1.5

Object

Representation ID: 6191

Received: 09/09/2021

Respondent: Peter Coles

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

Representation ID: 6237

Received: 09/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

Plan Period
2.19 Turning to the matter of Plan length AWG contend that the Plan Period should
run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan
and is not a sufficiently long enough extension to effect real change.
2.20 As the Council will be aware, strategic growth and development, along with
wide scale change, takes many years to deliver. Sites take a long time to plan
correctly and then commence delivery, and thus a longer Plan Period should be
allowed for.
2.21 Furthermore, by extending to 2050, this would bring the Plan in line with others
in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the
strategic and important role that Bedford Borough plays within the Arc, it would
represent ‘good planning’ and a holistic approach to align the Local Plan
Period with those other areas. The next review of the Local Plan would then
not need to extend the Plan Period, but instead revise housing and employment
growth to reflect the latest position as relevant at that time.

Object

Representation ID: 6242

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

National Context and Plan Period
Paragraphs 1.5 to 1.52 of the Strategy Option and Draft Policies consultation document set out the national context and the Council’s reasoning for extending the plan period to 2040.
Paragraph 22 of the NPPF sets out that 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. The current indicative timetable aims for the Plan to be adopted at the end of 2023. The Council acknowledges that a longer timescale would have the advantage of giving certainty for a longer period, however, there are 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 that are likely to be made in the next few years. We therefore agree that the plan period is appropriate in these circumstances.
The Arc Spatial Framework is also currently in preparation, with the first stage “Creating a vision for the Oxford-Cambridge Arc” currently ongoing until 12th October 2021. The Framework is expected to be implemented at the end of 2022 or at the start of 2023 (at a similar time or a little earlier than the expected examination/adoption of the BBLP 2040). The Council recognise that the Local Plan and Framework share many overarching principles relating to economic growth and the natural environment. We agree with the Council’s commitment to support the expansion of existing businesses and to attract inward investment and to make provision for significantly more homes as described in the Arc joint declaration. The current consultation is at a very high level, however, it outlines the overall commitment of the Framework. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself. The government will undertake additional Arc consultations on any specific proposals for such options as appropriate. The Spatial Framework will guide the future growth of the Arc to 2050, including on the question of new housing and infrastructure and will, as part of its development, take into consideration any significant new housing and infrastructure coming forward to meet the Arc‘s ambition. It is therefore vital that the Council work alongside the Oxford-Cambridge Arc to ensure the BBLP 2040 and the Spatial Framework align as far as possible. As the timescales for the preparation and submission of the BBLP 2040, do not allow the plan making process to follow the publication of the Spatial Framework, we would encourage to Council to commit to a further early review to ensure that the Borough’s Local Plan remains aligned with the Spatial Framework and to be able to fully take advantage of and support the opportunities brought to the Borough by the Oxford-Cambridge Arc.

Object

Representation ID: 6283

Received: 10/09/2021

Respondent: Mr Paul Zwetsloot

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

Representation ID: 6294

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

Our client objects to paragraph 1.5 as drafted on the basis of soundness concerns with the proposed approach (not consistent with national policy; and not effective).
The 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.
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.
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.
imescales 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.
Please refer to our supporting representations for further information.

