and quality of community facilities and the offer of local services. Consideration should also be given to how and where new development is best located to help support existing local shops and facilities.
Whilst the Local Plan 2030 was recently adopted, it is important to acknowledge that this plan was prepared in the context of the NPPF 2012 and does not reflect more recent national planning policy, as detailed within the subsequent revisions to the NPPF in 2018 and 2019. It cannot therefore be correct to assume that the recently adopted Plan is up to date in the context of national planning guidance. The Council will also be aware that the MHCLG’s consultation paper ‘Changes to the current planning system’ was published in August 2020, with a view to bringing forward further changes to the planning system that are expected to be brought into effect before the end of the year. The Council will therefore need to undertake a more comprehensive review of all current policies within the adopted Local Plan to ensure consistency, whilst also ensuring imminent new guidance is also taken into account.
Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (henceforth: the Respondent) consider that the scope of the Local Plan review should be expanded to consider changes to a number of older policies. Specifically, Policy AD23 contained in the Allocations and Designations Local Plan (ADLP) (adopted 2013) which allocates land at Bedford River Valley Park (BRVP) for ‘enabling development’ to deliver the consented water sports lake. Representations to this effect have already been submitted on behalf of the Respondent as part of the Call for Sites exercise. Those representations set out in greater detail the amendments that are considered necessary, however, for ease of reference, these arguments are briefly summarised here. Policy AD23 allocates land at BRVP to deliver development across a range of uses. This allocation serves as ‘enabling development’, the funds from which will be used to deliver the consented water sports lake. The uses permitted by Policy AD23 do not currently include residential development, however for the enabling development to generate sufficient funds to deliver the water sports lake residential development will be necessary. This is a result of the viability of the enabling development being impacted by various changes in circumstances since the ADLP was adopted, relating to both site specific matters and wider economic and social transitions, including to the planning policy context of the wider area, which has moved on considerably since the original allocation was adopted, particularly in respect of the need for new housing in the Borough. The representations provided as part of the Call for Sites exercise enter into greater detail on this matter and should be read in conjunction with this response. A Vision Document has also been provided in support of these representations and is enclosed herewith. The Vision Document provides an insight into how the water sports lake could be delivered in conjunction with residential development, an educational facility and a local centre, and demonstrates that a high-quality and thriving leisure amenity can be created. The water sports lake represents an opportunity to turn BRVP into a highly sought after and valuable leisure resource that will bring inward investment and will also benefit the local population through improved connectivity and leisure opportunities. However, to fund the delivery of the water sports lake, it is necessary to update Policy AD23 contained in the ADLP to reflect the impact of the aforementioned circumstances on the viability of the ‘enabling development’.
1.1 The local plan review should focus predominantly on the key strategic plan-making issues which have been derived from the updated development needs of the area, to provide a strategy for accommodating the appropriate requirement of housing and employment space. Such an approach is in line with the guidance set out in the recent White Paper and the fact that the development management policies which currently sit alongside the spatial strategy in the Local Plan 2030 have only recently been adopted, and are therefore likely to remain fit for purpose. 1.2 As such, reviewing the adopted development strategy and considering where land should be made available to meet identified housing and employment needs should be the focus of the revised Local Plan. This is consistent with the conclusions of the Inspector in finding the Local Plan 2030 sound. 1.3 Whilst the approach of the Council will need to be refined once the emerging requirements of the White Paper work their way through to national policy, it is encouraging that the Issues and Options Paper suggests that the Local Plan will make such land allocations to ensure the identified need will be met. However, the scope also suggests that a number of other very detailed topics will be addressed, which we suggest have the potential to take focus away from the primary purpose of the review. Particularly in light of the recommendations set out in the White Paper, we suggest the review should avoid dealing with such policies, which would be better addressed through neighbourhood plans where appropriate. 1.4 The scope of the review set out in the Issues and Options document does not explicitly address the fact that the scale of future housing and employment need will need to be reviewed. Whilst it is touched on under the spatial strategy, we feel that the quantum of development to be planned for is key and should be given more prominence in the scope of the review. 1.5 As is indicated in the document (page 16), the Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per year across Bedford Borough. At this time, it should be this level of growth, as a minimum, that the Local Plan seeks to provide. The Issues and Options Paper goes on to suggest a review of the Standard methodology may see the housing need figure drop to 800 dwellings per year. 1.6 The White Paper sets out the revised standard methodology and this indicates that the revised method would give a minimum housing needs figure of 1,153 per year, just below that of the current standard method – but in excess of that which forms the basis of the adopted Local Plan (970). Land west of Wyboston 1.7 Until the consultation on the revised standard methodology is over, we suggest that the current standard methodology figure of 1,305 dwellings per year should be seen as the starting point for the review. This would require that the plan review sets out to accommodate a minimum of 15,000 1.8 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations) with addition land identified to provided flexibility and contingency in supply. 1.9 The second key issue not fully addressed in the questions is the extent to which the ambitions for the Oxford to Cambridge Arc are addressed in the review. Whilst there is currently no arc-wide spatial strategy, progress has been made on a number of key infrastructure projects in the area and there is a clear intent from the Government to drive forward growth in the Arc. 1.10 As part of the most recent Budget announced in March 2020, it was confirmed that: The government has designated the corridor of land connecting Oxford, Milton Keynes, Bedford and Cambridge (the OxCam Arc) as a key economic priority. Earlier this year, the government announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… The Budget announces plans to develop, with local partners, a long-term Spatial Framework to support strategic planning in the OxCam Arc. This will support the area’s future economic success and the delivery of the new homes required by this growth up to 2050 and beyond. The government is also going to examine and develop the case for up to four new Development Corporations in the OxCam Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge, which includes plans to explore the case for a New Town at Cambridge, to accelerate new housing and infrastructure development.” 1.11 It is therefore clear that the Government remains committed to the Arc with the expectation being that there will be significant residential development to support the economic potential of the area. 1.12 Alongside the Government’s statements on the Arc, policy 1 of the adopted Local Plan requires the Local plan review to address Arc related issues. This suggests that the scope of the Local Plan review needs to give more emphasis to assessing the implications of Arc related policy announcements and infrastructure investment decisions. This is particularly important given the Government’s specific reference to a Development Corporation for Bedford, which we consider could have within its remit the delivery of a new settlement, such as that which Taylor Wimpey are proposing. 1.13 There are likely to be further announcements in relation to the Arc over the course of reviewing the Local Plan which the Council will need to be aware of and be in a position to respond to within the scope of the review. Additionally, the implications of the White Paper will also need to be considered within the scope. 1.14 One such implication is the potential abolition of the Duty to Co-operate. Whilst this is likely to be a positive as it will remove one of the legal tests to plan-making, the White Paper is clear that there will still be a need to consider strategic cross boundary issues through plan making. It states: Land west of Wyboston the Duty to Cooperate test would be removed (although further consideration will be given to the way in which strategic cross-boundary issues, such as major infrastructure or strategic sites, can be adequately planned for, including the scale at which plans are best prepared in areas with significant strategic challenges) 1.15 In this regard, the scope of the assessment needs to address the close relationship between Bedford Borough and Central Bedfordshire, including along the A1 corridor which is a key area of infrastructure investment. The proposed revisions to the standard methodology push Central Bedfordshire’s housing need up to 2,752 per year, significantly above the current level of need being planned for, which is likely to be difficult for them to accommodate. Therefore, it will be imperative that the scope of the review is expanded to ensure that cross boundary issues are sufficiently addressed.
