Object

Representation ID: 8943

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

3.23 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 BLP2030) in the context of updates to the development strategy explored through the LP2040 consultation.
3.24 The consultation fundamentally fails to assess the role and performance 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
3.25 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. Even where a Neighbourhood Plan has been made at Turvey there is demonstrably little appetite in a community that only narrowly voted to support the NDP, to now embark on a further similar exercise which is likely to be as divisive as the current NDP proved to be. Other communities have failed even to reach that stage other than as a means to try and prevent development taking place altogether.
3.26 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.
3.27 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.
3.28 Paragraph 28 of the NPPF2021 reaffirms the role for NDPs in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of NDPs not promoting 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 NPPF2012. However, the Council’s testing of options for the LP2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.29 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. It risks leading to planning by appeal in Neighbourhood Plan areas where the NDP has fallen out of date.
Remedy
3.30 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’.
3.31 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth. There may be scope to alter the distribution of the housing requirement to Key Service Centres upwards or downwards from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and other potential benefits for development in these settlements relative to their overall potential contribution to LHN.