1.5

Showing comments and forms 1 to 30 of 91

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3792

Received: 26/08/2021

Representation Summary:

Support planning up to 2040.

However, the consultation is misleading in that supporting documents (transport models) refer to development up to 2050 (Dennybrook) and Taylor Wimpey have published a Vision Document for a new settlement (Dennybrook) on land west of Wyboston for 10,000+ houses up to 2050.

The 2,500 home settlement will actually be a TOWN of 10,000+ homes. We are not being asked to consider the first phase of a town?


This is:

Misleading.
Not clear and transparent.

Full text:

Support planning up to 2040.

However, the consultation is misleading in that supporting documents (transport models) refer to development up to 2050 (Dennybrook) and Taylor Wimpey have published a Vision Document for a new settlement (Dennybrook) on land west of Wyboston for 10,000+ houses up to 2050.

The 2,500 home settlement will actually be a TOWN of 10,000+ homes. We are not being asked to consider the first phase of a town?


This is:

Misleading.
Not clear and transparent.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3839

Received: 26/08/2021

Representation Summary:

Considering the numbers expressed in this proposal, these dates are far too soon considering the epic expansion and destruction of our local environment.

Full text:

Considering the numbers expressed in this proposal, these dates are far too soon considering the epic expansion and destruction of our local environment.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3885

Received: 28/08/2021

Representation Summary:

A decision now to start development on the Dennybrook site would inevitably prejudice future decisions about extending it. Planning to build 2,500 dwellings would establish a strong momentum towards developing the full 10,500. If part of it was already included in the 2040 Local Plan, the proposed new town would no longer be a greenfield project. The National Planning Policy Framework says that when a strategy includes new settlements, policies should be set within a vision covering at least 30 years: why is that not being done in this case?

Full text:

A decision now to start development on the Dennybrook site would inevitably prejudice future decisions about extending it. Planning to build 2,500 dwellings would establish a strong momentum towards developing the full 10,500. If part of it was already included in the 2040 Local Plan, the proposed new town would no longer be a greenfield project. The National Planning Policy Framework says that when a strategy includes new settlements, policies should be set within a vision covering at least 30 years: why is that not being done in this case?

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 3941

Received: 29/08/2021

Representation Summary:

Developers should not be submitting developments of enormous sizes that will take beyond 2040 to complete.

Full text:

Developers should not be submitting developments of enormous sizes that will take beyond 2040 to complete.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4043

Received: 30/08/2021

Representation Summary:

Sensible and realistic timescale

Full text:

Sensible and realistic timescale

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4152

Received: 30/08/2021

Representation Summary:

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF

Full text:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4204

Received: 30/08/2021

Representation Summary:

We agree with the Borough that the Government's methodology for calculating and allocating future demand for housing is flawed and overstates the number of units needed. This is likely to result in a disproportionate and economically unsustainable increase in housing provision and place serious strain on transport infrastructure and public services.

Full text:

We agree with the Borough that the Government's methodology for calculating and allocating future demand for housing is flawed and overstates the number of units needed. This is likely to result in a disproportionate and economically unsustainable increase in housing provision and place serious strain on transport infrastructure and public services.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4450

Received: 31/08/2021

Representation Summary:

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Full text:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that Bedford Borough Council have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4574

Received: 01/09/2021

Representation Summary:

2040 plan creates a good balance

Full text:

2040 plan creates a good balance

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4606

Received: 01/09/2021

Representation Summary:

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Full text:

I have severe Parkinson’s and cannot type easily. Please duplicate all of Staploe Parish Councils responses for my views.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4665

Received: 01/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4912

Received: 02/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4990

Received: 02/09/2021

Representation Summary:

The Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan, and to take account of paragraph 22 of the NPPF.

Full text:

The Council proposes a plan period to 2040. As noted, this will differ from the plan period for the Oxford-Cambridge Arc Spatial Framework (Arc Framework) which is to 2050. Given the Local Plan will need to demonstrate its consistency with the Arc Framework when it becomes national policy in 2023 in order to be found ‘sound’, the Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan. It could seriously undermine the delivery of national policy if they are not reflected in the Development Plan for Bedford Borough. Whilst it is acknowledged this is challenging given both Plans are being prepared simultaneously, effective and on-going joint working is integral to a positively prepared and justified strategy.

