1.5

Object

Representation ID: 9059

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

2.1. The Draft Local Plan proposes a plan period of 2020-2040. It states:
“A longer timescale would have the advantage of giving certainty for a longer period but… many important decisions that will affect the scale and form of growth in and close to Bedford Borough in the medium and long term are likely to be made the next few years. As a result, and having considered the 2020 consultation responses, the Council’s view is that 2020 - 2040 is an appropriate time period for this plan. With a requirement now for five-yearly local plan reviews there will be sufficient opportunity to plan beyond 2040 once the regional planning context is clearer.”
2.2. The New NPPF (2021) requires a minimum 15 year period from the adoption of the Local Plan. BBC’s Local Development Scheme (Feb 2021) indicates a Local Plan adoption date of December 2023 which covers the monitoring period of 2023/2024 so the minimum Local Plan period would end 2038/2039. The proposed Local Plan period would therefore be compliant with the new NPPF (2021) if it weren’t for a new requirement imposed by Paragraph 22 of the NPPF which states:
“Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.3. There are a number of options in the Draft Local Plan that do propose ‘larger scale developments’ such as new settlements or significant extensions of existing villages and towns’. In this case Local Plan policies should look further ahead at least 30 years to account for the likely delivery time required for delivering strategic development.
2.4. Therefore, if the Local Plan proposes larger scale developments then the plan and its policies clearly need to develop a vision which covers at least 30 years from the point of Local Plan adoption. If one assumes that the Local Plan adoption date is in 2023/2024 then the policies and vision will need to extend to at least 2053/2054.
2.5. MHCLG introduced this change to the NPPF in response to the Building Better Building Beautiful Commission recommendations to clarify that councils need to take into account the likely timescale for delivery of larger scale developments which, as we explain in our representations, take considerable time to plan and deliver.
2.6. Therefore, the plan period should be changed to 2020-2053. As a result of this change in the plan-period the majority of the Council’s evidence base will need to be reviewed and updated. Given the extent of time that will be required to update the evidence base and proposed policies we suggest that BBC reconsider its timetable for production of the Local Plan so that it can prepare sound evidence base and properly align with the Arc proposals whilst working closely with its neighbouring authorities and prescribed bodies.
2.7. This recent change to the NPPF has all sorts of serious implications for BBC as it prepares its Local Plan and evidence base in terms of transport modelling, infrastructure delivery and phasing and housing and employment delivery. The Council’s stated logic for only planning to 2040 cannot be justified given the Government’s change in policy as explained above. However, it is not just the fact that the NPPF now requires at least a 30 year plan period from time of adoption, this should be a fundamental principle and practice of preparing the strategic plan for the Borough rather than another short term and piecemeal review. This is exactly the short-term approach to planning the Government is seeking to avoid through the new change to the NPPF particularly where larger scale developments are proposed.
2.8. It is disingenuous of BBC to only test the potential new settlements for the amount of development potentially deliverable by the end of the stated plan period (2040). For example the Dennybrook site is tested for 2,500 dwellings in BBC’s Sustainability Appraisal when the site promoters have promoted the site for 7,500 – 10,150 dwellings. The outputs of any evidence base which assesses the site on a fraction (25%-33%) of its promoted potential is clearly not an effective or genuine approach to plan-making.