Object

Representation ID: 6334

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

The most recent version of the National Planning Policy Framework was published in July 2021, following commencement of the Council’s Preferred Options consultation. The changes were published in draft format in January 2021 (including those relevant to the plan-making framework) and thus available for the Council to consider.
These representations highlight four important components of the 2021 Framework and the changes they necessitate for the scope of the review, relative to the 2012 version of the Framework against which the current Local Plan 2030 was assessed. Other specific provisions of the Framework and NPPG are referred to in comments relating to detailed elements of the consultation proposal.
Firstly, Paragraph 22 of the NPPF2021 confirms that strategic policies should look ahead over a minimum 15-year period from adoption and anticipate long-term requirements. This is a significant change from paragraph 157 of the 2012 Framework that specified that policies should be drawn up over an appropriate timeframe and only preferably a 15-year horizon.
Secondly, the second paragraph of NPPF2021 Paragraph 22 is a significant addition following the most recent revisions. This requires that policies should address a vision that looks further ahead (at least 30 years) where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area. The transitional arrangements for these provisions at Annex 1 confirm their application to the preparation of all Plans except those that have already undergone consultation on the Submission version Plan. The Oxford-Cambridge Spatial Framework is also seeking to cover the period to 2050 (i.e., 30 years).
The Council’s Preferred Options clearly anticipate reliance on these approaches to growth and the associated implications in terms of extended timescales for development. None of the Council’s Preferred Options set out the proposed approach beyond a 20-year horizon. As a result, detailed policies for the scale and distribution of growth cannot be considered consistent with national policy without significantly extending their scope alongside provision for the other requirements of sustainable development.
hirdly, the requirements of Policy 1 of the Local Plan 2030 accord with the circumstances outlined at Paragraph 33 of the NPPF2021 where a significant change in circumstances is identified as a result of the calculation of local housing need. Paragraph 61 of the NPPF2021 outlines that minimum annual local housing need should be calculated using the government’s standard method. This is translated into the requirements against which plans must be assessed for soundness in terms of ensuring they are positively prepared and seek to meet needs in full (see NPPF2021 paragraph 35 and footnote 21) alongside the consideration of unmet needs from neighbouring areas. NPPF2021 paragraph 31 also emphasises the importance of considering relevant market signals.
The NPPG provides further clarification that the standard method does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Circumstances where it may be appropriate to plan for a higher housing need figure than the standard method indicates include any growth strategies for the area and strategic infrastructure improvements that are planned for (ID: 2a-010-20201216).
The Council accepts that there are no exceptional local circumstances that justify deviating from the standard method but the Preferred Options do not assess any alternative approach identifying a higher need than calculated by the standard method (that will typically be considered sound) (ID: ID: 2a-015-20190220). The assessment of market signals should include expected changes in the labour market, engagement with stakeholders for economic development and changes that may affect the anticipated population and local housing stock (ID: 2a-027-20190220).
Finally, Paragraph 35 of the NPPF2021 confirms that the criteria for the assessment of soundness have changed since the 2012 Framework. In order to provide for a justified approach the policies for the Plan must provide for ‘an appropriate strategy’ rather than the ‘most appropriate’ strategy when assessed against reasonable alternatives. Paragraph 32 of the NPPF2021 provides further detail on the basis for assessing the proposed strategy in terms of seeking net gains for sustainable development and ensuring that the Plan has addressed relevant economic, social and environmental objectives.
In summary, there is no longer any support in national policy for the outcomes of the Local Plan 2030 Examination in terms of pursuing constraints to the plan period and overall level of growth and deferring decisions on key components of approaches to meet strategic priorities for the area (particularly in terms of overall housing need (including affordable housing) and the delivery of social and community infrastructure (including health and education).

Support

Representation ID: 6364

Received: 13/09/2021

Respondent: CPRE Bedfordshire

The proposal to set the timescale for the plan to 2040 is supported. A 2040 plan creates a good balance by establishing a longer-term strategic perspective, alongside the recognition that strategic policies need to show the required agility to respond to evolving economic and social conditions.

