1.5

Support

Representation ID: 7592

Received: 01/09/2021

Respondent: Miss Nicola Tagg

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: 7794

Received: 03/09/2021

Respondent: Mr Emilio Meola

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: 7834

Received: 03/09/2021

Respondent: Mr Mark 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: 7921

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

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: 7995

Received: 24/09/2021

Respondent: Mr Larry Gooch

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: 8042

Received: 24/09/2021

Respondent: North Northamptonshire Council

The NN JPC response to the Issues and Options consultation suggested that consideration should be given as to whether an end date of 2050 for the new BBC Local Plan to align with the Arc would be beneficial. It is noted that the Draft Plan end date is still 2040, however it is recognised that para 1.5 of the Plan states “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” and the context of the Arc is well considered throughout.

Within the context of the above, it is noted that the Arc Spatial Framework (ASF) sets out at para 5.3 of the ‘Creating a vision for the Oxford-Cambridge Arc’ consultation document that in parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. 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. In relation to this, it is also noted that an advisory panel for the Arc has been set up to explore potential opportunities for sustainable and economic growth in the Arc, with the Bedford-Cambridge area as its primary focus. From this, it is likely that the route of E-W rail between Bedford-Cambridge will be a potential location for new settlements, which will influence the longer-term development within Bedford Borough in future local plans. NNC will continue to engage in plan-making through the Duty to Cooperate to ensure ongoing consideration of cross-boundary issues.

Support

Representation ID: 8054

Received: 03/09/2021

Respondent: Mr Henry Vann

This Local Plan is being written in the context of a dramatic destruction of local democratic voice in the planning process proposed as part of the Conservative Government’s Planning White Paper proposals and as a central part of their programme of Government.
Claims that local government stops development are false. But it is true that the planning system, set out by the Government, benefits large developers at the expense of infrastructure, health, education and sustainable transport and, fundamentally, local residents.

Object

Representation ID: 8101

Received: 03/09/2021

Respondent: Dr Emma 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.
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: 8140

Received: 03/09/2021

Respondent: Mr Ross Thomson

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.
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: 8177

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

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: 8238

Received: 03/09/2021

Respondent: Mr Daniel Francis

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: 8282

Received: 03/09/2021

Respondent: Miss Erin Francis

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: 8325

Received: 03/09/2021

Respondent: Mrs K Francis

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: 8407

Received: 03/09/2021

Respondent: Axis Land Partnership

Agent: Strutt and Parker

on
cross-boundary strategic matters that have been dealt with rather than deferred, as
evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable
development in accordance with the policies in this Framework and other
statements of national planning policy (emphasis added), where relevant.
2.5 These tests need to be applied in a proportionate way to ensure they are consistent with
strategic relevant policies for the area.
2.6 The NPPF notes that:
Significant development should be focused on locations which are or can be made
sustainable, through limiting the need to travel and offering a genuine choice of transport
modes. This can help to reduce congestion and emissions, and improve air quality and
public health (paragraph 105).
9
2.7 It advises that, when assessing sites that may be allocated, or specific applications for
development:
(a) appropriate opportunities to promote sustainable transport modes can be – or have
been – taken up, given the type of development and its location;
(b) safe and suitable access to the site can be achieved for all users;
(c) the design of streets, parking areas, other transport elements and the content of
associated standards reflects current national guidance, including the National
Design Guide and the National Model Design Code: and
(d) any significant impacts from the development on the transport network (in terms of
capacity and congestion), or on highway safety, can be cost effectively mitigated to
an acceptable degree (paragraph 110).
2.8 NPPF further advises (at paragraph 112) that, for development proposals, priority should
be given first to pedestrian and cycle movements, and second – so far as possible – to
facilitating access to high-quality public transport. However, it also recognises (at
paragraph 105) that opportunities to maximise sustainable transport solutions will vary
between urban and rural areas, and this should be taken into account in both plan-making
and decision-making.
2.9 In respect of heritage matters Paragraph 189 notes that:
“These assets are an irreplaceable resource, and should be conserved in a manner
appropriate to their significance, so that they can be enjoyed for their contribution to the
quality of life of existing and future generations.”
2.10 Paragraph 202 goes on to state:
“Where a development proposal will lead to less than substantial harm to the significance
of a designated heritage asset, this harm should be weighed against the public benefits
(emphasis added) of the proposal including, where appropriate, securing its optimum
viable use.”
Oxford-Cambridge Arc Spatial Framework
2.11 In July 2021 the Government published a consultation document which set out how they
intend to develop a Spatial Framework for the Oxford – Cambridge Arc. The spatial
framework is intended to provide a vision for the Arc to guide future growth in the area to
2050. To ensure that sustainability is embedded in the spatial framework the consultation
also includes a scoping report in respect of the sustainability appraisal. The Arc covers
the county council areas of Oxfordshire, Buckinghamshire, Bedfordshire,
Northamptonshire and Cambridgeshire. Once approved the spatial framework will form
national planning policy and transport policy for the Arc and local planning and local
transport authorities must have regard to it when preparing local transport and local
development plans and policies. It will also be a material consideration in the
determination of planning applications in the area. This will be the first regional planning
10
policy document to be prepared since the abolition of regional plans which signals the
importance that the Government attributes to the Arc.
2.12 The Arc is a national economic priority area which the Government believes has the
potential to be one of the most prosperous, innovative and sustainable economic areas in
the world, and can make a major contribution to national economic recovery following on
from the impact of COVID-19.
2.13 It is intended that the framework will facilitate better planning for economic growth,
supported by new homes and infrastructure, and deliver more sustainable results. It is
intended that it will inform development plans.
2.14 The current consultation closes on 12th October 2021 following which a vision and issues
and options consultation will be published in spring 2022. The finalised spatial framework
will be published for consultation in autumn 2022 with implementation of the final
Framework shortly after.

