Question 1
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.
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.
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.
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. We support the proposal to include a policy to deliver self & custom build opportunities. Self-Build plots are an excellent way of facilitating good quality, well designed, cost effective, and energy efficient housing which is tailored to the needs of the purchaser. Self-build dwellings are an essential part of the housing mix going forward but they need to be provided in the right location. Up until now, Self Build dwellings have tended to come forward as individual windfall plots, where the self-builder is competing with the small and medium scale house builder, or as a small percentage of more recently approved larger sites. However, in order to encourage more self-build and custom housebuilding, it is important that the plots are located where the market wants them to be, and there is greater interest from the market for bespoke plots in the rural area rather than plots which are part of large scale sites dominated by market housing. The Council should therefore be looking for suitable sites in the rural area, that can address this need. Several of our clients have land which is suitable of providing small clusters of bespoke self-build plots in the rural area and this presents an opportunity for the Council to facilitate the delivery self-build in more desirable locations where the demand is higher. These self-build plots will encourage local people to stay in the locality and attract others to it, and this will contribute towards the NPPF’s objective of enhancing and maintaining the vitality of rural communities. The sites below have all been submitted through the Call For Sites process and are available for self-build: • Land East Of Heddings Farm, Wyboston • Top Farm, Wyboston • Shrubbery Farm, Wilden • Land North Of Home Farm, Renhold • Land South Of Home Farm, Renhold • Land Rear Of Home Farm, Renhold • Land To The West Of 52 Keeley Lane, Wootton • Land At 66 Hall End Road, Wootton
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 support the development of a strategy and allocate new development sites to accommodate growth in line with national policy requirements and hope this will include the allocation of small sites in the rural area.
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. The scope of the Local Plan Review should also include some allocations for leisure and tourism uses. Although previous Local Plans have encouraged leisure and tourism through general policies in the Plan, they have not actively promoted any sites through allocations. There is an opportunity for this be addressed as part of the Review.
It is noted that this consultation includes a revised housing figure provided as a range between 800-1,305 dwellings per annum. However, there is no consideration within this Local Plan consultation in regards to the suitability of these figures. It is centrally important to consider the Local Housing Need requirement in order for an appropriate and sustainable level of growth to be identified and provided for across the Borough, delivering a sufficient amount of housing within the plan period. The requirement for an early review of the Bedford Borough Local Plan 2030 was recognised through the main modifications with the inclusion of Policy 1S. The policy requires the Local Plan 2030 to be reviewed much sooner than usual: a review is required within a year, and a new plan to be submitted for examination within three years of the Local Plan 2030 being adopted. Within the Inspector’s final report, it was recognised that the Standard Method figure was circa 30% higher than current housing figure in the Local Plan 2030. The expectation was that the housing need figure would increase in order to accommodate the anticipated growth from the Oxford to Cambridge Arc. Rather than providing a housing figure of 1,305, based on the current Standard Methodology, (which is some 35% above the currently adopted Local Plan 2030 figure of 970 dwellings per annum) the range of 800 -1,305 has been considered for a number of reasons. These include the Governments figures for affordability, published on an annual basis, are subject to change when new data is published, as well as the Government has announced its intentions to review the Standard Method in its entirety, which is currently out for consultation. Whilst it is accepted that these are uncertainties, the Local Plan should be based on a figure which is in accordance with the agreed method of the time, which in this case, is the current Standard Method approach based on the 2014-based population projections. Furthermore, the Governments figures for affordability are likely to fluctuate in any given year. The Local Housing Need figure when calculated using the Standard Method can fluctuate year to year based upon the housing projections and the SM doesn’t take account of economic growth. Furthermore, if using a range is the preferred approach to the Local Housing Need, it may be more appropriate to use the current standard method figure as a base for the range, with the higher end to be set using an economically led figure which could include the additional dwellings for the Oxford to Cambridge Arc and an appropriate buffer. The Local Housing Need figure as calculated utilising the proposed new Standard Method approach has predicted c.1,153 dwellings per annum may be required across the Borough, some 300 dwellings more than the suggested 800 figure. It is not appropriate to use a figure (800) based on a calculation which has not, as yet, been confirmed. This figure would also provide some 170 dwellings less than the current Local Plan 2030, which was only adopted in January 2020. This will set an unrealistically low target and is unlikely to provide a sustainable amount of housing over the plan period, leading to further housing shortages and affordability problems. Therefore, it is unlikely the plan will be sound if using a figure lower than the current housing need figure in the current local plan. In addition, Paragraph 60 of the NPPF states that: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” It is important to note that Paragraph 60 of the NPPF and the associated guidance within the PPG are clear that the standard method represent the “…minimum number of homes needed…” Considering the uncertainty currently surrounding the additional growth due to the Oxford to Cambridge Arc, it is likely that there will be a higher need for housing than that which is currently proposed in the adopted Local Plan and may even be higher than the allowance provided for within the current Standard Method. Furthermore, the plan must respond to the Governments key objective of boosting the supply of housing, which a plan utilising a lower housing figure is unlikely to achieve. It is important that there is flexibility in the number of housing allocations, to ensure that a five-year housing land supply can be maintained over the plan period in order to meet the housing requirement. Therefore, the Council should