1.47

Support

Representation ID: 4369

Received: 31/08/2021

Respondent: Mrs Gerardine Meola

Neighbourhood Plan findings should be highly weighted in decision making.

Object

Representation ID: 4580

Received: 01/09/2021

Respondent: Mr Denis Ivins

concerns about the share of the overall target of around 2,260 dwellings to be contributed by the Key Service Centres which should probably be reduced by at least half.

Support

Representation ID: 4806

Received: 01/09/2021

Respondent: Mr Andrew Murray

Local communities are best placed to decide where development should go and how appropriate it is

Support

Representation ID: 7233

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

We welcome the text in paragraph 1.47 which confirms that the strategy for Neighbourhood Plans to allocate some 2,260 dwellings over the plan period will be rolled
over from the 2030 Local Plan to the emerging Local Plan 2040. It would be useful to clarify in future plans that this refers to the provision identified in adopted policy 4S, i.e.
500 new homes in Clapham as a key service centre.

Object

Representation ID: 8392

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.

These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030 and beyond. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ Plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford and recently at Sharnbrook).

At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with Parish Councils to meet additional requirements for growth where a range of suitable sites are identified.

This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.

Paragraph 28 of the Framework reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres, Rural Service Centres. The Council’s options test no distribution of requirements to other defined settlements whatsoever, which continues to overlook opportunities for sustainable settlements such as Felmersham to make a commensurate contribution towards the increased needs for development in the period to 2030 and beyond.

This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
The Council’s proposed approach is contrary to paragraphs 66 and 67 of the Framework. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.

This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the Neighbourhood Plan area and should minimise the risk of Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509).

The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the Government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened Plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of Plan-making for the LP2030).

It follows that the process for calculation of any indicative requirement would therefore materially and significantly exceed the evidence base for the LP2030 and the figures in Policy 4S. By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs and whether relating to settlements listed in Policy 4S or not such as in Felmersham) would need to be considered in the context of the overall result of the Standard Method to 2040.

Any impacts upon the evidence base for emerging Neighbourhood Plans must be read alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary to review and update a Neighbourhood Plan’ and states in relation to the above issues:
“There is no requirement to review or update a Neighbourhood Plan. However, policies in a Neighbourhood Plan may become out of date, for example if they conflict with policies in a Local Plan covering the neighbourhood area that is adopted after the making of the Neighbourhood Plan. In such cases, the more recent plan policy takes precedence.”
Remedy
The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the Framework. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the Plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.

Outside of the approach to identification of a housing requirement for Key Service Centres and Rural Service Centres the Council should adopt a flexible approach to supporting development opportunities at other defined settlements such as Felmersham in order to sustain and enhance their role. This is necessary to reflect the longer-term Plan period to 2040 and that such settlements were omitted from provision towards the scale and distribution of growth required to support the LP2030.

Object

Representation ID: 8431

Received: 27/09/2021

Respondent: Mrs G Hunt

Agent: DLP Planning Limited

he Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
aragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford).
At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.

Object

Representation ID: 8509

Received: 27/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford).
At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
In the context of Great Barford these representations recommend that the allocation of additional sites is confirmed within the Bedford Local Plan 2040, rather than deferred to a review of Neighbourhood Plans. The particular advantage of this approach in the context of our client’s Willoughby Park proposals reflects the ability to confirm support for a comprehensively planned village extension which is in one single ownership and to set out through the policies of the development plan the opportunity to contribute towards a number of the Plan’s objectives (including delivery of a new Countryside Park and GP Surgery).

