Object

Representation ID: 8643

Received: 28/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 1.47-1.48 (Neighbourhood Planning) – Object
2.2 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 Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
2.3 These representations identify that the consultation fundamentally fails to assess the role and ability 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’ Plans will remain in general conformity with the development strategy nor how further allocations in other defined settlements such as Souldrop might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
2.4 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.
2.5 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.
2.6 Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote 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 2012 version of the Framework.
2.7 The Council’s options test no distribution of requirements to other defined settlements whatsoever, which continues to overlook opportunities for sustainable settlements such as Souldrop to make a commensurate contributions towards the increased needs for development in the period to 2030 and beyond.
2.8 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.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
2.9 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021. For Souldrop, these provisions apply in the context that there is currently no designated Neighbourhood Area, and the defined settlement is not included within the scale and distribution of growth to be met through Neighbourhood Plans as part of the strategic policies of the LP2030 (Policy 4S).
2.10 Paragraphs 66 and 67 of the NPPF2021 should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the neighbourhood plan area and should minimise the risk of Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509). Rolling forward the distribution of growth in Policy 4S as suggested by the Council in its testing of strategy options for village-related growth is a flawed approach:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).
2.11 By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs and whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the Standard Method to 2040.
Remedy
2.12 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.
2.13 Outside of the approach to identification of a housing requirement for Key Service Centres and Rural Service Centres the Council should adopt a flexible approach to supporting development opportunities at other defined settlements such as Souldrop in order to sustain and enhance their role. This is necessary to reflect the longer-term plan period to 2040 and that such settlements were omitted from provision towards the scale and distribution of growth required to support the LP2030.