be seeking to over allocate housing land to ensure flexibility, choice and competition in the housing market reflecting government guidance. In addition, a buffer should also be provided in order to maintain flexibility and to take into account any fluctuations that may occur on a yearly basis. A 5% buffer above the top range is unlikely to be sufficient, just as the Local Housing Need can fluctuate, so can the buffer that is required in regards of the five-year housing land supply. Usually, with a confirmed five-year housing land supply, a 10% buffer would apply, unless the rate of deliverability falls over the plan period, in which case a 20% buffer would apply. To ensure the plan is future proofed and enough flexibility, choice and competition has been provided for in the housing market, in order to reflect government guidance, we consider that a 20% buffer in addition to the top range of housing need, would provide this. Any Local Plan currently under review or in current consultation will also have to consider the effect of the coronavirus pandemic on the housebuilding industry, and subsequently the deliverability of the Council’s current five-year housing land supply. Whilst still relatively unknown, delays in the deliverability of housing are likely and therefore a subsequent undersupply may occur. The Plan must be aspirational but deliverable to be positively prepared (NPPF, paragraph 16) and in order to be found sound, the Local Plan should be targeting higher growth, rather than less than the current target within the Local Plan 2030. Currently, the Local Plan 2030 relies on Neighbourhood Plans to identify and deliver a significant proportion of housing for the Borough. However, whilst a number are in progress, only two have been ‘made’. Any delays to these emerging neighbourhood plans, could stall the delivery of housing within the Borough. Furthermore, the two which have been ‘made’ are based on the current Local Plan 2030 housing need of 970 dwellings per annum. These ‘made’ neighbourhood plans are likely to require reviewing, to ensure their compliance with any new Local Plan and potentially higher Local Housing Need. It was also highlighted in the Inspector’s final report on the Local Plan 2030, that another reason for the early review of the plan was due to the uncertainty of the preparation and adoption of the Neighbourhood Plans within the timescales envisaged on the housing trajectory. (Para 123) Finally, Neighbourhood Plans are not subject to the same, stringent examination as Local Plans and therefore the suitability of relying on Neighbourhood Plans to deliver a significant proportion of the housing need for the Borough should also be reviewed.
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’.
We support the strong local need for infrastructure development before occupation of housing, strongly support biodiversity and environmental sustainability, and would support local policies to push as hard as legally possible for sustainable housing and the support of local energy generation and green transport. In addition, we would support specific policies and requirements for the provision of the following: a) sufficient affordable housing, b) meaningfully affordable housing, c) environmentally sustainable communities and green housing, d) sufficient upfront infrastructure including, but not limited to: a. education provision, b. health services, c. sustainable transport, d. full-fibre broadband, and e. other infrastructure capacity.
It is noted that the proposed scope of the local plan review will focus primarily on growth and infrastructure (housing, employment and supporting infrastructure). We agree that the focus of the plan should be on these primary strategic issues, particularly in light of the significant growth envisaged in the Borough, and specifically in relation to the Oxford-Cambridge Arc. The Inspector at the adopted Local Plan examination noted the Arc will have significant implications for Bedford, particularly in terms of the need for housing - hence the need for an early review of the plan. The NPPF states that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for housing including affordable housing) and as a minimum, provide for objectively assessed needs for housing and other uses. The plan should ensure that priority is given to identifying sufficient residential sites to meet objectively assessed need. There should be a series of residential allocations that are deliverable and demonstrably available within the plan period - including sites that are available early in the plan period - and located in sustainable locations.
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. 2.3 The Council also have an opportunity to positivity allocate sites where Neighbourhood Plans have failed to be made, or to allocate additional land where made Neighbourhood Plans deliver below any updated requirements necessary as part of this review. Any Neighbourhood Plans not adopted by the time the review goes to publication should have allocations made in the Local Plan. This is considered a fair compromise given the standard times to deliver a Neighbourhood Plan and the likely timeline remaining in the Local Plan review. Given the likely timescales to a publication draft of the Local Plan review, the Council should indicate clearly and early that it is its intentions to do so, for the avoidance of unnecessary or wasted work by the Neighbourhood Plan groups. It would 4 be considered unsound to continue to rely on Neighbourhood Plans which have still not come forward.
In general agree. However in parts of the Borough, in particular the edge of town, there is a loss in the sense of place and a need to protect it for the future. Overtime there has been an increase in urban sprawl and a coalescence of communities. Clapham has concerns about the creep of development from the town, prominent buildings on the ridge and infill development. Whilst it is accepted that growth is inevitable, policies need to be enhanced and strengthened to protect the uniqueness of the local areas throughout the Borough and so that any development becomes an integral part of the community and not just tacked on. Our communities need to be attractive, environmentally improved, and have a significance to local people. The plan focuses on the need for sustainability and this is to be welcomed. However, Bedford suffers from significant peak hour traffic on all the arteries of the town. It is hoped that the current infrastructure works will improve conditions, but they are addressing the situation that has developed over the last 20+ years and do not address the needs in the current Local Plan, let alone for the future, nor commuting into and around the town from the outlying communities and wider area. Polices need to be developed to address this, particularly with the arrival of EWR and the pressures that will bring. The Borough Council should consider the effect of EWR on issues such as community cohesion, landscape character, countryside access and visual amenity/tranquillity and should implement policies to address the need for supporting infrastructure and mitigation of the wider effects.