In any event, national policy now requires Councils should set a vision that looks at least 30 years ahead when allocating new settlements or significant extensions to existing villages and towns (paragraph 22 of the NPPF). Given the nature of the options presented in this consultation, it would be prudent for the Council to decide now to revise its Plan period to 2050.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5000

Received: 02/09/2021

Representation Summary:

The Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan, and to reflect paragraph 22 of the NPPF.

Full text:

The Council proposes a plan period to 2040. As noted, this will differ from the plan period for the Oxford-Cambridge Arc Spatial Framework (Arc Framework) which is to 2050. Given the Local Plan will need to demonstrate its consistency with the Arc Framework when it becomes national policy in 2023 in order to be found ‘sound’, the Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan. It could seriously undermine the delivery of national policy if they are not reflected in the Development Plan for Bedford Borough. Whilst it is acknowledged this is challenging given both Plans are being prepared simultaneously, effective and on-going joint working is integral to a positively prepared and justified strategy.

In any event, national policy now requires Councils should set a vision that looks at least 30 years ahead when allocating new settlements or significant extensions to existing villages and towns (paragraph 22 of the NPPF). Given the nature of the options presented in this consultation, it would be prudent for the Council to decide now to revise its Plan period to 2050.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5012

Received: 02/09/2021

Representation Summary:

The Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan, and to take account of paragraph 22 of the Framework.

Full text:

The Council proposes a plan period to 2040. As noted, this will differ from the plan period for the Oxford-Cambridge Arc Spatial Framework (Arc Framework) which is to 2050. Given the Local Plan will need to demonstrate its consistency with the Arc Framework when it becomes national policy in 2023 in order to be found ‘sound’, the Council should reconsider extending the Plan period to 2050 in order that the Arc Framework’s policies and proposals are fully reflected and captured in the Development Plan. It could seriously undermine the delivery of national policy if they are not reflected in the Development Plan for Bedford Borough. Whilst it is acknowledged this is challenging given both Plans are being prepared simultaneously, effective and on-going joint working is integral to a positively prepared and justified strategy.

In any event, national policy now requires Councils should set a vision that looks at least 30 years ahead when allocating new settlements or significant extensions to existing villages and towns (paragraph 22 of the NPPF). Given the nature of the options presented in this consultation, it would be prudent for the Council to decide now to revise its Plan period to 2050.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5224

Received: 03/09/2021

Representation Summary:

Catesby Estates object to the proposed plan period for the Local Plan Review. 2045 is the appropriate end period for the Local Plan Review.

Full text:

Catesby Estates object to the proposed plan period for the Local Plan Review.

2045 is the appropriate end period for the Local Plan Review. A plan period to 2040 would only represent an additional 10 years beyond the current adopted Local Plan period to 2030. This would be well below the minimum 15-year period required by the NPPF.
The Local Plan 2030 Inspectors Report identified the need for the Local Plan Review to respond appropriately to longer term requirements, in particular Arc growth ambitions. With the publication of the Government’s July 2021 consultation on the Spatial Framework for the Oxford-Cambridge Arc these ambitions are now starting to be established.

A plan period to 2045 is therefore considered fully justified. Planning for any less than this period will fail to represent positive planning.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5474

Received: 06/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5571

Received: 06/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5621

Received: 07/09/2021

Representation Summary:

Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Support

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5659

Received: 07/09/2021

Representation Summary:

Paragraph 1.5-1.7
Hallam Land Management supports the proposed Local Plan period of 2020-2040. Hallam considers that the period is most suitable for meeting a strategy that is enduring for accommodating growth across the Borough, in a way that meets the needs of the Borough and contributes effectively to growth ambitions of the Oxford Cambridge Arc. A longer-term plan period would allow the Borough Council to plan more appropriately for future strategic development allocations / locations which would in turn inform more strategic and longer-term infrastructure requirements.

