Question 1
You will recall that during the previous Local Plan review we raised concerns about the number of different plans and policies in place and the slightly confusing nature of these multiple documents. At the time we commented that it was unfortunate that the opportunity has not been taken to incorporate the Allocations and Designations Local Plan into the new Local Plan. This may lead to confusion and lack of transparency. It would be easier if all allocations and policies were included in one Plan. In our view it would be preferable if all allocations and policies were incorporated into one Plan. This is more user friendly both for planners and the public. As you will be aware the Planning White Paper indicates a fundamental shift in the approach to Local Plans, both in terms of plan preparation and plan content. It will be important that as these proposals are clarified the new Local Plan adheres to any new legislation and guidance.
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 the consultation, albeit the timetable for any such changes is currently unclear.
2.1 We broadly support the scope of the Local Plan review. It is of vital importance that this review utilises updated guidance relating to establishing a robust housing requirement based on Local Housing Need attained from the Standard Methodology. In August 2020, the Government published its updated methodology for undertaking the standard methodology. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement. 2.2 Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council sets out that the Government have not specifically set out that Bedford needs to increase its housing requirement (as is the case for all authorities), the publication of the revised Standard Methodology shows that without upward adjustment, the joint ambition to deliver a million new dwellings to 2050 within the Arc, will not be met. If all of the Arc authorities use the base Local Housing Need, as established from the Standard Methodology, this target will not be met, with a shortfall of over 156,000 dwellings. This can be easily remedied by increasing the level of growth above the Local Housing Need in each Authority to meet the shortfall, through negotiation, or by simply increasing the housing requirement proportionately to the level of housing need. For example, Bedford’s Local Housing Need is 4% of the entire Arc, so 4% of 156,000 dwellings would lead to an upward adjustment of 6,240 dwellings, only 208 dwellings per annum up to 2050. This would align with the Government’s ambition to significantly boost the supply of housing. 2.3 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.
2.1 Bedford Borough Council is seeking to satisfy the requirement to instigate the early review of the Bedford Local Plan 2030, as necessitated by Policy 1 of the existing development plan. The 2020 Issues and Options consultation is of very significant importance to ensuring that the Local Plan Review satisfies the requirements of national policy and guidance. 2.2 Policy 1 of the extant Local Plan was framed to ensure that future levels of growth respond to the government’s national policy objectives consistent with Bedford’s role in delivering strategic priorities for the sub-region. The Inspectors’ Report on the examination of the Local Plan makes clear that it (the Local Plan) provides for an annual housing requirement around 30% lower than the current version of the standard method to calculate Local Housing Need (see paragraph 40). 2.3 Transitional arrangements for the Examination of Plan’s prepared under the requirements of the NPPF 2012, are also cited in the Inspectors’ reasons for accepting a foreshortened plan period to 2030 upon adoption. 2.4 Paragraph 17 of the Inspectors’ Report nonetheless identifies a need to address longer-term strategic priorities, including the Oxford-Cambridge Arc at the earliest opportunity. This will of necessity require a greater degree of engagement on cross-boundary strategic matters, including preparation of Statements of Common Ground and associated outcomes under the Duty to Cooperate. The Inspectors’ Report acknowledges that the less stringent requirements of the NPPF 2012 were applicable to the Local Plan in terms of outcomes of engagement (see paragraph 11). 2.5 The Review of the Local Plan also demands an early evaluation of the effectiveness of the current development plan. This specifically relates to the requirement in Policy 1 that the review will secure levels of growth that accord with government policy. A key implication of this relates to the deferral of site allocations to neighbourhood plans. This fundamentally relates to issues of housing land supply and flexibility, including the monitoring of whether the Council is likely to meet even the housing requirement of the Local Plan in full. 2.6 The challenge for the Council in undertaking the Review of the Local Plan 2030 are that issues with its current approach manifest themselves in three main interrelated ways. 2.7 Firstly, the spatial strategy reflects that the current Plan is unable to meet its priorities through strategic options including large-scale sites (including New Settlements) or strategic spatial directions of growth. This makes importing such options into the strategy difficult in the context of meeting the immediate increased requirements from 2020, particularly with options such as New Settlements having been previously rejected. Some of the strategic options identified by the Council therefore only offer a reasonable prospect to meet a proportion of the Council’s requirement in the longer-term. It is, however, accepted that there are some planned improvements such as those centred around the A421 corridor that may enable some greater proportion of needs to be met in the early part of the plan period through a combination of option. 2.8 Secondly, the increased distribution of growth to Rural Key Service Centres and Rural Service Centres in the Local Plan 2030 is below levels previously tested and found to be just as sustainable as other options. This, together with deferral of allocations to Neighbourhood Plans, constrains the Council’s ability to effectively meet its priorities for development through this sustainable ‘dispersed’ strategy. 