On behalf of the Executors of the late Nigel Alington, CODE Development Planners support the proposed general themes set out in the eight bullet points on page 11 of the Issues and Options – Consultation Paper, Summer 2020. However, we have the following specific comments and contend that the scope under some of the eight themes should be expanded to ensure that sections of the current Local Plan 2030 are reviewed in full. We support the primary focus of the local plan review being growth and infrastructure. However, the challenges and opportunities of the Oxford-Cambridge Arc will create changes in the travel behaviour of those living and working in the borough. The spatial distribution of growth across the borough will need to change to ensure that opportunities for sustainable development (tapping into the opportunities presented by the A428 Black Cat roundabout to Caxton Gibbet improvements (expressway), the additional capacity of the existing A428 for local journeys once the expressway is open, and the location of the new station on the new East West Rail route, all to the east of the borough) are fully explored. Existing policies and supporting text covering spatial strategy, the amount and distribution of housing growth, and development in rural areas (settlement policy areas and development in small settlements) should be reviewed to assess whether there is scope to expand small settlements (in the widest use of the phrase rather than the Local Plan 2030’s limited definition) with housing and infrastructure developed at commensurate rates. This would facilitate changes in the position/status of settlements within the settlement hierarchy or their coalesce with other settlements in the form of urban expansion. We propose that a new category/definition of settlement be included in the local plan review to cover “potential areas for development and growth”. For example, Little Barford, the majority of which is in one ownership and within one parish, is defined in the current Local Plan 2030 as “countryside”. However, as representations to the Call for Sites consultation (4 September 2020) demonstrate, development options in relation to Little Barford range from the expansion of the settlement to provide 270-340 new homes (option AL1), 1,115-1,305 new homes (option AL2) and 3,385-3,955 new homes (option AL3) with all three options providing between circa 6,500sqm-20,250sqm of employment floor space. A new category of settlement defined as “potential areas for growth and change”, would enable the settlement to grow through phasing of development and infrastructure over the plan period, without the need to cap its potential by inserting it into a tier of the settlement hierarchy that does not provide flexibility over the plan period. The scope of the local plan review should include consideration of the location of development to capitalise on the strategic infrastructure to the east of the borough. It is particularly important for Bedford Borough Council (BBC) to develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements and BBC’s location at the heart of the Oxford-Cambridge Arc. In order to successfully deliver targets, the necessary supporting infrastructure will be required. We therefore contend that the scope of the review of the local plan, should be extended to include an updated Bedford Borough Local Transport Plan, Infrastructure Delivery Plan and CIL Charging Schedule. To unlock sustainable sites, to achieve strategic growth potential, strategic local infrastructure requirements and securing their delivery through inter alia developer delivery, compulsory purchase and/or BBC fulfilling a brokerage role need to be investigated through the early stages of plan review.
All existing and new policies should consider net biodiversity gain +20%, carbon reduction and sustainable development. Renewable energy should be of utmost importance and every effort should be made to protect our rural villages and open countryside as too many villages are merging with the town and so are no longer seen as separate entities. Wild life corridors (including those for insects) and open public spaces should be well supported financially. Existing policies and those saved from 2002 e.g. 75 Development in Countryside appear to be adequate.
Since the publication of this consultation document, we have seen one of the biggest proposed changes in the planning system since it was first established, we recognise and sympathise with the Policy Team in trying to plan in these uncertain times. Despite the proposed changes it is clear that Planning remains a plan led system and that the Local Plan will form a fundamental bedrock of the planning system. The work that is currently being undertaken by Bedford Borough Council (BBC) is commended and considered to be a proactive approach which is much needed in times of economic uncertainty. 1.7 The Local Plan should seek to identify the need and direct development to the most appropriate areas. Given the recent adoption of the Local Plan 2030, many of the policies are likely to be considered sound and the Revised Local Plan should focus on reviewing the adopted development strategy and making new land allocations to meet the identified housing and employment needs, as was suggested by the Inspector in finding the Local Plan 2030 sound. 1.8 The list of topics in the Issues and Options document suggest that the Local Plan will make such allocations and will have policies to ensure that this growth is sustainable and delivers high quality development, which is supported. 1.9 The inclusion of policies to control the location of food outlets is not considered necessary, particularly in light of the changes to the Use Class Order that comes into force on the 1st September 2020. It is also considered that reviewing such policies will dilute the core focus of the review which should be sustainable development. 1.10 The quantum of housing growth to be planned for does not seem to have been included within the scope of the plan. It is vital that the level of development required is identified so that it can be sufficiently planned for in a sustainable way. 1.11 As is indicated in the document (pages 6 and 16), the current Standard Methodology is proposed to be used to form the basis of the housing requirement for the borough. This requires a minimum of 1,305 dwellings per annum over the period to 2040. At this time, it should be this level of growth, as a minimum, that the Local Plan seeks to provided. In reality, depending on the proposed strategy and the risk to the delivery of allocated sites, the plan will need to plan for 10-20% additional growth above this figure to ensure the minimum need is met. Furthermore, the recent changes announced include a change to the Standard Methodology. In relation to BBC, this is unlikely to represent a significant increase from the 1,305 dwellings per annum, but the Local Plan must ensure that there is sufficient flexibility within the Plan to accommodate additional housing if required. This will create a strong housing market which ensures choice and affordability while not compromising the sustainability of the development. Bedford Borough Local Plan Issues and Options Response Land at Cotton End 1.12 The Oxford to Cambridge Arc has been identified as a key growth area from Government. It is anticipated that the Arc could deliver 1 million new homes and 1.1 million new jobs by 2050 in addition to significant infrastructure investment. It is therefore paramount that the authorities within the Arc plan positively for the predicted growth. BBC have planned for their existing growth projections however these are not considered to go far enough to enable the level of development and growth that is being proposed. 1.13 Given the Government’s objective of significantly boosting the supply of homes, originally set out in the 2017 Housing White Paper and reiterated in the current White Paper consultation, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge Arc and the current consultation on the Standard Methodology, it is clear that the current level of housing requirement of approximately 970 dwellings per annum will be unrealistic and insufficient to meet the needs of this growth area. 1.14 The scope of the Local Plan should therefore be to accommodate a minimum of 15,000 additional homes on top of existing completions in addition to any Neighbourhood Plan allocations. 1.15 The second key issue not 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. 1.16 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.” 1.17 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. 1.18 The Government’s position, alongside the fact that Policy 1 of the adopted Local Plan requires the review to address Arc related issues, suggest that the scope of the Local Plan review needs to give more emphasis to assessing the implications of the Arc related policy announcements and infrastructure investment decisions, particularly as they relate to the level of growth to be planned for and spatial decisions. Bedford Borough Local Plan Issues and Options Response Land at Cotton End 1.19 The significant changes currently being proposed by the Government in terms of the Arc, Standard Methodology and the White Paper are likely to evolve in parallel to the revised Local Plan, it is therefore paramount that sufficient flexibility is incorporated within the Local Plan review to enable it to adjust quickly to any changes required to ensure it is in accordance with national planning policy.