Object

Representation ID: 8643

Received: 28/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Paragraphs 1.47-1.48 (Neighbourhood Planning) – Object
2.2 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
2.3 These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ Plans will remain in general conformity with the development strategy nor how further allocations in other defined settlements such as Souldrop might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
2.4 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with Parish Councils to meet additional requirements for growth where a range of suitable sites are identified.
2.5 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the Standard Method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
2.6 Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework.
2.7 The Council’s options test no distribution of requirements to other defined settlements whatsoever, which continues to overlook opportunities for sustainable settlements such as Souldrop to make a commensurate contributions towards the increased needs for development in the period to 2030 and beyond.
2.8 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
2.9 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021. For Souldrop, these provisions apply in the context that there is currently no designated Neighbourhood Area, and the defined settlement is not included within the scale and distribution of growth to be met through Neighbourhood Plans as part of the strategic policies of the LP2030 (Policy 4S).
2.10 Paragraphs 66 and 67 of the NPPF2021 should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the neighbourhood plan area and should minimise the risk of Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509). Rolling forward the distribution of growth in Policy 4S as suggested by the Council in its testing of strategy options for village-related growth is a flawed approach:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).
2.11 By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs and whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the Standard Method to 2040.
Remedy
2.12 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.
2.13 Outside of the approach to identification of a housing requirement for Key Service Centres and Rural Service Centres the Council should adopt a flexible approach to supporting development opportunities at other defined settlements such as Souldrop in order to sustain and enhance their role. This is necessary to reflect the longer-term plan period to 2040 and that such settlements were omitted from provision towards the scale and distribution of growth required to support the LP2030.

Object

Representation ID: 8652

Received: 28/09/2021

Respondent: Mr and Mrs N/A Box

Agent: DLP Planning Limited

3.22 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
3.23 These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
Relationship with Delivery of the Area’s Strategic Priorities
3.24 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (e.g. Great Barford).
3.25 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
3.26 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
3.27 Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for
the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.28 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
Identification of Housing Requirements for Designated Neighbourhood Areas
3.29 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.
3.30 This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognises the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the neighbourhood plan area and should minimise the risk of neighbourhood plan figures being superseded when new strategic policies are adopted (ID:41-102-20190509).
3.31 The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate
review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).
3.32 It follows that the process for calculation of any indicative requirement would therefore materially and significantly exceed the evidence base for the LP2030 and the figures in Policy 4S. By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs) whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the standard method to 2040.
3.33 Any impacts upon the evidence based for emerging Neighbourhood Plans must be read alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary
to review and update a neighbourhood plan’ and states in relation to the above issues:
“There is no requirement to review or update a neighbourhood plan. However, policies
in a neighbourhood plan may become out of date, for example if they conflict with policies
in a local plan covering the neighbourhood area that is adopted after the making of the
neighbourhood plan. In such cases, the more recent plan policy takes precedence.”
Remedy
3.34 The solution to issues identified in these representations necessitates the Council complying
with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.
3.35 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth.
3.36 For Rural Service Centres (with the exception of the reclassification of Oakley) it appears proportionate in the first instance to apply a pro-rata addition to levels of development envisaged in Policy 4S of the current LP2030 (i.e., a minimum 25-50 dwellings to 2030). Proportionate additional development in these settlements has the greatest potential to increase the pace of development and diversify supply and any increase could be achieved before 2030 in many cases.
3.37 The benefits of such an approach would significantly and demonstrably outweigh any harms given the potential to support the most appropriate locations for growth in each settlement from a range of site options.

Object

Representation ID: 8715

Received: 28/09/2021

Respondent: Old Road Securities PLC

Agent: DLP Planning Limited

3.30 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.

3.31 These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.


Reasoning


(i) Relationship with Delivery of the Area’s Strategic Priorities

3.32 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford).

3.33 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.

3.34 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.

3.35 Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.

3.36 In the context of Great Barford these representations recommend that the allocation of additional sites is confirmed within the Bedford Local Plan 2040, rather than deferred to a review of Neighbourhood Plans. The particular advantage of this approach in the context of


our client’s Willoughby Park proposals reflects the ability to confirm support for a comprehensively planned village extension which is in one single ownership and to set out through the policies of the development plan the opportunity to contribute towards a number of the Plan’s objectives (including delivery of a new Countryside Park and GP Surgery).

