Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6109

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

Representation Summary:

3.16 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the BLP2030) in the context of updates to the development strategy explored through the LP2040 consultation.
3.17 The consultation fundamentally fails to assess the role and performance of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ and draft plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner. The Wootton Neighbourhood plan is being prepared at present in accordance with a plan being superseded, with lower and unrealistic growth targets to meet need and comply with national policy guidance.
Reasoning
3.18 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
3.19 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
3.20 Paragraph 28 of the NPPF2021 reaffirms the role for NDPs in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of NDPs not promoting less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the NPPF2012. However, the Council’s testing of options for the LP2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.21 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
3.22 Paragraph 28 of the NPPF2021 reaffirms the role for NDPs in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of NDPs not promoting less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the NPPF2012. However, the Council’s testing of options for the LP2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.23 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy. It risks leading to planning by appeal in Neighbourhood Plan areas where the NDP has fallen out of date or has not been prepared in accordance with the most current and relevant Local plan.
3.24 It is a necessary under national policy to ensure that the emerging Local Plan 2040 is able to provide a requirement figure to designated Neighbourhood Areas. This will inevitably materially exceed the evidence currently relied upon in the context of the LP2030. This forms a material consideration as specified in the PPG (ID: 41-084-20190509) to identify those circumstances where it will be necessary to review and update Neighbourhood Plans. This is particularly relevant in Wootton given the absence of any requirement to contribute towards the overall scale and distribution of growth in adopted strategic policies.