1.14
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7871
Received: 23/09/2021
Respondent: Central Bedfordshire Council
e recognise that the Bedford Local Plan 2040 will be only a partial update of existing policies, due to the Local Plan 2030 being adopted only last year and as a result the review finding that many of its policies were up to date and did not require changing.
We note that the review will focus on the following key policy areas:
• Development strategy up to 2040 and delivery of growth in order to meet national policy requirements.
• Town centre and retail policies
• Updated development management policies on: Self-build and custom homebuilding, Quality of development and residential space standards, and environmental net gain.
In the current round of plan-making, the plans of both CBC and North Hertfordshire District Council (NHDC) make provision to meet the unmet housing needs of Luton Borough Council, within the shared HMA. This involved the release of Green Belt land, which obviously requires the demonstration of exceptional circumstances (including the demonstration that all other options have been explored). Whilst any further unmet needs (arising from Luton’s next round of plan-making) are yet to be determined, if unmet needs do arise, it does need to be acknowledged that, bearing in mind supply in CBC and NHDC has already been maximised to meet the needs this time around, this is likely to need to be considered across a broader geographical area, including by Bedford Borough Council. It is considered that this should be acknowledged and addressed within the emerging Bedford Local Plan.
Further to this, we note the proposed timetable for the BBC plan to be submitted, ahead of the adoption of the emerging Ox/ Camb Arc Spatial Framework. We would be grateful for clarification on the relationship that is envisaged between the BBC LP and Arc Spatial Framework. Is it BBC’s intention to commence a further Local Plan review following the adoption of the Spatial Framework?
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7925
Received: 24/09/2021
Respondent: Ms Lorraine Jewell
The scope of the Local Plan is broadly acceptable however, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7999
Received: 24/09/2021
Respondent: Mr Larry Gooch
The scope of the Local Plan is broadly acceptable to I. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8105
Received: 03/09/2021
Respondent: Dr Emma Thompson
The scope of the Local Plan is broadly acceptable to I. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employs a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8144
Received: 03/09/2021
Respondent: Mr Ross Thomson
The scope of the Local Plan is broadly acceptable to I. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employs a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8182
Received: 03/09/2021
Respondent: Mrs Bernadette Yockney
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8242
Received: 03/09/2021
Respondent: Mr Daniel Francis
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8286
Received: 03/09/2021
Respondent: Miss Erin Francis
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8332
Received: 03/09/2021
Respondent: Mrs K Francis
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8422
Received: 03/09/2021
Respondent: Mr Theodore Cassell
The scope of the Local Plan is broadly acceptable however, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8429
Received: 27/09/2021
Respondent: Mrs G Hunt
Agent: DLP Planning Limited
The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
This sits alongside strategic decisions where direction will be provided by the Framework e.g. implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
The Council’s proposed strategy in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8506
Received: 27/09/2021
Respondent: Old Road Securities PLC
Agent: DLP Planning Limited
The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
This sits alongside strategic decisions where direction will be provided by the Framework e.g., implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
The Council’s proposed in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8529
Received: 03/09/2021
Respondent: Mrs Claire francis
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8581
Received: 27/09/2021
Respondent: AW Group Limited
Agent: Arrow Planning Limited
6.0 Summary and Conclusions
6.1 These representations have been prepared on behalf of Arnold White Group, a strategic landowner and promoter with a proven track record of delivery of housing, commercial and renewable energy developments in Bedfordshire.
6.2 This response finds that the emerging Local Plan does not meet employment needs. The level of employment growth proposed in the Plan is not sufficient to meet local needs, nor does it facilitate Bedford Borough’s active shaping of the Arc Spatial Framework in this area.
6.3 The Plan also fails to adequately address climate change, with a complete failure to meet the NPPF requirements and an absence of any evidence base documents that grapple with this issue.
6.4 The representations propose a new Development Strategy Option which would provide a significant uplift in employment growth in the south (A421 rail-based corridor) to be taken forward in the next iteration of the Local Plan.
6.5 Furthermore, the representations demonstrate that the Bedford Business Park, including the land at Broadmead, should be allocated for commercial development in accordance with the evidence base and proposed Development Strategy.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8601
Received: 13/09/2021
Respondent: Mr Henry Zwetsloot
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8651
Received: 28/09/2021
Respondent: Mr and Mrs N/A Box
Agent: DLP Planning Limited
3.15 The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.16 As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
3.17 This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
3.18 This sits alongside strategic decisions where direction will be provided by the Framework e.g. implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.19 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.20 The Council’s proposals in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
3.21 The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8668
Received: 13/09/2021
Respondent: Mr J Francis
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8714
Received: 28/09/2021
Respondent: Old Road Securities PLC
Agent: DLP Planning Limited
3.23 The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.24 As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
3.25 This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
3.26 This sits alongside strategic decisions where direction will be provided by the Framework e.g., implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.27 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.28 The Council’s proposed in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
3.29 The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8731
Received: 28/09/2021
Respondent: Mrs Nicola Gooch
The scope of the Local Plan is broadly acceptable to I. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8744
Received: 29/09/2021
Respondent: Bedfordshire Hospitals NHS Foundation Trust
Agent: Barton Willmore
1.1 These representations have been prepared by Barton Willmore LLP on behalf of the Bedfordshire Hospitals NHS Foundation Trust (“the Trust”). These representations respond to the Bedford Borough Council (BBC) Local Plan 2040 Regulation 18 consultation, specifically the Draft Plan: Strategy Options and Draft Policies consultation document (June 2021).