2.9 Thirdly, and related to this, the current distribution of growth outlined in Policy 4S of the Local 8 Plan 2030 is not based on a clear understanding of requirements and capacity for growth in individual settlements and instead adopts an arbitrary approach to apportioning requirements. Therefore, while it is evident that the rural area is a suitable location to meet a substantial proportion of the Plan’s increased requirements for development this can only be achieved as part of a detailed review of the settlement hierarchy and provision for development in individual centres. This must be supported by clear policies and allocations within the Plan itself. 2.10 The Council’s consultation documents acknowledge the impact of increases to the annual requirement from the proposed 2020 base-date of the revised plan period. What is apparent from options being assessed by the Council is the scope for ‘top-up’ allocations where contributions towards the increased requirement from 2020 onwards can be achieved in settlements across the rural area, compared to the current Policy 4S totals. This must be explicitly stated and addressed by the scope of the Local Plan Review, This is because this solution to meeting the Plan’s increased requirement for growth would alter the requirements for general conformity with adopted strategic policies, comprising part of the basic conditions tests that Neighbourhood Plans in the borough need to meet. 2.11 Where the capacity for sustainable development exists, we urge the Council not to impose limits to growth as part of its testing of strategy options or the totals identified for the rural area. Moreover, given the immediate impact of increases to the housing requirement, suitable opportunities for ‘top up’ allocations should be provided for as allocations rather than being further deferred to the preparation or review of Neighbourhood Plans. 9 3.0 NATIONAL POLICY AND GUIDANCE – IMPLICATIONS FOR THE REVIEW OF THE LOCAL PLAN 2030 Plan-Making 3.1 It is helpful to provide a brief overview of policies in the NPPF 2019, governing plan-making and central to assessing the soundness of proposals to be prepared as part of the Review of the Local Plan. 3.2 Paragraph 11(a and b) of the NPPF sets out the presumption in favour of sustainable development for plan-making. This establishes that plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change. Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses. It is essential that the options considered as part of the review of the Local Plan seek to fully address these requirements. 3.3 Paragraph 16(c) of the NPPF emphasises that plans must be positively prepared to ensure that they are aspirational but deliverable. Paragraph 20 makes clear that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for development needs (including housing), alongside requirements for infrastructure (including community facilities) and conservation and enhancement of the natural, built and historic environment. This combination of policy requirements is likely to demand an integrated range of approaches, depending on the area’s priorities. 3.4 Paragraph 22 of the NPPF stipulates the requirement for strategic policies to look over a minimum 15-year period upon adoption, in order to incorporate longer-term requirements and opportunities, including major infrastructure investment. Paragraph 23 sets out the importance of plan-making, providing for a clear strategy that ensures bringing forward sufficient land at a sufficient rate to meet needs over the plan period. 3.5 Paragraphs 24 to 27 of the Framework deal with requirements to maintain effective cooperation under the Duty to Cooperate. Ongoing joint working is key to determining how cross-boundary strategic priorities are addressed and setting out where additional infrastructure investment may be necessary. Planning Practice Guidance further sets out the importance of the preparation of Statements of Common Ground to address progress made via engagement. This is central to demonstrating how options have been assessed and that the strategy is deliverable over the plan period (PPG ID: 61-010-20190315) 3.6 Paragraphs 31 to 33 of the NPPF 2019 deal with the preparation and review of Plans and specifically the requirement to assess alternative options. Paragraph 33 sets out that the review of Plans “should take into account changing circumstances affecting the area, or any relevant changes in national policy.“ This is clearly reinforced by the requirements of Policy 1 of the Local Plan 2030. In accordance with Paragraph 32 of the Framework preparation of the Plan should seek to achieve net gains for the economic, social, and environmental objectives of sustainable development. 3.7 In relation to identifying land for housing in the context of options identified in the Borough’s consultation proposals paragraph 72 of the NPPF 2019 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. 10 3.8 We consider that this background to the requirement for the Review of the Local Plan 2030 is not sufficiently acknowledged in the Issues and Options Consultation document. Specifically: 3.9 The document includes no reference to the Duty to Cooperate, despite Policy 1 and the Local Plan Inspectors’ Report emphasising the importance of cross-boundary priorities 3.10 Notwithstanding specific reference to the Duty to Cooperate, the documents also fail to explicitly acknowledge that certain options will require greater impetus than others regarding potential matters including joint-working and infrastructure funding. This should be considered explicitly in terms of the potential timeframes for options to secure sustainable development over the plan period 3.11 The consultation document does not consider issues of flexibility and choice in terms of the scope for the Local Plan Review, which is imperative given the significant increase in the housing requirement to be provided for. It is noted that only the ‘Dispersed Growth’ option is listed as providing for “early delivery of new homes”. 3.12 The requirements of NPPF 2019 Paragraph 72 should be explicitly acknowledged to frame the Council’s assessment of strategic growth options. Rural Housing and Implications for the Existing Spatial Strategy 3.13 In relation to the spatial strategy of the adopted Local Plan, pp.15 of the Council’s consultation document acknowledges that “growth is directed to the larger villages (except where there are already large-scale commitments or nearby), with more in the key service centres and less in the rural service centres.” This recognition is welcome, but the document goes on to state that this approach to the distribution of growth will not meet development requirements in the longer-term. 3.14 Notwithstanding that the Council is seeking to explore alternative spatial options as part of the Review of the Local Plan, we consider that the consultation document should be explicit that the review will seek to maximise opportunities for growth as part of an overall approach to the distribution of development that has been found to be sustainable. This should acknowledge that: • The settlement hierarchy classification of Rural Key Service Centres and Rural Service Centres will be reviewed as part of the Review of the Local Plan 2030; and • The Council will specifically assess more dispersed options to distribute growth to settlements not currently classified as Rural Service Centres/Key Service Centres – for example other villages with a policy area boundary as encouraged by previous rounds of consultation and the capacity of other settlement is also reviewed. 