Object

Representation ID: 6107

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

3.2 Definition of the proposed plan period underpinning the Council’s Preferred Options has been rendered inconsistent with national policy following publication of the 2021 version of the NPPF.
3.3 Paragraph 1.2 of the ‘Creating a Vision for the Ox-Cam Arc’ consultation document also confirms that the Spatial Framework will extend to 2050 and beyond. Preparation of the Bedford Local Plan 2040 should be undertaken consistently with this aim.
3.4 The proposed plan period of 2020 to 2040, particularly when read in the context of the Council’s draft strategy could result in a further delay in meeting development needs in full (until at least 2030). This will generate a requirement for further, successive, reviews; and is setting the plan up to fail both in terms of overall supply and also the spatial distribution which will not allow a clear vision for planned growth in the villages that will be necessary to deliver the scale of growth needed. This includes parishes such as Wootton located within the A421 corridor.
3.5 Significant extensions to existing villages and towns that form part of the strategy for an area should be set within a vision that looks further ahead (at least 30 years) rather than the minimum 15 year time horizon from the date of adoption of a local plan.
3.6 Given Bedford’s location in the Ox-Cam Arc a 30 year horizon is essential where paragraph 1.2 of the ‘Creating a Vision for the Ox-Cam Arc’ consultation document confirms that the Spatial Framework will extend to 2050 and beyond. Preparation of the Bedford Local Plan 2040 should be undertaken consistently with this aim.
3.7 The larger-scale approaches to development (including new settlements) that the Council has identified as part of its Preferred Options accord with the circumstances that national policy identifies for considering a minimum 30-year horizon, to take account of longer timescales for development.
Remedy
3.8 Bedford Borough Council should not wait for transitional arrangements upon introduction of the Framework to have to undertake yet another review that will need to consider the shortfall in meeting needs and addressing strategic priorities to 2030. Realistically, as a result of the scale and pattern of the Preferred Options proposed, delays to timescales for development are also likely to result in delays to meeting needs in full between 2030 and 2040. Those parts of the Council’s draft strategy relying on larger-scale development including New Settlements and rail-based growth should be profiled to look further ahead to 2050.
3.9 This reemphasises that in terms of the soundness requirements, the Council must fully embrace those sustainable opportunities to meet the increased requirements for growth in the immediate term and enable this through the prioritisation of suitable and deliverable sites as part of a ‘hybrid’ strategy. Village-related growth in the ‘south’ corridor parishes is complementary this approach and the benefits of early delivery.
Remedy
3.21 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
3.22 This reemphasises that in terms of the soundness requirements for preparation of the Local Plan 2040 the Council’s proposed approach must also fully embrace those sustainable opportunities to meet the increased requirements for growth in the immediate term and enable this through the prioritisation of suitable and deliverable sites as part of a ‘hybrid’ strategy.
3.23 Policy 3S of the Bedford Local Plan 2030 sets out the spatial strategy. Through criteria (vi) this directs strategic scale residential development to Key Service Centres to be allocated through Neighbourhood Plans prepared in accordance with Policy 4S. While Wootton is not listed amongst the Key Service Centres in Policy 4S it is addressed in criteria (iv) of Policy 3S, with the spatial strategy providing for:
“The completion of Wixams new settlement and strategic urban and village extensions to the west of Bedford, at Wootton, Stewartby and Shortstown”
3.24 This reflects the background to the strategy selected in the LP2030. More detail is provided in the BBC ‘Development Strategy and Site Selection Methodology’ (September 2018). In the second Pre-Submission version Local Plan this explains (at paragraph 4.7) the exclusion of Wootton from further allocations through NPs to be prepared due to “significant recent and ongoing expansion of about 1,300 dwellings.”
3.10 Paragraph 6.14 of the LP2030 emphasises the Key Service Centres demonstrate a strong service role for local communities, and this includes Wootton. Paragraph 6.17 sets out that the scale of growth should have regard to the capacity of existing infrastructure. For Wootton, this takes account of the 1,300 units referred to above.
3.11 However, the process for the preparation of Policy 3S/4S in the adopted Bedford Borough Local Plan 2030 needs to take account of its background, namely:
• It was prepared and submitted for Examination under the requirements of the NPPF 2012;
• The Plan’s objectively assessed housing need falls significantly short of local housing need calculated using the standard method, with Bedford Borough Council expressly aware of this in dictating the timing for submission of the Plan
•The Plan has a significantly foreshortened plan period covering less than 10 years from its adoption in 2020.
3.12 The evidence base for site assessment and site selection does not indicate a lack of capacity for further significant sustainable growth adjacent or well-related to the Settlement Policy Area in the medium term. Earlier rounds of plan-making (prior to shortening the plan period to 2030 and summarised in the Development Strategy Topic Paper) recognised that for Wootton:
• growth in Wootton, Shortstown, Wixams and Stewartby should be limited until after current commitments have been completed. (paragraph 2.15); and
• identified a provisional requirement for Wootton of 250 to 350 units to be provided later in the plan period post-2025 (Table 2)
3.13 These circumstances are now borne out in details of the emerging Draft Plan Strategy Options for the Local Plan 2040, which identifies a significant potential for growth at Wootton and is a material consideration for the emerging WNP.
3.14 With the publication of the emerging Draft Plan Strategy Options review Local Plan 2040, the emerging WNP is already seeking to pre-empt the decision making on the updated strategy without taking account of future policy conflicts. Conflicting policies from the WNP will potentially undermine the objectives of the Plan through not allocating sufficient sites to give flexibility to housing delivery.
3.15 Planning Practice Guidance specifies that although a draft neighbourhood plan or Order is not tested against the policies in an emerging local plan the reasoning and evidence informing the local plan process is likely to be relevant to the consideration of the basic conditions against which a neighbourhood plan is tested (ID: 41-009-20190509). This is an area that should be the subject of discussion between the qualifying body and local planning authority.
3.16 Policy 1 of the Bedford Local Plan 2030, which requires that a new Local Plan containing policies to meet housing need calculated in accordance with the government’s standard method be submitted for Examination before February 2023, dictates that conflict between relevant strategic policies and the emerging WNP is to be anticipated. These circumstances are likely to take effect earlier than two years after any NP for Wootton is ‘made’. NPPF2021 paragraph 14 would therefore be disengaged on the grounds that criterion (b) (policies and allocations sufficient to meet the housing requirement) is no longer satisfied.
3.17 The strategic direction of the Draft Plan Strategy Options for the Local Plan 2040 continues to recognise the sustainable role and function of Key Service Centres and their capacity for growth whilst seeking to focus the provision of growth through strategic sites and corridors, together with the urban area of Bedford. Wootton is therefore well-related to the Council’s Preferred Options and provides a critical opportunity to contribute towards increased housing needs in the short and medium-term.
3.18 Wootton clearly falls into accommodating greater quantum of growth in this strategy and therefore a review of WNP will be required to consider how it would maintain general conformity with the emerging strategy.
3.19 The consideration of reserve sites as part of the ongoing WNP Examination would be a move towards the flexibility in adherence to the new Local Plan and the published growth options.
3.20 This becomes especially relevant when consideration is given to the ability to accommodate strategic infrastructure associated with growth (include progress with East-West Rail). Growth in the ‘south’ corridor parishes to complement these strategic opportunities, through recognising the longer-term role of sustainable Key Service Centres including Wootton to sustain and enhance their function, reflects the ability to expand and utilise social and community infrastructure at all locations suitable to address housing need within the corridor.