The Bedfordshire Hospitals NHS Foundation Trust
1.2 The Trust is a key stakeholder within Bedford, providing essential healthcare provision to the population of the town and the wider area from their established sites at South Wing (Kempston Road) and North Wing (Kimbolton Road). In addition to their role as healthcare provider, the Trust is a major landowner and employer within the Bedford area.
1.3 Bedford Hospital merged with the Luton and Dunstable Hospital in April 2020 to become the Bedfordshire Hospitals NHS Foundation Trust. The merged Trust aspire to provide high quality care to the population of Luton, Bedford, Bedfordshire and further afield. Core services on both sites will remain, such as Accident and Emergency (A&E), maternity and children’s services.
1.4 The Trust is part of a regional integrated care system – Bedfordshire, Luton & Milton Keynes (BLMK) ICS. BLMK ICS is made up of commissioning groups, local authorities, Acute Trusts, Community Trusts, Mental Health Care Providers and Ambulance Trusts who all have a health footprint across BLMK. A number of regional priorities have been agreed and continue to be delivered. They include illness prevention and health promotion and the provision of high quality primary, community, social and secondary care. A number of the priorities link to capital development, including proposed construction at Bedford Hospital.
1.5 The clinical strategy is an evolving document, responding to local health needs and population health requirements, as well as regional and national strategy and best practice.
Engaging with the emerging Local Plan 2040
1.6 We appreciate that the Local Plan 2040 will be a partial update, focused on the Development Strategy and delivery of growth; town centre and retail policies; and some updated development management policies (paragraph 1.14).
1.7 The provision of high quality healthcare is essential to the growth of the Borough, highlighted particularly during the recent Coronavirus Pandemic. Ongoing investment and development of Bedford’s healthcare infrastructure, including the Hospital’s sites, is therefore an important objective looking forward over the next 20 years. As set out within this Representation Report, we consider that this objective should be more explicitly acknowledged within planning policy. In land use planning terms, we believe that the development and improvement of the Hospital’s sites warrants their specific identification and allocation as a ‘Special Policy Area’.
1.8 The Trust is keen to engage with the Council in the emerging Local Plan. We note from paragraph 1.45 that BBC plans to prepare an ‘Infrastructure Delivery Plan’ alongside the site allocations. The healthcare and social infrastructure aspects of this would be particularly relevant to the Trust, and we would be happy to discuss any matters in further detail.
1.9 This Report is submitted in response to the formal public consultation and relates specifically to the Draft Plan: Strategy Options and Draft Policies consultation document (June 2021). Section 2 of this report provides comments on the Vision and Objectives; and Section 3 relates to the Growth and Spatial Strategy Options. Section 4 relates to Site Allocations and Sections 5 and 6 provide further information regarding both the South Wing and North Wing sites. Section 7 provides comment on relevant Development Management Policy, and Section 8 sets out a summary of our Representations, and the conclusions.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8760
Received: 29/09/2021
Respondent: Staploe Parish Council
The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
1.14 100 word summary
If the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based growth policy.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8869
Received: 30/09/2021
Respondent: DLP Planning Limited
Agent: DLP Planning Limited
Paragraph 1.14 (Scope of the Plan) – Object
3.9 The Council’s Preferred Option consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails to fully reflect the reasons for first introducing the requirement for immediate review and in-particular the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.10 As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
3.11 This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework sets policies to enable housing needs to be met in full, including much-needed affordable housing
3.12 This sits alongside strategic decisions where direction will be provided by the Framework e.g., implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.13 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.14 The Council’s proposed strategy in its Preferred Options consultation proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due to only considering a horizon to 2040 and as a result of likely timescales for the characteristics of larger-scale development (including new settlements) it is furthermore
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
13
highly likely a significant shortfall against full development needs will persist until 2040 and beyond.
3.15 The Council’s proposed strategy offers no flexibility and choice to address the current and persistent failure to meet needs in full. Our assessment indicates that current levels of development are likely to become significantly constrained substantially before any of the longer-term solutions proposed as part of the Preferred Options achieve significant delivery. Realistic assumptions must also be made in relation to new larger-scale developments.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8920
Received: 01/10/2021
Respondent: Mr James Browning
The scope of the Local Plan is broadly acceptable to I. However, it is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8938
Received: 01/10/2021
Respondent: Snelsons Farm Partnership
Agent: DLP Planning Limited
Paragraph 1.14 (Scope of the Plan) – Object
3.17 The Council’s draft strategy consultation proposals indicate that the purpose of updates to the Local Plan following the requirements of the review policy (BLP2030 Policy 1) are to outline a development strategy to 2040 and meet national policy requirements for the delivery of growth. This fails fully to reflect the reasons for first introducing the requirement for immediate review and, in particular, the pattern and scale of housing growth necessary to achieve sound outcomes for plan-making (particularly with regards paragraphs 20 and 74 of the NPPF2021).