Support

Representation ID: 6397

Received: 13/09/2021

Respondent: Ms Donna Thompson

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

Representation ID: 6412

Received: 13/09/2021

Respondent: Mr Steven Kent

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

Representation ID: 6503

Received: 13/09/2021

Respondent: Manor Oak Homes

Agent: Armstrong Rigg Planning

National context and plan period (paragraph 1.5)
A key point that the Council will need to address, and one that has admittedly arisen since the beginning of the consultation period, is the requirement set out at paragraph 22 of the new National Planning Policy Framework (NPPF, published 20th July 2021) which provides an expectation for local plans which encompass strategic scale development to include a vision looking ahead for the next 30 years. The new text states:
“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.”
This policy is subject to a transitional arrangement and applies only to plans that had not reached Regulation 19 (pre-submission) stage at on 20 July (or equivalent stage for Spatial Development Strategies). In which case it is applicable to the emerging Local Plan 2040. It is noted that the Government has decided against defining ‘larger-scale development’, instead concluding that this will depend on context, scale and setting and should be decided locally and tested at examination. Examples provided within the policy, however, include new settlements and large-scale extensions of existing settlements. On review of the spatial options set out at Section 3 of the consultation document this very much describes the types of development opportunities being explored by the Council.
The question which is therefore presented to the Council is whether this has any direct implications on both the plan period (currently 2020 to 2040 but plausibly should now be extended to 2050) and whether this has any additional impact on the growth targets set by the plan. Admittedly the response required by the Council is yet to be clarified in accompanying guidance (the Government’s Planning Practice Guidance is still to be updated). However, plausibly, there may now be a necessity to update the housing and jobs targets to cover an extended period beyond 2040. This could potentially increase the level of new homes to be delivered by the plan by up to 13,500 units (the current Local Housing Need figure over ten years plus a 5% uplift), although it is unclear what the repercussions on the extension of the vision would have on the objectively assessed needs to be planned for.
What is evident is that the same option no longer exists to the Council to arbitrarily shorten the plan period to address issues in respect of long-term delivery, a move taken prior to the adoption of the Local Plan 2030 and one which we maintain has now presented significant pressure on the Council to significantly increase housing delivery across the Borough in the short term (the first 5 years of the new plan period). The plan must include a positive and ambitious approach to the delivery of new homes from the very first year of the plan period to ensure a pipeline is in place to guarantee growth for the next 30 years.
What we do consider is now of critical importance in the preparation of the current plan is showing that the strategic sites to be included within it are demonstrably developable (that is there would be a reasonable prospect that they will be available and could be viably developed at the point envisaged). This issue must be met head on by the Council this time around. Indeed, the implications of paragraph 22 of the new NPPF would have resulted in a dramatically different outcome to the Local Plan 2030 which could realistically have embraced our client’s land as an allocation at that stage, a step which would have seen it delivering houses now. The problems faced in respect of the defunct Colworth village proposals aside, and despite the positive resolution of the Inspectors presiding over the examination of the Local Plan 2030, it is our view that there were (and remain) significant gaps in the evidence base surrounding how and when some of the Council’s strategic sites are to be delivered (Land South of the River and Ford End Road continue to represent sites of significant concern to our client).

Object

Representation ID: 6520

Received: 13/09/2021

Respondent: Mrs Susan Trolley

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

Representation ID: 6579

Received: 14/09/2021

Respondent: Mr Aiden Farmer

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.

1.5 100 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

Representation ID: 6625

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

The Draft Strategy Options were prepared ahead of the publication of the revised NPPF in July 2021, which introduced the requirement at Paragraph 22 for Local Plans which include new settlements or significant extensions to towns/villages, to be set within a vision which looks at least 30 years ahead. As the current aim is to plan to 2040, this requirement will not currently be met.
This policy requirement will apply to the Bedford Borough Local Plan review, given the options presented and it is therefore likely that the Council will need to undertake additional work to establish a longer-term vision within which the policies for the Local Plan 2040 can be set.
As is discussed in response to other aspects of the plan, given the constraints to development around the immediate edge of Bedford, combined with the level of development that will need to be accommodated in the Borough, the Council are rightly giving due consideration to a new settlement as part of the development strategy. This is likely to be combined with significant growth in the A421 corridor and around the southern stations. Given the key role that this corridor to the south of Bedford up to the A1 in the east will play in the period to 2040 and beyond, it is suggested that further visioning work may need to be undertaken specifically for this area to meet the requirements of the NPPF.
The revised Denybrook Vision Document accompanying these representations sets out the vision for delivery of the Denybrook proposal both up to and beyond the current plan review period of 2040. The vision is then underpinned in highway and access terms by the accompanying technical representations which sets out the approach to delivery up to and beyond the currently proposed Local Plan Review period to 2040.

Object

Representation ID: 6701

Received: 14/09/2021

Respondent: Mrs Elizabeth Froude

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

Representation ID: 6739

Received: 14/09/2021

Respondent: Ms S Kelly

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

Representation ID: 6791

Received: 15/09/2021

Respondent: Mr Damian Smith

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.