The Review should reference the major change which will arise if East West Rail is built. The impact on the countryside will be transformative. The railway is being used as a potential growth determinant. There needs to be a policy addressing the environmental change the railway will bring.
The Consultation Document sets out that the local plan review will focus mainly on growth and infrastructure (housing, employment and supporting infrastructure), with the majority of development management policies from the Local Plan 2030 (adopted January 2020) to be retained. The ongoing COVID-19 Pandemic has emphasised the value of healthcare providers as key stakeholders within the community, and the importance of hospital access for all. The Bedfordshire Hospitals NHS Foundation Trust provides essential healthcare provision to the population of Bedford and the wider area from their established sites in Bedford at the South Wing (Kempston Road) and the North Wing (Kimbolton Road). In addition to their role as healthcare provider, the Trust is a major landowner and employer within the Borough. Q1 Do you agree with the proposed scope of the local plan review? If you think that other areas of existing policy should be updated or new policy areas added to the list, please explain what they are and your reasons for wanting them to be included in the plan. National planning guidance set out in Healthy and Safe Communities PPG states that planning and health need to be considered together in two ways: in terms of creating environments that support and encourage healthy lifestyles, and in terms of identifying and securing the facilities need for primary, secondary and tertiary care, and the wider health and care system (taking into account the changing needs of the population)(Paragraph 001 Reference ID:53-001-20190722). Adopted Local Plan Policy 2S (Healthy Communities) sets out the Council’s support for programmes and strategies which aim to reduce health equalities and promote healthier lifestyles. Sections (i) and (ii) of the Policy refer to Health Impact Assessments and Sections (iii) and (iv) require development to promote health and support the role of allotments, gardens etc. Section (v) states that the Council will “work jointly with health providers to help deliver and protect a network of health facilities in locations accessible by walking, cycling and public transport where this will meet an existing deficiency, or support regeneration or new development.” Building upon this policy approach, the Trust is keen to work with the Council to ensure the ongoing provision of high-quality health facilities within Bedford. The Trust supports local planning policies that protect existing healthcare uses, allowing for the improvement of existing facilities and the development of new facilities and/or sites, whilst also maintaining flexibility for the alternative use of sites that are no longer required. Accessibility to healthcare is a key consideration, and the Trust will support the use of sustainable modes of transport whilst also ensuring access for emergency vehicles and for those who are less able. The Trust will support dedicated stakeholder engagement to patients, visitors and staff to understand how they would support a greater use of public transport. Adopted Local Plan Policy 14 (Land South of the River, Bedford) identifies land for residential use and a mix of retail, business and community uses around St John’s Station. This includes existing Hospital uses to the north/east of Britannia Road. The Trust is supportive of a policy approach which seeks the regeneration of the area and improvements to accessibility and infrastructure. However, we would again emphasise the need for flexibility in terms of land uses, to ensure the most efficient use of land to support the ongoing provision of high-quality healthcare provision. Whilst strategies are focused upon the constant improvement of the Hospital and its clinical facilities, there may be occasions where site disposal for alternative uses is an important mechanism to enable necessary redevelopment works.
2.1 We broadly support the scope of the Local Plan review. It is of vital importance that this review utilises updated guidance relating to establishing a robust housing requirement based on Local Housing Need attained from the Standard Methodology. In August 2020, the Government published its updated methodology for undertaking the standard methodology. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement. 2.2 Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council sets out that the Government have not specifically set out that Bedford needs to increase its housing requirement (as is the case for all authorities), the publication of the revised Standard Methodology shows that without upward adjustment, the joint ambition to deliver a million new dwellings to 2050 within the Arc, will not be met. If all of the Arc authorities use the base Local Housing Need, as established from the Standard Methodology, this target will not be met, with a shortfall of over 156,000 dwellings. This can be easily remedied by increasing the level of growth above the Local Housing Need in each Authority to meet the shortfall, through negotiation, or by simply increasing the housing requirement proportionately to the level of housing need. For example, Bedford’s Local Housing Need is 4% of the entire Arc, so 4% of 156,000 dwellings would lead to an upward adjustment of 6,240 dwellings, only 208 dwellings per annum up to 2050. This would align with the Government’s ambition to significantly boost the supply of housing.