3.15 These representations provide specific grounds to reflect more clearly each of the components within the scope of the review. Our suggestions accord with national policy for making provision for housing in rural areas. Paragraph 78 of the NPPF 2019 states that sustainable development can be achieved through locating housing where this would maintain or enhance the vitality of rural communities. This includes recognition of providing support for local services and supporting the needs of other nearby centres. 3.16 Planning Practice Guidance notes that plan-making authorities should consider the broader 11 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) 3.17 The importance of these elements of national policy are reinforced by Paragraph 65 of the NPPF 2019 and the requirement for strategic policy-making authorities to set out requirements for designated neighbourhood areas. This should be derived from the overall requirement and reflect the overall strategy for the pattern and scale of development (including any allocations). 3.18 It is not a sound basis for plan-making to suggest that the housing requirement figures and settlements identified for growth in Policy 4S of the Local Plan 2030 will not be reviewed as part of this process. 3.19 The NPPF does not stipulate that requirement figures for designated Neighbourhood Areas should be limited to any existing categories within the settlement hierarchy or adhere to the distribution of growth in the existing development plan. This is inherently logical in terms of considering options for development where, as in the case of the Review of the Local Plan 2030, needs are being considered over a minimum 15-year period. This is particularly relevant to potential requirements for growth in settlements with no figure identified in the current Policy 4S; and for other villages with a Settlement Policy Area Boundary not covered by the existing distribution of growth. Conclusions to Inform the Scope of the Review of the Local Plan 3.20 Taking account of the summary above we consider that the following elements and priorities for plan-making must be clearly set out and explored as part of the scope for the Review of the Local Plan 2030: • Incorporate a review of infrastructure requirements and opportunities as part of an update to existing policies (including 90S and 86S). • Reassess the capacity for growth across the settlement hierarchy in the existing Local Plan 2030 alongside a review of the classification on individual settlements (Policy 4S) • Review the strategic objectives of the Plan in relation to the requirements for sustainable development in the rural area, including supporting levels of growth and options for development that maximise net gains for sustainable development, including the delivery of social infrastructure and benefits to the wider community • Maximise opportunities to enhance Green Infrastructure and meet healthy communities objectives (Policy 2S and 35S) through the strategic policies and allocations supported through the Review of the Local Plan • Provide a realistic assessment of the ability for other strategic growth options to contribute towards meeting the increased needs for development over the plan period • Maximise opportunities for suitable, available, and deliverable development in the urban area as part of a composite spatial strategy while acknowledging the 12 constraints to this component of the overall strategy in terms of timeframes and levels of growth. • Support the provision of accommodation for older people on suitable sites where this an identified need for this type of accommodation. 3.21 The following sections set out the further justification and recommendations for plan-making on how this should be achieved as part of satisfying the legal compliance and soundness requirements for the Local Plan Review. Implications for Testing Options for Distribution of Growth Against the Local Plan 2030 3.22 In terms of the testing of options for the distribution of growth it is important to stress that during the preparation of the Local Plan the Council only excluded options for higher levels of growth in rural villages purely on the grounds that the level of development was beyond that required by the draft Plan. 3.23 Options deriving a greater proportion of development in these locations had been previously assessed as being some of the most sustainable (see Options 8, 19 and 33 of the Council’s January 2018 Sustainability Appraisal for the Local Plan 2030). This illustrates that in the Council’s consultant’s own view options to meet a higher overall requirement (or provide for an extended plan period) would be “just as sustainable” as the new village option that was selected in January 2018. An outline of options previously tested is summarised in Table 1 below: 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 1 9 0 0 0 2630 high growth 5100 low growth 225 795 5 SA September 2018 1 3 0 100 0 high growth 2895 high growth 4000 low growth 260 725 5 3.24 The Inspectors undertaking the Examination of the Local Plan 2030 identified the subsequent requirement for an immediate review on account of the resulting foreshortened plan period to 2030, and a significant change in circumstances arising from housing needs calculated using the government’s standard method. It is self-evident that the Council’s options for the Review of the Local Plan must incorporate the same (or greater) levels of development identified in previously excluded but sustainable options. 3.25 It is also a logical approach to carry forward the approach in the current Local Plan 2030, which recognises the relative importance of the rural area to deliver the Plan’s strategic priorities in terms of overall distribution. This is notwithstanding issues arising from the deferral of site allocations and the constraints imposed by the limited plan period. 