Support

Representation ID: 6839

Received: 13/09/2021

Respondent: Mrs Joanna Ibbett

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

Representation ID: 6878

Received: 15/09/2021

Respondent: Master Corey T Farmer

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

Representation ID: 6970

Received: 16/09/2021

Respondent: Mr Robert Tusting

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

Representation ID: 7008

Received: 17/09/2021

Respondent: Mr Robert Tusting

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

Representation ID: 7059

Received: 09/09/2021

Respondent: June Coles

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

Representation ID: 7106

Received: 09/09/2021

Respondent: Stephen Coles

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

Representation ID: 7186

Received: 17/09/2021

Respondent: Mr Peter Knight

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.

Support

Representation ID: 7273

Received: 01/09/2021

Respondent: Miss Laura Jones

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.

1.5 100 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

Representation ID: 7333

Received: 02/09/2021

Respondent: Miss Becky Browning

he 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.

1.5 100 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

Representation ID: 7390

Received: 02/09/2021

Respondent: Mr Simon Goodship

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.

1.5 100 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.

Support

Representation ID: 7439

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

With a holistic appreciation of the draft LP, since its publication, the Government have
published an updated and revised National Planning Policy Framework (July 2021).
Having reviewed the document in the context of this new publication, the LP appears
to be largely in alignment with its content. However, references within later iterations
of the emerging DPD will need to be revised to reflect the most up to date national
policy. It is also urged that the Council remain mindful of the progression of the
Government’s agenda for planning reform.

Support

Representation ID: 7451

Received: 03/09/2021

Respondent: Phillip C Bath Ltd

Agent: DLP Planning Limited

Emerging Oxford Cambridge Arc Spatial Framework
The proposed Oxford-Cambridge Spatial Framework will have the status of national policy and is intended to form a material consideration for plan-making alongside the National Planning Policy Framework.
The government is currently seeking view on priorities for the Framework as part of consultation on the document ‘Creating a Vision for the Oxford-Cambridge Arc’ (until October 2021). The latest consultation proposals set out that it will aim to guide sustainable planning and investment decisions under four policy pillars:
• the environment;
• the economy;
• connectivity and infrastructure; and
• place-making.
The current consultation follows publication of an initial policy paper in February 2021 setting out the approach to developing the Framework. Paragraphs 2.10 and 2.11 of the policy paper set out in terms of the strategy for housing and planning in the Arc the role of the Framework will not be to make site allocations or to include detailed policies set elsewhere in national policy or better left to local plans (including for example, setting out the housing requirement). However, the policy paper emphasises the importance of meeting housing needs in full (including the delivery of affordable housing) and therefore relies on the calculation of minimum annual local housing need in accordance with the standard method as its starting point. Opportunities to increase levels of development above this minimum starting point are clearly anticipated as part of the Framework’s aspirations to support economic development and ensure a balance between the delivery of new jobs and homes (see paragraph 2.6).
Paragraph 3.8 of the policy paper sets our that the government expects: “ local planning authorities to continue to develop local plans before the publication of the Spatial Framework. These changes will sit alongside wider planning reforms, and as we take forward our response to the ‘Planning for the Future’ consultation, we will outline transitional arrangements and the role of the Spatial Framework within any new system.”
The development of the Spatial Framework will be supported by two further public consultations: Towards a Spatial Framework (Spring 2022) and Draft Spatial Framework (Autumn 2022). It is the government’s intention to commence implementation of the Spatial Framework throughout 2023, meaning its policies are expected to be in place as a material consideration at the same point the Bedford Local Plan 2040 is undergoing Examination.

Object

Representation ID: 7483

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

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.

1.5 100 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.

