1.48

Support

Representation ID: 3549

Received: 11/08/2021

Respondent: Ms Claudia Dietz

The continued cooperation between the Council and Parish Councils regarding additional development in or around villages is welcomed and supported.

Support

Representation ID: 3555

Received: 11/08/2021

Respondent: Ms Claudia Dietz

The continued cooperation between the Council and Parish Council's regarding additional development in or around villages is welcomed and supported.

Support

Representation ID: 4055

Received: 30/08/2021

Respondent: Ann Mills

Consultation with villages on neighbourhood plans and the location of new development is essential for good planning and the integration of new residents into existing established communities.

Object

Representation ID: 4101

Received: 30/08/2021

Respondent: Debbie Irish

Based on the totally unacceptable approach taken by the BBC and EWR to consultation to date on the EWR and other plans, I would want to see a transparent, detailed, timely and well communicated series of reports before anything is agreed to. Putting a couple of small ads in local papers that are not read by the community, or posting a handful of individual leaflets is NOT public consultation. Include the people, and have the decency to actually include the parish councils before developing plans (and not pretend that you have done so).

Support

Representation ID: 4371

Received: 31/08/2021

Respondent: Mrs Gerardine Meola

Will this apply to site 977 in parish of Staploe to ensure it does not engulf or encroach Begwary and Honeydon?

Must apply in Duloe as sites proposed within it, could dramatically change its character.

Object

Representation ID: 4518

Received: 01/09/2021

Respondent: Mrs Clare Buddle

Residential development should be focused in sustainable locations, i.e. within the urban areas with the ‘20 Minute Neighbourhood’ approach applied. Existing urban areas should be the focus of new development (e.g. residential employment, services) to promote sustainable, efficient resource use.

Whilst village/rural development can help sustain rural communities, it must be accepted that these communities rely on roads to connect them to services/opportunities elsewhere: to accommodate this pattern of living is comparatively costly and very unsustainable. Rural areas should predominantly be restricted to rurally appoate development uses.

Object

Representation ID: 4581

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.

Object

Representation ID: 4808

Received: 01/09/2021

Respondent: Mr Andrew Murray

As a Parish Councillor for Cotton End I am NOT aware of our Parish Council being asked for any input, despite the Parish Council having started the Neighbourhood Plan

Support

Representation ID: 4954

Received: 02/09/2021

Respondent: Mrs Jacqueline Smith

The parish council would support 2a and 2c as their prefered option

Object

Representation ID: 4995

Received: 02/09/2021

Respondent: Rainier Developments Limited (Bromham)

Agent: Marrons Planning

In the context of the need to boost housing supply in light of the increased housing requirement (circa 33% increase per annum), the Council should in this Plan proceed with making allocations in order to speed up delivery and ensure the housing need (including affordable) is met as soon as possible. Awaiting Neighbourhood Plans to be reviewed or prepared would add unnecessary delay which may adversely affect the trajectory and five year housing land supply (against the higher housing requirement).

Object

Representation ID: 5005

Received: 02/09/2021

Respondent: Rainier Developments Limited (Roxton)

Agent: Marrons Planning

In the context of the need to boost housing supply in light of the increased housing requirement (circa 33% increase per annum), the Council should make housing allocations in this Local Plan to avoid unnecessary delay to housing delivery which is required to meet the increased need for this plan period. This is particularly relevant in Roxton where no Neighbourhood Plan has been prepared thus far.

Object

Representation ID: 5018

Received: 02/09/2021

Respondent: Rainier Developments Limited (Wootton)

Agent: Marrons Planning

In the context of the need to boost housing supply in light of the increased housing requirement (circa 33% increase per annum), the Council should in this Plan proceed with making allocations in order to speed up delivery and ensure the housing need (including affordable) is met as soon as possible. Awaiting Neighbourhood Plans to be reviewed or prepared would add unnecessary delay which may adversely affect the trajectory and five year housing land supply (against the higher housing requirement).

Object

Representation ID: 6109

Received: 09/09/2021

Respondent: Mr J Gill

Agent: DLP Planning Limited

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 BLP2030) in the context of updates to the development strategy explored through the LP2040 consultation.
3.17 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’ and draft 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. The Wootton Neighbourhood plan is being prepared at present in accordance with a plan being superseded, with lower and unrealistic growth targets to meet need and comply with national policy guidance.
Reasoning
3.18 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.
3.19 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.
3.20 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.
3.21 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.
3.22 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.
3.23 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 or has not been prepared in accordance with the most current and relevant Local plan.
3.24 It is a necessary under national policy to ensure that the emerging Local Plan 2040 is able to provide a requirement figure to designated Neighbourhood Areas. This will inevitably materially exceed the evidence currently relied upon in the context of the LP2030. This forms a material consideration as specified in the PPG (ID: 41-084-20190509) to identify those circumstances where it will be necessary to review and update Neighbourhood Plans. This is particularly relevant in Wootton given the absence of any requirement to contribute towards the overall scale and distribution of growth in adopted strategic policies.