3.26 Delivery of growth in the rural area remains of key importance to avoiding negative impacts 13 in sustainability terms and meeting the needs of certain settlements. It is surely the case, given earlier consultations, that if the Plan’s priorities required additional levels of development this could appropriately be delivered in a wider range of settlements (and/or more development where capacity allows in certain settlements). 3.27 Further comprehensive testing of reasonable alternatives that acknowledge the necessity for a flexible spatial strategy and maximisation of opportunities for sustainable development in the rural area to meet the plan area’s strategic priorities must form a key component when preparing the Review of the Local Plan 2030. As per the conclusions in the evidence base for the existing adopted development plan it is our view that: • This would again conclude that distributing a higher proportion of development in the rural areas is at least equally as sustainable as other options including provision of a New Settlement set out in the January 2018 version of the Regulation 19 Plan; and • It can further be demonstrated that the rural areas (and in-particular Key Service Centres and Rural Service Centres) are capable of sustainably accommodating higher totals for housing than proposed in the adopted Local Plan 2030; and • Sustainable options therefore exist to ensure that the Local Plan seeks to meet needs over a 15-year plan period. 3.28 One further implication for testing levels of growth as part of the ‘Dispersed’ spatial option is that the evidence base for the Local Plan 2030 did not test figures for growth in other villages with a Settlement Policy Area (or ‘Group 3’ villages) such as Turvey. 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 NPPF 2019 in terms of the provision of housing requirement figures to all designated neighbourhood areas. Testing of options should therefore assess scope to contribute towards needs for sustainable development across a wider range of centres. Implications for Management of Housing Land Supply and Delivery of the Housing Requirement 3.29 National Planning Practice Guidance sets out that when determining whether policies in existing plans should be updated it is relevant to consider the Council’s housing land supply position and whether issues have arisen that may impact on the deliverability of key site allocations. Both of these aspects are highly relevant in the Borough (ID: 61-065-20190723). 3.30 Appendix 2 of these representations provides further analysis of the Council’s current calculation of a Five Year Supply of deliverable sites and implications for the allocation of sites to accommodate additional housing requirement to be met through the Local Plan Review (i.e. 15,000 dwellings using the current calculation of local housing need). 3.31 Table 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. 14 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 3.32 The figure of at least 3,341 units broadly determines the scope for ‘top up’ allocations beyond the levels of development identified in Policies 3S and 4S of the current Local Plan. It is essential that the Review of the Local Plan adopts a positively prepared approach to providing for ‘top up’ allocations and does not impose arbitrary caps to growth in individual settlements as well as reflecting those centres where capacity is greatest. The ability for deliverable ‘top up’ allocations suitable to meet increased requirements in the period to 2030 should be considered favourable in the context of assessing site options and site selection. 3.33 The Council’s most recent ‘5 Year Supply of Deliverable Housing Sites’ Report highlights three key reasons why choice and flexibility in supply as part of preparation of the Local Plan Review is critical. This aligns with broader concerns regarding the effectiveness of the existing development plan and the conclusions undermine the Council’s current claimed supply of deliverable sites: 3.34 As a result of the approach to managing supply in the adopted Plan a surplus in delivery for the period 2015 to 2019 means the Council is seeking to provide for reduced annual five year requirement in order to maintain supply in excess of five years (798dpa vs 970dpa) 3.35 Furthermore, the Council’s accounting for oversupply exceeds the allowance proposed by the Inspectors, which would factor this over the remaining plan period (798dpa vs 918dpa) (see Inspectors’’ Report paragraphs 116 and 117) 3.36 The Council now acknowledges that it regards none of the sites allocated via the Local Plan 2030 or proposed for allocation in Neighbourhood Plans to be prepared (where permission is not already in place) are to be treated as deliverable 3.37 Table 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: 15 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 3.38 The Review of the Local Plan 2030 should therefore acknowledge its key role in ensuring the Borough Council’s ability to provide choice and flexibility in supply. This role will increase further in the event of any further delays to the preparation of Neighbourhood Plans or delivery of other allocated sites (including Town Centre sites) but is in any event necessitated by the increase in the housing requirement derived through national policy. Impact of Government Consultation on Proposed Planning Reforms 3.39 Appendix 3 of these representations considers the potential implications of the government’s ‘Planning for the Future’ White Paper in the context of the scope for the Local Plan Review. In summary, the contents of the White Paper comprise consultation proposals only and are of no material weight in terms of approaching the requirements of plan-making, however we reserve the right to comment further in due course. 3.40 It should be noted, however, that where page 16 of the Council’s consultation document refers to pending details of the government’s proposed revisions to the standard method to calculate local housing need this is on the basis of indicating a potential reduction in the housing requirement to 800 homes per annum. While the Council states this reflects uncertainties with the most recent 2018-based household projections the government has reasserted its commitment to delivering a figure of at least 300,000 homes per annum across England. 3.41 The government’s consultation proposals on a revised approach to calculation of the standard method achieve a total of 337,000 dwellings per annum, including an assessment 16 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.