2.1 Since the publication of this consultation document, we have seen one of the biggest proposed changes in the planning system since it was first established, we recognise and sympathise with the Policy Team in trying to plan in these uncertain times. Despite the proposed changes it is clear that Planning remains a plan led system and that the Local Plan will form a fundamental bedrock of the planning system. The work that is currently being undertaken by Bedford Borough Council (BBC) is commended and considered to be a proactive approach which is much needed in time of economic uncertainty. 2.2 The Local Plan should seek to identify the need and direct development to the most appropriate areas. Given the recent adoption of the Local Plan 2030, many of the policies are likely to be considered sound and the Revised Local Plan should focus on reviewing the adopted development strategy and making new land allocations to meet the identified housing and employment needs, as was suggested by the Inspector in finding the Local Plan 2030 sound. 2.3 The list of topics in the Issues and Options document suggest that the Local Plan will make such allocations and will have policies to ensure that this growth is sustainable and delivers high quality development, which is supported. 2.4 The inclusion of policies to control the location of food outlets is not considered necessary, particularly in light of the changes to the Use Class Order that comes into force on the 1st September 2020. It is also considered that reviewing such policies will dilute the core focus of the review which should be sustainable development. 2.5 The quantum of housing growth to be planned for does not seem to have been included within the scope of the plan. It is vital that the level of development required is identified so that it can be sufficiently planned for in a sustainable way. 2.6 As is indicated in the document (pages 6 and 16), the current Standard Methodology is proposed to be used to form the basis of the housing requirement for the borough. This requires a minimum of 1,305 dwellings per annum over the period to 2040. At this time, it should be this level of growth, as a minimum, that the Local Plan seeks to provided. In reality, depending on the proposed strategy and the risk to the delivery of allocated sites, the Plan will need to allocate 10-20% additional growth above this figure to ensure the minimum need is met. Furthermore, the recent changes announced include a change to the Standard Methodology need to be considered. In relation to BBC, this is unlikely to represent a significant increase from the 1,305 dwellings per annum, but the Local Plan must ensure that there is sufficient flexibility within the Plan to accommodate additional housing if required. This will create a strong housing market which ensures choice and affordability while not compromising the sustainability of the development. Bedford Borough Local Plan Issues and Options Response Land at Roxton 6 2.7 The Oxford to Cambridge Arc has been identified as a key growth area from Government. It is anticipated that the Arc could deliver 1 million new homes and 1.1 million new jobs by 2050 in addition to significant infrastructure investment. It is therefore paramount that the authorities within the Arc plan positively for the predicted growth. BBC have planned for their existing growth projections however these are not considered to go far enough to enable the level of development and growth that is being proposed. 2.8 Given the Government’s objective of significantly boosting the supply of homes, originally set out in the 2017 Housing White Paper and reiterated in the current White Paper consultation, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge Arc and the current consultation on the Standard Methodology, it is clear that the current level of housing requirement of approximately 970 dwellings per annum will be unrealistic and insufficient to meet the needs of this growth area. 2.9 The scope of the Local Plan should therefore be to accommodate a minimum of 15,000 additional homes on top of existing completions in addition to any Neighbourhood Plan allocations. 2.10 These homes should not be delivered in isolation, it is vital that sufficient infrastructure, employment opportunities, services and facilities come forward in line with the projected level of growth. This will ensure that Bedford Borough remains a place where people want to live and work. 2.11 Therefore, the second key issue not addressed in the question 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. 2.12 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.” 2.13 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. Bedford Borough Local Plan Issues and Options Response Land at Roxton 7 2.14 The Government’s position, alongside the fact that Policy 1 of the adopted Local Plan requires the review to address Arc related issues, suggest that the scope of the Local Plan review needs to give more emphasis to assessing the implications of the Arc related policy announcements and infrastructure investment decisions, particularly as they relate to the level of growth to be planned for and spatial decisions. 2.15 The significant changes currently being proposed by the Government in terms of the Arc, Standard Methodology and the White Paper are likely to evolve in parallel to the revised Local Plan, it is therefore paramount that sufficient flexibility is incorporated within the Local Plan review to enable it to adjust quickly to any changes required to ensure it is in accordance with national planning policy.