2.1 Bedford Borough Council is seeking to satisfy the requirement to instigate the early review of the Bedford Local Plan 2030, as necessitated by Policy 1 of the existing development plan. The 2020 Issues and Options consultation is of very significant importance to ensuring that the Local Plan Review satisfies the requirements of national policy and guidance. 2.2 Policy 1 of the extant Local Plan was framed to ensure that future levels of growth respond to the government’s national policy objectives consistent with Bedford’s role in delivering strategic priorities for the sub-region. The Inspectors’ Report on the examination of the Local Plan makes clear that it (the Local Plan) provides for an annual housing requirement around 30% lower than the current version of the standard method to calculate Local Housing Need (see paragraph 40). 2.3 Transitional arrangements for the Examination of Plan’s prepared under the requirements of the NPPF 2012, are also cited in the Inspectors’ reasons for accepting a foreshortened plan period to 2030 upon adoption. 2.4 Paragraph 17 of the Inspectors’ Report nonetheless identifies a need to address longer-term strategic priorities, including the Oxford-Cambridge Arc at the earliest opportunity. This will of necessity require a greater degree of engagement on cross-boundary strategic matters, including preparation of Statements of Common Ground and associated outcomes under the Duty to Cooperate. The Inspectors’ Report acknowledges that the less stringent requirements of the NPPF2012 were applicable to the Local Plan in terms of outcomes of engagement (see paragraph 11). 2.5 The Review of the Local Plan also demands an early evaluation of the effectiveness of the current development plan. This specifically relates to the requirement in Policy 1 that the review will secure levels of growth that accord with government policy. A key implication of this relates to the deferral of site allocations to neighbourhood plans. This fundamentally relates to issues of housing land supply and flexibility, including the monitoring of whether the Council is likely to meet even the housing requirement of the Local Plan in full. 2.6 The challenge for the Council in undertaking the Review of the Local Plan 2030 are that issues with its current approach manifest themselves in three main interrelated ways. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 8 2.7 Firstly, the spatial strategy reflects that the current Plan is unable to meet its priorities through strategic options including large-scale sites (including New Settlements) or strategic spatial directions of growth. This makes importing such options into the strategy difficult in the context of meeting the immediate increased requirements from 2020, particularly with options such as New Settlements having been previously rejected. Some of the strategic options identified by the Council therefore only offer a reasonable prospect to meet a proportion of the Council’s requirement in the longer-term. 2.8 However, current planned improvements (such as those related to the A421 corridor) are not sufficiently reflected in the Local Plan 2030. This reveals the existence of strategic spatial options that the Council might support in the immediate term. 2.9 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 is below levels previously tested and found to be just as sustainable as other options. Roxton is a particular example where the capacity for growth is substantially greater than the apportionment of requirements identified by Policy 4S and Policy 27 of the current Plan. This is before considering the settlement’s location within the A421 corridor. This, together with deferral of allocations to Neighbourhood Plans, constrains the Council’s ability to effectively meet its priorities for development through the current strategy in the Local Plan 2030. 2.10 Thirdly, and related to this, the delivery of substantially increased requirements for growth necessitates an approach that more fully reflects the requirements and opportunities to support development in individual centres. This must be supported by clear policies and allocations within the Plan itself. 2.11 The Council’s consultation documents acknowledge the impact of increases to the annual requirement from the proposed 2020 base-date of the revised plan period. What is apparent from options being assessed by the Council is the scope for ‘supplementary’ allocations where contributions towards the increased requirement from 2020 onwards can be achieved as part of sustainable spatial options. Roxton is uniquely placed in this context given its credentials as a Rural Service Centre within the A421 corridor. This must be explicitly stated and addressed by the scope of the Local Plan Review, This is because this solution to meeting the Plan’s increased requirement for growth would alter the requirements for general conformity with adopted strategic policies, comprising part of the basic conditions tests that BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 9 Neighbourhood Plans in the borough need to meet. 2.12 Where the capacity for sustainable development exists, we urge the Council not to impose limits to growth as part of its testing of strategy options or the totals identified for the rural area. Moreover, given the immediate impact of increases to the housing requirement, suitable opportunities for ‘supplementary’ allocations (effectively bridging the gap between the apportionment of growth in the LP2030 and levels of need identified by government policy) should be provided for as allocations rather than being further deferred to the preparation or review of Neighbourhood Plans. Greater weight should be given to those site options that offer clear benefits for delivery. For example, our client’s interest at Land at Ford Lane, comprises 7.5 ha of land withing single ownership that can support comprehensive residential development of 100 units. 2.13 The following sub-sections of this response consider the requirements for plan-making as part of the Local Plan review in the context of national policy and other material considerations. (a) National Policy and Guidance – Implications for the Review of the Local Plan 2030 (i) Plan-Making 2.14 It is helpful to provide a brief overview of policies in the NPPF2019, governing plan-making and central to assessing the soundness of proposals to be prepared as part of the Review of the Local Plan. 2.15 Paragraph 11(a and b) of the NPPF sets out the presumption in favour of sustainable development for plan-making. This establishes that plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change. Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses. It is essential that the options considered as part of the review of the Local Plan seek to fully address these requirements. 2.16 Paragraph 16(c) of the NPPF emphasises that plans must be positively prepared to ensure that they are aspirational but deliverable. Paragraph 20 makes clear that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for development needs (including housing), alongside requirements for infrastructure (including community facilities) and conservation and enhancement of the BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 10 natural, built and historic environment. This combination of policy requirements is likely to demand an integrated range of approaches, depending on the area’s priorities. 2.17 Paragraph 22 of the NPPF stipulates the requirement for strategic policies to look over a minimum 15-year period upon adoption, in order to incorporate longer-term requirements and opportunities, including major infrastructure investment. Paragraph 23 sets out the importance of plan-making, providing for a clear strategy that ensures bringing forward sufficient land at a sufficient rate to meet needs over the plan period. 2.18 Paragraphs 24 to 27 of the Framework deal with requirements to maintain effective cooperation under the Duty to Cooperate. Ongoing joint working is key to determining how cross-boundary strategic priorities are addressed and setting out where additional infrastructure investment may be necessary. Planning Practice Guidance further sets out the importance of the preparation of Statements of Common Ground to address progress made via engagement. This is central to demonstrating how options have been assessed and that the strategy is deliverable over the plan period (PPG ID: 61-010-20190315). 2.19 Paragraphs 31 to 33 of the NPPF2019 deal with the preparation and review of Plans and specifically the requirement to assess alternative options. Paragraph 33 sets out that the review of Plans “should take into account changing circumstances affecting the area, or any relevant changes in national policy”. This is clearly reinforced by the requirements of Policy 1 of the Local Plan 2030. In accordance with Paragraph 32 of the Framework preparation of the Plan should seek to achieve net gains for the economic, social, and environmental objectives of sustainable development. 