1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope includes an acknowledgement that there is a need to accommodate growth in line with national requirements, no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the aim of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper, the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”
1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope notes the need to accommodate growth in line with national requirements no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the desire of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”
1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope notes the need to accommodate growth in line with national requirements no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the desire of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”
1.1. In general terms the matters listed as forming the scope for the Local Plan review are considered appropriate. However, whilst the scope notes the need to accommodate growth in line with national requirements no specific reference is made to the Oxford to Cambridge Growth Arc. 1.2. It is considered that the desire of the plan to accommodate the arc requirements should be very specifically stated because as acknowledged on page 3 of the issues and options paper the first reason given by the Inspectors for the review was: “…….that there is a need for the Council to have a plan that responds appropriately to longer term growth requirements, and in particular in relation to the Oxford to Cambridge Arc, as soon as possible.”
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 derived from the Standard Methodology. In August 2020, the Government published its proposed updated methodology for undertaking the standard methodology for consultation. Against the new methodology, this would increase the housing requirement to at least 1,153 dwellings per annum. It should however be recognised that Local Housing Need is a policy-off requirement and forms the starting point of calculating a housing requirement and should therefore be treated as a minimum figure the Borough needs to plan for. Of particular relevance to Bedford is its location within the Oxford-Cambridge Arc. Whilst the consultation documentation published by the Council advises 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 proposed revised Standard Methodology illustrates 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, the 2050 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. 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; a further 208 dwellings per annum to 2050. This would align with the Governments ambition to significantly boost the supply of housing.
1. Introduction 1.1 These representations to the review of the Bedford Borough Local Plan 2030 (Issues and Options) are made by Pegasus Group on behalf of Martin Grant Homes (MGH). MGH submitted an outline planning application in September 2019 for land to the west of Bromham that has been promoted under the name of Beauchamp Park. The application site is the largest allocation in the submission Bromham Neighbourhood Plan. The Neighbourhood Plan successfully passed the examination stage earlier this year and the site should be allocated once the Neighbourhood Plan has been put to a referendum and is formally ‘made’. The planning application seeks consent for a development of up to 390 units and associated open space and play spaces, sports pitches, highways works, water attenuation features and other developments and is currently being considered by the Council (LPA ref. 19/01904/MAO). 1.2 MGH welcomes this consultation on the review of the Local Plan as part of the Council’s commitment to delivering sustainable growth to meet the future needs of the Borough. 2.1 MGH supports the early review in accordance with Policy 1 of the adopted Local Plan. Given that the Local Plan was submitted for determination under the National Planning Policy Framework 2012 there is the need to ensure that it adequately anticipates the scale of growth of the Borough and how it can be accommodated in the most sustainable locations, in accordance with the requirements of the National Planning Policy Framework 2019 (the Framework). Alongside this review there is also the need to ensure that, from a development control perspective, the Council prioritises the determination of applications for sites that have been allocated through the Local Plan or are to be allocated through Neighbourhood Plans, like Beauchamp Park. 2.2 Whilst the application of the standard method as currently set out in Planning Practice Guidance results in a local housing need assessment of 1,305 dwellings per annum (dpa) this figure should be set as a minimum. This will allow the Council to positively determine planning applications based on their merits and whether they will achieve sustainable development. This will help the Council to build up a buffer to ensure that it can meet its housing needs for the whole plan period. 2.3 Given the reliance on Neighbourhood Plans to deliver some of the growth identified in the adopted Local Plan there is the potential for delays in sites coming forward where Neighbourhood Plans have not yet been progressed. These delays could result in the Council not being able to demonstrate a five-year supply of housing until the larger sites allocated in the Local Plan start to deliver new homes. Accordingly, it is essential that the Council ensures that applications that are already in the system for developments in accordance with adopted or emerging allocations are determined without delay. 2.4 Moreover, proposals for allocated, or soon to be allocated, sites should not be delayed in coming forward in an attempt to meet wider planning objectives based on the delivery of unallocated sites where there is no certainty of them coming September 2020 | CAM.0109 September 2020 | CAM.0109 Page | 4 forward. This will further delay the delivery of new homes and could result in the Council having to defend sites in less sustainable locations if they cannot subsequently demonstrate a five-year supply of housing. All new sites that come forward through this latest call for sites should ensure that they can provide adequate access arrangements without relying on consented sites that are outside of their control.
development at Stewartby Brickworks will be complete, forming a new community on the old brickmaking site, celebrating its heritage.
