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Representation ID: 9011

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

The 30-year Vision
4.1 The publication of the changes to the NPPF on the 20th July 2021 introduced the requirement for policies for larger scale development, including new settlements, to be set within a vision that looks at least 30 years ahead to take into account likely timescales for delivery. See the full paragraph extract below.
“22. Strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” (emphasis added)
4.2 As BBC is including larger scale developments in its emerging spatial strategy, such as new settlements, the changes to the NPPF 2021 now mean that BBC will need to set these policies within a vision that looks at least 30 years ahead; this means a further ten years at least from the end of the Plan period.
4.3 Whilst the Rt Hon Robert Jenrick MP made clear in his letter to the Chief Executive of the Planning Inspectorate on the 2nd August 202115 that guidance on this issue would be available shortly, there is currently no specific indication from MHCLG on how this paragraph can be addressed. The NPPF infers that any vision for BBC would need to cover the strategic site in question and its immediate geography, be that an existing town it will be extending or if it is a new settlement it’s wider hinterland, including how it will interact with it. However, it is impossible for BBC to divorce this visioning exercise from the wider strategic matters at play in the OxCam Arc concerning sustainable growth (housing and jobs) and specifically the ambition to plan for growth in a more sustainable and strategic way as set out in the live MHCLG consultation ‘Creating a vision for the Oxford-Cambridge Arc’. However, alongside this, there will be a requirement to deliver the levels of housing that are necessary to facilitate this growth, and ensure that growth of business can be accommodated in a sustainable fashion, with shorter commuting times, and co-location of businesses and housing.
4.4 On face value, it would appear that the additional evidence required to inform the 2040 Local Plan and to address paragraph 22 of the NPPF would be a vision for BBC’s location in the OxCam Arc and its ability to accommodate strategic growth to 2050 and beyond. The long-term vision could be framed in a way that supports the case for the various strategic sites to emphasise why they are needed and the benefits they bring to their respective areas and borough as a whole, both in this plan period and beyond. The vision may address issues such as the below in a short topic paper:
1 The likelihood of ongoing growth needs associated with the location of Bedford in the OxCam Arc (particularly housing but also other forms of development) over the long-term including beyond the Plan period, to 2050 and beyond as per the emerging OxCam Spatial Framework;
2 The role of larger allocations in achieving key aspirations for the area it is within (e.g. delivering infrastructure to facilitate sustainable development including public and active
transport, supporting inward investment, addressing local and Arc wide housing pressures, etc); and
3 Place shaping and managing how the area will change over the long term (e.g. reducing the need for future piecemeal approaches).
4 Changes to sustainable transport over that longer-term period, meaning that the predict and provide, capacity-constrained approach currently framing the local Plan’s current spatial choices is unlikely to be compatible with longer term approach.