2.20 In relation to identifying land for housing in the context of options identified in the Borough’s consultation proposals paragraph 72 of the NPPF2019 deals with planning for larger-scale development. This stipulates that necessary consideration must be given to requirements for infrastructure and services; joint-working with other authorities (where required); and making a realistic assessment of potential delivery rates, given lead-in timescales for development. This is significant in the context of the Local Plan 2030 having avoided any decisions on strategic locations for growth. 2.21 The requirement for the Review of the Bedford Local Plan 2030, as set out in Policy 1, reflects paragraph 60 of the NPPF2019. This stipulates that strategic policies should be informed by BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 11 a local housing need assessment, conducted using the standard method in national planning guidance i.e. in order to support levels of growth that accord with government policy. The Council’s consultation document acknowledges the annual requirement of 1,305dpa produced as a result of the current local housing need calculation. However, the scope for the Local Plan Review must also acknowledge Planning Practice Guidance that recognises that the figure produced by the standard method is a minimum starting point (PPG ID: 2a-010-20190220). As well as considering unmet need from neighbouring authorities guidance also addresses circumstances where actual need is higher than the standard method indicates as well as where a higher requirement might be accommodated (such as because of planning infrastructure improvements). The Council’s consultation documents do not illustrate how issues relating to whether actual need exceeds the figure produced by the standard method will be assessed, nor whether options to support a higher housing requirement will be considered. We reserve our position to comment further on these elements in subsequent stages of consultation, dependent on the Council’s activities to test a sufficiently broad range of alternatives to levels of growth exceeding 1,305dpa. 2.22 In relation to housing in the rural area Paragraph 78 of the NPPF2019 states that sustainable development can be achieved through locating housing where this would maintain or enhance the vitality of rural communities. This includes recognition of providing support for local services and supporting the needs of other nearby centres. 2.23 Paragraph 65 of the NPPF2019 stipulates the requirement for strategic policy-making authorities to set out requirements for designated neighbourhood areas. This should be derived from the overall requirement and reflect the overall strategy for the pattern and scale of development (including any allocations). It is therefore not a sound basis for plan-making to suggest that the housing requirement figures in Policy 4S of the Local Plan 2030 will not be reviewed as part of this process. Particularly for settlements such as Roxton the updated requirement must positively reflect the ability to contribute towards the A421-based spatial option. 2.24 We consider that this background to the requirement for the Review of the Local Plan 2030 is not sufficiently acknowledged in the Issues and Options Consultation document. Specifically: • The document includes no reference to the Duty to Cooperate, despite Policy 1 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 12 and the Local Plan Inspectors’ Report emphasising the importance of cross-boundary priorities. • That local housing need, as calculated through the standard method, will be treated as a starting point and that opportunities to support a higher requirement will be assessed. • Notwithstanding specific reference to the Duty to Cooperate, the documents also fail to explicitly acknowledge that certain options will require greater impetus than others regarding potential matters including joint-working and infrastructure funding. This should be considered explicitly in terms of the potential timeframes for options to secure sustainable development over the plan period. • The consultation document does not consider issues of flexibility and choice in terms of the scope for the Local Plan Review, which is imperative given the significant increase in the housing requirement to be provided for. It is noted that only the ‘Dispersed Growth’ option is listed as providing for “early delivery of new homes”. • The requirements of NPPF2019 Paragraph 72 should be explicitly acknowledged to frame the Council’s assessment of strategic growth options. 2.25 Taking account of the summary above we consider that the following elements and priorities for plan-making must be clearly set out and explored as part of the scope for the Review of the Local Plan 2030: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). This should particularly focus on existing and planned infrastructure improvements along the A421 Corridor, to capitalise on this strategic priority and opportunity it provides to meet future needs. • Ensure that opportunities to sustain and enhance the role of settlements within the settlement hierarchy (e.g. Roxton as a Rural Service Centre) fully reflects their capacity for growth and positive relationship with wider spatial options e.g. A421-based growth. • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community • Maximise opportunities to enhance Green Infrastructure and meet ‘healthy communities’ objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan. • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period, including avoiding over optimism regarding forecast delivery towards the Plan’s requirements from sites in the Town Centre within the period to 2030 and beyond. 2.26 The following sections set out the further justification and recommendations for plan-making on how this should be achieved as part of satisfying the legal compliance and soundness requirements for the Local Plan Review. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 13 (b) Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 2.27 In terms of the testing of options for the distribution of growth it is important to stress that during preparation of the Local Plan the Council only excluded options for higher levels of growth in Key Service Centres and Rural Service Centres purely on the grounds that the level of development was beyond that required by the draft Plan. 2.28 Options deriving a greater proportion of development in these locations had been previously assessed as being some of the most sustainable (see Options 8, 19 and 33 of the Council’s January 2018 Sustainability Appraisal for the Local Plan 2030). This illustrates that in the Council’s consultant’s own view options to meet a higher overall requirement (or provide for an extended plan period) would be “just as sustainable” as the new village option that was selected in January 2018. 2.29 Delivery of growth in the rural area remains of key importance to avoiding negative impacts in sustainability terms and meeting the needs of certain settlements. It is surely the case, given earlier consultations, that if the Plan’s priorities required additional levels of development this could appropriately be delivered in a wider range of settlements (and/or more development where capacity allows in certain settlements). 2.30 It should also be noted that in terms of taking forward options previously tested the current Local Plan takes no account of planned improvements along the A421 corridor. The potential for higher levels of growth in the rural area takes no account of the distribution amongst individual settlements. This is particularly important for the settlement of Roxton, where the potential effects of higher levels of growth would also accord with the positive outcomes of delivering the A421-based spatial option. Revisiting the scope for appropriate higher levels of growth in the rural area should specifically reflect this spatial context for Roxton. BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 14 (c) Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 2.31 National Planning Practice Guidance sets out that when determining whether policies in existing plans should be updated it is relevant to consider the Council’s housing land supply position and whether issues have arisen that may impact on the deliverability of key site allocations. Both of these aspects are highly relevant in the Borough (ID: 61-065-20190723). 