The Review focuses on growth and infrastructure and given the Borough Council’s enthusiastic support for East-West Rail, it is surprising there is no reference to the railway in the proposed scope. Although this is a National Infrastructure Project, the Borough Council, through this Review, has a wider responsibility to consider the effect of the railway on issues such as community cohesion, landscape character, countryside access, visual amenity and tranquillity, the need for supporting infrastructure, and measures to mitigate the wider effects. This policy area should be added to the list. Of equal significance is the BBC’s approach to the proposed Oxford-Cambridge Expressway, both in terms of transport infrastructure within the Borough and its impact on prosperity through the development of the Arc.
We support the proposed scope of the Plan. The Plan will focus mainly on growth and infrastructure. As set out within the introductory text, Bedford is located within the centre of the Oxford to Cambridge Arc. The Government has a long-term ambition to see economic growth in this area. As well as taking advantaged of improved east-west connectivity, it is considered that the plan should also look at improving connectivity within the borough itself to enhance the attractiveness of Bedford for businesses and residents.
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.
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.
3.3 The scope is set out on page 11 of the Consultation Document. De Merke agree with the extent of areas covered, however raise concern that only the policies in relation to the Environment Act would be considered. With Britain leaving the European Union together with the fundamental changes the Government proposes to the planning system in England there are likely to further implications on legislation. 3.4 It is suggested that the scope of the Local Plan Review should consider all relevant legislation changes and revise all policies appropriately. This will ensure the Plan is legally compliant and passes the necessary tests of soundness.
1.6 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.
Yes, we agree with the scope of the review, ie growth and infrastructure, but we would place more emphasis on improving infrastructure which is by far the more urgent challenge within Bedford Borough. Transport infrastructure needs to be significantly improved, the cost of doing so will be substantial and so the location of the larger elements of housing growth may best be considered with the results of an infrastructure review determining what can actually be achieved within the early years of the plan period.
A key policy that requires an immediate review is existing policy 4S. At present, this policy seeks to identify land to deliver 3,169 dwellings to meet the Council’s aim of delivering 14,550 dwellings within the plan period to 2030. This translates to 970 dwellings per annum (dpa). The current Local Plan was submitted to the Secretary of State for examination ahead of 24 January 2019, ensuring it was assessed against the 2012 iteration of the National Planning Policy Framework (NPPF). The Local Plan Review will be assessed against the 2019 NPPF, which will include utilising the standard method of housing need calculation. At present, this is calculated using the 2014-based household projections and would result in the need for 1,305dpa. However, should the methodology for calculating housing need be amended as proposed through the current ‘Planning for the Future’ consultation, this would reduce to 1,153 dpa. In either case, this represents an increase in housing requirement above that of the current Local Plan. The Local Plan Review must therefore ensure appropriate housing need be provided within the plan in line with the NPPF and the appropriate housing need calculation. It may also wish to provide additional housing above the standard method given the aims and objections of the Oxford-Milton Keynes-Cambridge arc. Appropriate sites in sustainable locations will therefore need to be identified within the Review process. In order to meet this additional housing need, Land East of Wixams provides such a sustainable site. It has direct access to the A6 and is located approximately 3 miles from the centre of Bedford. The site would form an extension to Wixams, which has its own services and facilities, including an employment area and allocated town centre. The land directly north of the proposed site is an allocated ‘Protect and Develop’ employment area. Residential development would complement these neighbouring land uses. In transport terms, the site is a short journey to Bedford, which can be accessed via cycle or walking, as well as potential bus services as currently running to Wixams itself. Railway stations at Bedford, Bedford St John and the proposed station at Wixams allow wider sustainable connections. The benefits of the site were emphasised within the Call for Sites document, and these continue to apply.
25. The Issues and Options Paper includes a list of eight bullet points which set out the proposed scope of the Local Plan Review. The absence of any reference to the Oxford – Cambridge Arc is a significant omission. 26. As set out above, the context underpinning the preparation of Local Plan review, not to mention reason behind the requirement for an early review, is the need to sustainably facilitate the economic and housing growth that is required to support the Government’s ambitions in respect of the Arc. As such, the scope must explicitly refer to developing a strategy to achieve this aspiration.