Reasoning
3.18 As set out in the Spatial Framework consultation document (paragraph 5.5) the Ox-Cam Arc
demonstrates poor affordability where development has not kept pace with need. That is exactly the position in Bedford Borough resulting from the approach adopted in the BLP2030.
3.19 Thus (at paragraph 5.7) it is an aim of the Ox-Cam Spatial Framework to ensure that it establishes policies to enable housing needs to be met in full, including much-needed affordable housing where direction will be provided by the Framework e.g. implementation of East-West Rail, identification of Opportunity Areas and support for the delivery of previously developed land.
3.20 What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach providing for sustainable communities.
3.21 The LP2040 draft strategy proposals would sustain a very substantial shortfall against minimum annual local housing need until at least 2030. Due only to considering a horizon to 2040, and as a result of likely timescales for the characteristics of larger-scale development (including new settlements), it is furthermore highly likely a significant shortfall against full development needs will persist until 2040 and beyond unless the strategy is supported by a wider range of deliverable sites.
Remedy
3.22 The Council’s proposed draft strategy needs to offer flexibility and, moreover, choice to address the current and persistent failure to meet needs in full if the Local Plan is not to become significantly constrained for a substantial period before any of the longer-term solutions proposed as part of the emerging LP2040 achieve significant delivery – see supporting report oin Housing Delivery which generally accompanies the representations submitted on behalf of the clients of DLP Planning Ltd.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 8991
Received: 03/09/2021
Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd
Agent: DLP Planning Limited
The Council’s Preferred Option consultation proposals indicate that the purpose of updates
to the Local Plan following the requirements of the Review policy (Policy 1) are to outline a
development strategy to 2040 and meet national policy requirements for the delivery of
growth. This fails to fully reflect the reasons for first introducing the requirement for immediate
Review and in-particular the pattern and scale of housing growth necessary to achieve sound
outcomes for Plan-making (particularly with regards paragraphs 20 and 74 of the
NPPF2021).
Reasoning
As set out in the Spatial Framework consultation document (paragraph 5.5) the Arc
demonstrates poor affordability where development has not kept pace with need. That is
exactly the position in Bedford resulting from the approach adopted in the Local Plan 2030.
This means (at paragraph 5.7) it is an aim of the Framework to ensure that the Framework
sets policies to enable housing needs to be met in full, including much-needed
affordable housing.
This sits alongside strategic decisions where direction will be provided by the Framework
e.g., implementation of East-West Rail, identification of Opportunity Areas and support for
the delivery of previously developed land.
What this means in practice is that prioritizing opportunities to meet full development needs is an important component of the place-making pillar as part of a joined-up approach
providing for sustainable communities.
The Council’s Preferred Options consultation proposals would sustain a very substantial
shortfall against minimum annual local housing need until at least 2030. Due to only
considering a horizon to 2040 and as a result of likely timescales for the characteristics of
larger-scale development (including new settlements) it is furthermore highly likely a
significant shortfall against full development needs will persist until 2040 and beyond.
The Council’s proposed strategy offers no flexibility and choice to address the current and
persistent failure to meet needs in full. Our assessment indicates that current levels of
development are likely to become significantly constrained substantially before any of the
longer-term solutions proposed as part of the Preferred Options achieve significant delivery.
Realistic assumptions must also be made in relation to new larger-scale developments.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 9058
Received: 12/11/2021
Respondent: Colmworth Parish Council
Agent: Troy Planning + Design
1.6. As explained above, the Local Plan Inspectors required an ‘early review’ of the Local Plan to deal principally with the strategic issues of the Arc as it relates to BBC and its neighbours, however this is not currently possible as explained above. It seems that the point was to avoid another ‘piecemeal’ review of the Local Plan. Therefore, BBC’s proposed scope of the Local Plan update is difficult to follow. BBC explains that the 2040 Local Plan will be a partial update of existing policies given that it considers the vast majority of its policies are up to date and do not need to change7. BBC explains that the Local Plan update will cover the following:
• Development Strategy to 2040 and delivery of growth in order to meet national policy requirements
• Town centre and retail policies in order to support a more flexible future for our centres with a reduced focus on retailing
• Updated development management policies (those used to help make decisions on planning applications to do with:
o Self-building and custom homebuilding
o Quality of development and residential space standards
o Environmental net gain
1.7. We do not consider it possible to update the entire Development Strategy for the borough as part of partial review to plan for the proposed large scale of growth in the borough with a minimum of 12,500 dwellings and 123 hectares of employment land whilst attempting to align with the emerging strategy for the Arc. BBC should be preparing a full Local Plan Review rather than its current incremental approach which does not allow for long term and comprehensive planning based on effective cooperation which is so clearly needed for the borough and the surrounding area.