2.32 The Council’s current calculation of a Five Year Supply of deliverable sites demonstrates implications for the allocation of sites to accommodate additional housing requirement to be met through the Local Plan Review (i.e. 15,000 dwellings using the current calculation of local housing need). 2.33 Table 1 below illustrates that when committed supply against the requirements for growth to be provided for through the Review of the Local Plan 2030 are understood in the context of forecast supply a substantial requirement for allocations exists in the period 2023-2030. This equates to a further 3,341 units to be provided to meet housing needs identified by the government’s current standard method in the period 2024 to 2030, in addition to a small shortfall to be provided against adoption of this requirement for the proposed plan period from 2020. Table 1: Contribution of Forecast Local Plan 2030 Supply Towards Housing Requirement Options based on Local Housing Need Additional Allocations Required (by breakdown of Plan Period) Total Additional Allocations Required Annual Requirement 2020-2023 2024-2030 2030-2040 2040-2045 2020-2040 2020-2045 Committed Supply (based on Local Plan 2030 Housing Trajectory) 3,487 5,794 1,647 0 Supply vs Requirement (Future Plan Period) Local Housing Need - Current Standard Method 1305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1153 28 -2,277 -9,883 -5,765 -12,132 -17,897 BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 15 2.34 The figure of at least 3,341 units broadly determines the scope for ‘supplementary’ allocations beyond the levels of development identified in Policies 3S and 4S of the current Local Plan. It is essential that the Review of the Local Plan adopts a positively prepared approach to providing for the apportionment of additional requirements for growth and does not impose arbitrary caps to growth in individual settlements as well as reflecting those centres where capacity is greatest. The ability of suitable, deliverable, allocations to meet increased requirements in the period to 2030 should be considered favourably in the context of assessing site options and site selection. 2.35 The Council’s most recent ‘5 Year Supply of Deliverable Housing Sites’ Report highlights three key reasons why choice and flexibility in supply as part of preparation of the Local Plan Review is critical. This aligns with broader concerns regarding the effectiveness of the existing development plan and conclusions the undermine the Council’s current claimed supply of deliverable sites: • As a result of the approach to managing supply in the adopted Plan a surplus in delivery for the period 2015 to 2019 means the Council is seeking to provide for reduced annual five year requirement in order to maintain supply in excess of five years (798dpa vs 970dpa). • Furthermore, the Council’s accounting for oversupply exceeds the allowance proposed by the Inspectors, which would factor this over the remaining plan period (798dpa vs 918dpa) (see Inspectors’’ Report paragraphs 116 and 117). • The Council now acknowledges that it regards none of the sites allocated via the Local Plan 2030 or proposed for allocation in Neighbourhood Plans to be prepared (where permission is not already in place) are to be treated as deliverable. 2.36 Table 2 below summarises the impact of these elements of the calculation (in terms of forecast supply and the management of oversupply) of housing land supply using the adopted Local Plan 2030: BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 16 Table 2: Comparison of Calculations of the Five Year Requirement and Housing Land Supply Based on Bedford Local Plan 2030 Requirement Council's Update Inspectors' Method for Oversupply No Oversupply No. of Dwellings No. of Dwellings No. of Dwellings Local Plan Requirement 14550 14550 14550 Annual Requirement 970 970 970 5 Year Supply Requirement 2019-2024 (970 x 5) 4850 4850 4850 Requirement 2015 to 2019 3880 3880 3880 Completions 2015 to 2019 4,928 4,928 4,928 Shortfall / Oversupply 2015 to 2019 -1048 0 Residual Local Plan Requirement 9,622 Annual Requirement with Adjustment for Oversupply 760.4 875 970 Requirement incl. Shortfall 3802 4374 4850 5 year supply requirement (2019-2024) including 5% buffer 3992 4592 5093 Annual supply required 798 918 1019 Supply 4,593 4,593 4,593 Difference 601 1 -500 5 year housing land supply position 5.75 5.00 4.51 2.37 The Review of the Local Plan 2030 should therefore acknowledge its key role in ensuring the Borough Council’s ability to provide choice and flexibility in supply. This role will increase further in the event of any further delays to the preparation of Neighbourhood Plans or delivery of other allocated sites (including Town Centre sites) but is in any event necessitated by the increase in the housing requirement derived through national policy. (d) Impact of Government Consultation on Proposed Planning Reforms 2.38 In terms of considering the potential implications of the government’s ‘Planning for the Future’ White Paper, in the context of the scope for the Local Plan Review, it should be noted that the contents of the White Paper comprise consultation proposals only. Presently they are of no material weight in terms of approaching the requirements of plan-making, however we reserve the right to comment further in due course. 2.39 It should be noted, however, that where page 16 of the Council’s consultation document BE5553/1 Roxton Philip C Bath Ltd Issues & Options Consultation September 2020 17 refers to pending details of the government’s proposed revisions to the standard method to calculate local housing need this is on the basis of indicating a potential reduction in the housing requirement to 800 homes per annum. While the Council states this reflects uncertainties with the most recent 2018-based household projections the government has reasserted its commitment to delivering a figure of at least 300,000 homes per annum across England. 2.40 The government’s consultation proposals on a revised approach to calculation of the standard method achieve a total of 337,000 dwellings per annum, including an assessment of need equating to 1,153 dwellings per annum in Bedford Borough. This is substantially greater than the lower end of the range indicated in the Borough’s Consultation Document. We therefore consider that the Council’s indicative suggestion for a ‘lower end’ housing requirement has no basis in delivering a sound outcome against the requirements for the Local Plan Review, as stipulated by Policy of the Local Plan 2030.
2.1 Bedford Borough Council is seeking to satisfy the requirement to instigate the early review of the Bedford Local Plan 2030, as necessitated by Policy 1 of the existing development plan. The 2020 Issues and Options consultation is of very significant importance to ensuring that the Local Plan Review satisfies the requirements of national policy and guidance. 2.2 Policy 1 of the extant Local Plan was framed to ensure that future levels of growth respond to the government’s national policy objectives consistent with Bedford’s role in delivering strategic priorities for the sub-region. The Inspectors’ Report on the examination of the Local Plan makes clear that it (the Local Plan) provides for an annual housing requirement around 30% lower than the current version of the standard method to calculate Local Housing Need (see paragraph 40). 2.3 Transitional arrangements for the Examination of Plan’s prepared under the requirements of the NPPF 2012, are also cited in the Inspectors’ reasons for accepting a foreshortened plan period to 2030 upon adoption. 2.4 Paragraph 17 of the Inspectors’ Report nonetheless identifies a need to address longer-term strategic priorities, including the Oxford-Cambridge Arc at the earliest opportunity. This will of necessity require a greater degree of engagement on cross-boundary strategic matters, including preparation of Statements of Common Ground and associated outcomes under the Duty to Cooperate. The Inspectors’ Report acknowledges that the less stringent requirements of the NPPF2012 were applicable to the Local Plan in terms of outcomes of engagement (see paragraph 11). 