Object

Representation ID: 8738

Received: 29/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

2.2 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.

2.3 These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030 and beyond. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ Plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.

Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities

2.4 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030.

2.5 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with Parish Councils to meet additional requirements for growth where a range of suitable sites are identified.

2.6 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the Standard Method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised, which includes our client’s site proposed for allocation in Milton Ernest. This does not demand that meeting increased requirements for growth should extend beyond 2030.


2.7 Paragraph 28 of the Framework reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.

2.8 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.

(ii) Identification of Housing Requirements for Designated Neighbourhood Areas

2.9 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the Framework. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.

2.10 This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the Neighbourhood Plan area and should minimise the risk of neighbourhood plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509).

2.11 The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential


requirements against which Neighbourhood Plans are prepared for the following reasons:

• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).

2.12 It follows that the process for calculation of any indicative requirement would therefore materially and significantly exceed the evidence base for the LP2030 and the figures in Policy 4S. By extension this means that any evidence produced by groups preparing Neighbourhood Plans (for example assessments of local rural housing needs and whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the standard method to 2040.

2.13 Any impacts upon the evidence base for emerging Neighbourhood Plans must be read alongside NPPG ID: 41-084-20190509, which answers the question ‘when will it be necessary to review and update a Neighbourhood Plan’ and states in relation to the above issues:

“There is no requirement to review or update a Neighbourhood Plan. However, policies in a Neighbourhood Plan may become out of date, for example if they conflict with policies in a Local Plan covering the neighbourhood area that is adopted after the making of the Neighbourhood Plan. In such cases, the more recent plan policy takes precedence.”

Remedy
2.14 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the Framework. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the Plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030.

2.15 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth. There may be scope to alter


the distribution of the housing requirement to Rural Service Centres upwards or downwards from the arbitrary figure of 25- 50 units adopted by the Council, depending on the capacity and other potential benefits for development in these settlements relative to their overall potential contribution to LHN.

2.16 For Rural Service Centres (with the exception of the reclassification of Oakley) it appears proportionate in the first instance to apply a pro-rata addition to levels of development envisaged in Policy 4S of the current LP2030 (i.e., a minimum 25-50 dwellings to 2030). Proportionate additional development in these settlements has the greatest potential to increase the pace of development and diversify supply and any increase could be achieved before 2030 in many cases.

2.17 The benefits of such an approach would significantly and demonstrably outweigh any harms given the potential to support the most appropriate locations for growth in each settlement from a range of site options. In the case of our client’s interests at Marsh Lane, Milton Ernest this could be achieved through realising additional capacity within sites already selected as part of the process of Neighbourhood Plan preparation.

Object

Representation ID: 8870

Received: 30/09/2021

Respondent: DLP Planning Limited

Agent: DLP Planning Limited

Paragraphs 1.47-1.48 (Neighbourhood Planning) – Object
3.16 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options. Roxton however, declined to prepare a Neighbourhood Plan and development was allocated through the Local Plan. This is relevant to the Council determining the most appropriate approach to site selection and allocation within the Local Plan 2040.
3.17 Within the context of Roxton these representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030 and beyond. Given the background to the adopted Local Plan 2030 the Local Plan Review offers a significant opportunity for Bedford Borough Council to lead on the allocation of additional sites or otherwise provide clarity of the requirements of general conformity that any future Neighbourhood Plan for Roxton must satisfy. This includes meeting the objectives for growth within the ‘east’ corridor parishes.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
3.18 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030.
3.19 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with Parish Councils to meet additional requirements for growth where a range of suitable sites are identified.
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
14
3.20 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised, which includes our client’s site land in Roxton.
3.21 Paragraph 28 of the Framework reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.22 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
3.23 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the Framework. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.
3.24 This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognising the ability of Neighbourhood Plans to
BE5553 – Land at Ford Lane, Roxton
Philip C Bath Ltd
Representations to Bedford LP2040
September 2021
15
sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the neighbourhood plan area and should minimise the risk of neighbourhood plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509).
3.25 The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).
3.26 In the case of Roxton a requirement figure for the purposes of Neighbourhood Planning should be identified, in accordance with national policy. However, in the absence of a designated Neighbourhood Area for the parish this would alternatively provide the basis for the Borough Council to select the allocation of sites to meet this figure.