No answer given
I believe Bedford is being over-developed already and that developers who have bought land already should be forced to develop that first
2.0 QUESTION 1 – SCOPE OF THE LOCAL PLAN REVIEW 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 Plans 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. 2.8 These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 2.9 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 supports 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 8 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 2.10 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local 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. 2.11 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 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. 2.12 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. a) National Policy and Guidance – Implications for the Review of the Local Plan 2030 i) Plan-Making 2.13 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. 2.14 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. 2.15 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. 2.16 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. 2.17 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) 2.18 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. 2.19 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. 2.20 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 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 10 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.21 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 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. ii) Rural Housing and Implications for the Existing Spatial Strategy 2.22 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. 2.23 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 figures for individual settlements provided in Policy 4S of the adopted Local Plan are minima and will be reviewed in the period to 2030 and beyond as part of the Review of the Local Plan 2030; BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 11 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission • 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. 2.24 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. 2.25 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 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) 2.26 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). 2.27 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. 2.28 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. iii) Conclusions to Inform the Scope of the Review of the Local Plan 2.29 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 12 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.30 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 13 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission b) Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 2.31 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. 2.32 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 7955 SA September 2018 13 0 100 0 high growth 2895 high growth 4000 low growth 260 7255 2.33 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. 2.34 This is also a logical way 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. 2.35 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). 2.36 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: • This would again conclude that distributing a higher proportion of development in the BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 14 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.37 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 Felmersham. 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 15 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 2.38 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). 2.39 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). 2.40 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. 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 1,305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1,153 28 -2,277 -9,883 -5,765 -12,132 -17,897 2.41 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 development 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. 2.42 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 that undermine the Council’s current claimed BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 16 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.43 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: 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 2.44 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 17 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission d) Impact of Government Consultation on Proposed Planning Reforms 2.45 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. 2.46 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. 2.47 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 Plans 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. 2.8 These representations do, however, identify that the horizons for the Local Plan Review support a reassessment of options, subject to realistic assumptions regarding timescales. Paragraph 5.21 of these representations encourages this in the context of New Settlement options aligned with East-West Rail where net benefits of the scheme would complement contributions towards requirements from the existing settlement hierarchy earlier in the plan period. 2.9 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres that the Local Plan 2030 supports 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 8 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 2.10 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local 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. 2.11 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 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. 2.12 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 9 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission a) National Policy and Guidance – Implications for the Review of the Local Plan 2030 i) Plan-Making 2.13 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. 2.14 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. 2.15 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. 2.16 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. 2.17 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) 2.18 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. 2.19 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. 2.20 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 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 10 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.21 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 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. ii) Rural Housing and Implications for the Existing Spatial Strategy 2.22 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. 2.23 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 figures for individual settlements provided in Policy 4S of the adopted Local Plan are minima and will be reviewed in the period to 2030 and beyond as part of the Review of the Local Plan 2030; BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 11 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission • 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. 2.24 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. 2.25 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 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) 2.26 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). 2.27 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. 2.28 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. iii) Conclusions to Inform the Scope of the Review of the Local Plan 2.29 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 BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 12 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.30 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 13 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission b) Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 2.31 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. 2.32 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 7955 SA September 2018 13 0 100 0 high growth 2895 high growth 4000 low growth 260 7255 2.33 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. 2.34 This is also a logical way 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. 2.35 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). 2.36 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: • This would again conclude that distributing a higher proportion of development in the BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 14 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.37 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 Felmersham. 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 15 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission c) Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 2.38 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). 2.39 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). 2.40 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. 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 1,305 -428 -3,341 -11,403 -6,525 -15,172 -21,697 Local Housing Need - Proposed Revised Standard Method 1,153 28 -2,277 -9,883 -5,765 -12,132 -17,897 2.41 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 development 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. 2.42 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 that undermine the Council’s current claimed BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 16 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 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. 2.43 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: 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 2.44 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. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 17 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission d) Impact of Government Consultation on Proposed Planning Reforms 2.45 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. 2.46 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. 2.47 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 Plans 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 necessitate 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. 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 supports is below levels previously tested and found to be just as sustainable as other options. Great Barford is a particular example where the capacity for growth is substantially greater than the apportionment of requirements identified by Policy 4S 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 8 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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. Great Barford is uniquely placed in this context given its credentials as a Key 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 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 interests at Willoughby Park, Great Barford, comprise land within a single ownership, supporting proposals for a comprehensive development of 500-units as illustrated at Appendix 1. 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 9 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 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 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 BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 10 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 Great Barford 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 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 BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 11 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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. Great Barford as a Key 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 12 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 Great Barford, 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 Great Barford. 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 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). 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 13 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 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 that 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: BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 14 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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 additional 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 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. 2.39 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. 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. BE1719/4P (Old Road Securities PLC) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 15 08.31.JG .JG LP 2030 Review Consultation Response Document obo ORS vf Submission 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.
Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 4 2.8 To deliver this number of homes, the Local Plan should also include additional land to provide a 10-20% buffer above the identified housing need figure in order to ensure that there is flexibility in the plan to meet requirements should sites fail to come forward. 2.9 Therefore, the suggestion in the Issues and Options Consultation Document that 800 dwellings would be the lowest number in the housing range needs to be reviewed immediately and the appropriate development strategy considered in view of this higher figure. 2.10 The tone of central government is to plan positively to achieve a significant boost in housing delivery. This has been set out in both the 2017 and the 2020 Housing White Papers, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge arc and the fact that Government confirmed that the 2016-based household projections did not provide an appropriate basis for the standard method. 2.11 The scope of the Local Plan should therefore be to accommodate a minimum of 15,000 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance). If the standard methodology changes and the minimum need figure reduces slightly as a result, having planned for a higher target to start with allows flexibility to remove sites from the draft plan if necessary. This approach would not be possible should the Council take the approach of planning for an inappropriately low housing target from the outset. Oxford to Cambridge Arc 2.12 Another key issue which should be addressed in the scope of the Local Plan Review is Government ambition for the Oxford to Cambridge Arc. 2.13 Central Government have outlined the ambition for the Oxford to Cambridge arc to deliver 1 million new homes and 1.1 million new jobs by 2050. It is a key growth area, with significant infrastructure investment planned with committed funding. In order to accelerate new housing and infrastructure development, the Government is in the process of creating four new Development Corporations in the Oxford to Cambridge Arc at Bedford, St Neots/Sandy, Cambourne and Cambridge. 2.14 The March 2020 Budget identified the Oxford, Milton Keynes, Bedford and Cambridge Arc as a ‘key economic priority’ and noted that a preferred route for East West Rail between Bedford and Cambridge had been announced. The Budget also set out the plan to work with local partners to develop a long-term Spatial Framework with the intention being to assist in strategic planning across the Arc. 2.15 The Government is therefore committed to the delivery of the Oxford to Cambridge Arc, with the expectation being that there will be significant residential development to support the economic potential of the area. 2.16 Local authorities within the Arc, such as Bedford Borough, should plan positively/proactively for predicted growth in line with these key aspirations and commitments. Whilst Bedford Borough have planned for their existing growth projections, these are not considered to go far enough to enable the level of development and growth that is being proposed as part of the Arc initiative. Bedford Borough Local Plan Issues and Options response The Police and Crime Commissioner for Bedfordshire Page 5 2.17 Policy 1 of the adopted Local Plan 2030 requires the Local Plan Review to address Arc related issues. The implications of the Arc, including policy announcements and infrastructure investment decisions, should be assessed against Local Plan proposals. This is particularly important where they relate to the level of growth to be planned for and spatial decisions. 2.18 The position within the Arc is also likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council are able to respond to any announcements avoiding delays in the preparation of the Plan.
2.1 The scope of the Local Plan Review should include specific reference to the Ox-Cam Arc (‘the Arc’) as a key national issue that will have significant impacts and relevance to Bedford Borough. 2.2 There should, therefore, be a specific aim included within the scope of the Local Plan Review that addresses issues and proposals relating to the Arc. 2.3 It is acknowledged that the Government’s White Paper on proposed reforms to the Planning System was published partway through this consultation. Clearly, the scope of the Local Plan Review may have to be adjusted to consider any changes to National Policy which result from changes following the consultation, albeit the timetable for any such changes is currently unclear.
The main purpose of the Local Plan Review should be to confirm the revised development needs of the area and decide where employment and residential growth should be focused. 2.2 The development management policies in the adopted Local Plan have only recently been adopted and whilst these should be reviewed to ensure they are consistent with the National Planning Policy Framework (NPPF) 2019, they are likely to generally remain fit for purpose to guide decision making. 2.3 The Local Plan 2030 Inspector suggested that a review of the adopted development strategy and the identification of new allocations to meet housing and employment needs should be the focus of the Local Plan Review. 2.4 The list of topics in the Issues and Options document suggest that the Local Plan will mainly focus on growth and infrastructure, which is supported. 2.5 However, the list also suggests a number of far more detailed policy areas, such as the control food outlets, which are at odds with the suggestion that the main focus will be on growth and infrastructure. Whilst my client does not have a view of the need for such policy areas to be addressed, these would be better picked up in a general review of development management policies to avoid the focus being taken away from the high-level spatial issues that are integral to the soundness of the Local Plan. Such an approach would also appear to be consistent with the recent Housing and Planning White Paper which suggested policies on detailed topic matters would be set out at a national level rather than in local plans. 2.6 The questions outlined in the Issues and Option document does not address two key issues related to the scope of the Local Plan review and the spatial strategy - the level of housing growth and the implications of Bedford Borough’s location as part of the Oxford to Cambridge Arc. Level of Housing Growth 2.7 Firstly, the overall quantum of housing growth to be planned for should be a key part of the scope of the Local Plan Review. 2.8 The Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per annum over the period to 2040, which is noted on page 16 of the Issues and Options Document. 2.9 However, the Issues and Option Consultation Document goes on to note that the Standard Methodology for calculating housing need could end up using the 2018 Household Projections (replacing the use of the 2014 projections) and that as a result the Local Plan review could need to plan for a housing figure as low as 800 dwellings per year. 2.10 Following the publication of this Issues and Options consultation document, the Housing and Planning White Paper was released on 3rd August 2020 which has provided this expected update Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 4 to the standard method used for calculating housing need. Subject to the outcome of the consultation, the housing requirement for Bedford Borough is now expected to come in at 1,153 dwellings per annum. 2.11 Therefore, the suggestion by Bedford Borough Council in the Issues and Options Consultation Document that 800 dwellings would be the lowest number in the housing range needs to be reviewed immediately and the appropriate development strategy considered in view of this higher figure. 2.12 The plan will also realistically need to plan for 10-20% additional growth above this figure to ensure the minimum need is met (subject to the nature of the proposed strategy and the risk to the delivery of allocated sites). 2.13 Given the Government’s objective of significantly boost the supply of homes, originally set out in the 2017 Housing White Paper and re-iterated in the 2020 Housing and Planning White Paper, the current ‘build, build, build’ message, the aspirations for the Oxford to Cambridge Arc and the fact that Government confirmed that the 2016-based household projections did not provide an appropriate basis for the standard method, it is unrealistic to suggest that the Local Plan Review should consider such a low housing figure. 2.14 The scope of the Local Plan should therefore be based on providing land to accommodate a minimum of 15,000 additional homes on top of existing completions (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance) in line with the current standard methodology. This would allow the figure to be revised down should the new standard method introduce a small decrease in this figure. As was seen with the preparation of the Local Plan 2030 when the plan period had to be cut, such a change is not possible if insufficient suitable land is identified from the outset. Oxford to Cambridge Arc 2.15 The second key issue which should form part of the scope of the Local Plan review, which is not currently fully addressed in the questions, is Government ambition for the Oxford to Cambridge Arc. 2.16 Policy 1 of the adopted Local Plan 2030 requires the Local Plan review to address Arc related issues. This policy suggests that the scope of the Local Plan review needs to give more attention to assessing the implications of the Arc related policy announcements and infrastructure investment decisions, particularly as they relate to the level of growth to be planned for and spatial decisions. 2.17 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. 2.18 Notably, in 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 Bedford Borough Local Plan Issues and Options response Taylor Wimpey UK Limited Page 5 announced the East West Rail Company’s preferred route for the new line between Bedford and Cambridge…… 2.19 The Budget announcement included a plan to work with local partners to develop a long-term Spatial Framework to support strategic planning in the OxCam Arc; ensuring both the future economic success of the area and the delivery of the new homes required as a result of this growth up to 2050 and beyond. The government is also in the process of creating four new Development Corporations in the Oxford to Cambridge Arc, at Bedford, St Neots/Sandy, Cambourne and Cambridge, in order to accelerate new housing and infrastructure development. 2.20 It is therefore clear that the Government remains committed to the Oxford to Cambridge Arc, with the expectation being that there will be significant residential development to support the economic potential of the area. 2.21 The position with the Arc is also likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council respond positively and proactively to any announcements to avoid delay in the preparation of the Plan. 2.22 The Oxford to Cambridge Arc should play a key part of the scope of the Local Plan Review.