2.5 The Review of the Local Plan also demands an early evaluation of the effectiveness of the current development plan. This specifically relates to the requirement in Policy 1 that the review will secure levels of growth that accord with government policy. A key implication of this relates to the deferral of site allocations to neighbourhood plans. This fundamentally relates to issues of housing land supply and flexibility, including the monitoring of whether the Council is likely to meet even the housing requirement of the Local Plan in full. 2.6 The challenge for the Council in undertaking the Review of the Local Plan 2030 are that issues with its current approach manifest themselves in three main interrelated ways. 2.7 Firstly, the spatial strategy reflects that the current Plan is unable to meet its priorities through strategic options including large-scale sites (including New Settlements) or strategic spatial directions of growth. This makes importing such options into the strategy difficult in the context of meeting the immediate increased requirements from 2020, particularly with options such as New Settlements having been previously rejected. Some of the strategic options identified by the Council therefore only offer a reasonable prospect to meet a proportion of the Council’s requirement in the longer-term. It is, however, accepted that there are some planned improvements such as those centred around the A421 corridor that may enable some greater proportion of needs to be met in the early part of the plan period through a combination of option. 2.8 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres in the Local Plan 2030 is below levels previously tested and found to be just as sustainable as other options. This, together with deferral of allocations to Neighbourhood Plans, constrains the Council’s ability to effectively meet its priorities for development through this sustainable ‘dispersed’ strategy. 2.9 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local 7 Plan 2030 is not based on a clear understanding of requirements and capacity for growth in individual settlements and instead adopts an arbitrary approach to apportioning requirements. Therefore, while it is evident that the rural area is a suitable location to meet a substantial proportion of the Plan’s increased requirements for development this can only be achieved as part of a detailed review of the settlement hierarchy and provision for development in individual centres. This must be supported by clear policies and allocations within the Plan itself. 2.10 The Council’s consultation documents acknowledge the impact of increases to the annual requirement from the proposed 2020 base-date of the revised plan period. What is apparent from options being assessed by the Council is the scope for ‘top-up’ allocations where contributions towards the increased requirement from 2020 onwards can be achieved in settlements across the rural area, compared to the current Policy 4S totals. This must be explicitly stated and addressed by the scope of the Local Plan Review, This is because this solution to meeting the Plan’s increased requirement for growth would alter the requirements for general conformity with adopted strategic policies, comprising part of the basic conditions tests that Neighbourhood Plans in the borough need to meet. 2.11 Where the capacity for sustainable development exists, we urge the Council not to impose limits to growth as part of its testing of strategy options or the totals identified for the rural area. Moreover, given the immediate impact of increases to the housing requirement, suitable opportunities for ‘top up’ allocations should be provided for as allocations rather than being further deferred to the preparation or review of Neighbourhood Plans. 8 3.0 NATIONAL POLICY AND GUIDANCE – IMPLICATIONS FOR THE REVIEW OF THE LOCAL PLAN 2030 Plan-Making 3.1 It is helpful to provide a brief overview of policies in the NPPF2019, governing plan-making and central to assessing the soundness of proposals to be prepared as part of the Review of the Local Plan. 3.2 Paragraph 11(a and b) of the NPPF sets out the presumption in favour of sustainable development for plan-making. This establishes that plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change. Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses. It is essential that the options considered as part of the review of the Local Plan seek to fully address these requirements. 3.3 Paragraph 16(c) of the NPPF emphasises that plans must be positively prepared to ensure that they are aspirational but deliverable. Paragraph 20 makes clear that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for development needs (including housing), alongside requirements for infrastructure (including community facilities) and conservation and enhancement of the natural, built and historic environment. This combination of policy requirements is likely to demand an integrated range of approaches, depending on the area’s priorities. 3.4 Paragraph 22 of the NPPF stipulates the requirement for strategic policies to look over a minimum 15-year period upon adoption, in order to incorporate longer-term requirements and opportunities, including major infrastructure investment. Paragraph 23 sets out the importance of plan-making, providing for a clear strategy that ensures bringing forward sufficient land at a sufficient rate to meet needs over the plan period. 3.5 Paragraphs 24 to 27 of the Framework deal with requirements to maintain effective cooperation under the Duty to Cooperate. Ongoing joint working is key to determining how cross-boundary strategic priorities are addressed and setting out where additional infrastructure investment may be necessary. Planning Practice Guidance further sets out the importance of the preparation of Statements of Common Ground to address progress made via engagement. This is central to demonstrating how options have been assessed and that the strategy is deliverable over the plan period (PPG ID: 61-010-20190315) 3.6 Paragraphs 31 to 33 of the NPPF2019 deal with the preparation and review of Plans and specifically the requirement to assess alternative options. Paragraph 33 sets out that the review of Plans “should take into account changing circumstances affecting the area, or any relevant changes in national policy.“ This is clearly reinforced by the requirements of Policy 1 of the Local Plan 2030. In accordance with Paragraph 32 of the Framework preparation of the Plan should seek to achieve net gains for the economic, social, and environmental objectives of sustainable development. 3.7 In relation to identifying land for housing in the context of options identified in the Borough’s consultation proposals paragraph 72 of the NPPF2019 deals with planning for larger-scale development. This stipulates that necessary consideration must be given to requirements for infrastructure and services; joint-working with other authorities (where required); and making a realistic assessment of potential delivery rates, given lead-in timescales for development. This is significant in the context of the Local Plan 2030 having avoided any decisions on strategic locations for growth. 9 3.8 We consider that this background to the requirement for the Review of the Local Plan 2030 is not sufficiently acknowledged in the Issues and Options Consultation document. Specifically: 3.9 The document includes no reference to the Duty to Cooperate, despite Policy 1 and the Local Plan Inspectors’ Report emphasising the importance of cross-boundary priorities 3.10 Notwithstanding specific reference to the Duty to Cooperate, the documents also fail to explicitly acknowledge that certain options will require greater impetus than others regarding potential matters including joint-working and infrastructure funding. This should be considered explicitly in terms of the potential timeframes for options to secure sustainable development over the plan period 3.11 The consultation document does not consider issues of flexibility and choice in terms of the scope for the Local Plan Review, which is imperative given the significant increase in the housing requirement to be provided for. It is noted that only the ‘Dispersed Growth’ option is listed as providing for “early delivery of new homes”. 3.12 The requirements of NPPF2019 Paragraph 72 should be explicitly acknowledged to frame the Council’s assessment of strategic growth options. Rural Housing and Implications for the Existing Spatial Strategy 3.13 In relation to the spatial strategy of the adopted Local Plan, pp.15 of the Council’s consultation document acknowledges that “growth is directed to the larger villages (except where there are already large-scale commitments or nearby), with more in the key service centres and less in the rural service centres.” This recognition is welcome, but the document goes on to state that this approach to the distribution of growth will not meet development requirements in the longer-term. 3.14 Notwithstanding that the Council is seeking to explore alternative spatial options as part of the Review of the Local Plan, we consider that the consultation document should be explicit that the review will seek to maximise opportunities for growth as part of an overall approach to the distribution of development that has been found to be sustainable. This should acknowledge that: • The settlement hierarchy classification of Rural Key Service Centres and Rural Service Centres will be reviewed as part of the Review of the Local Plan 2030; and • The Council will specifically assess more dispersed options to distribute growth to settlements not currently classified as Rural Service Centres/Key Service Centres – for example other villages with a policy area boundary as encouraged by previous rounds of consultation and the capacity of other settlement is also reviewed. 