Object

Representation ID: 8904

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

2.2 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the context of updates to the development strategy explored via the Preferred Options.
2.3 These representations identify that the consultation fundamentally fails to assess the role and ability of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
2.4 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford and recently at Sharnbrook).
2.5 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
2.6 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the Standard Method. The
Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
2.7 Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of Neighbourhood Plans that do not promote less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the 2012 version of the Framework. However, the Council’s testing of options for the Local Plan 2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
2.8 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas
2.9 The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021. Paragraph 66 sets out that strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is not justified and not positively prepared.
2.10 This is an important component of national policy and guidance in terms of seeking to avoid conflict between existing and emerging Neighbourhood Plans and the strategic policies of the development plan. This should form part of positive discussions between qualifying bodies and the local planning authority, recognises the ability of Neighbourhood Plans to sustain and increase housing delivery. Any indicative requirement figure would take into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the Neighbourhood Plan area and should minimise the risk of
Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID: 41-102-20190509).
2.11 The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall against the government’s policy for calculating housing need, culminating in this immediate review;
• The figures are applicable only in the context of a foreshortened plan period to 2030; and
• Figures are provided only for certain settlements, with no requirement indicated for levels of the settlement hierarchy below Rural Service Centres (despite these having been considered in earlier rounds of plan-making for the LP2030).
2.12 It follows that the process for calculation of any indicative requirement would therefore materially and significantly exceed the evidence base for the LP2030 and the figures in Policy 4S. By extension this means that any evidence produced by groups preparing Plans (for example assessments of local rural housing needs) whether relating to settlements listed in Policy 4S or not) would need to be considered in the context of the overall result of the Standard Method to 2040.
2.13 Any impacts upon the evidence based for emerging Neighbourhood Plans must be read alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary to review and update a Neighbourhood Plan’ and states in relation to the above issues:
“There is no requirement to review or update a neighbourhood plan. However, policies in a Neighbourhood Plan may become out of date, for example if they conflict with policies in a Local Plan covering the neighbourhood area that is adopted after the making of the Neighbourhood Plan. In such cases, the more recent plan policy takes precedence.”
Remedy
2.14 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.
2.15 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth. There may be scope to alter the distribution of the housing requirement to Key Service Centres upwards or downwards from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and other potential benefits for development in these settlements relative to their overall potential contribution to LHN.
2.16 Outside of the approach to identification of a housing requirement for Key Service Centres and Rural Service Centres the Council should adopt a flexible approach to supporting development opportunities outside of defined settlements on suitable, previously developed, sites that could contribute towards housing needs in the wider rural area.