The scope of the Local Plan Review appears to cover most of what would be expected, however there are two additional points that Storey Homes proposes Bedford Borough Council should consider: • Whether the Council should commit to another ‘early review’ within 3 years of adopting the Local Plan Review • The need to update the affordable housing policy to reflect any national changes On page 6 of the Consultation Paper, the Council acknowledges that “little progress has been made on how the high-level ambitions for the Arc can or will translate into identifying where strategic growth is likely to be delivered.” Given this lack of progress and the uncertainty regarding the extent to which any progress will be made between now and 2023, the Council are likely to be producing this Local Plan Review with only a small degree of additional knowledge on this topic, in comparison to the information known during the Local Plan 2030 process. The Council therefore will not be able to fully understand how the Arc ambitions will affect their strategic growth. In light of this, it is suggested that the Council consider committing to another ‘early review’, 3 years from the adoption of this Local Plan Review, to once again reflect on any progress related to the Arc. The “Changes to the current planning system” national consultation remains open until 1st October 2020, following this, it is expected that a series of changes will be implemented towards the end of 2020/start of 2021. This may include a new requirement for a minimum of 25% of all affordable housing units secured through developer contributions to First Homes. First Homes are provided at a 30% discount on the open market price. Should this requirement become enshrined in national policy, the Council should update their local policy accordingly. This consultation also considers raising the unit threshold at which point affordable housing is a requirement. Although this is likely to be a temporary measure, this could change, and the Council should update their affordable housing policy as necessary.
NDPs should be included in the strategy because they have been through all the village consultations and have also considered their local housing need. Add policies to address climate change requirements. Policy required to ensure that Housing Design complies with minimum size guidelines as advised by the government technical housing standards-nationally described space standard March 2015 Public Open Space – who will own and maintain them in new developments? If a sum to maintain them is not from the developer does the public open space become the responsibility of the local council or a private management company? If so, how is the open space to be maintained?
I do not agree with the proposal to build 20,000 plus new homes in this North Bedfordshire village area. The villages do not have the infrastructure, roads or services to support this level of development. Moreover, this is a rural environment that will be completely eroded by this scale of urban development.
Odell PC is currently preparing a Neighbourhood Plan in consultation with residents of the village which has helped us to prepare this response. In addition, we are aware that Central Government has issued proposals that will, if passed into legislation, greatly reduce the involvement of local parish councillors and residents in planning decisions. This makes it more important that any Local Plan is agreed with the Parish Councils and passed by the Borough Council in a full meeting of Borough Councillors.
Pavenham PC believes that the approach proposed to be taken by the Council is both realistic and sensible. The Parish Council can see neither logic nor benefit in the reassessment of policies that have only recently been thoroughly reviewed and assessed at the Local Plan examination.
Generally, The Society agrees with the proposed scope of the local plan review.
I have read through the need to build more homes and infrastructure to support them. In view of society’s shift to communicate by electronic means following Covid 19, rather than face to face, is there any justification for either the East West Rail link or building more roads and the incurring of costs that might prove to be white elephants?
We write to you on behalf of our client, Manor Oak Homes, and further to our response to the Council’s Call for Sites exercise in respect of their land between Hookhams Lane and Ravensden Road, Salph End. Specifically, we are pleased to provide a further response in respect of the Issues and Options (I&O) consultation document which represents the first step of the review of the Local Plan 2030. Accordingly, the comments provided by this letter should be read in the context of our client’s ongoing promotion of our client’s land at Salph End. It is being promoted for a development of approximately 400 dwellings and a site for a new two forms-of-entry primary school, land that the Call for Sites submission confirms is available, deliverable and eminently achievable with delivery able to commence in the earliest years of the new plan period. This promotion follows on from a rigorous level of engagement with the Council during the preparation of the Local Plan 2030 and draws support from a recent planning application at the site which is now subject of an ongoing appeal. In light of our comprehensive submission to the Call for Sites it is not intended to review the merits of our client’s site again as part of this submission. Our response to the general questions set out in the I&O document, however, will be predicated on the availability of our client’s site for development and the clear opportunity it presents to secure a substantial and entirely sustainable new residential community on the northern edge of the Bedford urban area. Background to the Local Plan Review Prior to setting out our response to the general questions posed by the I&O document it is worth confirming the context of this review of a local plan only adopted 7 months ago, in January 2020. A brief overview of the need for the review is set out at pages 3 and 4 of the I&O document. However, to allow us to establish the proper context of the review it is useful to highlight the precise quotes of the Local Plan 2030 Inspectors. The pertinent passage of their report explaining the need for Policy 1 of the Local Plan 2030 securing its immediate review is as follows: “16. However, notwithstanding these cited reasons, in the medium – long term, and in particular after 2030, the proposed ‘Cambridge – Milton Keynes – Oxford Arc’ is likely to have significant implications for Bedford, particularly in terms of the need for housing, employment land and infrastructure. Nonetheless, there is currently insufficient clarity about these implications to include in the plan effective, detailed policies and proposals on development and infrastructure needs reflecting the Arc. Therefore, whilst the NPPF 2012 indicates that plans should take account of longer-term requirements, given the current uncertainty about development and infrastructure needs in Bedford post 2030, it would not be effective to, at the present time, extend the plan period beyond 2030. On this basis the plan is, therefore, also consistent with the NPPF 2012 requirement that plans should be drawn up over an appropriate time scale. 