Support

Representation ID: 7550

Received: 03/09/2021

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

The most recent version of the National Planning Policy Framework was published in July 2021, following commencement of the Council’s Preferred Options consultation.
In summary, there is no longer any support in national policy for the outcomes of the Local Plan 2030 Examination in terms of pursuing constraints to the plan period and overall level of growth. Paragraph 20(c) of the NPPF2021 seeks to ensure sufficient provision towards the need for development as part of the approach to preparing strategic policies in order to meet strategic priorities for the area (particularly in terms of the delivery of social and community infrastructure (including health and education).
The National Planning Policy Framework (NPPF) is clear that the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities (paragraph 92). Planning policies should plan positively for social, recreational and community facilities, including supporting the delivery of local strategies to improve well-being and panning positively for the provision and use of shared spaces, including open space (paragraph 93).
In particular the Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. To this end local planning authorities are required to take a proactive, positive, and collaborative approach to meeting this requirement, and to development that will widen choice in education (paragraph 95). This means giving great weight to the need to create, expand or alter schools, and being able to work with schools and promoters to identify and resolve key planning issues before applications are submitted.
National Planning Practice Guidance sets out the importance forward planning for the delivery of school places and understanding the direct impact of new development when assessing the potential to secure developer contributions, which are not in principle replaced by alternatives through government funding or delivery programmes (ID: 23b-007-20190315).
In determining when contributions are required it is important for Plans to support the efficient and timely creation, expansion, and alteration of high-quality schools. Plan-makers should consider existing or planned/committed school capacity and whether it is sufficient to accommodate proposed development within the relevant school place planning areas (ID: 23b-008-20190315).
Relationship with the Existing Development Plan – The Bedford Local Plan 2030 and Oakley Neighbourhood Plan
Current provision within the development plan singularly fails to recognise the requirements of up-to-date policy and guidance in terms meeting the requirements for growth in school places across the borough and particularly to support increased provision at Oakley required by existing development commitments.
Local Plan 2030 does contain proposed strategic policies that seek to prioritise meeting education needs as a strategic priority and a requirement for sustainable development, but these do not specifically address the circumstances at Oakley. Policy 3S(vii) applies specifically in relation to Key Service Centres, looking to ensure that education provision is expanded where necessary. Policy 90S deals with infrastructure delivery and ensuring that the Council works with developers to find the most appropriate and beneficial solution. While these policies provide ‘some’ support in principle to deliver the required expansion in school places, they do not reflect the role, function, and importance of Lincroft Academy.
As such, there is no requirement in adopted strategic policies to support bringing forward development that properly reflects the Academy’s current requirements, which were not captured in the evidence base for the Bedford Local Plan 2030 (including the Infrastructure Delivery Plan). As such, the issue has been deferred rather than dealt with through the Local Plan 2030.
As a result, the Oakley Neighbourhood Plan also avoids setting out any policy approach to facilitate the future expansion and enhancement of the facilities at Lincroft Academy.
The submission Neighbourhood Plan includes amongst its objectives a need to “maintain a sustainable community, including a sustainable business community, with adequate infrastructure and facilities” but does not indicate how this will be achieved for non-residential uses.
Policy BE2 seeks to support retail and community facilities ‘within the centre of Oakley’, indicating that such a boundary is delimited by Station Road therefore precluding use of land to the east of this. Particularly for educational uses the Plan states:
“The largest single employer in the parish is Lincroft School which also serves several surrounding parishes. Along with Oakley Primary School it provides a prime focus for the community but also is the source of significant traffic issues.”
There is no policy provision to recognise constraints on the existing use and capacity at the current school site and associated playing pitch facilities as a key component of community infrastructure requiring upgrade and expansion.
CMAT supports the recognition of the current and future land use and operational requirements of Lincroft Academy arising from the Examination of the Oakley Neighbourhood Plan, with the proposed designation of the Lovell Road Playing Fields as a Local Green Space having been rejected by the Examiner. The Examiner’s Report records that imposing an additional layer of protection would have unduly limited Lincroft Academy in terms of future uses of the site and notes:
“The playing fields are separated from the main part of the school buildings and Lincroft Academy wishes to reorganise its land parcels to enable the growth and efficient functioning of the school. In addition, Oakley Football Club has indicated that it is looking for flexibility in case a better site should come forward for the Club’s use. The designation of the site as LGS would limit the future options for the school in that reorganisation.”
Notwithstanding the longstanding issues with congestion on Station Road, the Oakley Neighbourhood Plan further notes that the requirements of existing organisations should be considered when assessing future proposals for development. This recognises that fulfilling the provision of community infrastructure (including education and school places) may mean it is not possible to alleviate all traffic issues raised as concerns with the Neighbourhood Plan.
Relationship with the Emerging Plan
CMAT would welcome further engagement with the Council regarding the strategic priorities for education associated with the current requirements of Lincroft Academy and future levels of growth in Oakley and surrounding settlements. It is considered essential that delivery of these requirements is supported through the policies and allocations of the Plan.