Object

Representation ID: 8943

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

3.23 The Council’s consultation document considers the role for development allocations to be identified in Neighbourhood Plans (as a result of the strategy in the BLP2030) in the context of updates to the development strategy explored through the LP2040 consultation.
3.24 The consultation fundamentally fails to assess the role and performance of Neighbourhood Plans in meeting the requirements for sustainable development (including housing delivery) in the period to 2030. The consultation proposals also provide no clarity on the impact of
meeting additional requirements for growth in terms of whether the policies in ‘made’ plans will remain in general conformity with the development strategy nor how further allocations might be provided for in an effective and positively prepared manner.
Reasoning
3.25 Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be delivered before 2030. Even where a Neighbourhood Plan has been made at Turvey there is demonstrably little appetite in a community that only narrowly voted to support the NDP, to now embark on a further similar exercise which is likely to be as divisive as the current NDP proved to be. Other communities have failed even to reach that stage other than as a means to try and prevent development taking place altogether.
3.26 At paragraph 1.48 the Borough Council only provides vague indications of where further engagement might take place with parish councils to meet additional requirements for growth where a range of suitable sites are identified.
3.27 This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for reviewing NDPs (which should encourage early review when strategic policies have changed). That is an inevitable consequence of the development plan in Bedford given its current failure to address levels of growth in accordance with the standard method. The Borough Council’s own evidence indicates the strong likelihood of sites where early delivery can be prioritised. This does not demand that meeting increased requirements for growth should extend beyond 2030.
3.28 Paragraph 28 of the NPPF2021 reaffirms the role for NDPs in providing for non-strategic allocations. Paragraph 29 confirms this must be within the context of NDPs not promoting less development than set out in adopted strategy policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the NPPF2021 outlines that strategic policies should set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. This is an important distinction from the NPPF2012. However, the Council’s testing of options for the LP2040 rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service Centres and Rural Service Centres.
3.29 This fundamentally fails to accord with the current requirements of national policy and guidance and, importantly, has currently precluded the Council from considering ‘hybrid’ alternatives to the spatial strategy that would allow appropriate levels of sustainable development to be prioritised across the settlement hierarchy. It risks leading to planning by appeal in Neighbourhood Plan areas where the NDP has fallen out of date.
Remedy
3.30 The solution to issues identified in these representations necessitates the Council complying with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider that a ‘hybrid’ development strategy must remain supported throughout the plan period, including recognition of the contribution that this would make towards the shortfall against local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.
3.31 Without prejudice to any specific conclusions from this work this would support inclusion of ‘village-related’ development as a component of future growth. There may be scope to alter the distribution of the housing requirement to Key Service Centres upwards or downwards from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and other potential benefits for development in these settlements relative to their overall potential contribution to LHN.

Object

Representation ID: 8995

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

The Council’s consultation document considers the role for development allocations to be
identified in Neighbourhood Plans (as a result of the strategy in the Local Plan 2030) in the
context of updates to the development strategy explored via the Preferred Options.

These representations identify that the consultation fundamentally fails to assess the role
and ability of Neighbourhood Plans in meeting the requirements for sustainable development
(including housing delivery) in the period to 2030. The consultation proposals also provide
no clarity on the impact of meeting additional requirements for growth in terms of whether
the policies in ‘made’ Plans will remain in general conformity with the development strategy
nor how further allocations might be provided for in an effective and positively prepared
manner.

Reasoning
(i) Relationship with Delivery of the Area’s Strategic Priorities
Paragraph 1.47 of the consultation proposals repeats the strategy outlined in Policy 4S of
the adopted Local Plan. This does not confirm a realistic prospect that all 2,260 units will be
delivered before 2030. There are outstanding objections to several of the emerging Neighbourhood Plans at Key Service Centres (in particular at Great Barford and recently at Sharnbrook).

At paragraph 1.48 the Borough Council only provides vague indications of where further
engagement might take place with parish councils to meet additional requirements for growth
where a range of suitable sites are identified.

This paragraph is inconsistent with the intentions for a stepped trajectory and the NPPG for
reviewing NDPs (which should encourage early review when strategic policies have
changed). That is an inevitable consequence of the Development Plan in Bedford given its
current failure to address levels of growth in accordance with the Standard Method. The
Borough Council’s own evidence indicates the strong likelihood of sites where early delivery
can be prioritised. This does not demand that meeting increased requirements for growth
should extend beyond 2030.