All existing and new policies should consider net biodiversity gain +20%, carbon reduction and sustainable development. Renewable energy should be of utmost importance and every effort should be made to protect our rural villages and open countryside as too many villages are merging with the town and so are no longer seen as separate entities. Wild life corridors (including those for insects) and open public spaces should be well supported financially. Existing policies and those saved from 2002 e.g. 75 Development in Countryside appear to be adequate.
The scope of the local plan review is broadly supported. There is particular support for the need to consider the role of Bedford Town Centre in particular as to how the town centre functions as a residential, transport, employment, retail, leisure and cultural destination and how it can contribute to the delivery of housing numbers through good quality and well designed development and regeneration. Raising design quality in new developments is supported, the Council should give consideration to the role that design codes could play in raising the quality of development. Any approach taken on design codes should not stifle but encourage innovation in housing design. A move towards a policy position that facilitates the creation of new homes that meet the National Space Standards would be supported. In relation to the proposal to introduce a policy on self and custom build opportunities, there is also a need to consider the role of Modern Methods of Construction and how the planning system can facilitate its growth. MMC could play an important role in accelerating housing delivery across Bedford Borough. The need to control food outlets at locations such as near schools is supported. This should be run alongside a clear strategy to support the provision of community gardens and community orchards and opportunities for exercise to encourage healthy eating and healthy lifestyles. There should be a consideration within the review as to how climate change is to be addressed. Part of this issue relate to housing design standards. The decisions taken should consider the financial considerations of standards, e.g there are relatively small increases in cost to move from current Buildings Regulations to AECB Silver Standard but to move to full Passiv Haus the change is significant and the impacts on viability and therefore delivery would need to be considered. A clear steer should be given in the review on the requirements emerging from the Environment Bill, this is particularly important in relation to the approach to be taken to Biodiversity Net Gain.
Bedfordia Property Response: 1.1 We agree that the Local Plan Review should propose to develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements. This will require sufficient amount and variety of land to come forward where it is needed to meet housing, economic and community needs. As part of that process, there should be a review of both the development management policies and land designations set out in the Local Plan 2030 and those saved from the ‘Allocations and Designations Local Plan 2013’ to ensure land is not unreasonably restricted in sustainable locations that would otherwise make a positive contribution to the Borough’s growth needs. 1.2 Housing needs, in particular, are set to rise with the Standard Method setting a minimum requirement of 5,550 additional homes over the next 15 year plan period. This warrants a review of current land designations as well as identification of new development sites. It should also be borne in mind that the needs of the local community are not static in time and should be consulted on and reviewed in terms of the local planning authority’s requirement to set out non-strategic policies for specific areas, neighbourhoods or types of development, as guided by paragraph 28 of the NPPF 2019. 1.3 Saved Policy AD43 (Urban Open Spaces and Gaps) of the Allocations and Designations Local Plan is now seven years old and aims to protect urban open spaces in Bedford that maintain the function, character and identity of the urban area. Development will not be permitted on these land designations unless it can be demonstrated that the reasons for designation are not compromised or that other material considerations outweigh the need to retain the urban open space and undeveloped gaps. 1.4 The urban open space identified north of Cemetery Road and west of Kempston Hammers Sports and Social Club was surveyed in 2010, as part of the ‘Review of Urban Open Space’ background paper and was not previously designated. Its reason for designation is due to its contribution as a visual break, which allows views across the open space to the north of the site. The site, however, is privately-owned and not formally designated as a public open space. Its contribution as a ‘visual break’ is incidental and not based on a robust and up-to-date assessment of the need for open space. The site is also not devoid of all development: adjacent to Cemetery Road is a foul water pumping station and the residential dwelling known as Walnut Tree Cottage. Both of these developments partly obscure views to the north along with existing boundary hedging. 1.5 We would therefore question the consistency of this urban open space designation with the NPPF’s paragraph 96, which states that planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses). This is pertinent given the site’s lack of formal public use over time and the close proximity of open space and sports to the east. Instead, we think the site should be allocated for development of much needed housing and community facilities. Such development would be in a very sustainable location, close to the existing community and of a scale that would make a meaningful contribution to the local area. 1.6 Such a proposal has been put forward by Bedfordia Property in the recent Call for Sites consultation and includes development of a community centre with accompanying residential development to help cross fund the centre. Land opportunity within Kempston for community uses is limited and demand for such facilities is expected to grow with an increasing population. Existing facilities such as the Addison Centre are outdated and constrained in their location, unable to expand sufficiently to meet larger community group needs. 1.7 Provision of new indoor community facilities to meet local needs is a topic that requires more focus in the Local Plan review and should not simply rely on development management policies (e.g. Policy 98) but a more proactive strategy for allocating new sites and sufficient land for indoor community provision, especially where existing community facilities are constrained and unable to meet the growing population’s needs. This would follow the NPPF (paragraph 92) objective for planning policies and decisions to plan positively for the provision and use of shared spaces, community facilities and other local services to enhance the sustainability of communities and residential environments taking into account local strategies to improve health, social and cultural well-being for all sections of the community. 1.8 Indoor and outdoor community space provision go hand-in-hand, with multiple social, health and wellbeing benefits. The submitted site at Cemetery Road, Kempston provides a suitable location for this complementary provision, along with supporting residential development, which should not be held back by artificial constraints, such as the historic Urban Open Space policy. This is not to say that the aims and objectives of such designations should be ignored, especially where there is scope to accommodate some open space within the site, which can be enhanced, along with the retention of key views, enhancement of biodiversity and protection of designated heritage assets. We believe the submitted site at Kempston has scope to achieve these objectives and should be reconsidered in terms of its purpose and designation in order to provide wider public benefits.
