Object

Representation ID: 8988

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Comments on the Proposed Approach and Supporting Evidence
The section of the representations provides observations on the soundness of the Council’s
overall approach towards preparation of the Local Plan 2040 and identification of the strategic
priorities it is required to address. Comments specifically relate to Chapters 1 and 2 of the
consultation document.

Paragraph 1.5 (proposed plan period)– Object
3.2 Definition of the proposed Plan period underpinning the Council’s Preferred Options has
been rendered inconsistent with national policy following publication of the 2021 version of
the NPPF.

Reasoning
The larger-scale approaches to development (including new settlements) that the Council
has identified as part of its Preferred Options accord with the circumstances that national
policy identifies for considering a minimum 30-year horizon, to take account of longer
timescales for development.


Paragraph 1.2 of the ‘Creating a Vision for the Ox-Cam Arc’ consultation document also
confirms that the Spatial Framework will extend to 2050 and beyond. Preparation of the
Bedford Local Plan 2040 should be undertaken consistently with this aim.


The proposed Plan period of 2020 to 2040, particularly when read in the context of the
Council’s Preferred Options resulting in a further delay to meeting development needs in full
(until at least 2030) will generate a requirement for further, successive, reviews and is setting
the plan up to fail.

Remedy
Bedford Borough Council should not wait for transitional arrangements upon introduction of
the Framework to have to undertake yet another review that will need to consider the shortfall
in meeting needs and addressing strategic priorities to 2030. Realistically, as a result of the
scale and pattern of the Preferred Options proposed, delays to timescales for development
are also likely to result in delays to meeting needs in full between 2030 and 2040.

Those parts of the Council’s Preferred Options relying on larger-scale development should
be profiled to look further ahead to 2050.

This reemphasises that in terms of the soundness requirements for preparation of the Local
Plan 2040 the Council’s proposed approach must also fully embrace those sustainable
opportunities to meet the increased requirements for growth in the immediate term and
enable this through the prioritisation of suitable and deliverable sites as part of a ‘hybrid’
strategy.