Object

Representation ID: 8418

Received: 03/09/2021

Respondent: Mr Theodore Cassell

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: 8423

Received: 27/09/2021

Respondent: Mrs G Hunt

Agent: DLP Planning Limited

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.
Reasoning
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.

Remedy
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 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.

Object

Representation ID: 8502

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

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.
Reasoning
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.
Remedy
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 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. This can be enabled through recognising the increased benefits of Preferred Option 2d. This enables the prioritisation of suitable and deliverable sites within the ‘east’ corridor parishes (including Great Barford) and more widely recognising village-related growth as part of a ‘hybrid’ strategy.

Object

Representation ID: 8525

Received: 03/09/2021

Respondent: Mrs Claire francis

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: 8576

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

2.21 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.
2.22 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.
2.23 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.

Support

Representation ID: 8597

Received: 13/09/2021

Respondent: Mr Henry 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: 8648

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

3.1 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.
Reasoning
3.2 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.
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 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.
Remedy
3.5 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.
3.6 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
3.7 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.

Support

Representation ID: 8664

Received: 13/09/2021

Respondent: Mr J Francis

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: 8707

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

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.
Reasoning
3.3 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.
3.4 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.
3.5 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.
Remedy
3.6 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.
3.7 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
3.8 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. This can be enabled through recognising the increased benefits of Preferred Option 2d. This enables the prioritisation of suitable and deliverable sites within the ‘east’ corridor parishes (including Great Barford) and more widely recognising village-related growth as part of a ‘hybrid’
strategy.

Object

Representation ID: 8727

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

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: 8756

Received: 29/09/2021

Respondent: Staploe Parish Council

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: 8868

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraph 1.5 (proposed plan period)– Object
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.
Reasoning
3.3 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.
3.4 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.
3.5 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.
Remedy
3.6 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.
3.7 Those parts of the Council’s Preferred Options relying on larger-scale development should be profiled to look further ahead to 2050.
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
12
3.8 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. This reinforces the benefits of village-related growth in the ‘east’ corridor parishes.

Object

Representation ID: 8916

Received: 01/10/2021

Respondent: Mr James Browning

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: 8924

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

Comments on Strategy Options / Proposed Approach and Supporting Evidence
Paragraph 1.5 (proposed plan period)– Object
3.2 Definition of the proposed plan period underpinning the LP2040 has been rendered inconsistent with national policy following publication of the NPPF2021.
Reasoning
3.3 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) than the minimum 15 year time horizon from the date of adoption of a local plan.
3.4 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.
3.5 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); 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.
Remedy
3.6 Bedford Borough Council should not wait for transitional arrangements upon introduction of the Ox-Cam Arc Spatial Framework and then undertake yet another review as this will generate continued uncertainty and delay. Realistically, as a result of the scale and pattern of the proposed in the LP2040 consultation, delays to timescales for development will likely result in failure to meet needs in full between 2030 and 2040.
3.7 Those parts of the Council’s draft strategy relying on larger-scale development including growth that is significant in relation to existing settlements should be profiled to look further
ahead, to 2050.
3.8 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.

Object

Representation ID: 8988

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Comments on the Proposed Approach and Supporting Evidence
The section of the representations provides observations on the soundness of the Council’s
overall approach towards preparation of the Local Plan 2040 and identification of the strategic
priorities it is required to address. Comments specifically relate to Chapters 1 and 2 of the
consultation document.

Paragraph 1.5 (proposed plan period)– Object
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.

Reasoning
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.

Remedy
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 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.

Object

Representation ID: 9056

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

1.3. As the Draft Local Plan explains, there still is not sufficient clarity about the implications of the Arc for Bedford Borough and its neighbours including that there is no information regarding housing numbers. BBC stresses the critical need for ‘collective determination over the long-term’ to plan and deliver the right quality and in the right places to meet it needs. BBC explains that it might include the expansion of existing settlements and new settlements but that it will require ‘long-term commitments to provide the enabling infrastructure and to deliver that ahead of the arrival of new communities’. Despite this clear stated need for collective determination for planning at a ‘larger than local’ scale, there is no evidence provided by BBC on how it has worked with any of its neighbours or Duty to Cooperate prescribed bodies which contradicts BBCs identification of the critical need for joint working on what are very complex issues.
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.”3
“The declaration itself is silent on housing numbers. It recognises that the Arc is first and foremost an area of significant economic strength and opportunity, and through the joint declaration the partners (including the then 43 local authorities across the Arc) set out to meet the Arc’s full economic potential for the benefit of existing and future local communities and businesses, and in the national interest. There is acknowledgement that to achieve this will demand collective determination over the long-term, to deliver significantly more homes in the Arc, of the right quality and in the right places to meet its needs. Also that this might include the expansion of existing as well as the development of new settlements. It will require long-term commitments to provide the enabling infrastructure and to deliver that ahead of the arrival of new communities, and to meet economic and housing ambitions while overall improving rather than degrading the environment in the Arc, in line with commitments in the government’s 25 Year Environment Plan”