Support

Representation ID: 6509

Received: 13/09/2021

Respondent: Mr Ian Laing

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages.

This is a process that can work well if the Parish’s act reasonably quickly following indication of an initial intention to prepare a neighbourhood plan (NP).

However, whilst some Parish Councils have taken forward NP’s others have not and some have stalled such that some potentially good quality sites have not come forward.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes this commitment clear.

The policy should provide a guideline for the level of growth that the NP will seek to deliver i.e., 50 homes, 75 homes etc.

In order to provide an incentive for the speedy preparation of an NP the policy should also make clear that if the NP has not been made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village can then be held to be out of date and so applications for new housing development close to or adjoining settlement boundaries would then benefit from a presumption in favour of sustainable development.

Support

Representation ID: 6511

Received: 13/09/2021

Respondent: Dr Hugh Laing

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages.

This is a process that can work well if the Parish’s act reasonably quickly following indication of an initial intention to prepare a neighbourhood plan (NP).

However, whilst some Parish Councils have taken forward NP’s others have not and some have stalled such that some potentially good quality sites have not come forward.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes this commitment clear.

The policy should provide a guideline for the level of growth that the NP will seek to deliver i.e., 50 homes, 75 homes etc.

In order to provide an incentive for the speedy preparation of an NP the policy should also make clear that if the NP has not been made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village can then be held to be out of date and so applications for new housing development close to or adjoining settlement boundaries would then benefit from a presumption in favour of sustainable development.

Object

Representation ID: 6689

Received: 14/09/2021

Respondent: Peter David Homes Limited

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages through the preparation of Neighbourhood Plans (NP’s).

This is a process that can work well if the Parish’s act reasonably quickly following indication of an initial intention to prepare a NP.

However, whilst some Parish Councils have taken forward NP’s, others have not and some have stalled such that potentially good quality sites have not come forward as there is no process in place for their allocation.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes this commitment clear.

The policy should provide a guideline for the level of growth that the NP will seek to deliver i.e. 50 homes, 75 homes etc.

In order to provide an incentive for expeditious preparation of an NP the policy should also make clear that if the NP has not been made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village can then be held to be out of date and so applications for new housing development close to or adjoining settlement boundaries would then benefit from a presumption in favour of sustainable development.

Where Parish Council’s confirm that they do not intend to prepare a NP it would be reasonable for allocations to be made through the Borough Plan (please see separate representations in respect of the small sites topic paper)

Support

Representation ID: 8072

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Paragraph 1.48 advises that the Council will provide Parish Council’s with a choice as to whether they wish to allocate sites around their villages.

This is a process that can work if the Parish’s act reasonably quickly following indication of an initial intention to prepare a neighbourhood plan (NP).

However, whilst some Parish Councils have taken forward NP’s others have not and some have stalled such that sites in the rural areas have not come forward as hoped leaving some villages with little or no growth over the plan period.

It is submitted that where Parish Council’s confirm a desire to prepare an NP that will allocate new housing there should be a Policy within the Borough Plan that makes clear that if an NP has not been prepared and made within 3 years of the adoption of the Borough Local Plan, the settlement boundaries for that particular village will be held to be out of date and applications for new development close to or adjoining boundaries would then benefit from a presumption in favour of sustainable development.

Paragraph 1.49 then notes that the Council will not expect NP’s to allocate strategic scale sites and this will be done in the Borough Local Plan.

The definition of a ‘strategic site’ is not provided. It is considered that the Borough Plan should consider allocations within Parish areas on sites over 50 units where these fit with the overall development strategy.

This would again assist in ensuring that the NP process does not prevent larger sustainable sites coming forward due to delays with the NP process.

Support

Representation ID: 8234

Received: 26/09/2021

Respondent: Amanda Quince

BEDFORD BOROUGH LOCAL PLAN 2040 – DRAFT PLAN: STRATEGY OPTIONS AND
DRAFT POLICIES
RESPONSE from RENHOLD PARISH COUNCIL September 2021
3. RENHOLD NEIGHBOURHOOD PLAN
It would have been helpful if there had been greater clarity for local parishes in the position of
working on a Plan, of which there are many, to understand how the new Local Plan will sit
alongside a Neighbourhood Plan. As a document driven by many volunteer hours it is important
that those kindly committing their time freely to benefit their community can see the value their
efforts bring in partnership with the BBC’s strategic growth work.
As a result, Renhold Parish Council sought clarification during the consultation on how the
existing Neighbourhood Plan process being undertaken in the parish would align with the new
Local Plan. The Planning Policy Officer response was helpful, though there does remain some
uncertainty and worry that going forwards the two very different, but equally important
processes do not align, which would be frustrating for those who have committed so much to
taking a Neighbourhood Plan forwards in Renhold.
Renhold Neighbourhood Plan Working Group continue with progressing a strategy that meets
the needs of the village as identified through the various consultations and engagement with
residents.