3.15 These representations provide specific grounds to reflect more clearly each of the components within the scope of the review. Our suggestions accord with national policy for making provision for housing in rural areas. Paragraph 78 of the NPPF2019 states that sustainable development can be achieved through locating housing where this would maintain or enhance the vitality of rural communities. This includes recognition of providing support for local services and supporting the needs of other nearby centres. 3.16 Planning Practice Guidance notes that plan-making authorities should consider the broader sustainability of rural communities and potential benefits to housing affordability when seeking to establish the approach to housing supply in rural areas. This goes on to state: “A wide range of settlements can play a role in delivering sustainable development 10 in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.” (ID: 67-009-20190722) 3.17 The importance of these elements of national policy are reinforced by Paragraph 65 of the NPPF2019 and the requirement for strategic policy-making authorities to set out requirements for designated neighbourhood areas. This should be derived from the overall requirement and reflect the overall strategy for the pattern and scale of development (including any allocations). 3.18 It is not a sound basis for plan-making to suggest that the housing requirement figures and settlements identified for growth in Policy 4S of the Local Plan 2030 will not be reviewed as part of this process. 3.19 The NPPF does not stipulate that requirement figures for designated Neighbourhood Areas should be limited to any existing categories within the settlement hierarchy or adhere to the distribution of growth in the existing development plan. This is inherently logical in terms of considering options for development where, as in the case of the Review of the Local Plan 2030, needs are being considered over a minimum 15-year period. This is particularly relevant to potential requirements for growth in settlements with no figure identified in the current Policy 4S; and for other villages with a Settlement Policy Area Boundary not covered by the existing distribution of growth. Conclusions to Inform the Scope of the Review of the Local Plan 3.20 Taking account of the summary above we consider that the following elements and priorities for plan-making must be clearly set out and explored as part of the scope for the Review of the Local Plan 2030: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). • Reassess the capacity for growth across the settlement hierarchy in the existing Local Plan 2030 alongside a review of the classification on individual settlements (Policy 4S) • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community • Maximise opportunities to enhance Green Infrastructure and meet healthy communities objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period • Maximise opportunities for suitable, available, and deliverable development in the urban area as part of a composite spatial strategy while acknowledging the constraints to this component of the overall strategy in terms of timeframes and levels of growth. 3.21 The following sections set out the further justification and recommendations for plan-making on how this should be achieved as part of satisfying the legal compliance and soundness requirements for the Local Plan Review. 11 Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 3.22 In terms of the testing of options for the distribution of growth it is important to stress that during preparation of the Local Plan the Council only excluded options for higher levels of growth in rural villages purely on the grounds that the level of development was beyond that required by the draft Plan. 3.23 Options deriving a greater proportion of development in these locations had been previously assessed as being some of the most sustainable (see Options 8, 19 and 33 of the Council’s January 2018 Sustainability Appraisal for the Local Plan 2030). This illustrates that in the Council’s consultant’s own view options to meet a higher overall requirement (or provide for an extended plan period) would be “just as sustainable” as the new village option that was selected in January 2018. An outline of options previously tested is summarised in Table 1 below: Table 1. Extracts from January 2018 and September 2018 Sustainability Appraisal list of options Date of SA Scenario New settlements Stewartby brickworks site Land South of Bedford Within and adjoining urban area Group 1 villages Group 2 villages Total dwellings SA January 2018 19 0 0 0 2630 high growth 5100 low growth 225 795 5 SA September 2018 13 0 100 0 high growth 2895 high growth 4000 low growth 260 725 5 3.24 The Inspectors undertaking the Examination of the Local Plan 2030 identified the subsequent requirement for an immediate review on account of the resulting foreshortened plan period to 2030, and a significant change in circumstances arising from housing needs calculated using the government’s standard method. It is self-evident that the Council’s options for the Review of the Local Plan must incorporate the same (or greater) levels of development identified in previously excluded but sustainable options. 3.25 It is also a logical approach to carry forward the approach in the current Local Plan 2030, which recognises the relative importance of the rural area to deliver the Plan’s strategic priorities in terms of overall distribution. This is notwithstanding issues arising from the deferral of site allocations and the constraints imposed by the limited plan period. 3.26 Delivery of growth in the rural area remains of key importance to avoiding negative impacts in sustainability terms and meeting the needs of certain settlements. It is surely the case, given earlier consultations, that if the Plan’s priorities required additional levels of development this could appropriately be delivered in a wider range of settlements (and/or more development where capacity allows in certain settlements). 3.27 Further comprehensive testing of reasonable alternatives that acknowledge the necessity for a flexible spatial strategy and maximisation of opportunities for sustainable development in the rural area to meet the plan area’s strategic priorities must form a key component when preparing the Review of the Local Plan 2030. As per the conclusions in the evidence base for the existing adopted development plan it is our view that: 12 • This would again conclude that distributing a higher proportion of development in the rural areas at is least equally as sustainable as other options including provision of a New Settlement set out in the January 2018 version of the Regulation 19 Plan; and • It can further be demonstrated that the rural areas (and in-particular Key Service Centres and Rural Service Centres) are capable of sustainably accommodating higher totals for housing than proposed in the adopted Local Plan 2030; and • Sustainable options therefore exist to ensure that the Local Plan seeks to meet needs over a 15-year plan period. 3.28 One further implication for testing levels of growth as part of the ‘Dispersed’ spatial option is that the evidence base for the Local Plan 2030 did not test figures for growth in other villages with a Settlement Policy Area (or ‘Group 3’ villages) such as Renhold / Salph End. This is despite such settlements previously being assessed as capable of making a sustainable contribution towards development needs in earlier iterations of the Plan. This view is also consistent with paragraph 65 of the NPPF2019 in terms of the provision of housing requirement figures to all designated neighbourhood areas. Testing of options should therefore assess scope to contribute towards needs for sustainable development across a wider range of centres. Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 3.29 National Planning Practice Guidance sets out that when determining whether policies in existing plans should be updated it is relevant to consider the Council’s housing land supply position and whether issues have arisen that may impact on the deliverability of key site allocations. Both of these aspects are highly relevant in the Borough (ID: 61-065-20190723). 