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

Representation ID: 7550

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Representation Summary:

The most recent version of the National Planning Policy Framework was published in July 2021, following commencement of the Council’s Preferred Options consultation.
In summary, there is no longer any support in national policy for the outcomes of the Local Plan 2030 Examination in terms of pursuing constraints to the plan period and overall level of growth. Paragraph 20(c) of the NPPF2021 seeks to ensure sufficient provision towards the need for development as part of the approach to preparing strategic policies in order to meet strategic priorities for the area (particularly in terms of the delivery of social and community infrastructure (including health and education).
The National Planning Policy Framework (NPPF) is clear that the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities (paragraph 92). Planning policies should plan positively for social, recreational and community facilities, including supporting the delivery of local strategies to improve well-being and panning positively for the provision and use of shared spaces, including open space (paragraph 93).
In particular the Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. To this end local planning authorities are required to take a proactive, positive, and collaborative approach to meeting this requirement, and to development that will widen choice in education (paragraph 95). This means giving great weight to the need to create, expand or alter schools, and being able to work with schools and promoters to identify and resolve key planning issues before applications are submitted.
National Planning Practice Guidance sets out the importance forward planning for the delivery of school places and understanding the direct impact of new development when assessing the potential to secure developer contributions, which are not in principle replaced by alternatives through government funding or delivery programmes (ID: 23b-007-20190315).
In determining when contributions are required it is important for Plans to support the efficient and timely creation, expansion, and alteration of high-quality schools. Plan-makers should consider existing or planned/committed school capacity and whether it is sufficient to accommodate proposed development within the relevant school place planning areas (ID: 23b-008-20190315).
Relationship with the Existing Development Plan – The Bedford Local Plan 2030 and Oakley Neighbourhood Plan
Current provision within the development plan singularly fails to recognise the requirements of up-to-date policy and guidance in terms meeting the requirements for growth in school places across the borough and particularly to support increased provision at Oakley required by existing development commitments.
Local Plan 2030 does contain proposed strategic policies that seek to prioritise meeting education needs as a strategic priority and a requirement for sustainable development, but these do not specifically address the circumstances at Oakley. Policy 3S(vii) applies specifically in relation to Key Service Centres, looking to ensure that education provision is expanded where necessary. Policy 90S deals with infrastructure delivery and ensuring that the Council works with developers to find the most appropriate and beneficial solution. While these policies provide ‘some’ support in principle to deliver the required expansion in school places, they do not reflect the role, function, and importance of Lincroft Academy.
As such, there is no requirement in adopted strategic policies to support bringing forward development that properly reflects the Academy’s current requirements, which were not captured in the evidence base for the Bedford Local Plan 2030 (including the Infrastructure Delivery Plan). As such, the issue has been deferred rather than dealt with through the Local Plan 2030.
As a result, the Oakley Neighbourhood Plan also avoids setting out any policy approach to facilitate the future expansion and enhancement of the facilities at Lincroft Academy.
The submission Neighbourhood Plan includes amongst its objectives a need to “maintain a sustainable community, including a sustainable business community, with adequate infrastructure and facilities” but does not indicate how this will be achieved for non-residential uses.
Policy BE2 seeks to support retail and community facilities ‘within the centre of Oakley’, indicating that such a boundary is delimited by Station Road therefore precluding use of land to the east of this. Particularly for educational uses the Plan states:
“The largest single employer in the parish is Lincroft School which also serves several surrounding parishes. Along with Oakley Primary School it provides a prime focus for the community but also is the source of significant traffic issues.”
There is no policy provision to recognise constraints on the existing use and capacity at the current school site and associated playing pitch facilities as a key component of community infrastructure requiring upgrade and expansion.
CMAT supports the recognition of the current and future land use and operational requirements of Lincroft Academy arising from the Examination of the Oakley Neighbourhood Plan, with the proposed designation of the Lovell Road Playing Fields as a Local Green Space having been rejected by the Examiner. The Examiner’s Report records that imposing an additional layer of protection would have unduly limited Lincroft Academy in terms of future uses of the site and notes:
“The playing fields are separated from the main part of the school buildings and Lincroft Academy wishes to reorganise its land parcels to enable the growth and efficient functioning of the school. In addition, Oakley Football Club has indicated that it is looking for flexibility in case a better site should come forward for the Club’s use. The designation of the site as LGS would limit the future options for the school in that reorganisation.”
Notwithstanding the longstanding issues with congestion on Station Road, the Oakley Neighbourhood Plan further notes that the requirements of existing organisations should be considered when assessing future proposals for development. This recognises that fulfilling the provision of community infrastructure (including education and school places) may mean it is not possible to alleviate all traffic issues raised as concerns with the Neighbourhood Plan.
Relationship with the Emerging Plan
CMAT would welcome further engagement with the Council regarding the strategic priorities for education associated with the current requirements of Lincroft Academy and future levels of growth in Oakley and surrounding settlements. It is considered essential that delivery of these requirements is supported through the policies and allocations of the Plan.