Object

Representation ID: 8979

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

Introduction to Site and Proposals
4.1 The site subject to this representation is land off Carlton Road, Turvey.
4.2 An area of approximately 2ha has been allocated in the Turvey Neighbourhood Plan (TNP), which passed referendum on the 15th July 2021. The TNP allocates two sites, and at paragraph 5.20 notes that each site is suitable for 25 dwellings. However, Policy T1 which is the development policy for Carlton Road, does not specify a number of dwellings to be provided, just that the site is allocated for housing development along with a set of development principles.
Figure 1: Turvey Settlement Boundary, with Carlton Road allocation marked yellow.
4.3 Our view is that the net developable area of the site (excluding open space to be retained on the Carlton Road frontage and significant boundary landscaping) could provide a capacity of at least 40 dwellings having regard to Framework paragraph 124.
4.4 The site has however no physical constraint which would prevent the increase in capacity beyond the boundaries of the present allocation. Having regard to our submissions above in respect to the timescale of the plan, the need to plan strategically even in relation to growth in villages and moreover to the scale of development that will be required, we consider that the current allocation should be extended.
4.5 In the first instance the site is demonstrably deliverable, and our client expects to bring forward development within the boundaries prescribed in the TNP once the TNP is ‘made’. It is our case that more, deliverable, sites are needed in the early years of the new Local Plan in order to sustain the supply of housing until such time as the major new development allocations can be relied upon to support the five-year supply. For the reasons set out we do not consider that they will be able to do so until at least 2035 and possibly 2040. Consequently, a further allocation should be made to Turvey and that, having regard to the assessment carried out for the TNP which concluded that land at Carlton Road was suitable for development, the only logical conclusion would be that the site is also suitable for an extension of the present site. That is supported by consideration that there are no physical boundaries on the land save for those that will be created by the current allocation and infrastructure will be provided to support the current allocated development.
4.6 Notwithstanding that Policy T2 of the TNP states ‘Housing development must include a mix of sizes of accommodation, based on the most recent evidence of local need that is available. This must include smaller units (1-2 bedrooms) to cater for first time buyers and those seeking to downsize’ there is no physical constraint on the delivery of a full range of house types including the provision of affordable homes including First Homes.
4.7 Furthermore, the site could also deliver self-build or custom dwellings, with there not being a policy that would inhibit a scheme that was largely consisting of these elements rather than market or affordable housing.
Response to Borough Council’s Site Assessment Pro-Forma and Neighbourhood Plan Assessment
4.8 The site was not submitted to the Summer 2020 Call for Sties event due to progression with the Neighbourhood Plan, as such it was not assessed as part of the production of the Local Plan. Therefore, a comparative assessment has been undertaken below on the Neighbourhood Plan assessment.
Site Assessment Criteria – Support
4.9 As part of the Neighbourhood Plan a much larger site than the allocation (2ha) was initially considered, comprising up to 19.5ha which had an indicative capacity of 380 dwellings. Smaller options of between 90 and 120 dwellings were also submitted and this formed the basis of the original site assessment.
Reasoning
4.10 The assessment rejected the delivery of 90-120 dwellings only insofar as it was considered in the context of the then emerging housing requirement to be a scale of development greater than proportionately required for Turvey. The assessment however acknowledged the ability of the site potentially to deliver around 50 dwellings. Subsequently 25 units have been indicatively allocated through the TNP. It follows however that a larger allocation could be delivered that was well related to the settlement in the circumstances where a greater scale of growth is required in the Borough to meet its future planned needs.
4.11 Issues in the assessment were raised in relation to landscaping, flood zones, mineral safeguarding areas, listed buildings and highways, but all were capable of being overcome through mitigation as set out in the assessment and affirmed through the current allocation.
4.12 The assessment concluded that the site was capable of delivering up to 50 dwellings and that this was an appropriate scale of development. The site was therefore deemed as suitable, available, deliverable, and recommended as an allocation.
Suggested Alternative Site Assessment Finding
4.13 Given the findings of the previous assessment, 50 dwellings, it is our view that the site has capacity to deliver development in the order of 90-100 dwellings. This would still be less than that originally appraised and could be accommodated without adverse impact on the site or breaching any existing natural barriers – of which the current TNP allocation would be a part.
4.14 As such, for the purposes of the emerging Local Plan 2040, a further allocation north of Carlton Road should be made of at least 75 dwellings.
For figure 1 see attachment