Paragraph 28 of the NPPF2021 reaffirms the role for Neighbourhood Plans in providing for
non-strategic allocations. Paragraph 29 confirms this must be within the context of
Neighbourhood Plans that do not promote less development than set out in adopted strategy
policies (which in this case will be replaced in the Local Plan 2040). Paragraph 66 of the
NPPF2021 outlines that strategic policies should set out a housing requirement for
designated neighbourhood areas which reflects the overall strategy for the pattern and scale
of development and any relevant allocations. This is an important distinction from the 2012
version of the Framework. However, the Council’s testing of options for the Local Plan 2040
rolls forward a ‘one-size fits all’ distribution of potential levels of growth in Key Service
Centres and Rural Service Centres.

This fundamentally fails to accord with the current requirements of national policy and
guidance and, importantly, has currently precluded the Council from considering ‘hybrid’
alternatives to the spatial strategy that would allow appropriate levels of sustainable
development to be prioritised across the settlement hierarchy.
(ii) Identification of Housing Requirements for Designated Neighbourhood Areas

The Council’s proposed approach is contrary to paragraphs 66 and 67 of the NPPF2021.
Paragraph 66 sets out that strategic policies should also set out a housing requirement for
designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations. The Council’s suggestion of rolling forward the contribution from the scale and distribution of growth identified in Policy 4S of the LP2030 is
not justified and not positively prepared.

This is an important component of national policy and guidance in terms of seeking to avoid
conflict between existing and emerging Neighbourhood Plans and the strategic policies of
the Development Plan. This should form part of positive discussions between qualifying
bodies and the local planning authority, recognises the ability of Neighbourhood Plans to
sustain and increase housing delivery. Any indicative requirement figure would take into
consideration relevant policies such as an existing or emerging spatial strategy, alongside
the characteristics of the Neighbourhood Plan area and should minimise the risk of
Neighbourhood Plan figures being superseded when new strategic policies are adopted (ID:
41-102-20190509).

The figures in Policy 4S of the LP2030 are a flawed basis for rolling forward potential
requirements against which Neighbourhood Plans are prepared for the following reasons:
• The figures were determined arbitrarily, without reference to the OAN in place at
the time or strategies for individual settlements;
• In any event the Council’s OAN knowingly represented a significant shortfall
against the government’s policy for calculating housing need, culminating in this
immediate review;
• The figures are applicable only in the context of a foreshortened plan period to
2030; and
• Figures are provided only for certain settlements, with no requirement indicated for
levels of the settlement hierarchy below Rural Service Centres (despite these
having been considered in earlier rounds of plan-making for the LP2030).

It follows that the process for calculation of any indicative requirement would therefore
materially and significantly exceed the evidence base for the LP2030 and the figures in Policy
4S. By extension this means that any evidence produced by groups preparing Plans (for
example assessments of local rural housing needs) whether relating to settlements listed in
Policy 4S or not) would need to be considered in the context of the overall result of the
Standard Method to 2040.

Any impacts upon the evidence based for emerging Neighbourhood Plans must be read
alongside PPG ID: 41-084-20190509, which answers the question ‘when will it be necessary
to review and update a Neighbourhood Plan’ and states in relation to the above issues:
“There is no requirement to review or update a Neighbourhood Plan. However, policies in a
Neighbourhood Plan may become out of date, for example if they conflict with policies in a
Local Plan covering the neighbourhood area that is adopted after the making of the
Neighbourhood Plan. In such cases, the more recent Plan policy takes precedence.”

Remedy
The solution to issues identified in these representations necessitates the Council complying
with the requirements of paragraphs 66 and 67 of the NPPF2021. In doing so, we consider
that a ‘hybrid’ development strategy must remain supported throughout the Plan period,
including recognition of the contribution that this would make towards the shortfall against
local housing need for the period 2020 to 2030 i.e., through ‘top up allocations’.

Without prejudice to any specific conclusions from this work this would support inclusion of
‘village-related’ development as a component of future growth. There may be scope to alter
the distribution of the housing requirement to Key Service Centres upwards or downwards
from the arbitrary figure of 500 units adopted by the Council, depending on the capacity and
other potential benefits for development in these settlements relative to their overall potential
contribution to LHN.