Object

Representation ID: 8870

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraphs 1.47-1.48 (Neighbourhood Planning) – Object
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 Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options. Roxton however, declined to prepare a Neighbourhood Plan and development was allocated through the Local Plan. This is relevant to the Council determining the most appropriate approach to site selection and allocation within the Local Plan 2040.
3.17 Within the context of Roxton 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 and beyond. Given the background to the adopted Local Plan 2030 the Local Plan Review offers a significant opportunity for Bedford Borough Council to lead on the allocation of additional sites or otherwise provide clarity of the requirements of general conformity that any future Neighbourhood Plan for Roxton must satisfy. This includes meeting the objectives for growth within the ‘east’ corridor parishes.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
3.18 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.
3.19 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.
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
14
3.20 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, which includes our client’s site land in Roxton.
3.21 Paragraph 28 of the Framework 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.
3.22 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
3.23 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the Framework. Paragraph 66 sets out that strategic policies should also 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. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.
3.24 This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
15
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).
3.25 The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• 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).
3.26 In the case of Roxton a requirement figure for the purposes of Neighbourhood Planning should be identified, in accordance with national policy. However, in the absence of a designated Neighbourhood Area for the parish this would alternatively provide the basis for the Borough Council to select the allocation of sites to meet this figure.