Attachments:

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5674

Received: 07/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5710

Received: 07/09/2021

Representation Summary:

1.5 National Policy requires that strategic policies in local plans should look ahead over a minimum of 15 years from adoption[1]. With adoption planned for late 2023, the shortest end-date for this plan would be 2038. A longer timescale would have the advantage of giving certainty for a longer period but, as is explained in the paragraphs below, many important strategic decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and longer term are likely to be made in the next few years. As a result, and having considered the 2020 consultation responses, the Council's view is that 2020 - 2040 is an appropriate time period for this plan. With a requirement now for five-yearly local plan reviews there will be sufficient opportunity to plan beyond 2040 once the regional planning context is clearer.

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5746

Received: 07/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15-year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
100-word Summary
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements, they should be planning at least 30 years ahead according to the NPPF.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5833

Received: 08/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
100 word summary
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5900

Received: 08/09/2021

Representation Summary:

The plan period should align with the Ox-Cam Arc proposed period, when this is defined by HMG.
Within the proposed plan period to 2040, the options that BBC put forward for consideration in the consultation should correctly reflect the build-out proposals for the various sites.
The consultation fails to do this and is therefore MISLEADING and FLAWED.
This is evidenced by the Dennybrook development where BBC state that 2,500 dwellings will be built by 2040. The developer plans to build out 5,150 dwellings by 2040 as recorded by BBC on their Call for Sites form 977. Ultimately the developer plans to build out 10,800 dwellings. This should be clear in the consultation or the Plan period should be extended to correctly reflect the build-out timescales.
Interestingly the BBC/AECOM transport studies appear to correctly reflect the full development to 2050. So why is the “hidden” detail correct, but the public headline information incorrect? This indicates either an error, or BBC are deliberately being MISLEADING in their public information?

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5951

Received: 08/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
100 word summary
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 5993

Received: 08/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6087

Received: 09/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6107

Received: 09/09/2021

Representation Summary:

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.
3.3 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.
3.4 The proposed plan period of 2020 to 2040, particularly when read in the context of the Council’s draft strategy could result in a further delay in meeting development needs in full (until at least 2030). This will generate a requirement for further, successive, reviews; and is setting the plan up to fail both in terms of overall supply and also the spatial distribution which will not allow a clear vision for planned growth in the villages that will be necessary to deliver the scale of growth needed. This includes parishes such as Wootton located within the A421 corridor.
3.5 Significant extensions to existing villages and towns that form part of the strategy for an area should be set within a vision that looks further ahead (at least 30 years) rather than the minimum 15 year time horizon from the date of adoption of a local plan.
3.6 Given Bedford’s location in the Ox-Cam Arc a 30 year horizon is essential where paragraph 1.2 of the ‘Creating a Vision for the Ox-Cam Arc’ consultation document 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.
3.7 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.
Remedy
3.8 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 draft strategy relying on larger-scale development including New Settlements and rail-based growth should be profiled to look further ahead to 2050.
3.9 This reemphasises that in terms of the soundness requirements, the Council must 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. Village-related growth in the ‘south’ corridor parishes is complementary this approach and the benefits of early delivery.
Remedy
3.21 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
3.22 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.
3.23 Policy 3S of the Bedford Local Plan 2030 sets out the spatial strategy. Through criteria (vi) this directs strategic scale residential development to Key Service Centres to be allocated through Neighbourhood Plans prepared in accordance with Policy 4S. While Wootton is not listed amongst the Key Service Centres in Policy 4S it is addressed in criteria (iv) of Policy 3S, with the spatial strategy providing for:
“The completion of Wixams new settlement and strategic urban and village extensions to the west of Bedford, at Wootton, Stewartby and Shortstown”
3.24 This reflects the background to the strategy selected in the LP2030. More detail is provided in the BBC ‘Development Strategy and Site Selection Methodology’ (September 2018). In the second Pre-Submission version Local Plan this explains (at paragraph 4.7) the exclusion of Wootton from further allocations through NPs to be prepared due to “significant recent and ongoing expansion of about 1,300 dwellings.”
3.10 Paragraph 6.14 of the LP2030 emphasises the Key Service Centres demonstrate a strong service role for local communities, and this includes Wootton. Paragraph 6.17 sets out that the scale of growth should have regard to the capacity of existing infrastructure. For Wootton, this takes account of the 1,300 units referred to above.
3.11 However, the process for the preparation of Policy 3S/4S in the adopted Bedford Borough Local Plan 2030 needs to take account of its background, namely:
• It was prepared and submitted for Examination under the requirements of the NPPF 2012;
• The Plan’s objectively assessed housing need falls significantly short of local housing need calculated using the standard method, with Bedford Borough Council expressly aware of this in dictating the timing for submission of the Plan
•The Plan has a significantly foreshortened plan period covering less than 10 years from its adoption in 2020.
3.12 The evidence base for site assessment and site selection does not indicate a lack of capacity for further significant sustainable growth adjacent or well-related to the Settlement Policy Area in the medium term. Earlier rounds of plan-making (prior to shortening the plan period to 2030 and summarised in the Development Strategy Topic Paper) recognised that for Wootton:
• growth in Wootton, Shortstown, Wixams and Stewartby should be limited until after current commitments have been completed. (paragraph 2.15); and
• identified a provisional requirement for Wootton of 250 to 350 units to be provided later in the plan period post-2025 (Table 2)
3.13 These circumstances are now borne out in details of the emerging Draft Plan Strategy Options for the Local Plan 2040, which identifies a significant potential for growth at Wootton and is a material consideration for the emerging WNP.
3.14 With the publication of the emerging Draft Plan Strategy Options review Local Plan 2040, the emerging WNP is already seeking to pre-empt the decision making on the updated strategy without taking account of future policy conflicts. Conflicting policies from the WNP will potentially undermine the objectives of the Plan through not allocating sufficient sites to give flexibility to housing delivery.
3.15 Planning Practice Guidance specifies that although a draft neighbourhood plan or Order is not tested against the policies in an emerging local plan the reasoning and evidence informing the local plan process is likely to be relevant to the consideration of the basic conditions against which a neighbourhood plan is tested (ID: 41-009-20190509). This is an area that should be the subject of discussion between the qualifying body and local planning authority.
3.16 Policy 1 of the Bedford Local Plan 2030, which requires that a new Local Plan containing policies to meet housing need calculated in accordance with the government’s standard method be submitted for Examination before February 2023, dictates that conflict between relevant strategic policies and the emerging WNP is to be anticipated. These circumstances are likely to take effect earlier than two years after any NP for Wootton is ‘made’. NPPF2021 paragraph 14 would therefore be disengaged on the grounds that criterion (b) (policies and allocations sufficient to meet the housing requirement) is no longer satisfied.
3.17 The strategic direction of the Draft Plan Strategy Options for the Local Plan 2040 continues to recognise the sustainable role and function of Key Service Centres and their capacity for growth whilst seeking to focus the provision of growth through strategic sites and corridors, together with the urban area of Bedford. Wootton is therefore well-related to the Council’s Preferred Options and provides a critical opportunity to contribute towards increased housing needs in the short and medium-term.
3.18 Wootton clearly falls into accommodating greater quantum of growth in this strategy and therefore a review of WNP will be required to consider how it would maintain general conformity with the emerging strategy.
3.19 The consideration of reserve sites as part of the ongoing WNP Examination would be a move towards the flexibility in adherence to the new Local Plan and the published growth options.
3.20 This becomes especially relevant when consideration is given to the ability to accommodate strategic infrastructure associated with growth (include progress with East-West Rail). Growth in the ‘south’ corridor parishes to complement these strategic opportunities, through recognising the longer-term role of sustainable Key Service Centres including Wootton to sustain and enhance their function, reflects the ability to expand and utilise social and community infrastructure at all locations suitable to address housing need within the corridor.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6134

Received: 09/09/2021

Representation Summary:

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, the plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘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.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.