3.30 Appendix 2 of these representations provides further analysis of the Council’s current calculation of a Five Year Supply of deliverable sites and implications for the allocation of sites to accommodate additional housing requirement to be met through the Local Plan Review (i.e. 15,000 dwellings using the current calculation of local housing need). 3.31 Table 2 below illustrates that when committed supply against the requirements for growth to be provided for through the Review of the Local Plan 2030 are understood in the context of forecast supply a substantial requirement for allocations exists in the period 2023-2030. This equates to a further 3,341 units to be provided to meet housing needs identified by the government’s current standard method in the period 2024 to 2030, in addition to a small shortfall to be provided against adoption of this requirement for the proposed plan period from 2020. 13 Table 2. Contribution of Forecast Local Plan 2030 Supply Towards Housing Requirement Options based on Local Housing Need Additional Allocations Required (by breakdown of Plan Period) Total Additional Allocations Required Annual Requirement 2020- 2023 2024- 2030 2030- 2040 2040- 2045 2020- 2040 2020- 2045 Committed Supply (based on Local Plan 2030 Housing Trajectory) 3,487 5,794 1,647 0 Supply vs Requirement (Future Plan Period) Local Housing Need - Current Standard Method 1305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1153 28 -2,277 -9,883 -5,765 -12,132 -17,897 3.32 The figure of at least 3,341 units broadly determines the scope for ‘top up’ allocations beyond the levels of development identified in Policies 3S and 4S of the current Local Plan. It is essential that the Review of the Local Plan adopts a positively prepared approach to providing for ‘top up’ allocations and does not impose arbitrary caps to growth in individual settlements as well as reflecting those centres where capacity is greatest. The ability for deliverable ‘top up’ allocations suitable to meet increased requirements in the period to 2030 should be considered favourable in the context of assessing site options and site selection. 3.33 The Council’s most recent ‘5 Year Supply of Deliverable Housing Sites’ Report highlights three key reasons why choice and flexibility in supply as part of preparation of the Local Plan Review is critical. This aligns with broader concerns regarding the effectiveness of the existing development plan and conclusions the undermine the Council’s current claimed supply of deliverable sites: 3.34 As a result of the approach to managing supply in the adopted Plan a surplus in delivery for the period 2015 to 2019 means the Council is seeking to provide for reduced annual five year requirement in order to maintain supply in excess of five years (798dpa vs 970dpa) 3.35 Furthermore, the Council’s accounting for oversupply exceeds the allowance proposed by the Inspectors, which would factor this over the remaining plan period (798dpa vs 918dpa) (see Inspectors’’ Report paragraphs 116 and 117) 3.36 The Council now acknowledges that it regards none of the sites allocated via the Local Plan 2030 or proposed for allocation in Neighbourhood Plans to be prepared (where permission is not already in place) are to be treated as deliverable 3.37 Table 3 below summarises the impact of these elements of the calculation (in terms of forecast supply and the management of oversupply) of housing land supply using the adopted Local Plan 2030: 14 Table 3. Comparison of Calculations of the Five Year Requirement and Housing Land Supply Based on Bedford Local Plan 2030 Requirement Council's Update Inspectors' Method for Oversupply No Oversupply No. of Dwellings No. of Dwellings No. of Dwellings Local Plan Requirement 14550 14550 14550 Annual Requirement 970 970 970 5 Year Supply Requirement 2019- 2024 (970 x 5) 4850 4850 4850 Requirement 2015 to 2019 3880 3880 3880 Completions 2015 to 2019 4,928 4,928 4,928 Shortfall / Oversupply 2015 to 2019 -1048 0 Residual Local Plan Requirement 9,622 Annual Requirement with Adjustment for Oversupply 760.4 875 970 Requirement incl. Shortfall 3802 4374 4850 5 year supply requirement (2019- 2024) including 5% buffer 3992 4592 5093 Annual supply required 798 918 1019 Supply 4,593 4,593 4,593 Difference 601 1 -500 5 year housing land supply position 5.75 5.00 4.51 3.38 The Review of the Local Plan 2030 should therefore acknowledge its key role in ensuring the Borough Council’s ability to provide choice and flexibility in supply. This role will increase further in the event of any further delays to the preparation of Neighbourhood Plans or delivery of other allocated sites (including Town Centre sites) but is in any event necessitated by the increase in the housing requirement derived through national policy. Impact of Government Consultation on Proposed Planning Reforms 3.39 Appendix 3 of these representations considers the potential implications of the government’s ‘Planning for the Future’ White Paper in the context of the scope for the Local Plan Review. In summary, the contents of the White Paper comprise consultation proposals only and are of no material weight in terms of approaching the requirements of plan-making, however we reserve the right to comment further in due course. 3.40 It should be noted, however, that where page 16 of the Council’s consultation document refers to pending details of the government’s proposed revisions to the standard method to calculate local housing need this is on the basis of indicating a potential reduction in the housing requirement to 800 homes per annum. While the Council states this reflects uncertainties with the most recent 2018-based household projections the government has reasserted its commitment to delivering a figure of at least 300,000 homes per annum across England. 3.41 The government’s consultation proposals on a revised approach to calculation of the 15 standard method achieve a total of 337,000 dwellings per annum, including an assessment of need equating to 1,153 dwellings per annum in Bedford Borough. This is substantially greater than the lower end of the range indicated in the Borough’s Consultation Document. We therefore consider that the Council’s indicative suggestion for a ‘lower end’ housing requirement has no basis in delivering a sound outcome against the requirements for the Local Plan Review, as stipulated by Policy of the Local Plan 2030.
2.1 We broadly support the scope of the Local Plan review. It is of vital importance that this review utilises updated guidance relating to establishing a robust housing requirement based on Local Housing Need attained from the Standard Methodology. In August 2020, the Government published its updated methodology for undertaking the standard methodology. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement. 2.2 Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council sets out that the Government have not specifically set out that Bedford needs to increase its housing requirement (as is the case for all authorities), the publication of the revised Standard Methodology shows that without upward adjustment, the joint ambition to deliver a million new dwellings to 2050 within the Arc, will not be met. If all of the Arc authorities use the base Local Housing Need, as established from the Standard Methodology, this target will not be met, with a shortfall of over 156,000 dwellings. This can be easily remedied by increasing the level of growth above the Local Housing Need in each Authority to meet the shortfall, through negotiation, or by simply increasing the housing requirement proportionately to the level of housing need. For example, Bedford’s Local Housing Need is 4% of the entire Arc, so 4% of 156,000 dwellings would lead to an upward adjustment of 6,240 dwellings, only 208 dwellings per annum up to 2050. This would align with the Government’s ambition to significantly boost the supply of housing.
Yes, we need to work to a plan, but must recognise that changes to the population may need the plan to be amended.
The general proposed scope of the plan appears to cover the main matters which would be anticipated to be included within the Local Plan Review. However, given that one of the background requirements for the review relates to providing for long term growth (in particular in relation to delivery within the Oxford to Cambridge Arc), it is considered that the scope should explicitly reference this matter. We welcome the inclusion of employment growth in the scope of the Local Plan Review as this was not included in the Local Plan 2030, and this is crucial for the economic growth of the Borough, particularly as we try to bounce back from the impacts of the Covid 19 crisis.