Object

Representation ID: 8991

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s Preferred Option consultation proposals indicate that the purpose of updates
to the Local Plan following the requirements of the Review policy (Policy 1) are to outline a
development strategy to 2040 and meet national policy requirements for the delivery of
growth. This fails to fully 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
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc
demonstrates poor affordability where development has not kept pace with need. That is
exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.

This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework
sets policies to enable housing needs to be met in full, including much-needed
affordable housing.

This sits alongside strategic decisions 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.

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.

The Council’s Preferred Options consultation proposals would sustain a very substantial
shortfall against minimum annual local housing need until at least 2030. Due to only
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.

The Council’s proposed strategy offers no flexibility and choice to address the current and
persistent failure to meet needs in full. Our assessment indicates that current levels of
development are likely to become significantly constrained substantially before any of the
longer-term solutions proposed as part of the Preferred Options achieve significant delivery.
Realistic assumptions must also be made in relation to new larger-scale developments.