You have made no mention of how Route E will affect development in Bedford. Specifically what you will do to mitigate the adverse affects of this route to the villages it will go through.
2.1 The main purpose of the Local Plan Review should be to confirm the revised development needs of the area and set out where housing and employment growth should occur. The development management policies in the Local Plan 2030 have only recently been adopted and whilst these should be reviewed to ensure they are consistent with the National Planning Policy Framework (NPPF) 2019, they are likely to generally remain fit for purpose to guide decision making. 2.2 Reviewing the adopted development strategy and making new land allocations to meet the identified housing and employment needs should be the focus of the Local Plan Review, as suggested by the Inspector in finding the Local Plan 2030 sound. 2.3 The list of topics in the Issues and Options document suggests that the Local Plan Review will make such allocations and will have policies to ensure that growth is sustainable and will deliver high quality development. However, the list also suggests a number of far more detailed policy areas, such as the control of fast-food outlets, which is at odds with the suggestion that the main focus will be on growth and infrastructure. 2.4 While Axiom do not have a view of the need for such policy areas to be addressed, these would be better covered in a general review of development management policies to avoid the focus being taken away from the high level spatial issues that are integral to the soundness of the Local Plan Review. This is in line with emerging Government policy set out in the recent Planning/Housing White Paper. 2.5 There are a number of key issues related to the scope of the Local Plan Review and the spatial strategy which are not addressed in the questions on the Issues and Options document. The first of these is the overall quantum of planned housing growth. 2.6 As indicated in the Issues and Options consultation document (page 16), the Standard Methodology currently sets out a minimum housing need of 1,305 dwellings per annum over the period to 2040. The Local Plan Review should seek to provide this level of growth as a minimum but depending on the proposed strategy and the risk to the delivery of allocated sites, the plan should also provide 10-20% additional growth above the current figure to ensure the minimum need is met. 2.7 Whilst the Standard Methodology is under review, it should not be assumed that this will mean the recently published 2018 Household Projections will simply replace the use of the 2014 projections. This is implied in the consultation document, suggesting the Local Plan Review could need to plan for a housing figure as low as 800 dwellings per year. 2.8 Given the Government’s objective of significantly increasing the supply of new homes, alongside the aspirations for the Oxford to Cambridge Arc and the recent announcements in the White Paper about a revised methodology, it is unrealistic to suggest that the Local Plan review should be considering such a low housing figure. 2.9 The scope of the Local Plan Review should therefore be to accommodate a minimum of 15,000 additional homes on top of existing commitments (plus any un-progressed Neighbourhood Plan allocations and a flexibility allowance). If a revised Standard Methodology is introduced and reduces this figure slightly, then the scale of planned growth can be adjusted in due course – this would not be possible if a lower figure were to be planned for. 2.10 The second key issue not fully addressed in the questions is the extent to which the ambitions for the Oxford to Cambridge Arc are considered 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. 2.11 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.” 2.12 It is therefore clear that the Government is firmly committed to the Arc with the expectation being that there will be significant residential development to support the economic potential of the area. 2.13 The Government’s position, alongside the fact that policy 1 of the adopted Local Plan 2030 requires the review to address Arc related issues, suggest 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, particularly as they relate to spatial decisions and the level of planned growth.. 2.14 The Arc strategy is likely to evolve throughout the preparation of the Local Plan Review and it will be important that the Council are in a position to respond positively to any announcements to avoid delay in preparing the Plan, reinforcing the need for greater consideration of Arc related matters in the scope of the review.
Yes, the proposed scope of the Local Plan review is supported. In addition, the calculated housing need for 1,305 dwellings per annum based on the calculation of standard method within the Planning Practice Guidance is also supported. It is important, in line with National Planning Policy Framework, that 1,305 dwellings per annum is treated as a minimum target and that a suitable range of deliverable sites are allocated in order to ensure that this figure is met. In addition, accounting for the location of Bedford Borough being situated centrally within the growth arc, consideration should be given to a higher housing figure than 1,305 per annum. Bedford Borough benefits from excellent and improving road and rail links. It is also one of the areas within the growth arc that benefits from being situated on land outside of the Green Belt.