Object

Representation ID: 8715

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

3.30 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.

3.31 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 might be provided for in an effective and positively prepared manner.


Reasoning


(i) Relationship with Delivery of the Area’s Strategic Priorities

3.32 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford).

3.33 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.

3.34 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.

3.35 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. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.

3.36 In the context of Great Barford these representations recommend that the allocation of additional sites is confirmed within the Bedford Local Plan 2040, rather than deferred to a review of Neighbourhood Plans. The particular advantage of this approach in the context of


our client’s Willoughby Park proposals reflects the ability to confirm support for a comprehensively planned village extension which is in one single ownership and to set out through the policies of the development plan the opportunity to contribute towards a number of the Plan’s objectives (including delivery of a new Countryside Park and GP Surgery).