Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9887

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Representation Summary:

2. Plan Period
2.1 With regard to the plan period the Council will need to consider paragraph 22 of the Framework which was published after the start of the consultation. It states:
“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.”
2.2 The Plan sets out a significant level of development and new settlements and/or significant extensions to South Bedford. Given the scale of development, the strategy chosen, the stepped trajectory and ambitious annual delivery rates we consider the 400 dwellings that are shown to be post 2040 is an underestimate. We consider that the plan should be extended to 2050 if the
current proposed strategy involving new settlements is adopted.
2.3 A further point on why the plan period should be extended to 2050 is the consultation on the Arc Spatial Framework. Paragraphs 1.9 and 1.10 of the consultation paper for LP2040 states:
“1.15 In response to this, and in order to create a more joined up and legible process, some local authorities in the Arc have adjusted their local plan review timetables so that local plan activity follows the completion of the spatial framework. Government, however, has urged Councils in the Arc to carry on with plan-making and, in Bedford Borough’s case, the consequences of not doing so could be significant for the reasons relating to policies becoming “out of date” described above; so local plan work in Bedford Borough continued.
1.16 Whilst this local plan has emerged alongside rather than after the development of the Arc Spatial Framework, it shares many of the overarching principles relating to a focus on climate change, economic growth and the natural environment..”
2.4 We agree that LP2040 should progress and not be delayed by the Arc Spatial Framework, but we do question whether the two plans will be aligned on the key matters, one of which is the plan period with the Arc Spatial Framework planning to 2050 yet the LP2040 to 2040. This approach is different to other authorities within the Arc which are aligning emerging plans for the period up to 2050, such as West Northamptonshire.