Object

Representation ID: 8938

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

Paragraph 1.14 (Scope of the Plan) – Object
3.17 The Council’s draft strategy consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (BLP2030 Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails fully to reflect the reasons for first introducing the requirement for immediate review and, in particular, the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.18 As set out in the Spatial Framework consultation document (paragraph 5.5) the Ox-Cam Arc
demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford Borough resulting from the approach adopted in the BLP2030.
3.19 Thus (at paragraph 5.7) it is an aim of the Ox-Cam Spatial Framework to ensure that it establishes policies to enable housing needs to be met in full, including much-needed affordable housing where direction will be provided by the Framework e.g. implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.20 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.21 The LP2040 draft strategy proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due only to considering a horizon to 2040, and as a result of likely timescales for the characteristics of larger-scale development (including new settlements), it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond unless the strategy is supported by a wider range of deliverable sites.
Remedy
3.22 The Council’s proposed draft strategy needs to offer flexibility and, moreover, choice to address the current and persistent failure to meet needs in full if the Local Plan is not to become significantly constrained for a substantial period before any of the longer-term solutions proposed as part of the emerging LP2040 achieve significant delivery – see supporting report oin Housing Delivery which generally accompanies the representations submitted on behalf of the clients of DLP Planning Ltd.