17. Nevertheless, there is a need for the plan to respond appropriately to longer term requirements, and in particular the Arc, as soon as possible. Consequently, notwithstanding the statutory requirement for the plan to be reviewed, and then updated if necessary, within five years of its adoption, it is necessary for a review and update to be completed more quickly. On this basis (and for other reasons detailed elsewhere in this report), MM1 is necessary for the plan to be justified and effective. This requires a review of the plan and any update of it/new plan to be submitted for examination within three years of adoption of the current plan. Based on the discussion at the hearings the three year deadline appropriately balances the need for the plan to be reviewed and updated as quickly as possible with the realities of the time likely to be necessary for the Council to effectively undertake this work.” These comments essentially recognise that the Local Plan 2030 represents a strategy that is fit for purpose for a short moment in time only. It is sufficient to provide an up-to-date policy framework capable of meeting an immediate need for a set of policies more in line with the requirements of the NPPF in light of it replacing a 12 year old development plan framework. In short, the plan is a stopgap. In respect of even the basic growth requirements for the Borough moving forward, before any uplift relating to the Arc is factored in, the Inspectors’ report went on to observe: “As set out in the Introduction of this report, the plan is being examined under transitional arrangements detailed in NPPF 2019. These mean it is not being tested for its compliance with this document’s statement that, other than in exceptional circumstances, the minimum number of homes within a plan area should be determined using the standard method detailed in national planning guidance (i.e. the updated PPG). The standard method identifies an annual minimum housing need figure for Bedford of around 1,280 dpa, more than 30% higher than the plan’s objectively-assessed need of 970 dpa. The two housing need figures are formulated using different approaches and, thus, at the present time and given the transitional arrangements for the examination of local plans, the 1,280 dpa figure does not undermine the robustness of the 970 dpa objectively-assessed need figure for new housing in Bedford.” Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 3 The Local Plan 2030 was adopted under a set of transitional arrangements designed to ensure that emerging plans could successfully negotiate their examinations without the need for a wholesale review in respect of either the baseline objectively assessed housing need or the approach taken by the Council in the production of the plan. What this has resulted in, however, is a strategy which now proposes a supply of new homes which falls significantly short of the actual up-to-date requirements of the Borough. As will be demonstrated as part of our client’s ongoing appeal this quirk has resulted in the current Local Plan 2030 only being able to facilitate the delivery at best 80-85% of the Borough’s housing needs, based on the lower 970 dwelling per annum figure of the adopted plan, over the current 5-year period. On this basis the central objective of the new Local Plan subject of this I&O consultation is clear – to significantly boost the supply of new homes across the Borough in a way that the Local Plan 2030 failed to achieve. This will ensure that the replacement strategy accommodates significant and ambitious growth through the identification of a range of deliverable sustainable sites that are currently absent from the adopted development plan. Set on this foundation we now seek to address what we consider to be the most relevant questions posed by the I&O document, Questions 2 and 4 relating to the draft vision for the plan and the appropriate spatial distribution of growth.
We do NOT agree with the proposed scope of the Local Plan Review. It lacks any commitment to develop policies designed to ensure that the new development allocated will be sustainable in terms of natural resources, natural capital, agriculture and food production and climate change. To address our concerns, we would want to see the scope of the revision revised along the following lines; Retain the first bullet point, • Develop a strategy and allocate new development sites to accommodate growth in line with national policy requirements Add bullet points as follows, • Include new policies to ensure that the totality of new allocated development, when fully completed, would be sustainable in terms of natural resources, in particular water supply and treatment of waste and surface water, would maintain, and if possible improve, the level of natural capital, and would maintain, and if possible improve, the agricultural and food production assets of the borough. • Include policies to ensure that new allocated development is at least neutral, and if possible negative, in terms of its contribution to climate change. • Include policies to ensure that new allocated development is built to explicit standards that mitigate the potential impacts of future climate change. Omit bullet point 4, • Consider the need for additional policies to address climate change
St Modwen agree that the focus of the Local Plan Review includes employment growth. The review should include policies to promote economic growth, with an update to Policy 70 of the Local Plan 2030 to reflect the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 which took effect on 1st September 2020. This provides increased flexibility for businesses, which should be reflected in Policy 70.